Text

CNP Units 1 and 2 Improved Technical Specifications Conversion, Volume 13, Rev 0, ITS Section 3.8 Electrical Power Systems.
	ML041200385
Person / Time
Site:	Cook
Issue date:	04/06/2004
From:	; Indiana Michigan Power Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	AEP:NRC:4901
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Attachment 1, Volume 13, Rev. 0, Page 1 of 496 VOLUME 13 CNP UNITS 1 AND 2 IMPROVED TECHNICAL SPECIFICATIONS CONVERSION ITS SECTION 3.8 ELECTRICAL POWER SYSTEMS Revision 0 Attachment 1, Volume 13, Rev. 0, Page 1 of 496

Attachment 1, Volume 13, Rev. 0, Page 2 of 496 LIST OF ATTACHMENTS

1. ITS 3.8.1

2. ITS 3.8.2

3. ITS 3.8.3

4. ITS 3.8.4

5. ITS 3.8.5

6. ITS 3.8.6

7. ITS 3.8.7

8. ITS 3.8.8

9. ITS 3.8.9

10. ITS 3.8.10

11. Relocated/Deleted Current Technical Specifications (CTS)

Attachment 1, Volume 13, Rev. 0, Page 2 of 496

, Volume 13, Rev. 0, Page 3 of 496 ATTACHMENT 1 ITS 3.8.1, AC Sources - Operating , Volume 13, Rev. 0, Page 3 of 496

, Volume 13, Rev. 0, Page 4 of 496 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 13, Rev. 0, Page 4 of 496

Attachment 1, Volume 13, Rev. 0, Page 5 of 496 ITS 3.8.1 A.1 ITS LCO 3.8.1 qualified LA.1 LA.1 101.4 SR 3.8.1.4 A.12 See ITS 3.8.3 Add proposed LCO 3.8.1.c and d A.2 LA.1 Add proposed Applicability Note and ITS ACTIONS A and B for Unit 2 AC M.2 Sources one L.1 ACTION A Add proposed Required Action A.3 second ACTION F Completion Time L.21 ACTION B 12 L.1 Add proposed Required Action B.4 second ACTION F Completion Time L.2 See ITS 3.8.3 Page 1 of 18 Attachment 1, Volume 13, Rev. 0, Page 5 of 496

Attachment 1, Volume 13, Rev. 0, Page 6 of 496 ITS 3.8.1 A.1 ITS Add proposed Required Action A.3 D Note ACTION D Required Action A.1 Required Actions B.3.1 and B.3.2 12 L.21 ACTION D ACTION F L.1 and MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months M.3 ACTION C ACTION F L.1 ACTION E Required Action B.1 ACTION E ACTION F L.1 L.1 Add proposed ACTION G A.4 A.9 SR 3.8.1.1 Add proposed Note 1 to SR 3.8.1.9 24 L.3 SR 3.8.1.9 Page 2 of 18 Attachment 1, Volume 13, Rev. 0, Page 6 of 496

Attachment 1, Volume 13, Rev. 0, Page 7 of 496 ITS 3.8.1 A.1 ITS L.2 L.4 L.5 SR 3.8.1.4 every 31 days See ITS 3.8.3 LA.1 system SR 3.8.1.6 automatically M.4 L.19 L.2 every 31 days steady state 92 days SR 3.8.1.2 SR 3.8.1.8 voltage > 3740 V and SR 3.8.1.16 frequency > 58.8 Hz L.18 M.5 SR 3.8.1.3

> 3150 kW and < L.6 L.2 every 31 days LA.2 See ITS 3.8.3 SR 3.8.1.5 L.7 See ITS 3.8.3 See ITS 5.5 Add proposed SR 3.8.1.7 M.6 Add proposed Note 1 to SR 3.8.1.2, Note to SR 3.8.1.8, and Note 2 to SR 3.8.1.16 A.5 SR 3.8.1.8 LA.5 Note 2 to SR 3.8.1.2 Add proposed Note 1 to SR 3.8.1.3 A.6 Note 2 to SR 3.8.1.3 Add proposed Notes 3 and 4 to SR 3.8.1.3 M.7 See ITS 3.8.3 Page 3 of 18 Attachment 1, Volume 13, Rev. 0, Page 7 of 496

Attachment 1, Volume 13, Rev. 0, Page 8 of 496 ITS 3.8.1 A.1 ITS See ITS 5.5 See ITS 3.8.3 A.10 L.8 SR 3.8.1.10 through SR 3.8.1.19 24 L.3 LA.3 See ITS 3.8.3 Page 4 of 18 Attachment 1, Volume 13, Rev. 0, Page 8 of 496

Attachment 1, Volume 13, Rev. 0, Page 9 of 496 ITS 3.8.1 A.1 ITS M.8 M.5 single largest post-LA.4 accident load Add proposed Note 2 to SR 3.8.1.10 L.9 SR 3.8.1.10 L.6 the frequency < 64.4 Hz and within 2 seconds M.8 Add proposed Note 2 to SR 3.8.1.11 > 3150 kW and <

without tripping the DG L.10 SR 3.8.1.11 voltage is maintained

< 5000 V M.1 Add proposed Note 1 to SR 3.8.1.12 actual or A.5 L.11 SR 3.8.1.12 M.5 A.5 Add proposed Note 1 to SR 3.8.1.13 SR 3.8.1.13 actual or L.11 M.9 Add SR 3.8.1.13 parts a, b, d, and e Add proposed Note 1 to SR 3.8.1.19 A.5 actual or L.11 SR 3.8.1.19 M.5 Page 5 of 18 Attachment 1, Volume 13, Rev. 0, Page 9 of 496

Attachment 1, Volume 13, Rev. 0, Page 10 of 496 ITS 3.8.1 A.1 ITS L.6 A.11 SR 3.8.1.14 L.12 Add proposed Note

> 3150 kW and < 3 to SR 3.8.1.15 SR 3.8.1.15 SR 3.8.1.16 A.5 Add proposed Note 2 to SR 3.8.1.16 L.13 SR 3.8.1.17 L.20 SR 3.8.1.18 SR 3.8.1.20 See ITS 3.8.3 SR 3.8.1.15 Note 1, SR 3.8.1.16 Note 1 SR 3.8.1.16 Note 1

> 3150 kW and < L.6 A.8 Page 6 of 18 Attachment 1, Volume 13, Rev. 0, Page 10 of 496

Attachment 1, Volume 13, Rev. 0, Page 11 of 496 ITS 3.8.1 A.1 ITS See ITS 3.8.3 A.5 Add proposed Note to SR 3.8.1.20 SR 3.8.1.20 L.14 Add proposed voltage limit M.10 58.8 Hz L.15 Add proposed SR Notes 1 and 2 Add proposed SR 3.8.1.21 M.11 L.16 Page 7 of 18 Attachment 1, Volume 13, Rev. 0, Page 11 of 496

Attachment 1, Volume 13, Rev. 0, Page 12 of 496 ITS 3.8.1 A.1 ITS L.2 L.2 Page 8 of 18 Attachment 1, Volume 13, Rev. 0, Page 12 of 496

Attachment 1, Volume 13, Rev. 0, Page 13 of 496 ITS 3.8.1 A.1 ITS See ITS Section 3.0 Required Actions A.2, B.2, and C.1 L.17 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for proposed Required Action A.2 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for proposed Required Actions B.2 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for proposed Required Action C.1 L.17 Declare required features inoperable.

A.7 See ITS Section 3.0 Page 9 of 18 Attachment 1, Volume 13, Rev. 0, Page 13 of 496

Attachment 1, Volume 13, Rev. 0, Page 14 of 496 ITS 3.8.1 A.1 ITS LCO 3.8.1 qualified LA.1 LA.1 101.4 SR 3.8.1.4 A.12 See ITS 3.8.3 Add proposed LCO 3.8.1.c and d A.2 LA.1 Add proposed Applicability Note and M.2 ITS ACTIONS A and B for Unit 1 AC Sources L.1 ACTION A one Add proposed Required Action ACTION F A.3 second Completion Time ACTION B L.21 L.1 12 Add proposed Required Action ACTION F B.4 second Completion Time L.2 See ITS 3.8.3 Page 10 of 18 Attachment 1, Volume 13, Rev. 0, Page 14 of 496

Attachment 1, Volume 13, Rev. 0, Page 15 of 496 ITS 3.8.1 A.1 ITS Add proposed Required Action A.3 D Note ACTION D Required Action A.1 Required Actions L.21 12 B.3.1 and B.3.2 ACTION D L.1 ACTION F qualified and MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months M.3 ACTION C L.1 ACTION F ACTION E Required Action B.1 ACTION E ACTION F L.1 L.1 Add proposed ACTION G A.4 A.9 SR 3.8.1.1 Add proposed Note 1 to SR 3.8.1.9 24 L.3 SR 3.8.1.9 Page 11 of 18 Attachment 1, Volume 13, Rev. 0, Page 15 of 496

Attachment 1, Volume 13, Rev. 0, Page 16 of 496 ITS 3.8.1 ITS A.1 L.2 L.4 L.5 SR 3.8.1.4 every 31 days See ITS 3.8.3 LA.1 system SR 3.8.1.6 automatically M.4 L.19 L.2 every 31 days steady state 92 days SR 3.8.1.2 SR 3.8.1.8 voltage > 3740 V and SR 3.8.1.16 frequency > 58.8 Hz L.18 M.5 SR 3.8.1.3 > 3150 kW and < L.6 L.2 every 31 days LA.2 See ITS 3.8.3 SR 3.8.1.5 L.7 See ITS 3.8.3 See ITS 5.5 Add proposed SR 3.8.1.7 M.6 Add proposed Note 1 to SR 3.8.1.2, Note to SR 3.8.1.8, and Note 2 to SR 3.8.1.16 A.5 SR 3.8.1.8 LA.5 Note 2 to Add proposed Note 1 SR 3.8.1.2 to SR 3.8.1.3 A.6 Note 2 to SR 3.8.1.3 Add proposed Notes 3 and 4 to SR 3.8.1.3 M.7 See ITS 3.8.3 Page 12 of 18 Attachment 1, Volume 13, Rev. 0, Page 16 of 496

Attachment 1, Volume 13, Rev. 0, Page 17 of 496 ITS 3.8.1 ITS A.1 See ITS 5.5 See ITS 3.8.3 A.10 L.8 SR 3.8.1.10 through SR 3.8.1.19 L.3 24 LA.3 See ITS 3.8.3 Page 13 of 18 Attachment 1, Volume 13, Rev. 0, Page 17 of 496

Attachment 1, Volume 13, Rev. 0, Page 18 of 496 ITS 3.8.1 ITS A.1 M.8 M.5 single largest post-LA.4 accident load Add proposed Note 2 to SR 3.8.1.10 L.9 L.6 SR 3.8.1.10 the frequency < 64.4 Hz and within 2 seconds M.8 Add proposed Note 2 to SR 3.8.1.11 > 3150 kW and <

without tripping the DG L.10 SR 3.8.1.11 voltage is maintained

< 5000 V M.1 Add proposed Note 1 to SR 3.8.1.12 actual or A.5 L.11 SR 3.8.1.12 M.5 A.5 Add proposed Note 1 to SR 3.8.1.13 SR 3.8.1.13 actual or L.11 M.9 Add SR 3.8.1.13 parts a, b, d, and e Add proposed Note 1 to SR 3.8.1.19 A.5 actual or L.11 SR 3.8.1.19 M.5 Page 14 of 18 Attachment 1, Volume 13, Rev. 0, Page 18 of 496

Attachment 1, Volume 13, Rev. 0, Page 19 of 496 ITS 3.8.1 ITS A.1 L.6 A.11 SR 3.8.1.14 L.12 Add proposed Note

> 3150 kW and < 3 to SR 3.8.1.15 SR 3.8.1.15 SR 3.8.1.16 A.5 Add proposed Note 2 to SR 3.8.1.16 L.13 SR 3.8.1.17 L.20 SR 3.8.1.18 SR 3.8.1.20 See ITS 3.8.3 SR 3.8.1.15 Note 1, SR 3.8.1.16 Note 1 SR 3.8.1.16 Note 1

> 3150 kW and < L.6 A.8 Page 15 of 18 Attachment 1, Volume 13, Rev. 0, Page 19 of 496

Attachment 1, Volume 13, Rev. 0, Page 20 of 496 ITS 3.8.1 ITS A.1 See ITS 3.8.3 A.5 Add proposed Note to SR 3.8.1.20 L.14 SR 3.8.1.20 Add proposed voltage limit M.10 58.8 Hz L.15 Add proposed SR Notes 1 and 2 Add proposed SR 3.8.1.21 M.11 L.16 Page 16 of 18 Attachment 1, Volume 13, Rev. 0, Page 20 of 496

Attachment 1, Volume 13, Rev. 0, Page 21 of 496 ITS 3.8.1 ITS A.1 L.2 L.2 Page 17 of 18 Attachment 1, Volume 13, Rev. 0, Page 21 of 496

Attachment 1, Volume 13, Rev. 0, Page 22 of 496 ITS 3.8.1 ITS A.1 See ITS Section 3.0 Required Actions A.2, B.2, and C.1 L.17 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for proposed Required Action A.2 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for proposed Required Actions B.2 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for proposed Required Action C.1 L.17 Declare required features inoperable.

A.7 See ITS Section 3.0 Page 18 of 18 Attachment 1, Volume 13, Rev. 0, Page 22 of 496

Attachment 1, Volume 13, Rev. 0, Page 23 of 496 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING ADMINISTRATIVE CHANGES A.1 In the conversion of the CNP Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 2, "Standard Technical Specifications-Westinghouse Plants" (ISTS).

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

A.2 CTS LCO 3.8.1.1 does not contain the OPERABILITY requirements for the opposite unit qualified offsite circuit and diesel generators (DGs). However, the CTS definition of "OPERABLE - OPERABILITY" requires that, for all equipment required to be OPERABLE, all attendant equipment (this includes normal and emergency electrical sources) are also capable of performing their related support functions. New requirements were added as ITS LCO 3.8.1.c and ITS LCO 3.8.1.d. ITS LCO 3.8.1.c will require one opposite unit qualified circuit between the offsite transmission network and the opposite unit onsite Class 1E AC electrical power distribution system capable of supporting the equipment required to be OPERABLE by LCO 3.7.8, "Essential Service Water (ESW)

System," and LCO 3.8.1.d will require the opposite unit DG(s) capable of supporting the equipment required to be OPERABLE by LCO 3.7.8. This changes the CTS by adding explicit AC Source requirements for the opposite unit to the LCO.

The purpose of ITS LCO 3.8.1.c and ITS LCO 3.8.1.d is to ensure the appropriate AC Sources are available to support the ESW System.

CTS LCO 3.7.4.1 requires two independent ESW loops to be OPERABLE. The CTS 3/4.7.4 Bases state that the LCO also ensures that an inoperable opposite unit ESW pump does not result in flow being diverted from an OPERABLE unit ESW pump sharing the same header. Therefore, if the header between the two units is not isolated, both ESW pumps on the same header support both units.

Since the ESW pumps of the opposite unit are supported by the offsite circuits and DG(s) of the opposite unit, per the definition of OPERABILITY, these AC Sources are currently required to be OPERABLE when the associated ESW pump is not isolated from the other unit. This change is designated as administrative because it does not result in a technical change to the CTS.

A.3 CTS 3.8.1.1 Action c applies when one offsite circuit and one DG are inoperable.

In this condition, an emergency bus may be de-energized. CTS LCO 3.8.2.1 provides an Action for an emergency bus that is de-energized. A Note to ITS 3.8.1 ACTION D in the Required Actions column states, "Enter applicable Conditions and Required Action of LCO 3.8.9, "Distribution System - Operating,"

when Condition D is entered with no AC power source to any train." This changes the CTS by requiring the compensatory actions for Distribution System -

Operating to be taken if a distribution train is made inoperable by inoperable AC Sources.

This change is acceptable because no changes are made to CTS requirements.

The change in format from the CTS to the ITS maintains all technical CNP Units 1 and 2 Page 1 of 28 Attachment 1, Volume 13, Rev. 0, Page 23 of 496

Attachment 1, Volume 13, Rev. 0, Page 24 of 496 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING requirements. The addition of the Note only acts as a reminder to enter all appropriate ACTIONS if any emergency bus becomes de-energized. In the event AC Sources are inoperable such that a distribution subsystem were inoperable, ITS LCO 3.0.6 would allow taking only the AC Sources ACTIONS; taking exception to complying with the Distribution System ACTIONS. Since the AC Sources ACTIONS may not be sufficiently conservative in this event (an entire train may be without power), specific direction to take appropriate ACTIONS for the Distribution System is added (ITS 3.8.1, Note to ACTION D) when there is no power for a train. This format and construction implements the existing treatment of this condition within the framework of the CNP Units 1 and 2 ITS methods. This change is designated as administrative because it does not result in a technical change to the CTS.

A.4 CTS LCO 3.8.1.1 does not contain an Action for more than two sources of either offsite circuits or DGs inoperable. Having more than two sources inoperable requires entering CTS LCO 3.0.3. ITS 3.8.1 ACTION G requires entering LCO 3.0.3 immediately if three or more AC Sources are inoperable. This changes the CTS by adding a specific ACTION requiring entry into LCO 3.0.3.

The change is acceptable because the CTS Actions for more than two sources inoperable are the same as the ITS ACTIONS. The change is necessary due to the format of the ITS. This change is designated as administrative because it does not result in a technical change to the CTS.

A.5 CTS 4.8.1.1.2.a.4, CTS 4.8.1.1.2.e.4, CTS 4.8.1.1.2.e.5, CTS 4.8.1.1.2.e.6, CTS 4.8.1.1.2.e.7, and CTS 4.8.1.1.2.f.3) require the DGs to be started. ITS SR 3.8.1.2, SR 3.8.1.8, SR 3.8.1.12, SR 3.8.1.13, SR 3.8.1.19, and SR 3.8.1.20 also require the DGs to be started. However, each of the ITS Surveillances include a Note concerning a prelube. ITS SR 3.8.1.2 Note 1 states that all DG starts may be preceded by an engine prelube period and followed by a warmup period prior to loading. The Note to SR 3.8.1.8 and SR 3.8.1.20, Note 1 to SR 3.8.1.12, SR 3.8.1.13, and SR 3.8.1.19, and Note 2 to SR 3.8.1.16 state that all DG starts may be preceded by an engine prelube period. This changes the CTS by adding the Notes to the applicable Surveillance Requirements.

A Note has been added to various Surveillances which allows all DG starts to be preceded by an engine prelube period to minimize wear and tear on the DGs during testing. The addition of the Note is considered administrative since the DGs at CNP Units 1 and 2 run in a continuous prelube mode of operation. In addition, the Note to ITS SR 3.8.1.2 allows a warmup period prior to loading.

The addition of this part of the Note is considered administrative because the DGs are not immediately loaded upon startup, but are allowed to warmup for a short time after startup while the operations staff performs post startup DG checks. This change is designated as administrative because it does not result in a technical change to the CTS.

A.6 CTS 4.8.1.1.2.a.5 requires the DG to be synchronized and loaded for

> 60 minutes. Footnote ** allows for momentary load transients to not invalidate this test. In addition, the CTS does not place a time limit on loading the DG for this test. ITS SR 3.8.1.3 requires this same test and Footnote ** is incorporated as Note 2 to SR 3.8.1.3. However, SR 3.8.1.3 Note 1 has been added, which CNP Units 1 and 2 Page 2 of 28 Attachment 1, Volume 13, Rev. 0, Page 24 of 496

Attachment 1, Volume 13, Rev. 0, Page 25 of 496 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING states that DG loadings may include gradual loading as recommended by the manufacturer. This changes the CTS by adding an explicit Note that states that DG loadings may include gradual loading as recommended by the manufacturer.

CTS 4.8.1.1.2.a.5 requires the load to be at a specific value for > 60 minutes.

The added allowances simply state that prior to entering the load range of the test the DG can be gradually loaded. This is currently allowed by the CTS since there is no explicit requirement precluding this operation. This change is acceptable because Note 1 to SR 3.8.1.3 simply clarifies how the DG can be loaded prior to entering the load range for the test. This change is designated as administrative because it does not result in a technical change to the CTS.

A.7 CTS 3.0.5 states that it is not applicable in MODE 5 or 6. CTS 3.0.5 has been incorporated into the ACTIONS of ITS 3.8.1. This changes the CTS by incorporating the allowances of CTS 3.0.5 in ITS 3.8.1.

This change is acceptable because ITS 3.8.1 is only applicable in MODES 1, 2, 3, and 4. Therefore, the statement in CTS 3.0.5, which states that the Specification is not applicable in MODE 5 or 6, is no longer necessary and is deleted. This change is designated as administrative because it does not result in technical changes to the CTS.

A.8 CTS 4.8.1.1.2.e.7 requires verification that the DG operates at a power factor of less than or equal to 0.86 for at least 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . Within 5 minutes after completing this test, CTS 4.8.1.1.2.a.4, the normal DG start test, must be performed.

CTS 4.8.1.1.2.e.7 footnote ** states that if CTS 4.8.1.1.2.a.4 is not completed satisfactorily, it is not necessary to repeat the 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months test. Instead, the DG may be operated at the load required in CTS 4.8.1.1.2.e.7 for 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months "or until operating temperature has stabilized." The criteria for performing the normal DG start test within 5 minutes after completing the 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months test has been incorporated into ITS SR 3.8.1.16 Note 1. This Note states that the SR must be performed within 5 minutes of shutting down the DG after the DG has operated for > 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months within a specified load range. This changes the CTS by deleting the allowance to allow the DG to operate until temperature has stabilized.

The purpose of CTS 4.8.1.1.2.e.7 and associated footnote is to verify the ability of the DG to start at hot conditions. If CTS 4.8.1.1.2.a.4 (the DG restart test portion) fails after the performance of the 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months DG load test, the ** footnote to CTS 4.8.1.1.2.e.7 allows the DG to be operated at the specified load for 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months or until operating temperature has stabilized. ITS SR 3.8.1.16 Note 1 only includes a requirement that load must be within the load range for > 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months within 5 minutes of starting the SR. Operation for at least 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months has been demonstrated to be the time to achieve hot conditions (i.e., a stabilized operating temperature). Since the prerequisite for the SR is effectively unchanged, this change is considered administrative. This change is designated as administrative because it does not result in technical changes to the CTS.

A.9 CTS 4.8.1.1.1.b requires the demonstration of the offsite circuits by transferring the unit power source automatically from the normal auxiliary source to the preferred reserve source and by transferring manually to the alternate reserve source. ITS SR 3.8.1.9 requires the same Surveillance, however a Note is CNP Units 1 and 2 Page 3 of 28 Attachment 1, Volume 13, Rev. 0, Page 25 of 496

Attachment 1, Volume 13, Rev. 0, Page 26 of 496 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING added which states that the automatic transfer is only required to be met when the auxiliary source is supplying the onsite electrical power distribution subsystem. This changes the CTS by adding a clarification Note to the Surveillance (Note to ITS SR 3.8.1.9).

This change is acceptable since the preferred offsite circuit would be in a configuration to perform its safety function, and the auxiliary source (main generator) is not required for OPERABILITY. This change is designated as administrative because it does not result in technical changes to the CTS.

A.10 CTS 4.8.1.1.2.e contains a requirement to perform various tests "during shutdown." These tests have been incorporated in ITS SR 3.8.1.10 through SR 3.8.1.15 and SR 3.8.1.17 through SR 3.8.1.19. These Surveillances include a Note which state that the Surveillance shall not normally be performed in MODE 1 or 2 or MODE 1, 2, 3, or 4. However, portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. In addition, the Note states that credit may be taken for unplanned events that satisfy the SR. This changes the CTS by adding the allowance that credit may be taken for unplanned events that satisfy the associated SR. Additional changes to CTS 4.8.1.1.2.e are discussed in DOC L.8.

The ITS Notes clearly presents the allowance of the current practice of taking credit for unplanned events, provided the necessary data is obtained. This change is designated as administrative because it does not result in technical changes to the CTS.

A.11 CTS 4.8.1.1.2.e.6.c) requires the verification that all automatic DG trips, except engine overspeed and generator differential, are automatically bypassed upon loss of voltage on the emergency bus "and/or" Safety Injection actuation signal.

ITS SR 3.8.1.14 requires the verification that each DGs automatic trips are bypassed on an actual or simulated loss of voltage signal on the emergency bus "or" an actual or simulated ESF signal. This changes the CTS by clarifying the automatic trips are bypassed either upon loss of voltage on the emergency bus "or" an ESF signal, not both of them concurrently as could be interpreted by use of the "and/or" term.

This change is acceptable since it reflects the actual design of the system and the manner in which the current testing is being performed. The automatic trips other than the engine overpseed and generator differential are automatically bypassed when either the ESF signal or the loss of voltage signal are present.

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

A.12 CTS LCO 3.8.1.1.b.1 requires each DG fuel day tank to contain a minimum volume of 70 gallons of fuel. ITS SR 3.8.1.4 requires each DG fuel day tank to contain > 101.4 gallons of fuel oil. This changes the CTS by clarifying that the amount of fuel oil required to be stored in the DG day tank includes both the usable and unusable volumes.

CNP Units 1 and 2 Page 4 of 28 Attachment 1, Volume 13, Rev. 0, Page 26 of 496

Attachment 1, Volume 13, Rev. 0, Page 27 of 496 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING The purpose of CTS LCO 3.8.1.1.b.1 is to ensure the DG has sufficient fuel oil supply to allow the DG to run at full load before one of the fuel oil transfer pumps must be started to replenish the fuel oil supply and ensure uninterrupted DG service. As stated in the CTS Bases, the 70 gallons of fuel required by CTS LCO 3.8.1.1.b.1 is the usable volume. For clarity and for consistency with the fuel oil storage tank volume requirement, the contained volume is provided.

Each fuel oil day tank has 31.4 gallons of unusable volume (taking into account the geometry of the tank and a minimum submergence to suppress vortexing).

Therefore, the proposed value of 101.4 gallons ensures 70 gallons of usable fuel oil in the day tank. The change is acceptable since the proposed DG fuel oil volume in each day tank will ensure at least 15 minutes of DG operation. This change is designated as administrative because the day tank volume requirements are now explicit in stating the required volume of 101.4 gallons is a contained volume.

MORE RESTRICTIVE CHANGES M.1 CTS 4.8.1.1.2.e.3 requires a verification that the DG is capable of rejecting a load of 3500 kW without exceeding 75% of the difference between nominal speed and the overspeed trip setpoint. ITS SR 3.8.1.11 requires verification that each DG does not trip and voltage is maintained < 5000 V during and following a load rejection of > 3150 kW and < 3500 kW. This changes the CTS by adding a DG voltage limitation to the full load reject test. The change to the load range is discussed in DOC L.6 and the change to the speed limitation is discussed in DOC L.10.

The purpose of CTS 4.8.1.1.2.e.3 is to verify the proper operation of the DG governor and load control circuits. This change adds a DG voltage limitation to the acceptance criteria for the full load reject test. This Surveillance ensures proper engine generator load response under the simulated test conditions. This test simulates the loss of the total connected load that the DG experiences following a full load rejection and verifies that the DG does not trip upon loss of the load. This new acceptance criterion ensures that the DG is protected from damage upon loss of load. While the DG is not expected to experience this transient during an event, and is expected to continue to be available, verifying this response ensures that the DG is not degraded for future application, including reconnection to the bus if the trip initiator can be corrected or isolated.

This change is acceptable since it is consistent with Regulatory Guide 1.9, Rev. 3, paragraph C.2.2.8. This Surveillance demonstrates the DG capability to reject a full load without overspeed tripping or exceeding the predetermined voltage limits. This change is designated as more restrictive because a new acceptance criterion has been added to the DG full load reject test.

M.2 CTS 3.8.1.1 does not contain any explicit Action requirements for the opposite unit qualified circuits and DGs when these AC Sources are inoperable but are required to support the ESW System. CTS LCO 3.0.5 would allow the ESW System not to be declared inoperable as long as its normal or emergency power source is OPERABLE and all of its redundant support equipment are OPERABLE. ITS 3.8.1 ACTIONS A and B have been added to cover the situation when the opposite unit qualified offsite circuit or DG is inoperable, CNP Units 1 and 2 Page 5 of 28 Attachment 1, Volume 13, Rev. 0, Page 27 of 496

Attachment 1, Volume 13, Rev. 0, Page 28 of 496 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING respectively. ITS 3.8.1 Required Action A.3 will require the offsite circuit to be restored to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months while ITS 3.8.1 Required Action B.4 will require the inoperable DG to be restored to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . ITS 3.8.1 Required Actions B.3.1 and B.3.2 require a determination that the OPERABLE DG(s) is not inoperable due to common cause failure or to perform a DG start for each OPERABLE DG. In addition, a Note has been added to the Applicability which allows the opposite unit AC electrical power sources required by LCO 3.8.1.c and LCO 3.8.1.d to not be required to be OPERABLE when the associated equipment is inoperable. This change adds additional compensatory actions for the inoperable opposite unit AC Sources.

The purpose of ITS 3.8.1 ACTIONS A and B are to limit the time the unit can operate with inoperable AC Sources and to perform other compensatory measures. When an ESW header is cross-tied, the opposite unit ESW pump is required to be OPERABLE to support the associated ESW train. CTS 3.0.5 would allow continuous operation as long as the opposite unit ESW pump has at least one offsite circuit or DG to support its operation and there is no redundant equipment inoperable. This time has been limited to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The proposed change is acceptable since the proposed Completion Times are consistent with the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time currently allowed for the unit AC Sources. The added Applicability Note will allow the associated ESW equipment to be declared inoperable. This exception is intended to allow declaring the opposite unit supported equipment inoperable either in lieu of declaring the opposite unit power source inoperable, or at any time subsequent to entering ACTIONS for an inoperable opposite unit power source. This exception is acceptable since it is consistent with CTS 3.0.5, which allows an exception to the definition of OPERABLE - OPERABILITY (i.e., the component can always be declared inoperable). This change is designated as more restrictive since the Completion Time for restoring inoperable opposite unit AC Sources has been reduced consistent with the current Completion Times for the unit AC Sources.

M.3 CTS 3.8.1.1 Action d specifies the compensatory actions for two inoperable offsite circuits. The action requires restoration of at least one of these sources, and if not restored within the allowed time, the unit is required to 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 . In the ITS, if at least one offsite circuit is not restored to OPERABLE status within the allowed time, then ITS 3.8.1 ACTION F 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 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . This changes the CTS by adding the requirement to be in MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

The purpose of CTS 3.8.1.1 Action d is to provide the appropriate compensatory actions for two inoperable offsite circuits. The current action does not place the unit outside of the Applicability of the Specification. All other CTS 3.8.1.1 Actions require the unit to be placed outside of the Applicability of the Specification (i.e., MODE 5). This action is also considered appropriate for two inoperable offsite circuits. This change is designated as more restrictive because the unit must be placed outside of the Applicability of the Specification (i.e., MODE 5) instead of just to MODE 3.

CNP Units 1 and 2 Page 6 of 28 Attachment 1, Volume 13, Rev. 0, Page 28 of 496

Attachment 1, Volume 13, Rev. 0, Page 29 of 496 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING M.4 CTS 4.8.1.1.2.a.3 requires the verification that the fuel transfer pump can be started and that it transfers fuel from the storage system to the day tank. ITS SR 3.8.1.6 requires each verification that each fuel oil transfer system operates to "automatically" transfer fuel oil from the storage tank to the day tank. This changes the CTS by adding a requirement that the fuel oil transfer system must operate automatically.

The purpose of CTS 4.8.1.1.2.a.3 is to ensure the fuel transfer system is OPERABLE. This change will require a verification that a transfer pump starts automatically to transfer fuel on low level in the day tank. This change is necessary since it ensures a continuous fuel supply for the DG so that the DG can supply power to safety related equipment. This change is designated as more restrictive since the transfer pump will be required to start automatically.

M.5 CTS 4.8.1.1.2.a.4, the normal DG start test, requires a verification that each DG starts from standby conditions and achieves in less than or equal to 10 seconds, a voltage of 4160 + 420 V and a frequency of 60 + 1.2 Hz. CTS 4.8.1.1.2.a.4 footnote

clarifies that the DG start (10 seconds) from standby conditions shall be performed at least once per 184 days in these surveillance tests. All other engine starts for the purpose of this Surveillance testing and compensatory action may be at reduced acceleration rates as recommended by the manufacturer so that mechanical stress and wear on the DG are minimized.

CTS 4.8.1.1.2.e.2, the single largest load reject test, requires the verification of the generator capability to reject a load greater than or equal to the specified value while maintaining voltage at 4160 + 420 V and frequency of 60 + 1.2 Hz.

CTS 4.8.1.1.2.e.4, the simulated loss of offsite power test, and CTS 4.8.1.1.2.e.6, the simulated loss of offsite power test in conjunction with a Safety Injection signal test, also specify a steady state voltage of 4160 + 420 V and frequency of 60 + 1.2 Hz. CTS 4.8.1.1.2.e.7 requires the performance of CTS 4.8.1.1.2.a.4 within 5 minutes after performing the 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months test (commonly called a hot restart test). CTS 4.8.1.1.2.a.4 is divided into three Surveillances in the ITS. ITS SR 3.8.1.2 requires the verification that each DG starts from standby conditions and achieves steady state voltage of > 3910 V and < 4400 V and frequency of

> 59.4 Hz and < 61.2 Hz. ITS SR 3.8.1.2 Note 2 specifies that the modified DG start involving gradual acceleration to synchronous speed may be used for this SR as recommended by the manufacturer. ITS SR 3.8.1.8, the 184 day quickstart test, and SR 3.8.1.16, the 24 month hot restart test, require a steady state voltage of > 3910 V and < 4400 V and a steady state frequency of

> 59.4 Hz and < 61.2 Hz. ITS SR 3.8.1.10, the single largest load reject test, requires the verification that within 2 seconds following load rejection voltage is

> 3910 V and < 4400 V and frequency is > 59.4 Hz and < 61.2 Hz. ITS SR 3.8.1.12, the loss of offsite power test, and SR 3.8.1.19 the loss of offsite power test in conjunction with an ESF signal, also require verification of the same limitations for steady state voltage and frequency. This changes the CTS in that the steady state voltage range has been reduced from 4160 + 420 V to 4160 +240 V, -250 V and the steady state frequency range has been reduced from 60 + 1.2 Hz to 60 + 1.2 Hz, -0.6 Hz. The deletion of the maximum voltage and frequency limit for the quick start tests are described in DOC L.18.

The purpose of the CTS 3.8.1.1 Surveillances is to provide the appropriate limitations for DG voltage and frequency. This change reduces the steady state CNP Units 1 and 2 Page 7 of 28 Attachment 1, Volume 13, Rev. 0, Page 29 of 496

Attachment 1, Volume 13, Rev. 0, Page 30 of 496 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING voltage and frequency range. The more restrictive steady state voltage and frequency limits provide assurance that the emergency safety features (ESF) pumps have the appropriate level of voltage and frequency available so that they are assured of achieving adequate fluid flow to meet their safety and accident mitigation functions. The maximum voltage limit also provides a 10% voltage allowance for the 4000 V rated motors. This change is designated as more restrictive because the proposed limits for voltage and frequency have been reduced.

M.6 CTS 3/4.8.1.1 does not specify any requirements for the DG air start receiver pressure. ITS SR 3.8.1.7 requires verification that each required DG air start receiver pressure is > 190 psig every 31 days. This changes the CTS by adding a new Surveillance to the Technical Specifications that is not currently required.

The purpose of ITS SR 3.8.1.7 is to ensure sufficient air is available to start the DG. This Surveillance ensures that, without the aid of the refill compressor, sufficient air start capacity in the air start receiver for each DG is available. The pressure specified in this SR is intended to reflect the lowest value at which one start can be accomplished with one air start receiver. The 31 day Frequency takes into account the capacity, capability, redundancy, and diversity of the AC Sources and other indications available in the control room, including alarms, to alert the operator to below normal air start pressure. This change is designated as more restrictive because a new requirement concerning DG air start receiver pressure has been added to the Technical Specifications.

M.7 CTS 4.8.1.1.2.a.5 requires each DG to be synchronized and loaded for

> 60 minutes. ITS SR 3.8.1.3 requires the same test, however two additional Notes have been added which place restrictions on the test. Notes 3 and 4 modify the CTS requirements by stating that the SR shall be conducted on only one DG at a time, and the SR shall be preceded by and immediately follow, without a shutdown of the DG, a successful performance of ITS SR 3.8.1.2 or ITS SR 3.8.1.8. This changes the CTS by adding restrictions when performing this test.

This change is acceptable because CTS 4.8.1.1.2.a.5 is normally conducted on one DG at a time. In addition, the loading of a DG is usually conducted without shutdown after a successful start during performance of CTS 4.8.1.1.2.a.4. This change is designated as more restrictive because explicit restrictions are added to the DG load test.

M.8 CTS 4.8.1.1.2.e.2 requires the testing of a DG with the loss of a load 600 kW while CTS 4.8.1.1.2.e.3 requires the testing of DG with a loss of load of 3500 kW.

These Surveillances do not specify that a DG shall be tested at a specific power factor. ITS SR 3.8.1.10 requires the verification that each DG can reject a load equal to or greater than its associated single largest post-accident load. ITS SR 3.8.1.11 requires the verification that each DG can reject a load of > 3150 kW and < 3500 kW. The SRs additionally state in a Note "If performed with DG synchronized with offsite power, it shall be performed at a power factor 0.86.

However, if grid conditions do not permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as practicable." This changes the CTS requirement by specifying a power CNP Units 1 and 2 Page 8 of 28 Attachment 1, Volume 13, Rev. 0, Page 30 of 496

Attachment 1, Volume 13, Rev. 0, Page 31 of 496 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING factor of 0.86 if the testing is conducted by synchronizing with the offsite sources. Other changes to CTS 4.8.1.1.2.e.2 (ITS SR 3.8.1.10) are discussed in DOCs M.5, LA.4, and L.9, while other changes to CTS 4.8.1.1.2.e.3 (ITS SR 3.8.1.1.11) are discussed in DOCs L.6 and L.10.

This change is acceptable because the testing should be conducted as close as possible to the conditions that would be experienced by a DG following an accident. Loading the DG solely with the inductive characteristics of a large motor will create a power factor less than unity. The design of the DG is set for full power operation with a power factor of 0.8. Therefore, testing of the DG for a loss of the single largest load and at full load is acceptable with a power factor 0.86. This change is designated as more restrictive because the testing required by the CTS does not currently contain this limitation.

M.9 CTS 4.8.1.1.2.e.5, the Safety Injection actuation test (without a loss of power) requires the DG to start and operate for greater than or equal to 5 minutes.

ITS SR 3.8.1.13 requires the verification that each DG auto-start from standby condition and; a) in < 10 seconds the DG achieves voltage > 3740 V and frequency > 58.8 Hz; b) achieves steady state voltage > 3910 V and < 4400 V and frequency > 59.4 Hz and < 61.2 Hz; c) operates for > 5 minutes; d) permanently connected loads remain energized from the offsite power system; and e) emergency loads are auto-connected through the time delay relays, where applicable, from the offsite power system. This changes the CTS by adding additional performance requirements for the Safety Injection actuation test (without a loss of power).

The purpose of the CTS 4.8.1.1.2.e.5 is to test the performance of each DG when a Safety Injection actuation test (without a loss of power) signal is simulated. The proposed change adds explicit minimum voltage and frequency limits to achieve within 10 seconds of a start signal and adds explicit steady state voltage and frequency limits. In addition, the Surveillance verifies that the appropriate loads are connected to the offsite circuit. The change is acceptable because the acceptance criteria are consistent with the design requirements of the DGs and with other similar SRs where the DG starts but does not tie to the emergency buses. This change is designated as more restrictive because additional acceptance criteria have been added to the CTS.

M.10 CTS 4.8.1.1.2.f.3) requires, at least every 10 years, that both DGs are started simultaneously with a verification that both DGs start and accelerate to at least 514 RPM in less than or equal to 10 seconds. ITS SR 3.8.1.20 requires verification when started simultaneously from standby condition that each DG achieves, in < 10 seconds, voltage > 3740 V and frequency > 58.8 Hz. This changes the CTS by placing a minimum voltage limit for the DGs during this test.

The change to the speed limit is discussed in DOC L.15.

The purpose of CTS 4.8.1.1.2.f.3) is to test the interdependence of the DGs. The new voltage limit ensures that components powered by the associated bus will have sufficient voltage to perform their required function. This change is acceptable since the acceptance criteria is consistent with all other DG start CNP Units 1 and 2 Page 9 of 28 Attachment 1, Volume 13, Rev. 0, Page 31 of 496

Attachment 1, Volume 13, Rev. 0, Page 32 of 496 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING acceptance criteria. This change is designated as more restrictive because a DG voltage limit is added to the CTS for the DG interdependence test.

M.11 CTS LCO 3.8.1.1 does not contain any explicit LCO or Surveillance Requirements for the opposite unit qualified circuits and DGs when these AC Sources are required to support the ESW System. The opposite unit LCO requirements have been added as discussed in DOC A.2. ITS SR 3.8.1.21 has been added, and states which SRs of the opposite unit Specification 3.8.1 apply for the required opposite unit AC Sources. In addition, SR Table Notes 1 and 2 have been added to clarify which Surveillances are applicable to the given unit and which Surveillances are applicable to the opposite unit. SR Note 1 states that SR 3.8.1.1 through SR 3.8.1.20 apply to the given unit and SR Note 2 states that SR 3.8.1.21 is applicable to the opposite unit AC Sources. This changes the CTS by adding explicit Surveillances for the opposite unit required equipment.

The purpose of ITS SR 3.8.1.21 is to ensure the opposite unit AC Sources are OPERABLE. The proposed Surveillances are consistent with the current requirements that apply to the opposite unit. The change is acceptable since the Surveillances along with the Frequencies are consistent with the CTS as modified by other Discussion of Changes. This change is designated as more restrictive since the opposite unit Surveillances have been made applicable to the given unit.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS LCO 3.8.1.1.a requires two "physically independent" circuits between the offsite transmission network and the onsite Class 1E distribution system to be OPERABLE. CTS LCO 3.8.1.1.b requires two "separate and independent" DGs to be OPERABLE, each with a "separate" day fuel tank and a "separate fuel transfer pump." CTS 4.8.1.1.2.a.3 requires the verification that the fuel transfer "pump" can be started and that it transfers fuel from the storage system to the day tank. ITS LCO 3.8.1 requires two qualified circuits between the offsite transmission network and the onsite Class 1E distribution system and two DGs capable of supplying the onsite Class 1E power distribution subsystem(s) to be OPERABLE. ITS SR 3.8.1.4 requires verification that each day tank contains > 101.4 gallons of fuel oil. ITS SR 3.8.1.6 requires verification that the fuel oil transfer system operates automatically to transfer fuel oil from the storage tank to the day tank. This changes the CTS by moving the details that the offsite circuits are "physically independent," that the DGs are "separate and independent," that the day tanks are "separate," and that each OPERABLE DG has "a separate fuel transfer pump" from the CTS 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 CNP Units 1 and 2 Page 10 of 28 Attachment 1, Volume 13, Rev. 0, Page 32 of 496

Attachment 1, Volume 13, Rev. 0, Page 33 of 496 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirements for OPERABLE offsite sources and DGs and that the fuel oil transfer system operates automatically to transfer fuel oil from the storage tank to the day tank.

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

LA.2 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 4.8.1.1.2.a.6 requires the verification that each DG is aligned to provide standby power to the associated emergency buses. ITS 3.8.1 SRs do not contain this requirement. This changes the CTS by moving the detail that each DG is aligned to provide standby power to the associated emergency buses from the CTS to the ITS Bases.

The removal of these details, which are related to system design, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still requires the DGs to be OPERABLE. An OPERABLE DG must be capable of providing power to the associated emergency buses as indicated in the Bases. The details of what an OPERABLE DG must be capable of performing does not need to appear in the Specification in order for the requirement to apply. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LA.3 (Type 6 - Relocation of LCO, SR, or other TS requirement to the TRM, UFSAR, ODCM, QAPD, or IIP) CTS 4.8.1.1.2.e.1 requires each DG to be subjected to an inspection in accordance with procedures prepared in conjunction with its manufacturers recommendations for this class of standby service. The ITS does not include this DG inspection requirement. This changes the CTS by moving the explicit DG inspection Surveillance from the Technical Specifications to the Technical Requirements Manual (TRM).

The removal of these details from the Technical Specifications is acceptable because this type of information is not necessary to provide adequate protection of public health and safety. The purpose of CTS 4.8.1.1.2.e.1 is to ensure that each DG is inspected in accordance with procedures performed in conjunction with the manufacturers recommendations. The other DG Surveillances will ensure the DG is capable of performing its safety function. This requirement is proposed to be relocated to the TRM since the requirement is not needed to ensure that the DG remains OPERABLE. This change is acceptable because the removed information will be adequately controlled in the TRM. The TRM is CNP Units 1 and 2 Page 11 of 28 Attachment 1, Volume 13, Rev. 0, Page 33 of 496

Attachment 1, Volume 13, Rev. 0, Page 34 of 496 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING incorporated by reference into the UFSAR and any changes to the TRM are made under 10 CFR 50.59, which ensures changes are properly evaluated. This change is designated as a less restrictive removal of detail change because a requirement is being removed from the Technical Specifications.

LA.4 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 4.8.1.1.2.e.2 requires verification of the DG performance during a load rejection of greater than or equal to 600 kW. ITS SR 3.8.1.10 requires verification of the DG performance during a load rejection greater than or equal to the single largest post-accident load. This changes the CTS by moving the detail of the actual load value (600 kW) from the CTS to the ITS Bases.

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

LA.5 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 4.8.1.1.2.a.4 footnote

states that all engine starts for the purpose of this surveillance testing and compensatory action may be at reduced acceleration rates as recommended by the manufacturer "so that mechanical stress and wear on the DG are minimized." Note 2 to ITS SR 3.8.1.2 states that a modified DG start involving gradual acceleration to synchronous speed may be used for this SR as recommended by the manufacturer. This changes the CTS by moving the detail that mechanical stress and wear on the DG are minimized from the CTS to the ITS Bases.

The removal of these details, which are related to system design, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the Note that a modified DG start involving gradual acceleration to synchronous speed may be used as recommended by the manufacturer. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases.

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

CNP Units 1 and 2 Page 12 of 28 Attachment 1, Volume 13, Rev. 0, Page 34 of 496

Attachment 1, Volume 13, Rev. 0, Page 35 of 496 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING LESS RESTRICTIVE CHANGES L.1 (Category 3 - Relaxation of Completion Time) CTS 3.8.1.1 Action a specifies the compensatory actions for one inoperable offsite source. The action requires restoration of the two offsite circuits and two DGs to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . CTS 3.8.1.1 Action b specifies the compensatory actions for one inoperable DG. The action requires restoration of the DGs to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . CTS 3.8.1.1 Action c specifies the compensatory actions for one inoperable offsite circuit and one inoperable DG. The action requires restoration of at least one of these sources within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , and if the DG is restored to OPERABLE status to follow Action a and if the offsite circuit is restored to OPERABLE status to follow Action b. CTS 3.8.1.1 Action c also includes a footnote

that states that the Action time shall be based upon the time associated with the component inoperability, and is not reset when exiting this Action statement. CTS 3.8.1.1 Action d specifies the compensatory actions for two inoperable offsite circuits. The action requires restoration of at least one of these sources within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , and with only one offsite circuit restored to OPERABLE status to follow Action a. CTS 3.8.1.1 Action d also includes the same footnote mentioned above. CTS 3.8.1.1 Action e specifies the compensatory actions for two inoperable DGs. The action requires restoration of at least one of these sources within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , and with one DG restored to OPERABLE status to follow Action b or c. CTS 3.8.1.1 Action e also includes the same footnote mentioned above. ITS 3.8.1 Required Actions A.3, B.4, D.1 and D.2, C.2, and E.1, respectively include the same Completion Times as in the CTS. However, ITS 3.8.1 Required Actions A.3 (for an inoperable offsite circuit) and B.4 (for an inoperable DG) both include an additional requirement that restoration is required within 6 days from discovery of failure to meet LCO 3.8.1.a or b. This changes the CTS by extending the Completion Times for multiple concurrent AC Source inoperabilities from 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to 6 days.

The purpose of the CTS 3.8.1.1 Actions are to limit the time the AC Sources can be inoperable prior to requiring a shutdown of the unit. 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 event of multiple concurrent AC Source inoperabilities (i.e., one Train A or B DG and one offsite circuit), CTS 3.8.1.1 Action a limits restoration time to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months from the time of initial loss of the first AC Source since CTS 3.8.1.1 Action a requires restoration of at least two offsite circuits and two DGs within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . When a second inoperability occurs just prior to restoration of the initial inoperability and close to the expiration of the initial 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , this limitation can provide little or no time to effect repair. The result would be a forced shutdown of the unit. While these simultaneous inoperabilities are expected to be rare, it is also expected that any AC source inoperability would be repaired in a reasonable time (72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ). Given the minimal risk of an event during the repair of the subsequent inoperability, the likelihood of a satisfactory return to OPERABLE status, and the risks involved with introducing plant transients associated with a forced shutdown, it is proposed to allow a separate time period for this subsequent repair. Since this rationale can be taken to extreme with continuous multiple overlapping inoperabilities, a maximum restoration time limit is imposed.

CNP Units 1 and 2 Page 13 of 28 Attachment 1, Volume 13, Rev. 0, Page 35 of 496

Attachment 1, Volume 13, Rev. 0, Page 36 of 496 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING The ITS format presents this as an additional Completion Time of "6 days from discovery of failure to meet LCO 3.8.1.a or b" in ITS 3.8.1 Required Actions A.3 and B.4. This change is designated as less restrictive because additional time is allowed to restore the components to within the LCO limits than is allowed in the CTS.

L.2 (Category 7 - Relaxation of Surveillance Frequency, Non-24 Month Type Change) CTS 4.8.1.1.2.a requires that each DG be demonstrated OPERABLE in accordance with the frequency specified in Table 4.8-1 on a STAGGERED TEST BASIS. CTS Table 4.8-1 specifies the test frequency based on the number of failures that have occurred in testing each DG during the previous 20 tests. If the number of failures do not exceed the specified limit, testing is to be performed every 31 days on a STAGGERED TEST BASIS. If failures occur above the specified limits, then testing is conducted every 7 days on a STAGGERED TEST BASIS. In addition, CTS 3.8.1.1 Action b which covers inoperabilities associated with a DG includes a cross reference to the Table that states "At the number of failures for the inoperable diesel indicated in Table 4.8-1 perform the Additional Reliability Actions prescribed in Table 4.8-1." ITS 3.8.1 does not include the requirements to test at an accelerated testing Frequency based on DG failures.

ITS SR 3.8.1.2 requires each DG to be started at a fixed frequency of 31 days.

ITS SR 3.8.1.3 requires each DG be synchronized and loaded and operated for

> 60 minutes at a fixed frequency of 31 days. This changes the CTS by eliminating the requirement to test the DGs at an increased frequency based on the number of test failures. The change to the STAGGERED TEST BASIS requirements is discussed in DOC L.4 and the changes to the test frequency of CTS 4.8.1.1.2.a.1 and 3 are discussed in DOCs L.5 and L.19, respectively.

The purpose of CTS Table 4.8-1 is to test the DG in accordance with Regulatory Guide 1.9, Rev. 3. This change is acceptable because the new Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability. This change deletes the requirement to test the DG at an increasing frequency based on the number of test failures. A plant procedure implements requirements and responsibilities for tracking DG failures for the determination of reaching trigger values specified in NUMARC 87-00. In addition, Generic Letter 94-01, "Removal of Accelerated Testing and Special Reporting Requirements for Diesel Generators," allows Licensees to request removal from the Technical Specifications of provisions for accelerated testing.

CNP also proposes to make the changes allowed by Generic Letter 94-01. The basis for removing the accelerated testing requirements from the Technical Specifications and modifying the Surveillance Frequency of CTS 4.8.1.1.2.a.4 and CTS 4.8.1.1.2.a.5 (these Surveillances are tested in accordance with Table 4.8-1 in accordance with CTS 4.8.1.1.2.a), as stated in the Generic Letter, is for the licensee to commit to implement a maintenance program for monitoring and maintaining emergency DG performance in accordance with the provisions of the 10 CFR 50.65 (Maintenance Rule) and consistent with the guidance of Regulatory Guide 1.160. This commitment must be implemented within 90 days of issuance of the license amendment that removes the accelerated testing and special reporting requirements for emergency DGs from the Technical Specifications. CNP has already implemented a maintenance program for monitoring and maintaining emergency DG performance in accordance with the provisions of the Maintenance Rule and consistent with the guidance in CNP Units 1 and 2 Page 14 of 28 Attachment 1, Volume 13, Rev. 0, Page 36 of 496

Attachment 1, Volume 13, Rev. 0, Page 37 of 496 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING Regulatory Guide 1.160. Therefore, since the commitment has already been met, the requirements are not required to be in the ITS to provide adequate protection of the public health and safety and the allowances in Generic Letter 94-01 are acceptable. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

L.3 (Category 10 - 18 to 24 Month Surveillance Frequency Change, Non-Channel Calibration Type) CTS 4.8.1.1.1.b requires a demonstration that the offsite circuits are OPERABLE by transferring the unit power source automatically from the normal auxiliary source to the preferred reserve source and by transferring manually to the alternate reserve source. CTS 4.8.1.1.2.e.2 requires a verification that the DG is capable of rejecting a load > 600 kW.

CTS 4.8.1.1.2.e.3 requires a verification that the DG is capable of rejecting a load of 3500 kW. CTS 4.8.1.1.2.e.4 requires a verification of the DG performance during a simulated loss of offsite power. CTS 4.8.1.1.2.e.5 requires a verification of the DG performance during a simulated Safety Injection actuation.

CTS 4.8.1.1.2.e.6 requires a verification of the DG performance during a simulated Safety Injection actuation test signal with a loss of offsite power.

CTS 4.8.1.1.2.e.7 requires a verification of the DG performance during an 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months run at the continuous load rating. CTS 4.8.1.1.2.e.9 requires a verification of the DG performance during a simulated restoration of offsite power.

CTS 4.8.1.1.2.e.11 requires a verification of the automatic sequence timing relays. These Surveillances are performed on an 18 month Frequency. ITS SR 3.8.1.9 through SR 3.8.1.19 require the same testing (as modified by specific DOCs) at a 24 month Frequency. This changes the CTS by extending the Frequency of the Surveillance from 18 months (i.e., a maximum of 22.5 months accounting for the allowable grace period specified in CTS 4.0.2 and ITS SR 3.0.2) to 24 months (i.e., a maximum of 30 months accounting for the allowable grace period specified in CTS 4.0.2 and ITS SR 3.0.2).

The purpose of the CTS 3.8.1.1 Surveillances are to ensure the offsite circuits and the DGs are OPERABLE.

SR 3.8.1.9 requires automatic transfer from the auxiliary source to the preferred offsite circuit and manual alignment to the alternate offsite circuit to demonstrate the OPERABILITY of the required offsite circuits.

SR 3.8.1.10 verifies each DG rejects a load greater than or equal to its associated single largest post-accident load and following load rejection, the specified frequency limit is not exceeded and the specified frequency and voltage are achieved within the specified time. This SR verifies the proper operation of the DG governor and load control circuits.

SR 3.8.1.11 verifies each DG does not trip and the specified voltage is maintained during and following a load rejection of the specified load. This SR verifies the proper operation of the DG governor and load control circuits.

SR 3.8.1.12 verifies on an actual or simulated loss of offsite power signal: a) de-energization of emergency buses; b) load shedding from emergency buses; and c) DG auto-starts from standby condition and 1) energizes permanently CNP Units 1 and 2 Page 15 of 28 Attachment 1, Volume 13, Rev. 0, Page 37 of 496

Attachment 1, Volume 13, Rev. 0, Page 38 of 496 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING connected loads in the specified time, 2) energizes auto-connected shutdown loads, 3) maintains the specified steady state voltage, 4) maintains the specified steady state frequency, and 5) supplies permanently connected and auto-connected shutdown loads for greater than the specified time. This Surveillance demonstrates the as-designed operation of the standby power sources during loss of the offsite source. This test verifies all actions encountered from the loss of offsite power, including shedding of the nonessential loads and energization of the emergency buses and respective loads from the DG. It further demonstrates the capability of the DG to automatically achieve the required voltage and frequency within the specified time.

SR 3.8.1.13 verifies on actual or simulated Engineered Safety Feature (ESF) actuation signal each DG auto-starts from standby condition and: a) within the specified time after auto-start, achieves the specified voltage and frequency; b) achieves the specified steady state voltage and frequency; c) operates for the specified minimum time; d) permanently connected loads remain energized from the offsite power system; and e) emergency loads are auto-connected through the time delay relays from the offsite power system. This Surveillance demonstrates that the DG automatically starts and achieves the required voltage and frequency within the specified time from the design basis actuation signal (ESF signal) and operates for greater than the specified time period which provides sufficient time to demonstrate stability. In addition, it verifies the OPERABIITY of the offsite power system.

SR 3.8.1.14 verifies each DGs automatic trips are bypassed on an actual or simulated loss of offsite power signal on the emergency bus or an actual or simulated ESF actuation signal except: a) engine overspeed; and b) generator differential current. This SR is essentially a verification of logic since the normal operation of the DG has all automatic trips active, and the trips are only bypassed with an ESF actuation signal or a loss of power signal.

SR 3.8.1.15 verifies each DG operates > 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months at the specified load range.

This Surveillance demonstrates that the DG can operate at or above the maximum load during an accident and within the continuous rating of the diesel.

SR 3.8.1.16 verifies each DG starts and achieves: a) in the specified time the required voltage and frequency; and b) specified steady state voltage and frequency. This Surveillance demonstrates that the diesel engine can restart from a hot condition, such as subsequent to shutdown from normal Surveillances, and achieve the required voltage and frequency within the required time.

SR 3.8.1.17 verifies each DG: a) synchronizes with offsite power source while loaded with emergency loads upon a simulated restoration of offsite power; b) transfers loads to offsite power source; and c) returns to ready-to-load operation.

This Surveillance ensures that the manual synchronization and load transfer from the DG to a required offsite power source can be made and that the DG can be returned to ready-to-load status when offsite power is restored. It also ensures that the undervoltage logic is reset to allow the DG to reload if a subsequent loss of offsite power occurs.

CNP Units 1 and 2 Page 16 of 28 Attachment 1, Volume 13, Rev. 0, Page 38 of 496

Attachment 1, Volume 13, Rev. 0, Page 39 of 496 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING SR 3.8.1.18 verifies the interval between each sequenced load block is within the specified design interval for each time delay relay. Under accident conditions, loads are sequentially connected to the bus by the time delay relays. The time delay relays control the permissive and starting signals to motor breakers to prevent overloading of the bus power supply due to high motor starting currents.

The load sequence time tolerance ensures that sufficient time exists for the bus power supply to restore frequency and voltage prior to applying the next load and that safety analysis assumptions regarding emergency equipment time delays are not violated.

SR 3.8.1.19 verifies on an actual or simulated loss of offsite power signal in conjunction with an actual or simulated ESF actuation signal: a) de-energization of emergency buses; b) load shedding from emergency buses; and c) DG auto-starts from standby condition and, 1) energizes permanently connected loads in less than the specified time, 2) energizes auto-connected emergency loads, 3) achieves steady state voltage specified, 4) achieves steady state frequency specified, and 5) supplies permanently connected and auto-connected emergency loads for greater than or equal to the specified time. This Surveillance demonstrates the DG operation, as discussed in the Bases for SR 3.8.1.12, during a loss of offsite power actuation test signal in conjunction with an ESF actuation signal. In lieu of actual demonstration of connection and energization of loads, testing that adequately shows the capability of the DG system to perform these functions is acceptable.

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 offsite circuits and DG SRs is acceptable because the DGs are verified to be operating properly throughout the operating cycle by other Technical Specification Surveillances. This testing ensures that a significant portion of the DG and offsite circuits are operating properly and will detect significant failures of the AC Sources. Additional justification for extending the Surveillance test interval is that the design provides substantial redundancy in AC sources. Based on system redundancy, component reliability, and the testing performed during the operating cycle, the impact, if any, from this change on system availability is minimal. The review of historical surveillance data also demonstrated that there are no failures that would invalidate this conclusion. In addition, the proposed 24 month Surveillance Frequency, if performed at the maximum interval allowed by ITS SR 3.0.2 (30 months) does not invalidate any assumptions in the plant licensing basis. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

L.4 (Category 7 - Relaxation Of Surveillance Frequency, Non-24 Month Type Change) CTS 4.8.1.1.2.a states that each DG shall be demonstrate OPERABLE in accordance with the frequency specified in Table 4.8-1 "on a STAGGERED CNP Units 1 and 2 Page 17 of 28 Attachment 1, Volume 13, Rev. 0, Page 39 of 496

Attachment 1, Volume 13, Rev. 0, Page 40 of 496 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING TEST BASIS." The Surveillance Frequency for ITS SR 3.8.1.2, SR 3.8.1.3, and SR 3.8.1.4 is every 31 days, but does not include the "STAGGERED TEST BASIS" requirement. The ITS SR 3.8.1.6 Surveillance Frequency is every 92 days as discussed in DOC L.19, and also 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 4.8.1.1.2.a is to demonstrate the OPERABILITY of the DG(s) and the associated support equipment (fuel oil day tank and fuel oil transfer system). This change is acceptable because the new Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability. This change deletes the requirement to perform the Surveillances of CTS 4.8.1.1.2.a on a STAGGERED TEST BASIS. The intent of a requirement for staggered testing is to increase reliability of the component/system being tested. A number of studies have been performed that demonstrate 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 DG 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.

L.5 (Category 7 - Relaxation Of Surveillance Frequency, Non-24 Month Type Change) CTS 4.8.1.1.2.a.1 requires the verification of the fuel level in the day tank. The test Frequency for this Surveillance is in accordance with the frequency specified in Table 4.8-1 (the DG Test Schedule Table) on a STAGGERED TEST BASIS. ITS SR 3.8.1.4 requires verification that each day tank contains the required volume of fuel oil every 31 days. This changes the CTS by deleting the requirement to perform this Surveillance in accordance with the DG Test Schedule Table. The change to the STAGGERED TEST BASIS requirement is discussed in DOC L.4.

The purpose of CTS 4.8.1.1.2.a.1 is to ensure there is sufficient fuel oil in the day tank. This change is acceptable because the new Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability. The CTS test frequency has been changed by deleting the requirement to perform this Surveillance in accordance with the DG Test Schedule Table and includes a Frequency of 31 days. This change is acceptable because the DG failures that result in a more frequent DG test frequency have no impact on the day tanks ability to perform the intended function since the day tanks are normally maintained well above the minimum level. 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 4.8.1.1.2.a.5 specifies that the DG must be loaded to 3500 kW during the CNP Units 1 and 2 Page 18 of 28 Attachment 1, Volume 13, Rev. 0, Page 40 of 496

Attachment 1, Volume 13, Rev. 0, Page 41 of 496 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING 60 minute run test. CTS 4.8.1.1.2.e.3 specifies that the load rejection test must be performed by rejecting a load of 3500 kW. CTS 4.8.1.1.2.e.7 requires the diesel to be loaded to 3500 kW during the 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months run test. CTS 4.8.1.1.2.e.7 states that within 5 minutes after completing this 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months test to perform CTS 4.8.1.1.2.a.4, and footnote ** states that if CTS 4.8.1.1.2.a.4 is not satisfactorily completed, then it is not necessary to repeat the preceding 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months test. Instead, the DG may be operated at 3500 kW for 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months or until operating temperatures has stabilized. ITS SR 3.8.1.3, the 60 minute run test, specifies that each DG must be loaded to > 3150 kW and < 3500 kW. ITS SR 3.8.1.11, the full load rejection test, specifies the load rejection range for the test to be

> 3150 kW and < 3500 kW. ITS SR 3.8.1.15, the 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months endurance run, specifies the load range to be > 3150 kW and < 3500 kW. ITS SR 3.8.1.16, the hot restart test, is modified by Note 1, which includes the details of CTS 4.8.1.1.2.e.7 footnote **, however the load has also been changed to

> 3150 kW and < 3500 kW. This changes the CTS by allowing the DGs to be tested at a lower load during these Surveillances.

The purpose of CTS 4.8.1.1.2.a.5 is to ensure the DG can operate at the continuous rating. The purpose of CTS 4.8.1.1.2.e.3 is to ensure the DG operates properly during a full load rejection test. The purpose of CTS 4.8.1.1.2.e.7 is to ensure the DG can operate for an extended period at its continuous rating. The purpose of CTS 4.8.1.1.2.e.7 footnote ** is to ensure the DG hot restart test is performed with the DG at hot conditions. This change allows the DGs to be tested at a lower load during these Surveillances. 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 proposed minimum value is consistent with Regulatory Guide 1.9, Rev. 3 (paragraph C.2.2.2), which recommends a load range of 90% to 100% for the load-run test; Regulatory Guide 1.9, Rev. 3 (paragraph C.2.2.8), which recommends a load range of 90% to 100% for the full load rejection test; and Regulatory Guide 1.9, Rev. 3 (paragraph C.2.2.9), which recommends this same load range for most of the endurance run. The proposed values are 90% to 100% of the continuous load rating and therefore are considered to be consistent with the recommendations of Regulatory Guide 1.9, Rev. 3. The values will preclude routine overloading of the DG and the lower value will still ensure the DG is at operating temperatures and that the maximum loads assumed in the safety analyses can be supported. 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 7 - Relaxation Of Surveillance Frequency, Non-24 Month Type Change) CTS 4.8.1.1.2.b.1) requires the removal of accumulated water from the day tank at least once per 31 days and "after each occasion when the diesel is operated for greater than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months ." ITS SR 3.8.1.5, which requires the same Surveillance to be performed once per 31 days, does not include the conditional Frequency. This changes the CTS by deleting the requirement to test for accumulated water after each occasion when the DG is operated for greater than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

CNP Units 1 and 2 Page 19 of 28 Attachment 1, Volume 13, Rev. 0, Page 41 of 496

Attachment 1, Volume 13, Rev. 0, Page 42 of 496 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING The purpose of CTS 4.8.1.1.2.b.1) is to provide a degree of assurance that the day tank is free of accumulated water each time the associated DG is operated for more than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . This change is acceptable because the new Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability. Water condensation within the fuel oil day tanks is a time dependent process, not a process dependent on the transfer of fuel oil during DG operation. Since it is the expectation that the DG will not be operated except for the nominal monthly OPERABILITY tests (based on experience), and that the fuel oil storage tanks are also periodically checked for water, no increased Frequency is necessary. This change is designated as less restrictive because the explicit requirement to remove accumulated water in the day tank after a DG run of greater than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months has been deleted.

L.8 (Category 12 - Deletion of Surveillance Requirement Shutdown Performance Requirements) CTS 4.8.1.1.2.e contains a requirement to perform various test "during shutdown." These tests have been incorporated in ITS SR 3.8.1.10 through SR 3.8.1.15 and SR 3.8.1.17 through SR 3.8.1.19. ITS SR 3.8.1.10, SR 3.8.1.11, and SR 3.8.1.13 through SR 3.8.1.15 include a Note which state that the Surveillance shall not normally be performed in MODE 1 or 2. ITS SR 3.8.1.12 and SR 3.8.1.17 through SR 3.8.1.19 include a Note which state that the Surveillance shall not normally be performed in MODE 1, 2, 3, or 4. The Notes also state that the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. This changes the CTS by deleting the requirement to perform the Surveillances during shutdown, and replacing the shutdown requirement with a Note stating when the Surveillances are not normally performed but allowing the test to be performed in these MODES as long as the associated assessment is performed.

The purpose of CTS 4.8.1.1.2.e is to confirm the OPERABILITY of the DGs. 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.

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

CTS 4.8.1.1.2.e.2 requires a verification that the DG is capable of rejecting a load

> 600 kW while maintaining a voltage of 4160 + 420 V and frequency of 60 + 1.2 Hz. ITS SR 3.8.1.10 requires verification that each DG rejects a load greater than or equal to its associated single largest post-accident load and following load rejection, frequency is < 64.4 Hz, and after 2 seconds steady state voltage is > 3910 V and < 4400 V and frequency is > 59.4 Hz and < 61.2 Hz.

This changes the CTS by allowing the transient frequency to exceed the limit for the first 2 seconds and deleting the voltage limits during the first 2 seconds of the CNP Units 1 and 2 Page 20 of 28 Attachment 1, Volume 13, Rev. 0, Page 42 of 496

Attachment 1, Volume 13, Rev. 0, Page 43 of 496 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING transient. Other changes to the minimum frequency limit and the minimum and maximum voltage limits are discussed in DOC M.5.

The purpose of CTS 4.8.1.1.2.e.2 is to ensure the proper operation of the DG governor and load control circuits. This change is acceptable because it has been determined that the relaxed Surveillance Requirement acceptance criteria are not necessary for verification that the equipment used to meet the LCO can perform its required functions. This changes the CTS by allowing the transient frequency and voltage to exceed the current limit, but provides a time limit for the stabilization of voltage and frequency. Consistent with Regulatory Guide 1.9, the load rejection test is acceptable if the diesel speed does not exceed 75% of the difference between nominal speed and the overspeed trip setpoint, or 15% above nominal speed, whichever is lower. This corresponds to 64.4 Hz, which is the nominal speed plus 75% of the difference between nominal speed and the overspeed trip setpoint. The time to reach steady state voltage is also consistent with the recommendation of Regulatory Guide 1.9 for response during load sequence intervals. The 2 seconds specified is equal to approximately 60% of the 3.49 second load sequence interval associated with sequencing of the largest load. This change is acceptable since the maximum frequency limitation is consistent with the limitation specified in CTS 4.8.1.1.2.e.3 for the full load rejection test and consistent with the recommendations of Regulatory Guide 1.9.

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 4.8.1.1.2.e.3 requires a verification that the DG is capable of rejecting a load of 3500 kW without exceeding 75% of the difference between nominal speed and the overspeed trip setpoint. ITS SR 3.8.1.11 requires verification that each DG does not trip and voltage is maintained < 5000 V during and following a load rejection of > 3150 kW and < 3500 kW. This changes the CTS by changing the DG full load rejection speed limitation acceptance criteria. The change to the load range is discussed in DOC L.6 and the addition of the voltage limit is discussed in DOC M.1.

The purpose of CTS 4.8.1.1.2.e.3 is to verify the proper operation of the DG governor and load control circuits. This change is acceptable because it has been determined that the relaxed Surveillance Requirement acceptance criteria are not necessary for verification that the equipment used to meet the LCO can perform its required functions. This changes the speed limitation acceptance criteria of the full load rejection test. This Surveillance ensures proper engine generator load response under the simulated test conditions. This test simulates the loss of the total connected load that the DG experiences following a full load rejection and verifies that the DG does not trip upon loss of the load. This acceptance criterion verifies that the DG is adequately protected from damage upon loss of load. While the DG is not expected to experience this transient during an event, and is expected to continue to be available, verifying this response ensures that the DG is not degraded for future application, including reconnection to the bus if the trip initiator can be corrected or isolated. The change is also acceptable since it is consistent with Regulatory Guide 1.9, Rev.3, paragraph C.2.2.8. This change is designated as less restrictive because less CNP Units 1 and 2 Page 21 of 28 Attachment 1, Volume 13, Rev. 0, Page 43 of 496

Attachment 1, Volume 13, Rev. 0, Page 44 of 496 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

L.11 (Category 6 - Relaxation Of Surveillance Requirement Acceptance Criteria)

CTS 4.8.1.1.2.e.4 requires verification of DG performance following a "simulated" loss of offsite power. CTS 4.8.1.1.2.e.5 requires verification of DG performance following a Safety Injection actuation "test" signal. CTS 4.8.1.1.2.e.6 requires verification of DG performance following a "simulated" loss of offsite power in conjunction with a Safety Injection actuation "test" signal. ITS SR 3.8.1.12, SR 3.8.1.13, SR 3.8.1.14, and SR 3.8.1.19 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 4.8.1.1.2.e.4, CTS 4.8.1.1.2.e.5, and CTS 4.8.1.1.2.e.6 is to ensure that the AC Sources 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.

L.12 (Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria)

CTS 4.8.1.1.2.e.7 requires verification that the DG operates at a power factor of less than or equal to 0.86 for at least 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . ITS SR 3.8.1.15 requires verification that each DG operates at a power factor of < 0.86 for > 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , but a Note (ITS SR 3.8.1.15 Note 3) has been added which allows the power factor to be outside of the limit under certain conditions. The Note states that if performed with DG synchronized with offsite power, it shall be performed at a power factor

< 0.86. However, if grid conditions do not permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as practicable. This changes the CTS by allowing the 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months endurance run to be performed at a power factor outside of the CTS limit.

The purpose of CTS 4.8.1.1.2.e.7 is to test the DG at the continuous load for an extended period of time. This change is acceptable because it has been determined that the relaxed Surveillance Requirement acceptance criteria are not necessary for verification that the equipment used to meet the LCO can perform its required functions. This change allows the DG 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months endurance run to be performed at a power factor outside of the CTS limit. However, this is only permitted if the DG is not synchronized with offsite power, or if the DG is synchronized with offsite power but grid conditions do not permit. Under this second condition the power factor shall be maintained as close to the limit as practicable. This power factor is representative of the actual inductive loading a DG would see under design basis accident conditions. When grid voltage is high, additional field excitation may be needed to get the power factor to 0.86 which could lead to voltages on the emergency buses that are too high. Under CNP Units 1 and 2 Page 22 of 28 Attachment 1, Volume 13, Rev. 0, Page 44 of 496

Attachment 1, Volume 13, Rev. 0, Page 45 of 496 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING these conditions, the power factor should be maintained as close as practicable to 0.86 while still maintaining acceptable voltage limits on the emergency buses.

In other circumstances, the grid voltage may be such that the DG excitation levels needed to obtain a power factor of 0.86 may not cause unacceptable voltages on the emergency buses, but the excitation levels are in excess of those recommended for the DG. In such cases, the power factor shall be maintained close as practicable to 0.86 without exceeding the DG excitation limits. This change is acceptable since the DG will continue to be tested as close as practicable to design conditions. 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.13 (Category 5 - Deletion of Surveillance Requirement) CTS 4.8.1.1.2.e.8 requires verification that the auto-connected loads to each DG do not exceed 3500 kW.

ITS 3.8.1 does not require the verification of this loading limit to ensure OPERABILITY of the DGs. This changes the CTS by deleting the Surveillance Requirement.

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. Each DG will continue to be tested in a manner to ensure the safety analyses assumption will be met. Changes to the auto-connected loads will be controlled and evaluated by the design change control process to ensure the DG is not overloaded. This change is designated as less restrictive because a Surveillance which is required in the CTS will not be required in the ITS.

L.14 (Category 12 - Deletion of Surveillance Requirement Shutdown Performance Requirements) CTS 4.8.1.1.2.f.3) contains a requirement to start both DGs simultaneously "during shutdown." ITS SR 3.8.1.20 removes the MODE restrictions for performing the required test. This changes the CTS by deleting the requirement to perform the Surveillance during shutdown.

The purpose of CTS 4.8.1.1.2.f.3) is to verify the interdependence of the DGs.

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 Surveillance can be adequately tested in the operating conditions without jeopardizing safe plant operations, since the Surveillance does not require the DGs to be connected to their respective buses and only requires a start of the DGs. 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 23 of 28 Attachment 1, Volume 13, Rev. 0, Page 45 of 496

Attachment 1, Volume 13, Rev. 0, Page 46 of 496 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING L.15 (Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria)

CTS 4.8.1.1.2.f.3) contains a requirement to start both DGs simultaneously and verifying that both DGs accelerate to at least 514 RPM in less than or equal to 10 seconds. ITS SR 3.8.1.20 requires verification when the DGs are started simultaneously that each DG achieves a frequency of greater than or equal to 58.8 Hz. This changes the CTS by decreasing the speed (i.e., frequency) requirement from 514 RPM (60 Hz) to 58.8 Hz.

The purpose of CTS 4.8.1.1.2.f.3) is to ensure the DGs retain their independence from one another. This change is acceptable because it has been determined that the relaxed Surveillance Requirement acceptance criteria are not necessary for verification that the equipment used to meet the LCO can perform its required functions. This change decreases the minimum frequency requirement for the DG during a simultaneous start. This change is acceptable because the value is consistent with the minimum frequency proposed in other Surveillances (e.g., ITS SR 3.8.1.8). 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.16 (Category 5 - Deletion of Surveillance Requirement) CTS 4.8.1.1.2.f.3) footnote

specifies that CTS 4.8.1.1.2.f.3) must be performed following any modification that could affect DG interdependence. ITS 3.8.1 does not include this testing requirement. This changes the CTS by deleting this testing requirement.

This change is acceptable because the deleted Surveillance Requirement is not necessary to verify that the equipment used to meet the LCO is consistent with the safety analyses. Thus, appropriate equipment continues to be tested in a manner and at a Frequency necessary to give confidence that the assumptions in the safety analyses are protected. Following repair, maintenance, modification, or replacement of a component that may affect OPERABILITY, post maintenance testing is required to demonstrate OPERABILITY of the system or component. This is described in the Bases of ITS SR 3.0.1 and required under SR 3.0.1. The OPERABILITY requirements of the DGs are described in the Bases for Specification 3.8.1. 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 is required under the units 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.17 (Category 3 - Relaxation of Completion Time) CTS 3.0.5 allows a system, subsystem, train, component, or device to be considered OPERABLE with an inoperable emergency or normal power source provided its corresponding normal or emergency power source is OPERABLE and its redundant system(s),

subsystem(s), train(s), component(s), and device(s) are OPERABLE. CTS 3.0.5 requires a unit shutdown to start within two hours with these requirements not met. CTS 3.0.5 also provides an explicit time period to be in HOT STANDBY (MODE 3), HOT SHUTDOWN (MODE 4), and COLD SHUTDOWN (MODE 5).

CNP Units 1 and 2 Page 24 of 28 Attachment 1, Volume 13, Rev. 0, Page 46 of 496

Attachment 1, Volume 13, Rev. 0, Page 47 of 496 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING ITS 3.8.1 ACTION A (one required offsite source inoperable) requires the declaration of required feature(s) with no offsite power available inoperable when its redundant required feature(s) is inoperable. The Completion Time allowed by the Required Action A.2 is 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from discovery of no offsite power to one train concurrent with inoperability of redundant required feature(s). ITS 3.8.1 ACTION B (one required DG inoperable) requires the declaration of required feature(s) supported by the inoperable DG inoperable when its required redundant feature(s) is inoperable. The Completion Time allowed by the Required Action B.2 is 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from discovery of Condition B concurrent with inoperability of redundant required feature(s). ITS 3.8.1 ACTION C (two required offsite circuits inoperable) requires the declaration of required feature(s) inoperable when its redundant required feature(s) is inoperable. The Completion Time allowed by the Required Action C.1 is 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from discovery of Condition C concurrent with inoperability of redundant required features. This changes the CTS by allowing more time to restore inoperable equipment and replaces the explicit times to be in MODE 3, MODE 4, and MODE 5 with a requirement to declare the affected features inoperable (and thus to take the ACTIONS required by the individual system LCO, including possible shutdown of the unit).

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. This change allows more time to restore inoperable equipment when required AC Sources are inoperable concurrent with inoperabilities of redundant required features and deletes the explicit times to be in MODE 3, MODE 4, and MODE 5.

By declaring the affected supported equipment inoperable, and as a result, taking the Technical Specifications ACTIONS of the affected supported equipment, unit operation is maintained within the bounds of the Technical Specifications and approved ACTIONS. Since the AC Sources support the OPERABILITY of the affected equipment, it is appropriate that the proper action, in this condition, would be to declare that affected supported equipment inoperable. CTS 3.0.5 is overly restrictive, in that if the associated supported equipment were inoperable for other reasons and the redundant equipment was also inoperable, a restoration time is sometimes provided, in other CTS sections. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time when one required offsite circuit is inoperable is acceptable because: a) the redundant counterpart to the inoperable required feature is still OPERABLE although single failure protection may have been lost; b) the capacity and capability of the remaining AC Sources is still available; c) a reasonable time for repairs is provided for restoration before the unit is subjected to transients associated with shutdown; and d) the low probability of a DBA occurring during this period. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Completion Time when two required offsite circuits are inoperable is acceptable because Regulatory Guide 1.93 allows a Completion Time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for two required offsite circuits inoperable.

When a concurrent redundant required function is inoperable, a shorter Completion Time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is appropriate. The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time with one required DG inoperable takes into account the component OPERABILITY of the redundant counterpart to the inoperable required feature and is considered to be less of a risk than subjecting the unit to transients associated with shutdown.

CNP Units 1 and 2 Page 25 of 28 Attachment 1, Volume 13, Rev. 0, Page 47 of 496

Attachment 1, Volume 13, Rev. 0, Page 48 of 496 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING Additionally, the 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time takes into account the capacity and capability of the remaining AC Sources, reasonable time for repairs, and low probability of a DBA occurring during this period. This change is designated as less restrictive because additional time is allowed to restore equipment to OPERABLE status and the change deletes the explicit times to reach MODE 3, MODE 4, and MODE 5.

L.18 (Category 6 - Relaxation Of Surveillance Requirement Acceptance Criteria)

CTS 4.8.1.1.2.a.4, the normal DG start test, and CTS 4.8.1.1.2.e.7, the DG hot restart test, each require a verification that the DG starts from standby conditions and achieves in less than or equal to 10 seconds, a voltage of 4160 + 420 V and a frequency of 60 + 1.2 Hz. ITS SR 3.8.1.8, the 184 day quick start test, and SR 3.8.1.16, the 24 month hot restart test, require the verification that each DG starts from standby conditions and achieves a voltage of > 3740 V and frequency

> 58.8 Hz within 10 seconds and a steady state voltage of > 3910 V and < 400 V and a steady state frequency of > 59.4 Hz and < 61.2 Hz. This changes the CTS by specifying a minimum voltage and frequency to be achieved within 10 seconds instead of requiring the voltage and frequency to be within range in 10 seconds. This effectively allows the upper steady state limits to be exceeded during DG acceleration and stabilization. The change to the actual frequency and voltage values is discussed in DOC M.5.

The purpose of the CTS 4.8.1.1.2.a.4 and CTS 4.8.1.1.2.e.7 is to test for the OPERABILITY of each DG during cold and hot conditions. This change is acceptable because it has been determined that the relaxed Surveillance Requirement acceptance criteria are not necessary for verification that the equipment used to meet the LCO can perform its required functions. This changes the CTS by specifying a minimum voltage and frequency limit to be achieved within 10 seconds instead of a voltage and frequency range. This effectively allows the upper voltage and frequency limits to be exceeded during DG acceleration and stabilization. As stated above, the proposed SRs will require only the establishment of the minimum frequency (58.8 Hz) and voltage (3740 V) within the given time frame. The accident analyses and other Surveillances require that the DGs be capable of being loaded within 10 seconds. This can be accomplished at 58.8 Hz and 3740 V. While the upper level requirement regarding the frequency and voltage acceptance criterion is being eliminated, the requirement to establish a steady state voltage and frequency has been retained. Changes to the steady state voltage and frequency ranges are discussed in DOC M.5. Thus, for steady state conditions, the proposed SRs will be more restrictive. Once steady state conditions are reached, the minimum and maximum voltage and frequency limits must be maintained. Therefore, the proposed requirements will require that the DG start and achieve in < 10 seconds, voltage > 3740 V and frequency > 58.8 Hz; and steady state voltage > 3910 V and < 4400 V and frequency > 59.4 Hz and

< 61.2 Hz. The tests in question are those that automatically start the DG but do not connect it to a bus. Verification that the minimum voltage and frequency limits are met within the proper time is sufficient to ensure the DG can perform its design function. When called upon, the DG must start and accept load within the proper time. Once the minimum voltage and frequency limits are met, the DG can connect to the bus. When a test is performed that does not result in connecting the DG to the bus, a voltage or frequency overshoot can occur since CNP Units 1 and 2 Page 26 of 28 Attachment 1, Volume 13, Rev. 0, Page 48 of 496

Attachment 1, Volume 13, Rev. 0, Page 49 of 496 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING no loads are connected (the loading tends to minimize overshoot). This overshoot could be such that the voltage or frequency is outside the band high when the time limit expires. However, this condition is not indicative of an inoperable DG, provided that steady state voltage and frequency are maintained.

The DG start times are monitored and trend evaluated to identify degradation of DG governor and voltage regulator performance as described in the Bases. 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.19 (Category 7 - Relaxation Of Surveillance Frequency, Non-24 Month Type Change) CTS 4.8.1.1.2.a.3 requires that the fuel transfer pump can be started and that it transfers fuel from the storage system to the day tank. The test Frequency for these Surveillance is in accordance with the frequency specified in Table 4.8-1 (the DG Test Schedule Table) on a STAGGERED TEST BASIS.

The nominal test Frequency in CTS Table 4.8-1 is 31 days. ITS SR 3.8.1.6 requires the verification that the fuel oil transfer system operates to automatically transfer fuel oil from the storage tank to the day tank every 92 days. This changes the CTS by deleting the requirement to perform this Surveillance in accordance with the DG Test Schedule Table, and changes the nominal test Frequency to 92 days. The change to the STAGGERED TEST BASIS requirement is discussed in DOC L.4.

The purpose of CTS 4.8.1.1.2.a.3 is to ensure the fuel oil transfer system can function properly. A detailed review of the test history for the fuel oil transfer pumps indicates no failures during any demand cycles. The IST program requires operation of the transfer pumps only on a quarterly basis and degradation has not been indicated for these pumps. The change concerning the deletion of more frequent testing than the nominal 31 day test Frequency is acceptable because the DG failures that result in a more frequent DG test Frequency have no impact on the ability of the fuel oil transfer pumps to perform their intended function. In addition, the proposed 92 day fuel oil transfer pump test Frequency is consistent with the requirements of ASME Operation and Maintenance Standards and Guides (OM Codes) for similar pumps. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

L.20 CTS 4.8.1.1.2.e.10 requires verifying that with the DG operating in a test mode while connected to its test load, a simulated Safety Injection (SI) signal overrides the test mode by returning the DG to standby operation and ensuring the emergency loads remain powered by offsite power. The ITS does not include this Surveillance Requirement. This changes the CTS by deleting this Surveillance Requirement.

The purpose of CTS 4.8.1.1.2.e.10 is to verify the design of the DG logic when the DG is connected to the test bank. The CNP design includes the capability of paralleling the DG with a test bank instead of actually paralleling the DG with offsite power (i.e., via the emergency buses). However, the test bank only provides a capability to load the DG to approximately 50% of the rating of the DG (i.e., 1690 kW). With the exception of a single Surveillance (CTS 4.8.1.1.2.e.2),

all DG loading Surveillances require the DG to be loaded to greater than the rating of the test bank. Thus, the test bank is not allowed to be used to meet CNP Units 1 and 2 Page 27 of 28 Attachment 1, Volume 13, Rev. 0, Page 49 of 496

Attachment 1, Volume 13, Rev. 0, Page 50 of 496 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING these Surveillances. In the ITS, the DG loading required for these Surveillances will also remain greater than the capability of the test bank. CTS 4.8.1.1.2.e.2, the Surveillance that does not require the DG to be loaded greater than the rating of the test bank, is a test of the DGs capability to reject a load equivalent to the single largest post-accident load. Since this test is normally performed in conjunction with the full load rejection test (CTS 4.8.1.1.2.e.3), the load bank is not used for the test and the DG is normally paralleled with offsite power. In addition, CTS 4.8.1.1.2.e.2 is required to be performed while shutdown and ITS SR 3.8.1.10 maintains this requirement (i.e., it cannot be performed in MODES 1 and 2). Thus, even if this test were performed using the test bank, the unit would not be critical. Furthermore, this change is only requesting the removal of the requirement to test this design feature from the CTS and will not result in physically removing the feature from the DG logic. Therefore, this change is acceptable since the CTS Surveillance verifies a design feature that cannot be used to meet the requirements for the vast majority of the CTS Surveillances, and the one Surveillance the design feature can be used for is not normally performed using the test bank. This change is designated as less restrictive because a Surveillance Requirement has been deleted from the CTS.

L.21 CTS 3.8.1.1 Action b specifies the compensatory actions for one inoperable DG and CTS 3.8.1.1 Action c specifies the compensatory actions for one inoperable offsite circuit and one inoperable DG. The Actions include a requirement to demonstrate the OPERABILITY of the remaining OPERABLE DG by performing Surveillance Requirement 4.8.1.1.2.a.4 within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , unless the absence of any potential common mode failure for the remaining DG is demonstrated. ITS 3.8.1 Required Actions B.3.1 and B.3.2 allows 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to perform similar checks on the remaining OPERABLE DGs. This changes the CTS by extending the time to perform these checks from 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

The purpose of the above specified CTS Actions is to ensure that the other unit DG is not inoperable as a result of a similar, yet undetected, failure (i.e., due to a common mode failure). Currently, the 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months time limit specified is sufficient to actually perform CTS 4.8.1.1.2.a.4, a normal DG start test, on the other unit DG.

However, due to the addition of the opposite unit DG requirements discussed in DOC M.2, there is a possibility that ITS 3.8.1 ACTION B will be entered due to an opposite unit DG inoperability. This could result in ITS 3.8.1 Required Action B.3.2 being required on two unit DGs. That is, the DG start test could have to be performed on two DGs. Based on Operations Department experience, it would be difficult to perform a DG start test on two DGs within the current 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months time limit, considering the time it normally takes to perform the test on a single DG, as well as to perform pre-evolution briefs for the operating crew and to safely transition between the DG tests. The proposed 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months time limit is considered a reasonable time to complete the DG start tests on two DGs.

Generic Letter 84-15 identified that a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months time limit was acceptable to perform these common mode failure checks. Since the 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months time limit being proposed is within the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months limit allowed by the NRC in Generic Letter 84-15, the change is considered acceptable. In addition, the change is considered acceptable since the vast majority of DG start tests demonstrate that the DG is in fact OPERABLE.

CNP Units 1 and 2 Page 28 of 28 Attachment 1, Volume 13, Rev. 0, Page 50 of 496

Attachment 1, Volume 13, Rev. 0, Page 51 of 496 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

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Attachment 1, Volume 13, Rev. 0, Page 58 of 496 3.8.1 3

INSERT 3

-NOTES-DOC 1. SR 3.8.1.1 through SR 3.8.1.20 are applicable only to the AC electrical power M.11 sources for Unit 1 (Unit 1) and Unit 2 (Unit 2).

DOC 2. SR 3.8.1.21 is applicable only to the Unit 2 (Unit 1) and Unit 1 (Unit 2) required M.11 AC electrical power sources. The Surveillances referenced in SR 3.8.1.21 are the Unit 2 (Unit 1) and Unit 1 (Unit 2) Surveillance Requirements.

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Attachment 1, Volume 13, Rev. 0, Page 82 of 496 JUSTIFICATION FOR DEVIATIONS ITS 3.8.1, AC SOURCES - OPERATING

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

2. ISTS LCO 3.8.1.c and ISTS 3.8.1 ACTION F have been deleted since CNP Units 1 and 2 do not use load sequencers. Each load or load block is sequenced with the use of its associated time delay relay. Subsequent Conditions and Required Actions have been renumbered, as applicable. ITS SR 3.8.1.12, SR 3.8.1.13, SR 3.8.1.18, and SR 3.8.1.19 have been revised to reflect the use of time delay relays.

3. Additional requirements were added to ISTS LCO 3.8.1 to ensure the appropriate AC Sources are OPERABLE during unit operation in MODES 1, 2, 3 and 4 to satisfy the design requirements. The new requirements were added as ITS LCO 3.8.1.c and LCO 3.8.1.d. This modification was necessary due to a shared system (Essential Service Water) between both units. A Note has been added to the Applicability that allows the opposite unit AC electrical power sources not to be required when the associated equipment is inoperable. This is an exception that is intended to allow declaring the opposite unit equipment inoperable in lieu of declaring the opposite unit power source inoperable. This exception also allows the supported equipment to be declared inoperable at any time subsequent to entering ACTIONS for an inoperable opposite unit power source. This exception is acceptable since, with the opposite unit equipment inoperable and the associated ACTIONS entered, the opposite unit AC Sources provide no additional assurance of meeting the safety criteria of the given units AC Sources.

Two Notes have been added to the Surveillance Requirements Table and an additional Surveillance (ITS SR 3.8.1.21) has been added to clearly define the Applicability of the Surveillances for both units and to ensure the opposite units power sources are OPERABLE.

In addition, the Completion Times for multiple AC Sources inoperable (Required Actions A.3 and B.4) have been revised to not reflect these additional LCO requirements since the equipment supported by the opposite unit AC power sources may be declared inoperable in lieu of declaring the power sources inoperable.

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

5. 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.

6. ITS SR 3.8.1.7 has been added to verify each required DG air start receiver pressure is within the specified limit. This pressure will ensure one automatic start of each required DG. This change is consistent with the current licensing basis to have OPERABLE DG(s). The requirements of the air start receiver pressure in ISTS 3.8.3 has not been added since only one air start receiver is required to be OPERABLE per required DG. CNP Units 1 and 2 are not licensed for the five DG starts as required by ISTS 3.8.3. Subsequent SRs have been renumbered, as applicable.

7. ISTS SR 3.8.1.8 Note (ITS SR 3.8.1.9 Note), which states that this Surveillance shall not normally be performed in MODE 1 or 2, has been deleted. This test is currently CNP Units 1 and 2 Page 1 of 3 Attachment 1, Volume 13, Rev. 0, Page 82 of 496

Attachment 1, Volume 13, Rev. 0, Page 83 of 496 JUSTIFICATION FOR DEVIATIONS ITS 3.8.1, AC SOURCES - OPERATING allowed to be performed at any time. The Note has not been added since the Surveillance test procedure currently allows the test to be performed during a shutdown of the unit from power operation (i.e., MODE 1) by tripping the main turbine and verifying the transfer to the preferred offsite circuit.

8. The DG endurance run time of > 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months has been changed to > 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months consistent with the current licensing basis as approved in License Amendment 207 (Unit 1) and 191 (Unit 2). The test is limited to the continuous rating consistent with the current licensing basis as approved in Licensing Amendment 125 (Unit 1) and 112 (Unit 2).

The load range specified has been changed to values consistent with Regulatory Guide 1.9, Rev. 3, paragraph C.2.2.9 (90% to 100% of the continuous rating). The allowance to test the DG within the prescribed range is discussed in the Discussion of Changes for ITS 3.8.1.

9. The steady state limit does not apply to the simultaneous start of all DGs (ISTS SR 3.8.1.20), since it is a test of starting independence, not operating independence.

This is consistent with the current licensing basis.

10. TSTF-276, Rev.2 was approved by the NRC on April 14, 2000. However, when NUREG-1431, Rev. 2 was issued, this TSTF was not completely included.

Therefore, changes approved by TSTF-276, Rev. 2 have been made.

11. Editorial/grammatical error corrected.

12. ISTS SR 3.8.1.8 (ITS SR 3.8.1.9) has been revised to include two parts consisting of:

a) a transfer from the auxiliary source (i.e., main generator) to the preferred offsite circuit; and b) a manual alignment to the alternate offsite circuit. These changes were made consistent with the current licensing basis. However, a Note has also been added to ISTS SR 3.8.1.8 (ITS SR 3.8.1.9) that states SR 3.8.1.9.a is only required to be met when the auxiliary source is supplying the electrical power distribution subsystem. This change is necessary since the automatic transfer from the auxiliary source to the preferred offsite circuit is not necessary when the preferred offsite circuit is supplying onsite power. In this situation the preferred offsite circuit is performing its function by supplying the onsite power.

13. TSTF-283, Rev. 3 was approved by the NRC on April 13, 2000. However, when NUREG-1431, Rev. 2 was issued, this TSTF was not completely included.

Therefore, changes approved by TSTF-283, Rev. 3 have been made.

14. ISTS SR 3.8.1.12 part a has been modified by deleting the words "after auto-start and during tests" for consistency with similar words in ISTS SR 3.8.1.7 and SR 3.8.1.15. In addition, the words "auto-start" are redundant to the words in the first part of ISTS SR 3.8.1.12, and the words "and during tests" is not correct; the voltage and frequency limits of part b are different than those in part a of the SR.

15. ISTS 3.8.1 Required Actions A.1 and B.1 have been modified by the addition of Notes. The Note for Required Action A.1 states that the Required Action is not applicable if a require opposite unit offsite circuit is inoperable and the Note for Required Action B.1 states that the Required Action is not applicable if a required opposite unit DG is inoperable. With an opposite unit offsite circuit or DG inoperable, there is no reason to check the given unit's offsite circuits, since neither they nor the CNP Units 1 and 2 Page 2 of 3 Attachment 1, Volume 13, Rev. 0, Page 83 of 496

Attachment 1, Volume 13, Rev. 0, Page 84 of 496 JUSTIFICATION FOR DEVIATIONS ITS 3.8.1, AC SOURCES - OPERATING unit DGs are inoperable and the inoperable opposite unit offsite circuit and DG only affect the Essential Service Water System. This is also consistent with current licensing basis, since the CTS does not require an offsite circuit check when a required opposite unit offsite circuit or DG is inoperable.

16. ISTS SR 3.8.1.17 requires verifying that with the DG operating in test mode and connected to its bus, that an ESF actuation signal will override the test mode. The CNP design does not include this feature. With the DG connected to its respective buses, neither DG output breaker will trip on an ESF actuation signal; the DG remains connected to its buses under this condition. Therefore, this specific SR has not been included in the ITS.

CNP Units 1 and 2 Page 3 of 3 Attachment 1, Volume 13, Rev. 0, Page 84 of 496

Attachment 1, Volume 13, Rev. 0, Page 85 of 496 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 13, Rev. 0, Page 85 of 496

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Attachment 1, Volume 13, Rev. 0, Page 87 of 496 B 3.8.1 1

INSERT 1

, an alternate offsite power source, an auxiliary source (main generator),

Unit 2 only 1

INSERT 2 Additionally, the AC electrical sources must include those electrical sources from Unit 2 (Unit 1) and Unit 1 (Unit 2) that are required to support the Essential Service Water (ESW) System since the ESW headers are common to both units. In addition, the AC electrical sources must include those AC electrical sources from Unit 1 during fuel handling operations in the auxiliary building since the Fuel Handling Area Exhaust Ventilation (FHAEV) System loads are supplied by Unit 1. The onsite Class 1E AC Distribution System associated with the other unit is also divided into redundant load groups and include the same connections to AC sources.

1 INSERT 3 (Unit 1 only)

The onsite Class 1E AC Distribution System includes Train A and Train B. Train A and Train B are normally powered from the main generator. The main generator supplies Train A via unit auxiliary transformer TR1CD and supplies Train B via unit auxiliary transformer TR1AB. The unit auxiliary transformer TR1CD supplies Bus 1C, which in turn supplies the onsite Class 1E 4.16 kV emergency bus T11C, a Train A bus. The unit auxiliary transformer TR1CD also supplies Bus 1D, which in turn supplies the onsite Class 1E 4.16 kV emergency bus T11D, also a Train A bus. The unit auxiliary transformer TR1AB supplies Bus 1A, which in turn supplies the onsite Class 1E 4.16 kV emergency bus T11A, a Train B bus. The unit auxiliary transformer TR1AB also supplies Bus 1B, which in turn supplies the onsite Class 1E 4.16 kV emergency bus T11B, also a Train B bus. The preferred qualified offsite circuit is supplied via reserve auxiliary transformers (RAT) TR101CD and TR101AB. The Train A and Train B 4.16 kV emergency buses will automatically transfer to the preferred qualified offsite circuit as a result of a turbine generator trip. Each RAT is supplied by a separate 34.5 kV line from an onsite switchyard. RAT TR101CD supplies the Train A 4.16 kV emergency bus T11C via bus 1C while emergency bus T11D is supplied via bus 1D. RAT TR101AB supplies the Train B 4.16 kV emergency bus T11A via bus 1A while emergency bus T11B is supplied via bus 1B. A 69 kV line supplies the alternate qualified offsite circuit. The 69 kV line supplies transformers TR12EP-1 and TR12EP-2, either of which can be manually aligned to directly supply Train A 4.16 kV emergency buses T11C and T11D and Train B 4.16 kV emergency buses T11A and T11B. The qualified offsite circuits are physically independent from one another.

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Attachment 1, Volume 13, Rev. 0, Page 91 of 496 B 3.8.1 1 INSERT 5C (however the continuous service rating is not exceeded in the post accident load profile) 1 INSERT 5D Each DG has its own starting air system consisting of two redundant starting air trains.

Each train has one start receiver that normally contains sufficient air for two EDG start sequences. One start sequence includes a 10 second continuous crank and the second start sequence includes an actual run of the DG. The energy used for the first start sequence is greater than that required for the DG run sequence. Also each DG has its own day tank and fuel oil transfer system. The fuel oil transfer system, which includes two transfer pumps, is capable of transferring fuel oil from the associated fuel oil storage tank to the day tank. Each transfer pump is capable of maintaining the level in the day tank when the associated DG is operating a full load.

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INSERT 6C

, except for the fuel oil storage tanks, which are shared between units 1

INSERT 7 If the main generator is supplying the Class 1E Distribution System, the preferred qualified offsite circuit must be capable of fast transfer to both trains of the Class 1E Distribution System. The alternate qualified offsite circuit must be capable of manual transfer to one train of the Class 1E Distribution System. The qualified preferred or alternate offsite circuit may be connected to more than one ESF train and not violate separation criteria.

5 INSERT 8 Additionally, the electrical units electrical sources must include electrical sources from the other unit that is required to support the Essential Service Water (ESW) System.

When an ESW train is not isolated from Unit 2 (Unit 1) and Unit 1 (Unit 2), the Unit 2 (Unit 1) and Unit 1 (Unit 2) AC sources are required to be OPERABLE and capable of supplying the appropriate Unit 2 (Unit 1) and Unit 1 (Unit 2) Class 1E Distribution subsystems. In this case, at least one Unit 2 (Unit 1) and Unit 1 (Unit 2) qualified circuit shall be OPERABLE. If a Unit 2 (Unit 1) and Unit 1 (Unit 2) qualified circuit is not supplying the appropriate Unit 2 (Unit 1) and Unit 1 (Unit 2) Class 1E Distribution subsystem, then the required Unit 2 (Unit 1) and Unit 1 (Unit 2) preferred qualified circuit must be OPERABLE with the capability to fast transfer to the appropriate Unit 2 (Unit 1) and Unit 1 (Unit 2) Class 1E Distribution subsystem. If both ESW trains are not isolated from Unit 2 (Unit 1) and Unit 1 (Unit 2), then two Unit 2 (Unit 1) and Unit 1 (Unit 2) DGs are required to be OPERABLE. If only one ESW train is isolated from Unit 2 (Unit 1) and Unit 1 (Unit 2), then the Unit 2 (Unit 1) and Unit 1 (Unit 2) DG associated with the un-isolated ESW train must be OPERABLE.

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Attachment 1, Volume 13, Rev. 0, Page 98 of 496 B 3.8.1 8

INSERT 11 designed with redundant safety related trains.

1 INSERT 12 are normally not included, although, for this Required Action, the turbine driven auxiliary feedwater pump is considered redundant to Trains A and B. Redundant required features failures consist of inoperable features associated with a train, redundant to the train that has no offsite power available.

5 INSERT 13 or the required Unit 2 (Unit 1) and Unit 1 (Unit 2) onsite Class 1E Electrical Power Distribution System 5

INSERT 14 and the Unit 2 (Unit 1) and Unit 1 (Unit 2) Class 1E Distribution System when required to be OPERABLE Insert Page B 3.8.1-5 Attachment 1, Volume 13, Rev. 0, Page 98 of 496

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Attachment 1, Volume 13, Rev. 0, Page 108 of 496 B 3.8.1 8

INSERT 19 designed with redundant safety related trains.

1 INSERT 20 are normally not included, although, for this Required Action, the turbine driven auxiliary feedwater pump is considered redundant to Trains A and B. Redundant required features failures consist of inoperable features associated with a train, redundant to the train that has no offsite power available.

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Attachment 1, Volume 13, Rev. 0, Page 113 of 496 B 3.8.1 10 INSERT 21A Plant Specific Design Criterion (PSDC) 39 1 INSERT 21B ensures the ESF pumps have an adequate level of voltage so that they are assured of achieving adequate fluid flow to meet their safety and accident mitigation functions.

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INSERT 21C ensure the ESF pumps can achieve adequate fluid flow to meet their safety and accident mitigation functions. The minimum voltage and frequency limits specified to be met within the DG start time of 10 seconds are based upon the recommendations given in Regulatory Guide 1.9 (Ref. 3).

6 INSERT 21D the required qualified offsite circuits are OPERABLE Insert Page B 3.8.1-14 Attachment 1, Volume 13, Rev. 0, Page 115 of 496

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Attachment 1, Volume 13, Rev. 0, Page 117 of 496 B 3.8.1 O ~INSERT 22 the DG is required to maintain proper voltage and frequency limits after steady state is achieved. The voltage and frequency limits are normally achieved within 10 seconds.

O ~INSERT 22A Consistent with Regulatory Guide 1.9 (Ref. 3),

O ~INSERT 22B 90% to 100% of the continuous rating of the DG 15INSERT 22C being required in order to maintain DG reliability Insert Page B 3.8.1-15 Attachment 1, Volume 13, Rev. 0, Page 117 of 496

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Attachment 1, Volume 13, Rev. 0, Page 119 of 496 B 3.8.1 INSERT 22D of which 31.4 gallons is unusable (due to tank geometry and vortexing considerations) and 70 gallons is usable, Insert Page B 3.8.1-16 Attachment 1, Volume 13, Rev. 0, Page 119 of 496

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Attachment 1, Volume 13, Rev. 0, Page 123 of 496 B 3.8.1 Q ~INSERT 25 Voltage and frequency are also verified to reach steady state conditions within 2 seconds.

Q ~INSERT 26 Consistent with Regulatory Guide 1.9 (Ref. 3)

Q INSERT 27 This corresponds to 64.4 Hz, which is the nominal speed plus 75% of the difference between nominal speed and the overspeed trip setpoint.

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Attachment 1, Volume 13, Rev. 0, Page 139 of 496 B 3.8.1 O ~INSERT 34D This Surveillance demonstrates O ~INSERT 34E (90% to 100% of the DG continuous rating)

INSERT 34F The run duration of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months is consistent with IEEE Standard 387-1995 (Ref. I11).

OINS ERT34G being required in order to maintain DG reliability Q ~INSERT35 is based on engineering judgement, taking into consideration unit conditions required to perform the Surveillance. Operating experience has shown that these components usually pass the SR when performed at the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

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Attachment 1, Volume 13, Rev. 0, Page 143 of 496 B 3.8.1 (11111) INSERT 36 based on engineering judgement, taking into consideration unit conditions required to perform the Surveillance. Operating experience has shown that these components usually pass the SR when performed at the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

OINSERT 36A being required in order to maintain DG reliability Q ~INSERT 36B Consistent with Regulatory Guide 1.9 (Ref. 3), paragraph C.2.2.1 1, Q ~INSERT37 based on engineering judgement, taking Q ~INSERT 38 Operating experience has shown that these components usually pass the SR wh~en performed at the 24 month Frequency. Therefore, the Frequency was concluded~to be acceptable from a reliability standpoint.

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INSERT 40 or RATs (as applicable) 1 INSERT 41 and RATs to restore voltage 1

INSERT 41A based on engineering judgement, taking 1

INSERT 42 Operating experience has shown that these components usually pass the SR when performed at the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

8 INSERT 43 This restriction from normally performing the Surveillance in MODE 1, 2, 3, or 4 is further amplified to allow portions of the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines unit safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed partial Surveillance, a successful partial Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the partial Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a unit shutdown and startup to determine that unit safety is maintained or enhanced when portions of the Surveillance are performed in MODE 1, 2, 3, or 4. Risk insights or deterministic methods may be used for the assessment. Credit may be taken for unplanned events that satisfy this SR.

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Attachment 1, Volume 13, Rev. 0, Page 154 of 496 JUSTIFICATION FOR DEVIATIONS ITS 3.8.1 BASES, AC SOURCES - OPERATING

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

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

3. This bracketed requirement, information is deleted since it is not applicable.

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

6. Changes are made to reflect the Specifications.

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

8. Changes have been made to be consistent with similar phrases in other Bases.

9. Grammatical/editorial error corrected.

10. 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.

11. The description in the Bases for ISTS SR 3.8.1.13 (ITS SR 3.8.1.14) concerning the critical protective function being capable of tripping the DG has been deleted consistent with proposed TSTF-400.

12. TSTF-283, Rev. 3 was approved by the NRC on April. 13, 2000. However, when NUREG-1431, Rev. 2 was issued, this TSTF was not completely included.

Therefore, changes approved by TSTF-283, Rev. 3 have been made.

13. Changes are made to be consistent with Regulatory Guide 1.9, Rev. 3 recommendations.

14. This statement has been deleted since the LCO requirements for the qualified offsite circuits are described in the fifth paragraph of the LCO Section.

15. The recommendations of the CNP DG vendor regarding tear-down inspections do not make specific adjustments in frequencies based on engine overloading. They recommend that frequencies be adjusted based on overall operating history of the machine, including consideration of engine loading. In addition, the statement concerning DG run time to achieve hot conditions is based on operating experience CNP Units 1 and 2 Page 1 of 2 Attachment 1, Volume 13, Rev. 0, Page 154 of 496

Attachment 1, Volume 13, Rev. 0, Page 155 of 496 JUSTIFICATION FOR DEVIATIONS ITS 3.8.1 BASES, AC SOURCES - OPERATING not manufacturer recommendations. The wording of the Bases has been adjusted to reflect this.

CNP Units 1 and 2 Page 2 of 2 Attachment 1, Volume 13, Rev. 0, Page 155 of 496

Attachment 1, Volume 13, Rev. 0, Page 156 of 496 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 13, Rev. 0, Page 156 of 496

Attachment 1, Volume 13, Rev. 0, Page 157 of 496 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.1, AC SOURCES - OPERATING 10 CFR 50.92 EVALUATION FOR LESS RESTRICTIVE CHANGE L.20 CNP is converting to the Improved Technical Specifications (ITS) as outlined in NUREG-1431, "Standard Technical Specifications, Westinghouse Plants." The proposed change involves making the Current Technical Specifications (CTS) less restrictive. Below is the description of this less restrictive change and the determination of No Significant Hazards Considerations for conversion to NUREG-1431.

CTS 4.8.1.1.2.e.10 requires verifying that with the DG operating in a test mode while connected to its test load, a simulated Safety Injection (SI) signal overrides the test mode by returning the DG to standby operation and ensuring the emergency loads remain powered by offsite power. The ITS does not include this Surveillance Requirement. This changes the CTS by deleting this Surveillance Requirement.

The purpose of CTS 4.8.1.1.2.e.10 is to verify the design of the DG logic when the DG is connected to the test bank. The CNP design includes the capability of paralleling the DG with a test bank instead of actually paralleling the DG with offsite power (i.e., via the emergency buses). However, the test bank only provides a capability to load the DG to approximately 50% of the rating of the DG (i.e., 1690 kW). With the exception of a single Surveillance (CTS 4.8.1.1.2.e.2), all DG loading Surveillances require the DG to be loaded to greater than the rating of the test bank. Thus, the test bank is not allowed to be used to meet these Surveillances. In the ITS, the DG loading required for these Surveillances will also remain greater than the capability of the test bank.

CTS 4.8.1.1.2.e.2, the Surveillance that does not require the DG to be loaded greater than the rating of the test bank, is a test of the DGs capability to reject a load equivalent to the single largest post-accident load. Since this test is normally performed in conjunction with the full load rejection test (CTS 4.8.1.1.2.e.3), the load bank is not used for the test and the DG is normally paralleled with offsite power. In addition, CTS 4.8.1.1.2.e.2 is required to be performed while shutdown and ITS SR 3.8.1.10 maintains this requirement (i.e., it cannot be performed in MODES 1 and 2). Thus, even if this test were performed using the test bank, the unit would not be critical.

Furthermore, this change is only requesting the removal of the requirement to test this design feature from the CTS and it will not result in physically removing the feature from the DG logic. Therefore, this change is acceptable since the CTS Surveillance verifies a design feature that cannot be used to meet the requirements for the vast majority of the CTS Surveillances, and the one Surveillance the design feature can be used for is not normally performed using the test bank, and even if performed using the test bank, the Surveillance cannot be performed in MODES 1 and 2. This change is designated as less restrictive because a Surveillance Requirement has been deleted from 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.

CNP Units 1 and 2 Page 1 of 4 Attachment 1, Volume 13, Rev. 0, Page 157 of 496

Attachment 1, Volume 13, Rev. 0, Page 158 of 496 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.1, AC SOURCES - OPERATING The proposed change deletes the requirement to verify a design feature that cannot be used to meet the requirements for the vast majority of the CTS Surveillances, and the one Surveillance the design feature can be used for is not normally performed using the test bank, and even if performed using the test bank, the Surveillance cannot be performed in MODES 1 and 2. This change will not affect the probability of an accident, since the performance of any of the DG Surveillance Requirements is not considered as an initiator of an analyzed accident. The consequences of an analyzed accident cannot be significantly increased since only one SR can be performed using the test bank, and it is normally not performed with a test bank. In addition, if performed with the test bank, it cannot be performed in MODES 1 and 2 (i.e., the reactor will not be critical). Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change deletes the requirement to verify a design feature that cannot be used to meet the requirements for the vast majority of the CTS Surveillances, and the one Surveillance the design feature can be used for is not normally performed using the test bank, and even if performed using the test bank, the Surveillance cannot be performed in MODES 1 and 2. This change will not physically alter the plant (no new or different type of equipment will be installed). In addition, no changes will be made to the operation of the unit.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

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

Response: No.

The proposed change deletes the requirement to verify a design feature that cannot be used to meet the requirements for the vast majority of the CTS Surveillances, and the one Surveillance the design feature can be used for is not normally performed using the test bank, and even if performed using the test bank, the Surveillance cannot be performed in MODES 1 and 2. The margin of safety is not affected by this change because the Surveillance is normally performed without using the test bank (i.e., it is performed in a condition that does not rely on the design feature), and if performed while relying on the test feature (i.e., while paralleled to the test bank), it can only be performed when the unit is not critical. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

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

CNP Units 1 and 2 Page 2 of 4 Attachment 1, Volume 13, Rev. 0, Page 158 of 496

Attachment 1, Volume 13, Rev. 0, Page 159 of 496 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.1, AC SOURCES - OPERATING 10 CFR 50.92 EVALUATION FOR LESS RESTRICTIVE CHANGE L.21 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 3.8.1.1 Action b specifies the compensatory actions for one inoperable DG and CTS 3.8.1.1 Action c specifies the compensatory actions for one inoperable offsite circuit and one inoperable DG. The Actions include a requirement to demonstrate the OPERABILITY of the remaining OPERABLE DG by performing Surveillance Requirement 4.8.1.1.2.a.4 within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , unless the absence of any potential common mode failure for the remaining DG is demonstrated. ITS 3.8.1 Required Actions B.3.1 and B.3.2 allows 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to perform similar checks on the remaining OPERABLE DGs.

This changes the CTS by extending the time to perform these checks from 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

The purpose of the above specified CTS Actions is to ensure that the other unit DG is not inoperable as a result of a similar, yet undetected, failure (i.e., due to a common mode failure). Currently, the 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months time limit specified is sufficient to actually perform CTS 4.8.1.1.2.a.4, a normal DG start test, on the other unit DG. However, due to the addition of the opposite unit DG requirements discussed in DOC M.2, there is a possibility that ITS 3.8.1 ACTION B will be entered due to an opposite unit DG inoperability. This could result in ITS 3.8.1 Required Action B.3.2 being required on two unit DGs. That is, the DG start test could have to be performed on two DGs. Based on Operations Department experience, it would be difficult to perform a DG start test on two DGs within the current 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months time limit, considering the time it normally takes to perform the test on a single DG, as well as to perform pre-evolution briefs for the operating crew and to safely transition between the DG tests. The proposed 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months time limit is considered a reasonable time to complete the DG start tests on two DGs. Generic Letter 84-15 identified that a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months time limit was acceptable to perform these common mode failure checks. Since the 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months time limit being proposed is within the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months limit allowed by the NRC in Generic Letter 84-15, the change is considered acceptable.

In addition, the change is considered acceptable since the vast majority of DG start tests demonstrate that the DG is in fact OPERABLE.

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 extends the time allowed to perform the DG common mode failure checks from 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This change will not affect the CNP Units 1 and 2 Page 3 of 4 Attachment 1, Volume 13, Rev. 0, Page 159 of 496

Attachment 1, Volume 13, Rev. 0, Page 160 of 496 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.1, AC SOURCES - OPERATING probability of an accident, since the DG is not considered as an initiator of an analyzed accident. The consequences of an analyzed accident will not be significantly increased since the vast majority of DG start tests demonstrate that the DG is in fact OPERABLE and the NRC has approved (in Generic Letter 84-15) up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to demonstrate the remaining DG(s) are not inoperable due to common mode failure. 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 extends the time allowed to perform the DG common mode failure checks from 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This change will not physically alter the plant (no new or different type of equipment will be installed). In addition, no changes will be made to the operation of the unit. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

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

Response: No.

The proposed change extends the time allowed to perform the DG common mode failure checks from 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The margin of safety is not affected by this change because the vast majority of DG start tests demonstrate that the DG is in fact OPERABLE and the NRC has approved (in Generic Letter 84-15) up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to demonstrate the remaining DG(s) are not inoperable due to common mode failure. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

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

CNP Units 1 and 2 Page 4 of 4 Attachment 1, Volume 13, Rev. 0, Page 160 of 496

, Volume 13, Rev. 0, Page 161 of 496 ATTACHMENT 2 ITS 3.8.2, AC Sources - Shutdown , Volume 13, Rev. 0, Page 161 of 496

, Volume 13, Rev. 0, Page 162 of 496 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 13, Rev. 0, Page 162 of 496

Attachment 1, Volume 13, Rev. 0, Page 163 of 496 ITS 3.8.2 A.1 ITS LCO 3.8.2 M.1 M.2 101.4 SR 3.8.2.1 A.5 See ITS 3.8.3 LA.1 M.3 During movement of irradiated fuel assemblies in the containment, auxiliary building, and Unit 2 containment Add proposed ACTIONS Note M.3 Add proposed ACTION A Note Add proposed Required Action A.1 A.2 L.4 ACTIONS A and B L.1 additions that could result in loss of required SDM or boron concentration Add proposed Required Actions A.2.2 and B.2 M.3 Add proposed Required Actions A.2.4 and B.4 M.4 SR 3.8.2.1 L.2 L.3 Note to SR Add proposed SR 3.8.2.1 exceptions 3.8.2.1 L.6 A.3 Page 1 of 2 Attachment 1, Volume 13, Rev. 0, Page 163 of 496

Attachment 1, Volume 13, Rev. 0, Page 164 of 496 ITS 3.8.2 A.1 ITS LCO 3.8.2 M.1 M.2 101.4 SR 3.8.2.1 A.5 See ITS 3.8.3 L.5 LA.1 A.4 M.3 Add proposed LCO 3.8.2.c During movement of irradiated fuel assemblies in the containment, auxiliary building, and Unit 1 containment Add proposed ACTIONS Note M.3 Add proposed ACTION A Note Add proposed Required Action A.1 A.2 L.4 ACTIONS A and B L.1 M.3 Add proposed Required Actions A.2.2 and B.2 additions that could result in loss of required SDM or boron concentration M.4 Add proposed Required Actions A.2.4 and B.4 SR 3.8.2.1 L.2 Note to SR L.3 Add proposed SR 3.8.2.1 exceptions 3.8.2.1 L.6 A.3 Add SR 3.8.2.1 for Unit 1 AC Source M.5 Page 2 of 2 Attachment 1, Volume 13, Rev. 0, Page 164 of 496

Attachment 1, Volume 13, Rev. 0, Page 165 of 496 DISCUSSION OF CHANGES ITS 3.8.2, AC SOURCES - SHUTDOWN 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 3.8.1.2 does not address the situation when an ESF bus is de-energized as a result of the loss of an AC Source to an ESF bus. A Note has been added to the Required Actions for an inoperable offsite circuit (ITS 3.8.2 ACTION A) which requires entry into the applicable Conditions and Required Actions of LCO 3.8.10 when one required train (ESF bus) is de-energized as a result of an inoperable offsite circuit. This changes the CTS by directing entry into LCO 3.8.10.

AC Sources are considered a support system to the AC Distribution System (ITS 3.8.10). If AC Sources are inoperable such that a distribution subsystem is made inoperable, then ITS LCO 3.0.6 would allow taking only the AC Sources ACTIONS; taking exception to complying with the AC Distribution System ACTIONS. Since the AC Sources ACTIONS may not be sufficiently conservative in this event (e.g., RHR-shutdown cooling could be inoperable), specific direction to take appropriate ACTIONS for the Distribution System is added (proposed Note to ITS 3.8.2 ACTION A). This format and construction implements the existing treatment of this condition within the framework of the CNP Unit 1 and 2 CTS methods. This change is designated as administrative because it does not result in a technical change to the CTS.

A.3 CTS 4.8.1.2 allows certain 18 month Surveillance Requirements, commencing in 1999 during the extended shutdown initiated in 1997, to be delayed one time until just prior to the first entry into MODE 4 following the shutdown. ITS 3.8.2 does not include this allowance.

This allowance in CTS 4.8.1.2 has expired; therefore it will not be included in the ITS. This change is designated as administrative because it does not result in a technical change to the CTS.

A.4 (Unit 2 only) CTS 3.8.1.2.a requires one circuit between the offsite transmission network and the onsite Class 1E distribution system to be OPERABLE and CTS 3.8.1.2.b requires one DG to be OPERABLE. These two required AC Sources are Unit 2 sources. CTS 3.9.12 requires the Fuel Handling Area Exhaust Ventilation (FHAEV) System (which is powered from Unit 1 AC Sources) to be OPERABLE whenever irradiated fuel is in the storage pool. The CTS definition of "OPERABLE - OPERABILITY" includes both a normal and emergency electrical power source requirement. However, there are no specific requirements in Unit 2 CTS 3.8.1.2 requiring the Unit 1 AC Sources to be OPERABLE to support the FHAEV System. In addition, CTS 3.0.5, which provides compensatory actions when an AC Source is inoperable, is not applicable in MODES 5 and 6. Unit 2 ITS LCO 3.8.2.c requires one Unit 1 CNP Units 1 and 2 Page 1 of 10 Attachment 1, Volume 13, Rev. 0, Page 165 of 496

Attachment 1, Volume 13, Rev. 0, Page 166 of 496 DISCUSSION OF CHANGES ITS 3.8.2, AC SOURCES - SHUTDOWN qualified circuit between the offsite transmission network and the Unit 1 onsite Class 1E AC electrical power distribution subsystem required by LCO 3.8.10. In addition, Unit 2 ITS 3.8.2 ACTION A also applies to an inoperable Unit 1 AC Source. This changes the Unit 2 CTS by explicitly requiring one Unit 1 offsite circuit to be OPERABLE and powering the Unit 1 equipment required to be OPERABLE, and requires the FHAEV System to be declared inoperable or to suspend movement of irradiated fuel assemblies if the Unit 1 AC Source is inoperable.

The purpose of Unit 2 ITS LCO 3.8.2.c is to ensure an AC Source is available to support required equipment. The explicit requirement for the Unit 1 AC Source is not included in Unit 2 CTS 3.8.1.2. However, based on the definition of OPERABILITY, the normal source is required to be OPERABLE to support the FHAEV System. Thus adding the explicit Unit 2 ITS LCO 3.8.2.c requirement is considered administrative since this support component is currently required to be OPERABLE in accordance with the definition of OPERABILITY. The new ACTION to declare the associated equipment inoperable or suspend movement of irradiated fuel assemblies is also administrative since this declaration is currently required by the application of the CTS (equipment is declared inoperable when the associated support equipment is inoperable). This change is designated as administrative because it does not result in a technical change to the Unit 2 CTS.

A.5 CTS LCO 3.8.1.2.b.1 requires a DG fuel day tank to contain a minimum volume of 70 gallons of fuel. ITS SR 3.8.2.1 (which references SR 3.8.1.4) requires a DG fuel day tank to contain > 101.4 gallons of fuel oil. This changes the CTS by clarifying that the amount of fuel oil required to be stored in the DG day tank includes both the usable and unusable volumes.

The purpose of CTS LCO 3.8.1.2.b.1 is to ensure the DG has sufficient fuel oil supply to allow the DG to run at full load before one of the fuel oil transfer pumps must be started to replenish the fuel oil supply and ensure uninterrupted DG service. As stated in the CTS Bases, the 70 gallons of fuel required by CTS 3.8.1.2.b.1 is the usable volume. For clarity and for consistency with the fuel oil storage tank volume requirement, the contained volume is provided.

Each day tank has 31.4 gallons of unusable volume (taking into account the geometry of the tank and a minimum submergence to suppress vortexing).

Therefore, the proposed value of 101.4 gallons ensures 70 gallons of usable fuel oil in the day tank. The change is acceptable since the proposed DG fuel oil volume in each day tank will ensure at least 15 minutes of DG operation. This change is designated as administrative because the day tank volume requirements are now explicit in stating the required volume of 101.4 gallons is a contained volume.

MORE RESTRICTIVE CHANGES M.1 CTS 3.8.1.2.a requires one circuit between the offsite transmission network and the onsite Class 1E distribution system to be OPERABLE. ITS LCO 3.8.2.a requires one qualified circuit between the offsite transmission network and the onsite Class 1E AC electrical power distribution subsystem(s) required by CNP Units 1 and 2 Page 2 of 10 Attachment 1, Volume 13, Rev. 0, Page 166 of 496

Attachment 1, Volume 13, Rev. 0, Page 167 of 496 DISCUSSION OF CHANGES ITS 3.8.2, AC SOURCES - SHUTDOWN LCO 3.8.10, "Distribution Systems - Shutdown," to be OPERABLE. This changes the CTS by being specific as to what the required circuit must be capable of powering.

The purpose of CTS 3.8.1.2.a is to ensure the offsite circuit is OPERABLE in order to supply the equipment supported by the onsite Class 1E distribution system. The existing requirement of CTS LCO 3.8.1.2.a for one offsite circuit to be OPERABLE during shutdown conditions is not specific as to what that circuit must be powering. The requirement in ITS LCO 3.8.2.a specifies that the circuit must be available to supply power to all equipment required to be OPERABLE in the current plant condition. This change is acceptable since the added restriction conservatively assures the needed offsite circuit is powering all AC loads required to be OPERABLE. This change is designated as more restrictive because more explicit offsite circuit requirements have been added.

M.2 CTS 3.8.1.2.b requires one DG to be OPERABLE. ITS LCO 3.8.2.b requires one DG capable of supplying one train of the onsite Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8.10. This changes the CTS by being specific as to what the required DG must be capable of powering.

The purpose of CTS 3.8.1.2.b is to ensure the DG is OPERABLE. This change provides an explicit requirement as to what the required DG must be capable of powering. Similar to the added restrictions for an OPERABLE offsite circuit (refer to DOC M.1 above), the single unit DG required OPERABLE during shutdown conditions by CTS 3.8.1.2.b is not specific as to what train that DG must be associated with. The requirement in ITS LCO 3.8.2.b will ensure the OPERABLE DG is associated with one or more systems, subsystems, or components required to be OPERABLE. This added restriction enforces a level of Technical Specification control which currently is enforced only by administrative procedures. This change is designated as more restrictive because more explicit DG requirements have been added.

M.3 CTS 3.8.1.2 is applicable during MODES 5 and 6. ITS 3.8.2 is applicable in MODES 5 and 6, and during the movement of irradiated fuel assemblies in the containment, auxiliary building, and Unit 2 (Unit 1) and Unit 1 (Unit 2) containment. ITS 3.8.2 Required Action A.2.2 (for an inoperable required offsite circuit) and ITS 3.8.2 Required Action B.2 (for an inoperable required DG) requires the immediate suspension of movement of irradiated fuel assemblies. In addition, a Note has been added to the ACTIONS of ITS 3.8.2 which states that LCO 3.0.3 is not applicable. This changes the CTS by requiring the AC Sources to be OPERABLE under more conditions and provides additional compensatory actions when the LCO requirements are not met.

The purpose of CTS 3.8.1.2 is to ensure that sufficient AC Sources are available to mitigate the consequences of an analyzed event during shutdown modes.

This change provides an explicit requirement that the AC Sources must be OPERABLE during the movement of irradiated fuel assemblies in the containment, auxiliary building, and Unit 2 (Unit 1) and Unit 1 (Unit 2) containment. The movement of irradiated fuel assemblies may occur during MODE 5 or 6, however the operations could also occur while the unit is operating. CTS 3.8.1.1 (ITS 3.8.1) and CTS 3.8.1.2 do not provide the CNP Units 1 and 2 Page 3 of 10 Attachment 1, Volume 13, Rev. 0, Page 167 of 496

Attachment 1, Volume 13, Rev. 0, Page 168 of 496 DISCUSSION OF CHANGES ITS 3.8.2, AC SOURCES - SHUTDOWN appropriate compensatory actions. The activity should be suspended immediately when the AC Sources are not available consistent with the immediate actions for CORE ALTERATIONS and positive reactivity changes.

The ACTIONS Note which states that LCO 3.0.3 is not applicable is necessary because moving fuel assemblies in MODE 1, 2, 3, or 4 is independent of reactor operations; that is the actions in LCO 3.0.3 will not place the unit in a safe condition. This change is acceptable because the proposed Applicability is consistent with the Applicability in the AC Distribution System - Shutdown Specification (CTS 3.8.2.2 and ITS 3.8.10). AC Sources provides the power for the AC Distribution System. This change is designated as more restrictive because the Applicability of the Specification has been expanded.

M.4 The CTS 3.8.1.2 Action requires the suspension of CORE ALTERATIONS and certain positive reactivity changes when a required AC Source is inoperable. It does not include an action to restore the inoperable AC Source or to exit the Applicability of the Specification. ITS 3.8.2 Required Actions A.2.4 and B.4 require the immediate initiation of action to restore the required AC Source to OPERABLE status. This changes the CTS by adding explicit Required Actions to restore the inoperable AC Source to OPERABLE status.

The purpose of ITS 3.8.1.2 Required Action A.2.4 and B.4 are to place the unit within the requirements of the LCO. When a required offsite circuit or a required DG is inoperable, the actions imposed by CTS 3.8.1.2 Action a do not necessarily place the unit in a MODE or other specified condition in which CTS LCO 3.8.1.2 is not applicable. Therefore, proposed ITS 3.8.2 Required Actions A.2.4 and B.4 are being added. These Required Actions implement a requirement to immediately initiate action to restore the required AC Sources to an OPERABLE status. These additional restrictions are consistent with implicit assumptions and will ensure action is immediately taken to restore compliance with the LCO requirements. This change is designated as more restrictive because the Required Actions do not exist in the CTS.

M.5 (Unit 2 only) CTS 3.8.1.2.a requires one circuit between the offsite transmission network and the onsite Class 1E distribution system to be OPERABLE and CTS 3.8.1.2.b requires one DG to be OPERABLE. These two required AC Sources are Unit 2 sources. CTS 3.9.12 requires the Fuel Handling Area Exhaust Ventilation (FHAEV) System (which is powered from Unit 1 AC Sources) to be OPERABLE whenever irradiated fuel is in the storage pool. The CTS definition of "OPERABLE - OPERABILITY" includes both a normal and emergency electrical power source requirement. However, there are no specific requirements in Unit 2 CTS 3.8.1.2 requiring the testing of the Unit 1 AC Sources that support the FHAEV System. Unit 2 ITS LCO 3.8.2.c requires one Unit 1 qualified circuit between the offsite transmission network and the Unit 1 onsite Class 1E AC electrical power distribution subsystem required by LCO 3.8.10.

This change is discussed in DOC A.4. An explicit SR (ITS SR 3.8.2.1) has been added which requires the applicable SRs of ITS 3.8.1, "AC Sources - Operating,"

to be applicable to each AC source required to be OPERABLE. This changes the Unit 2 CTS by explicitly requiring Surveillance Requirements for the Unit 1 AC Source required to be OPERABLE to support Unit 2 operation.

CNP Units 1 and 2 Page 4 of 10 Attachment 1, Volume 13, Rev. 0, Page 168 of 496

Attachment 1, Volume 13, Rev. 0, Page 169 of 496 DISCUSSION OF CHANGES ITS 3.8.2, AC SOURCES - SHUTDOWN The purpose of Surveillance Requirements is to ensure the OPERABILITY of required equipment. An explicit SR (ITS SR 3.8.2.1) has been added which requires the applicable SRs of ITS 3.8.1 to be applicable to the Unit 1 AC Source required to be OPERABLE for Unit 2 operation. The added Surveillance helps to ensure the required Unit 1 qualified circuit remains OPERABLE. This change is designated as more restrictive because additional Surveillance Requirements will be applicable to the Unit 2 Technical Specifications.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS LCO 3.8.1.2.b specifies that a DG be OPERABLE with a fuel transfer pump. ITS LCO 3.8.2.b requires an OPERABLE DG capable of supplying one train of the onsite Class 1E power distribution subsystem(s). This changes the CTS by moving the details that an OPERABLE DG requires "a fuel transfer pump" from the CTS to the Bases.

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

LESS RESTRICTIVE CHANGES L.1 (Category 4 - Relaxation of Required Action) The CTS 3.8.1.2 Action specifies the compensatory action for an inoperable required AC Source. One of the compensatory actions is the suspension of positive reactivity "changes except: 1) heatup or cooldown of the reactor coolant volume provided that SHUTDOWN MARGIN sufficient to accommodate the change in temperature is maintained in accordance with Specification 3.1.1.2 in MODE 5 or Specification 3.9.1 in MODE 6, and the heatup or cooldown rate is restricted to 50°F or less in any one-hour period in MODE 5, or 2) addition of water from the RWST, provided the boron concentration in the RWST is greater than or equal to the minimum required by Specification 3.1.2.7.b.2." ITS 3.8.2 Required Action A.2.3 (for an inoperable required offsite circuit) or Required Action B.3 (for an inoperable required DG) require the immediate suspension of operations involving positive CNP Units 1 and 2 Page 5 of 10 Attachment 1, Volume 13, Rev. 0, Page 169 of 496

Attachment 1, Volume 13, Rev. 0, Page 170 of 496 DISCUSSION OF CHANGES ITS 3.8.2, AC SOURCES - SHUTDOWN reactivity "additions that could result in loss of required SDM or boron concentration." This changes the CTS compensatory actions by deleting the limitation on the heatup and cooldown rates of 50ºF or less in any one hour period in MODE 5 and allows the addition of water from any source including the RWST as long as SDM and boron concentration limitations are met.

The purpose of this CTS 3.8.1.2 Action is to suspend any positive reactivity additions that could affect the SDM of the reactor core. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the affected 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 CTS allows two types of positive reactivity changes (heatup/cooldown and addition of water).

Heatup and cooldown of the reactor coolant volume are allowed provided SDM is sufficient to accommodate the change in temperature in accordance with CTS 3.1.1.2 in MODE 5 or CTS 3.9.1 in MODE 6. The requirements of these Specifications are included in ITS LCO 3.1.1, "SHUTDOWN MARGIN (SDM),"

and ITS LCO 3.9.1, "Boron Concentration," respectively. Therefore, there is no technical change in this portion of the change. The Bases provides the appropriate cross reference to the appropriate LCOs. The CTS also allows positive reactivity changes by the addition of water from the RWST provided the boron concentration in the RWST is greater than or equal to the minimum required by CTS 3.1.2.7.b.2. CTS 3.1.2.7.b.2 has been relocated to the TRM as indicated in the Discussion of Changes for CTS LCO 3/4.1.2.7. CTS 3/4.1.2.7 is applicable during MODE 5 and 6 operations. The proposed Required Actions require the suspension of operations involving positive reactivity additions that could result in loss of required SDM or boron concentration. The requirements for SDM are specified in ITS LCO 3.1.1 while the requirements for boron concentration are specified in ITS LCO 3.9.1. The current and proposed actions may result in an overall reduction in SDM or RCS boron concentration, but provide acceptable margin to maintaining subcritical operation. The CTS compensatory action restricted the heatup and cooldown rates of the RCS to 50ºF or less in any one hour period in MODE 5. This limitation has been deleted, since the rate of SDM change is not germane provided SDM is not lost. The proposed Required Action is to suspend operations involving positive reactivity additions that could result in loss of required SDM or boron concentration. These limitations are considered acceptable. The Bases also indicate that introduction of temperature changes including temperature increases when operating with a positive moderator temperature coefficient must be evaluated to ensure they do not result in a loss of required SDM. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L.2 (Category 7 - Relaxation Of Surveillance Frequency, Non-24 Month Type Change) CTS 4.8.1.2 requires the AC electrical power sources to be demonstrated OPERABLE by the performance of each of the Surveillance Requirements of CTS 4.8.1.1.1 and CTS 4.8.1.1.2 except for requirement CNP Units 1 and 2 Page 6 of 10 Attachment 1, Volume 13, Rev. 0, Page 170 of 496

Attachment 1, Volume 13, Rev. 0, Page 171 of 496 DISCUSSION OF CHANGES ITS 3.8.2, AC SOURCES - SHUTDOWN CTS 4.8.1.1.2.a.5. ITS SR 3.8.2.1 has included this allowance in the Note to SR 3.8.2.1 (it exempts performance of ITS SR 3.8.1.3), however additional SRs are excepted from being performed. ITS SR 3.8.2.1 states that the following SRs are also not required to be performed: SR 3.8.1.10 through SR 3.8.1.12, SR 3.8.1.15 through SR 3.8.1.17, and SR 3.8.1.18. This changes the CTS by not requiring the performance of additional AC Source Surveillances.

The purpose of CTS 4.8.1.2 is to ensure the appropriate AC Sources are demonstrated to be OPERABLE. This change is acceptable because the new Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability. CTS 4.8.1.2 does not require CTS 4.8.1.1.2.a.5 to be performed (however, it must be met). Many of the currently required Surveillances specified in CTS 4.8.1.2 involve tests that would require the DG to be paralleled to offsite power. This condition (the only required DG and the only required offsite circuit connected) presents a significant risk of a single fault resulting in a station blackout. The NRC has previously recognized this in the exception stated in CTS 4.8.1.2 (4.8.1.1.2.a.5) and provided a Surveillance exception to the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months DG load test to avoid this condition. In an effort to consistently address this concern and to avoid potential conflicting Technical Specifications, the Surveillances that would require the DG to be connected to the offsite source or would require disconnection of the required offsite circuit and deenergization of required buses are excepted from performance requirements. The exception does not take exception to the requirement for the DG to be capable of performing the particular function; just to the requirement to demonstrate it while that source of power is being relied on to support meeting the LCO. The exception is being presented as a Note to ITS SR 3.8.2.1. The excluded Surveillances are CTS 4.8.1.1.2.a.5 (ITS SR 3.8.1.3),

the DG 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months load test, CTS 4.8.1.1.2.e.2 (ITS SR 3.8.1.10), the single largest load reject test, CTS 4.8.1.1.2.e.3 (ITS SR 3.8.1.11), the full load rejection test, CTS 4.8.1.1.2.e.4 (ITS SR 3.8.1.12), the simulated loss of offsite power test, CTS 4.8.1.1.2.e.7 (ITS SR 3.8.1.15), the 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months endurance run, CTS 4.8.1.1.2.e.7 (ITS SR 3.8.1.16), the hot re-start test, CTS 4.8.1.1.2.e.9 (ITS SR 3.8.1.17), the DG synchronization test, and CTS 4.8.1.1.2.e.11 (ITS SR 3.8.1.18), the DG automatic sequence time delay relay test. This change is acceptable since it is the intent that these SRs must still be capable of being met, but actual performance is not required during periods when the DG and offsite circuit is required to be OPERABLE. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

L.3 (Category 6 - Deletion Of Surveillance Requirements) CTS 4.8.1.2 requires the AC electrical power sources to be demonstrated OPERABLE by the performance of each of the Surveillance Requirements of 4.8.1.1.1 and 4.8.1.1.2 except for requirement 4.8.1.1.2.a.5. ITS SR 3.8.2.1 has included this allowance in the Note to SR 3.8.2.1 (see DOC L.2). However, additional ITS SRs are excepted from being required to be met. ITS SR 3.8.2.1 states, in part, that the following SRs are not required to be met: SR 3.8.1.9 and SR 3.8.1.20. This changes the CTS by not requiring certain Surveillances to be met. Further changes to CTS 3.8.1.2 are discussed in DOC L.6.

CNP Units 1 and 2 Page 7 of 10 Attachment 1, Volume 13, Rev. 0, Page 171 of 496

Attachment 1, Volume 13, Rev. 0, Page 172 of 496 DISCUSSION OF CHANGES ITS 3.8.2, AC SOURCES - SHUTDOWN The purpose of CTS 4.8.1.2 is to ensure the appropriate AC Sources are demonstrated to be OPERABLE. This change is acceptable because the deleted Surveillance Requirements are 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.

This change deletes certain Surveillances from being required to be met. These Surveillances are CTS 4.8.1.1.1.b (ITS SR 3.8.1.9), the offsite source transfer verification test, and CTS 4.8.1.1.2.f.3 (ITS SR 3.8.1.20), the DG simultaneous start test. SR 3.8.1.9 is not required to be met since the auxiliary source cannot power the Class 1E electrical power distribution subsystems in these conditions and since only one offsite circuit is required to be OPERABLE. SR 3.8.1.20 is excepted because starting independence is not required with only one DG required to be OPERABLE. This change is designated as less restrictive because Surveillances which are required in the CTS will not be required in the ITS.

L.4 (Category 4 - Relaxation of Required Action) The CTS 3.8.1.2 Action requires the suspension of certain activities when the required AC Source is inoperable.

ITS 3.8.2 provides an alternate Required Action (ITS 3.8.2 Required Action A.1) that allows the declaration of affected required feature(s) with no offsite power available inoperable instead of requiring the specified activities to be suspended.

This changes the CTS by allowing the affected required feature(s) with no offsite power available to be declared inoperable instead of suspending the specified activities.

The purpose of CTS 3.8.1.2 is to ensure the appropriate offsite circuit is OPERABLE. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a loss of offsite power occurring during the repair period. This changes the CTS by allowing the affected required feature(s) with no offsite power available to be declared inoperable instead of suspending specified activities (i.e., CORE ALTERATIONS, movement of irradiated fuel assemblies, and operations involving positive reactivity additions that could result in loss of required SDM or boron concentration). Since the ITS 3.8.2 circuit OPERABILITY requirements are proposed to require supplying power to all required electrical power distribution subsystems, if one or more subsystems are not powered by an offsite circuit, that circuit is inoperable. In this event it may not be necessary to suspend all CORE ALTERATIONS, irradiated fuel handling, and operations involving positive reactivity additions that could result in loss of required SDM or boron concentration as required by CTS 3.8.1.2 Action (and as modified by DOC L.1). Conservative actions can be assured if all required equipment without offsite power is declared inoperable and the associated ACTIONS of the individual equipment taken (ITS 3.8.2 Required Action A.1). This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

CNP Units 1 and 2 Page 8 of 10 Attachment 1, Volume 13, Rev. 0, Page 172 of 496

Attachment 1, Volume 13, Rev. 0, Page 173 of 496 DISCUSSION OF CHANGES ITS 3.8.2, AC SOURCES - SHUTDOWN L.5 (Category 1 - Relaxation of LCO Requirements) (Unit 2 only) CTS 3.8.1.2.a requires one circuit between the offsite transmission network and the onsite Class 1E distribution system to be OPERABLE and CTS 3.8.1.2.b requires one DG to be OPERABLE. These two required AC Sources are Unit 2 sources.

CTS 3.9.12 requires the Fuel Handling Area Exhaust Ventilation (FHAEV)

System (which is powered from Unit 1 AC Sources) to be OPERABLE whenever irradiated fuel is in the storage pool. The CTS definition of "OPERABLE -

OPERABILITY" includes both a normal and emergency electrical power source requirement. However, there are no specific requirements in Unit 2 CTS 3.8.1.2 requiring the Unit 1 AC Sources to be OPERABLE to support the FHAEV System. In addition, CTS 3.0.5, which provides compensatory actions when an AC Source is inoperable, is not applicable in MODES 5 and 6. Unit 2 ITS LCO 3.8.2.c requires one Unit 1 qualified circuit between the offsite transmission network and the Unit 1 onsite Class 1E AC electrical power distribution subsystem required by LCO 3.8.10. This changes the Unit 2 CTS by explicitly requiring only one Unit 1 AC Source (the offsite source) associated with the Unit 1 equipment required to be OPERABLE to support Unit 2 operation.

The purpose of Unit 2 ITS LCO 3.8.2.c is to ensure an AC Source is available to support required equipment. 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 explicit requirements for AC Sources of the Unit 1 sources are not included in CTS 3.8.1.2 for Unit 2. However, based on the definition of OPERABILITY, both the normal and emergency sources are required to be OPERABLE to support the FHAEV System. Thus, deleting the explicit requirement that a DG is OPERABLE is less restrictive since currently one is required. In general, when the unit is shutdown, the Technical Specifications requirements ensure that the unit has the capability to mitigate the consequences of postulated accidents. However, assuming a single failure and concurrent loss of all offsite or all onsite power is not required. This change is acceptable since this allowance is in recognition that certain testing and maintenance activities must be conducted provided an acceptable level of risk is not exceeded. During MODES 5 and 6, performance of a significant number of required testing and maintenance activities is also required. In MODES 5 and 6, the activities are generally planned and administratively controlled. 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.6 CTS 4.8.1.2 requires the AC electrical power sources to be demonstrated OPERABLE by the performance of each of the Surveillance Requirements of 4.8.1.1.1 and 4.8.1.1.2 except for requirement 4.8.1.1.2.a.5. ITS SR 3.8.2.1 has included this allowance in the Note to SR 3.8.2.1 (see DOC L.2). However, additional ITS SRs are excepted from being required to be met. ITS SR 3.8.2.1 states, in part, that the following SRs are not required to be met: SR 3.8.1.13, SR 3.8.1.14 (ESF actuation signal portion only) and SR 3.8.1.19. This changes the CTS by not requiring certain Surveillances to be met. Further changes to CTS 3.8.1.2 are discussed in DOC L.3.

CNP Units 1 and 2 Page 9 of 10 Attachment 1, Volume 13, Rev. 0, Page 173 of 496

Attachment 1, Volume 13, Rev. 0, Page 174 of 496 DISCUSSION OF CHANGES ITS 3.8.2, AC SOURCES - SHUTDOWN The purpose of CTS 4.8.1.2 is to ensure the appropriate AC Sources are demonstrated to be OPERABLE. This change is acceptable because the deleted Surveillance Requirements are 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.

This change deletes certain Surveillances from being required to be met. These Surveillances are CTS 4.8.1.1.2.e.5 (ITS SR 3.8.1.13), the Safety Injection actuation test, CTS 4.8.1.1.2.e.6.c (ITS SR 3.8.1.14), the bypass of automatic trips test (ESF actuation signal portion only), and CTS 4.8.1.1.2.e.6 (ITS SR 3.8.1.19), the loss of offsite power in conjunction with a Safety Injection actuation test. SR 3.8.1.13, SR 3.8.1.14 (ESF actuation signal portion only), and SR 3.8.1.19 are not required to be met because the ESF actuation signal is not required to be OPERABLE, as indicated in the Surveillance Requirements in ITS 3.3.2. The CTS and ITS also do not require the ECCS subsystem(s) to be OPERABLE in MODES 5 and 6. The DGs are required to support the equipment powered from the emergency buses. However, when the ECCS subsystem(s) are not required to be OPERABLE, then there is no reason to require the DGs to autostart on an ESF initiation signal. In addition, the ESF actuation signal is only an anticipatory start signal; the DGs are only needed during a LOCA if a loss of offsite power occurs concurrently. The DGs are also required to autostart if a loss of offsite power occurs. The requirement to autostart the required DG(s) on a loss of offsite power signal is being maintained in the ITS (ITS SR 3.8.1.12).

Thus, when in these conditions (associated ECCS subsystem(s) not required to be OPERABLE), there is no reason to require the DGs to be capable of automatically starting on an ESF actuation signal (either by itself or concurrent with a loss of offsite power signal). This change is designated as less restrictive because Surveillance Requirements have been deleted from the CTS.

CNP Units 1 and 2 Page 10 of 10 Attachment 1, Volume 13, Rev. 0, Page 174 of 496

Attachment 1, Volume 13, Rev. 0, Page 175 of 496 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

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Attachment 1, Volume 13, Rev. 0, Page 180 of 496 JUSTIFICATION FOR DEVIATIONS ITS 3.8.2, AC SOURCES - SHUTDOWN

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

2. An additional requirement has been added to ISTS LCO 3.8.2 for Unit 2 to ensure the appropriate AC Source is OPERABLE during the movement of irradiated fuel assemblies in the auxiliary building. The new requirement was added as LCO 3.8.2.c. This modification was necessary since the Fuel Handling Area Exhaust Ventilation (FHAEV) System is supplied by Unit 1 AC Sources. In addition, ITS 3.8.2 ACTION A for Unit 2 has been modified to reflect this change.

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

4. Since only one circuit and one DG are required, the term "One" is redundant and has been deleted, consistent with other similar Conditions in the ISTS (e.g., ISTS 3.5.3).

5. These changes have been included consistent with proposed TSTF-433, Rev. 0. In addition, ISTS SR 3.8.1.13 (ITS SR 3.8.1.14) has been deleted from Note 1 to SR 3.8.2.1 and added to those Surveillances not required to be met. ISTS SR 3.8.1.13 (ITS SR 3.8.1.14) is the verification that the DGs automatic trips are bypassed on an actual or simulated loss of voltage signal on the emergency bus or an actual or simulated ESF actuation signal. The ESF actuation signal portion of this Surveillance is not required to be met because the ESF actuation signal is not required to be OPERABLE. This change is consistent with the technical analysis for TSTF-433 modifications.

6. The SRs have been changed to be consistent with the changes made to the Surveillance Requirements in ITS 3.8.1.

7. The Applicability has been clarified since CNP has two units, and irradiated fuel movement can occur in three different locations.

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Attachment 1, Volume 13, Rev. 0, Page 181 of 496 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

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Attachment 1, Volume 13, Rev. 0, Page 190 of 496 B 3.8.2 5

INSERT 8 specified in LCO 3.1.1, "SHUTDOWN MARGIN (SDM),"

5 INSERT 9 specified in LCO 3.9.1, "Boron Concentration."

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Attachment 1, Volume 13, Rev. 0, Page 194 of 496 JUSTIFICATION FOR DEVIATIONS ITS 3.8.2 BASES, AC SOURCES - SHUTDOWN

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

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

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

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. Changes are made to reflect the actual Specification.

6. Changes are made to be consistent with other places in the Bases and Specifications.

7. These punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, NEI 01-03, Section 3.2.2.

8. Spelling/grammatical error corrected.

9. Editorial change made for enhanced clarity.

10. These changes are made to reflect the modifications in proposed TSTF-433, Rev. 0.

11. This statement is discussing the cross-tying of distribution buses and is not applicable to this AC Sources Specification. Therefore it has been deleted. This allowance has been described in the Bases for ITS LCO 3.8.10, "Distribution Systems - Shutdown."

12. This statement has been deleted since the LCO requirements for the qualified offsite circuits are described in the next paragraph of the LCO Section.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 194 of 496

Attachment 1, Volume 13, Rev. 0, Page 195 of 496 Specific No Significant Hazards Considerations (NSHCs)

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Attachment 1, Volume 13, Rev. 0, Page 196 of 496 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.2, AC SOURCES - SHUTDOWN 10 CFR 50.92 EVALUATION FOR LESS RESTRICTIVE CHANGE L.6 CNP is converting to the Improved Technical Specifications (ITS) as outlined in NUREG-1431, "Standard Technical Specifications, Westinghouse Plants." The proposed change involves making the Current Technical Specifications (CTS) less restrictive. Below is the description of this less restrictive change and the determination of No Significant Hazards Considerations for conversion to NUREG-1431.

CTS 4.8.1.2 requires the AC electrical power sources to be demonstrated OPERABLE by the performance of each of the Surveillance Requirements of 4.8.1.1.1 and 4.8.1.1.2 except for requirement 4.8.1.1.2.a.5. ITS SR 3.8.2.1 has included this allowance in the Note to SR 3.8.2.1. However, additional ITS SRs are excepted from being required to be met. ITS SR 3.8.2.1 states, in part, that the following SRs are not required to be met:

SR 3.8.1.13, SR 3.8.1.14 (ESF actuation signal portion only) and SR 3.8.1.19. This changes the CTS by not requiring certain Surveillances to be met. Further changes to CTS 3.8.1.2 are discussed in DOC L.3.

The purpose of CTS 4.8.1.2 is to ensure the appropriate AC Sources are demonstrated to be OPERABLE. This change is acceptable because the deleted Surveillance Requirements are 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. This change deletes certain Surveillances from being required to be met. These Surveillances are CTS 4.8.1.1.2.e.5 (ITS SR 3.8.1.13),

the Safety Injection actuation test, CTS 4.8.1.1.2.e.6.c (ITS SR 3.8.1.14), the bypass of automatic trips test (ESF actuation signal portion only), and CTS 4.8.1.1.2.e.6 (ITS SR 3.8.1.19), the loss of offsite power in conjunction with a Safety Injection actuation test. SR 3.8.1.13, SR 3.8.1.14 (ESF actuation signal portion only), and SR 3.8.1.19 are not required to be met because the ESF actuation signal is not required to be OPERABLE, as indicated in the Surveillance Requirements in ITS 3.3.2. The CTS and ITS also do not require the ECCS subsystem(s) to be OPERABLE in MODES 5 and 6.

The DGs are required to support the equipment powered from the emergency buses.

However, when the ECCS subsystem(s) are not required to be OPERABLE, then there is no reason to require the DGs to autostart on an ESF initiation signal. In addition, the ESF actuation signal is only an anticipatory start signal; the DGs are only needed during a LOCA if a loss of offsite power occurs concurrently. The DGs are also required to autostart if a loss of offsite power occurs. The requirement to autostart the required DG(s) on a loss of offsite power signal is being maintained in the ITS (ITS SR 3.8.1.12).

Thus, when in these conditions (associated ECCS subsystem(s) not required to be OPERABLE), there is no reason to require the DGs to be capable of automatically starting on an ESF actuation signal (either by itself or concurrent with a loss of offsite power signal).

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

as discussed below:

CNP Units 1 and 2 Page 1 of 3 Attachment 1, Volume 13, Rev. 0, Page 196 of 496

Attachment 1, Volume 13, Rev. 0, Page 197 of 496 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.2, AC SOURCES - SHUTDOWN

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

Response: No.

The proposed change deletes certain Surveillances from being required to be met. These Surveillances are CTS 4.8.1.1.2.e.5 (ITS SR 3.8.1.13), the Safety Injection actuation test, CTS 4.8.1.1.2.e.6.c (ITS SR 3.8.1.14), the bypass of automatic trips test (ESF actuation signal portion only), and CTS 4.8.1.1.2.e.6 (ITS SR 3.8.1.19), the loss of offsite power in conjunction with a Safety Injection actuation test. SR 3.8.1.13, SR 3.8.1.14 (ESF actuation signal portion only), and SR 3.8.1.19 are not required to be met because the ESF actuation signal is not required to be OPERABLE, as indicated in the Surveillance Requirements in ITS 3.3.2. The CTS and ITS also do not require the ECCS subsystem(s) to be OPERABLE in MODES 5 and 6. The DGs are required to support the equipment powered from the emergency buses. However, when the ECCS subsystem(s) are not required to be OPERABLE, then there is no reason to require the DGs to autostart on an ESF initiation signal. In addition, the ESF actuation signal is only an anticipatory start signal; the DGs are only needed during a LOCA if a loss of offsite power occurs concurrently. The DGs are also required to autostart if a loss of offsite power occurs. The requirement to autostart the required DG(s) on a loss of offsite power signal is being maintained in the ITS (ITS SR 3.8.1.12).

Thus, when in these conditions (associated ECCS subsystem(s) not required to be OPERABLE), there is no reason to require the DGs to be capable of automatically starting on an ESF actuation signal (either by itself or concurrent with a loss of offsite power signal). This change will not affect the probability of an accident, since neither these SRs nor an ESF actuation signal are considered as an initiator of an analyzed accident. The consequences of an analyzed accident would not be significantly increased because the ESF actuation signal is only an anticipatory start signal; the DGs are only needed during a LOCA if a loss of offsite power occurs concurrently (and this SR is being maintained).

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change deletes certain Surveillances from being required to be met. These Surveillances are CTS 4.8.1.1.2.e.5 (ITS SR 3.8.1.13), the Safety Injection actuation test, CTS 4.8.1.1.2.e.6.c (ITS SR 3.8.1.14), the bypass of automatic trips test (ESF actuation signal portion only), and CTS 4.8.1.1.2.e.6 (ITS SR 3.8.1.19), the loss of offsite power in conjunction with a Safety Injection actuation test. SR 3.8.1.13, SR 3.8.1.14 (ESF actuation signal portion only), and SR 3.8.1.19 are not required to be met because the ESF actuation signal is not required to be OPERABLE, as indicated in the Surveillance Requirements in ITS 3.3.2. The CTS and ITS also do not require the ECCS subsystem(s) to be OPERABLE in MODES 5 and 6. The DGs are required to support the equipment powered from the emergency buses. However, when the ECCS subsystem(s) are not required to be OPERABLE, then there is no reason to require the DGs to CNP Units 1 and 2 Page 2 of 3 Attachment 1, Volume 13, Rev. 0, Page 197 of 496

Attachment 1, Volume 13, Rev. 0, Page 198 of 496 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.2, AC SOURCES - SHUTDOWN autostart on an ESF initiation signal. In addition, the ESF actuation signal is only an anticipatory start signal; the DGs are only needed during a LOCA if a loss of offsite power occurs concurrently. The DGs are also required to autostart if a loss of offsite power occurs. The requirement to autostart the required DG(s) on a loss of offsite power signal is being maintained in the ITS (ITS SR 3.8.1.12).

Thus, when in these conditions (associated ECCS subsystem(s) not required to be OPERABLE), there is no reason to require the DGs to be capable of automatically starting on an ESF actuation signal (either by itself or concurrent with a loss of offsite power signal). This change will not physically alter the plant (no new or different type of equipment will be installed). In addition, no changes will be made to the operation of the unit. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

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

Response: No.

The proposed change deletes certain Surveillances from being required to be met. These Surveillances are CTS 4.8.1.1.2.e.5 (ITS SR 3.8.1.13), the Safety Injection actuation test, CTS 4.8.1.1.2.e.6.c (ITS SR 3.8.1.14), the bypass of automatic trips test (ESF actuation signal portion only), and CTS 4.8.1.1.2.e.6 (ITS SR 3.8.1.19), the loss of offsite power in conjunction with a Safety Injection actuation test. SR 3.8.1.13, SR 3.8.1.14 (ESF actuation signal portion only), and SR 3.8.1.19 are not required to be met because the ESF actuation signal is not required to be OPERABLE, as indicated in the Surveillance Requirements in ITS 3.3.2. The CTS and ITS also do not require the ECCS subsystem(s) to be OPERABLE in MODES 5 and 6. The DGs are required to support the equipment powered from the emergency buses. However, when the ECCS subsystem(s) are not required to be OPERABLE, then there is no reason to require the DGs to autostart on an ESF initiation signal. In addition, the ESF actuation signal is only an anticipatory start signal; the DGs are only needed during a LOCA if a loss of offsite power occurs concurrently. The DGs are also required to autostart if a loss of offsite power occurs. The requirement to autostart the required DG(s) on a loss of offsite power signal is being maintained in the ITS (ITS SR 3.8.1.12).

Thus, when in these conditions (associated ECCS subsystem(s) not required to be OPERABLE), there is no reason to require the DGs to be capable of automatically starting on an ESF actuation signal (either by itself or concurrent with a loss of offsite power signal). The margin of safety is not affected by this change because the ESF actuation signal is only an anticipatory start signal; the DGs are only needed during a LOCA if a loss of offsite power occurs concurrently (and this SR is being maintained). 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 13, Rev. 0, Page 198 of 496

, Volume 13, Rev. 0, Page 199 of 496 ATTACHMENT 3 ITS 3.8.3, Diesel Fuel Oil , Volume 13, Rev. 0, Page 199 of 496

, Volume 13, Rev. 0, Page 200 of 496 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 13, Rev. 0, Page 200 of 496

Attachment 1, Volume 13, Rev. 0, Page 201 of 496 ITS 3.8.3 A.1 ITS Add proposed LCO 3.8.3 A.2 LCO 3.8.3 See ITS 3.8.1 LA.1 SR 3.8.3.1 See ITS 3.8.1 When associated DG is required to be OPERABLE A.2 Add proposed ACTIONS A and D and ACTIONS Note for fuel oil storage tank volume L.1 See ITS 3.8.1 LA.1 Page 1 of 14 Attachment 1, Volume 13, Rev. 0, Page 201 of 496

Attachment 1, Volume 13, Rev. 0, Page 202 of 496 ITS 3.8.3 A.1 ITS L.2 L.3 See ITS 3.8.1 SR 3.8.3.1 every 31 days L.2 See ITS 3.8.1 A.3 See ITS 3.8.1 SR 3.8.3.3 Add proposed SR 3.8.3.2 A.4 M.1 See ITS 5.5 See ITS 3.8.1 A.3 Add proposed ACTION D for accumulated water Add proposed ACTION C M.1 Page 2 of 14 Attachment 1, Volume 13, Rev. 0, Page 202 of 496

Attachment 1, Volume 13, Rev. 0, Page 203 of 496 ITS 3.8.3 A.1 ITS See ITS 5.5 M.1 See ITS 3.8.1 Add proposed ACTION B M.1 Page 3 of 14 Attachment 1, Volume 13, Rev. 0, Page 203 of 496

Attachment 1, Volume 13, Rev. 0, Page 204 of 496 ITS 3.8.3 A.1 ITS See ITS 3.8.1 LA.2 See ITS 3.8.1 Page 4 of 14 Attachment 1, Volume 13, Rev. 0, Page 204 of 496

Attachment 1, Volume 13, Rev. 0, Page 205 of 496 ITS 3.8.3 A.1 ITS LA.2 See ITS 3.8.1 See ITS 3.8.1 Page 5 of 14 Attachment 1, Volume 13, Rev. 0, Page 205 of 496

Attachment 1, Volume 13, Rev. 0, Page 206 of 496 ITS 3.8.3 A.1 ITS L.2 L.2 Page 6 of 14 Attachment 1, Volume 13, Rev. 0, Page 206 of 496

Attachment 1, Volume 13, Rev. 0, Page 207 of 496 ITS 3.8.3 A.1 ITS Add proposed LCO 3.8.3 A.2 LCO 3.8.3 See ITS 3.8.2 SR 3.8.3.1 See ITS 3.8.2 A.2 When associated DG is required to be OPERABLE Add proposed ACTIONS A and D and ACTIONS Note for fuel oil storage tank volume L.1 See ITS 3.8.2 See CTS markup SR 3.8.3.1, pages 2 of 14 SR 3.8.3.2, through 5 of 14 SR 3.8.3.3 See ITS 3.8.2 Page 7 of 14 Attachment 1, Volume 13, Rev. 0, Page 207 of 496

Attachment 1, Volume 13, Rev. 0, Page 208 of 496 ITS 3.8.3 A.1 ITS Add proposed LCO 3.8.3 A.2 LCO 3.8.3 See ITS 3.8.1 LA.1 SR 3.8.3.1 See ITS 3.8.1 When associated DG is required to be OPERABLE A.2 Add proposed ACTIONS A and D and ACTIONS Note for fuel oil storage tank volume L.1 See ITS 3.8.1 LA.1 Page 8 of 14 Attachment 1, Volume 13, Rev. 0, Page 208 of 496

Attachment 1, Volume 13, Rev. 0, Page 209 of 496 ITS 3.8.3 A.1 ITS L.2 L.3 See ITS 3.8.1 SR 3.8.3.1 every 31 days L.2 See ITS 3.8.1 A.3 See ITS 3.8.1 SR 3.8.3.3 Add proposed SR 3.8.3.2 A.4 M.1 See ITS 5.5 See ITS 3.8.1 A.3 Add proposed ACTION D for accumulated water Add proposed ACTION C M.1 Page 9 of 14 Attachment 1, Volume 13, Rev. 0, Page 209 of 496

Attachment 1, Volume 13, Rev. 0, Page 210 of 496 ITS 3.8.3 A.1 ITS See ITS 5.5 M.1 See ITS 3.8.1 Add proposed ACTION B M.1 Page 10 of 14 Attachment 1, Volume 13, Rev. 0, Page 210 of 496

Attachment 1, Volume 13, Rev. 0, Page 211 of 496 ITS 3.8.3 A.1 ITS See ITS 3.8.1 LA.2 See ITS 3.8.1 Page 11 of 14 Attachment 1, Volume 13, Rev. 0, Page 211 of 496

Attachment 1, Volume 13, Rev. 0, Page 212 of 496 ITS 3.8.3 A.1 ITS LA.2 See ITS 3.8.1 See ITS 3.8.1 Page 12 of 14 Attachment 1, Volume 13, Rev. 0, Page 212 of 496

Attachment 1, Volume 13, Rev. 0, Page 213 of 496 ITS 3.8.3 A.1 ITS L.2 L.2 Page 13 of 14 Attachment 1, Volume 13, Rev. 0, Page 213 of 496

Attachment 1, Volume 13, Rev. 0, Page 214 of 496 ITS 3.8.3 A.1 ITS Add proposed LCO 3.8.3 A.2 LCO 3.8.3 See ITS 3.8.2 SR 3.8.3.1 See ITS 3.8.2 A.2 When associated DG is required to be OPERABLE Add proposed ACTIONS A and D and ACTIONS Note for fuel oil storage tank volume L.1 See ITS 3.8.2 See CTS markup SR 3.8.3.1, pages 9 of 14 SR 3.8.3.2, through 14 of 14 SR 3.8.3.3 See ITS 3.8.2 Page 14 of 14 Attachment 1, Volume 13, Rev. 0, Page 214 of 496

Attachment 1, Volume 13, Rev. 0, Page 215 of 496 DISCUSSION OF CHANGES ITS 3.8.3, DIESEL FUEL OIL 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 LCOs 3.8.1.1 and 3.8.1.2 state the requirements for the AC Sources during operating and shutdown conditions, respectively. These requirements are used to form the LCO and Applicability for the ITS diesel fuel oil Specification. ITS LCO 3.8.3, "Diesel Fuel Oil," states that the stored diesel fuel oil shall be within limits for each required DG. The Applicability for this requirement is when associated DG is required to be OPERABLE. This changes the CTS by combining the requirements for diesel fuel oil into one Specification.

This change is acceptable because the current requirements are translated into ITS form with no technical changes. Diesel fuel oil is a support system for each DG. The CTS and ITS maintain this relationship between the DGs and the Diesel Fuel Oil System without any changes in the technical requirements. This change is designated as administrative because it does not result in a technical change to the CTS.

A.3 CTS 4.8.1.1.2.b.2 requires the removal of accumulated water from the diesel fuel oil storage tanks at least once per 31 days. CTS 4.8.1.1.2.b footnote *** states that the actions to be taken should any of the properties be found outside of specified limits are defined in the Bases. For CTS 4.8.1.1.2.b.2, the Bases state that the removal of accumulated water as required by CTS 4.8.1.1.2.b.2 is performed by drawing the contents off the bottom of the tank until acceptable results are obtained for either a tape test or a water and sediment test. An acceptable result for the water and sediment content is a measured value less than 0.05 percent volume. ITS SR 3.8.3.3 specifies to check and remove accumulated water from each fuel oil storage tank. ITS 3.8.3 ACTION D states that with one or more DGs with diesel fuel oil not within limits for reasons other than Condition A, B, or C, to immediately declare the associated DG inoperable.

ITS 3.8.3 Conditions A, B, and C are not related to accumulated water, therefore, if for some reason accumulated water could not be removed, then ITS 3.8.3 ACTION D would be entered and the associated DG could be declared inoperable. This changes the CTS by providing an ACTION for diesel fuel oil not within limits (in this case, fuel oil accumulated water present).

The purpose of CTS 4.8.1.1.2.b.2 is to check and remove any accumulated water to help ensure microbiological fouling does not cause fuel oil degradation. The CTS 4.8.1.1.2.b Footnote *** and associated Bases do not really provide any specific action for accumulated water. ITS 3.8.3 ACTION D requires entry for diesel fuel oil not within limit for reasons other than Condition A, B, or C. The ITS SR 3.8.3.3 Bases state that the presence of water does not necessarily represent failure of this SR, provided the accumulated water is removed during CNP Units 1 and 2 Page 1 of 7 Attachment 1, Volume 13, Rev. 0, Page 215 of 496

Attachment 1, Volume 13, Rev. 0, Page 216 of 496 DISCUSSION OF CHANGES ITS 3.8.3, DIESEL FUEL OIL performance of the Surveillance. The ITS 3.8.3 guidance is consistent with the current intent of the CTS. If accumulated water could not be removed, the DG would be declared inoperable. This change is designated as administrative because it does not result in a technical change to the CTS.

A.4 CTS 4.8.1.1.2.c and CTS 4.8.1.1.2.d specify the requirements for the properties of new and stored fuel oil, respectively. The technical content of CTS 4.8.1.1.2.c and CTS 4.8.1.1.2.d is being moved to ITS 5.5.11. A Surveillance Requirement is added (ITS SR 3.8.3.2) to clarify that the tests of the Diesel Fuel Oil Testing Program must also be completed and passed for determining OPERABILITY of the DG fuel oil subsystem.

The purpose of CTS 4.8.1.1.2.c and CTS 4.8.1.1.2.d are to ensure the new and stored diesel fuel oil properties are consistent with the specified standards. This change simply moves the actual properties to ITS 5.5.11. Any technical changes will be addressed in the Discussion of Changes for ITS 5.5. This change is acceptable since this is a presentation preference that maintains current requirements except for those discussed in the Discussion of Changes for ITS 5.5. This change is designated as administrative because it does not result in a technical change to the CTS.

MORE RESTRICTIVE CHANGES M.1 CTS 4.8.1.1.2.c and CTS 4.8.1.1.2.d specify the requirements for the properties of new and stored fuel oil, respectively. CTS 4.8.1.1.2.c footnote *** and CTS 4.8.1.1.2.d footnote

state that the actions to be taken should any of the properties be found outside of specified limits are defined in the Bases. The requirements in CTS 4.8.1.1.2.c.1), 2), and 3) apply to properties associated with the new fuel oil. The properties must be met before adding the new fuel to the storage tank. There are no actions specified in the Bases for these properties since the new fuel will not be added to the storage tank unless these properties are within limits. CTS 4.8.1.1.2.c.4) applies to the new fuel oil properties which must be evaluated within 31 days after the fuel is added to the storage tank. The CTS 3/4.8 Bases provides the following guidance and actions for CTS 4.8.1.1.2.c.4): a) The sample specified in CTS 4.8.1.1.2.c.4) is sent offsite for testing; b) A serious attempt will be made to meet the 31 day limit on the offsite tests; however, if for reason this limit is not met (e.g., if the sample is lost or broken or if the results are not received in 31 days), the DGs should not be considered inoperable; c) If the sample is lost, broken, or fails the offsite tests and the new oil has already been put into the storage tank, the offsite tests will be performed on a sample taken from the storage tank; and d) If the results on the subsequent storage tank sample are not within specified limits, the DGs should be considered OPERABLE and the out-of-spec properties should be returned to within specification as soon as possible. CTS 4.8.1.1.2.d applies to particulate contamination of the fuel in the storage tank. The CTS 3/4.8 Bases provides the following guidance and actions for CTS 4.8.1.1.2.d. If the monthly storage tank sample taken fails the particulate contamination test, the DG should be considered inoperable and the contamination level should be restored to below 10 mg/liter as soon as possible. ITS 3.8.3 ACTION B specifies the compensatory actions for one or more DG with stored fuel oil total particulates CNP Units 1 and 2 Page 2 of 7 Attachment 1, Volume 13, Rev. 0, Page 216 of 496

Attachment 1, Volume 13, Rev. 0, Page 217 of 496 DISCUSSION OF CHANGES ITS 3.8.3, DIESEL FUEL OIL not within limits. ITS 3.8.3 Required Action B.1 requires the restoration of the fuel oil total particulates to within limits in 7 days. ITS 3.8.3 ACTION C specifies the compensatory actions for one or more DGs with new fuel oil properties not within limits. ITS 3.8.3 Required Action C.1 requires the restoration of the stored fuel oil properties to within limits within 30 days. This changes the CTS by providing explicit ACTIONS for fuel oil total particulates and new fuel oil properties limits not met.

The purpose of CTS 4.8.1.1.2.c and associated Bases is to provide the appropriate property limits for new and stored fuel and to provide the appropriate compensatory actions for when the stored fuel oil properties are not within limits.

The purpose of CTS 4.8.1.1.2.d and associated Bases is to provide the appropriate limit for total particulate contamination and to provide the appropriate compensatory actions for when the total particulate contamination is not within limit. This change provides explicit Required Actions and Completion Times for restoring both total particulates and fuel oil properties to within limits. ITS 3.8.3 ACTION B is entered as a result of a failure to meet the acceptance criterion of total particulate concentration specified in ITS 5.5.11.c. Normally, trending of particulate levels allows sufficient time to correct high particulate levels prior to reaching the limit of acceptability. Poor sample procedures (bottom sampling),

contaminated sampling equipment, and errors in laboratory analysis can produce failures that do not follow a trend. Since the presence of particulates does not mean failure of the fuel oil to burn properly in the diesel engine, particulate concentration is unlikely to change significantly between Surveillance Frequency intervals, and proper engine performance has been recently demonstrated (within 31 days), it is prudent to allow a brief period prior to declaring the associated DG inoperable. The 7 day Completion Time allows for further evaluation, re-sampling and re-analysis of the DG fuel oil. ITS 3.8.3 ACTION C is entered as a result of failure to meet the requirements specified in ITS 5.5.11.b. With the new fuel oil properties defined in the Bases for ITS SR 3.8.3.2 not within the required limits, a period of 30 days is allowed for restoring the stored fuel oil properties. This period provides sufficient time to test the stored fuel oil to determine that the new fuel oil did not cause the stored fuel oil to be outside of the required limits, or to restore the stored fuel oil properties to within limits. This restoration may involve feed and bleed procedures, filtering, or combinations of these procedures. Even if a DG start and load was required during this time interval and the stored fuel oil properties were outside limits, there is a high likelihood that the DG would still be capable of performing its intended function. This change is designated as more restrictive because explicit Required Actions and Completion Times are included in the Technical Specifications for stored fuel oil total particulates and new diesel fuel oil properties not within limits.

RELOCATED SPECIFICATIONS None CNP Units 1 and 2 Page 3 of 7 Attachment 1, Volume 13, Rev. 0, Page 217 of 496

Attachment 1, Volume 13, Rev. 0, Page 218 of 496 DISCUSSION OF CHANGES ITS 3.8.3, DIESEL FUEL OIL REMOVED DETAIL CHANGES LA.1 (Type 1 - Removing Details of System Design and System Description including Design Limits) CTS LCO 3.8.1.1.b.2 requires a "separate" fuel storage system for each required DG. CTS 3.8.1.1.b.2 footnote

states that the tanks are "separate between diesels but shared between Units 1 and 2." ITS 3.8.3 does not state that the fuel oil storage tanks are separate between diesels, or that they are shared between Units 1 and 2. This changes the CTS by moving these details to the ITS Bases.

The removal of these details, which are related to system design, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement that the required fuel storage tank contains the specified volume of diesel fuel oil.

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 6 - Removal of LCO, SR, or other TS requirement to the TRM, UFSAR, ODCM, QAPD, or IIP) CTS 4.8.1.1.2.f.1 requires a cleaning of the fuel oil storage tanks by one of two methods every 10 years. CTS 4.8.1.1.2.f.2 requires the performance of a precision leak detection test to verify that the leakage rate from the fuel oil system is < .05 gallons/hour. ITS 3.8.3 does not include these requirements for the fuel oil storage tanks. This changes the CTS by moving these fuel oil storage tank requirements from the Technical Specifications to the Technical Requirements Manual (TRM).

The removal of these details from the Technical Specifications is acceptable because this type of information is not necessary to provide adequate protection of public health and safety. The purpose of CTS 4.8.1.1.2.f.1 is to ensure the contaminant level is below 10 mg/l. The purpose of CTS 4.8.1.1.2.f.2 is to satisfy the requirements of the National Fire Protection Association (NFPA) 329 and to ensure the leak tightness of the tank. The criteria and Frequencies established in the ITS 5.5.11, "Diesel Fuel Oil Testing Program," and ITS SR 3.8.3.3 will ensure the diesel fuel oil is at a quality that will ensure proper operation of the DG during a design basis accident. Also, this change is acceptable because the removed information will be adequately controlled in the TRM. The TRM is incorporated by reference into the UFSAR and any changes to the TRM are made under 10 CFR 50.59, which ensures changes are properly evaluated. This change is designated as a less restrictive removal of detail change because information is being removed from the Technical Specifications.

CNP Units 1 and 2 Page 4 of 7 Attachment 1, Volume 13, Rev. 0, Page 218 of 496

Attachment 1, Volume 13, Rev. 0, Page 219 of 496 DISCUSSION OF CHANGES ITS 3.8.3, DIESEL FUEL OIL LESS RESTRICTIVE CHANGES L.1 (Category 4 - Relaxation of Required Action) The CTS 3.8.1.1 and 3.8.1.2 Actions do not provide explicit compensatory actions if the volume of fuel oil in the storage tank is less than the specified limit. Thus, if the minimum indicated volume is not met, the associated DG must be declared inoperable and CTS 3.8.1.1 Action b or the CTS 3.8.1.2 Action must be entered, as applicable.

ITS 3.8.3 ACTION A allows the unit to not declare the associated DG inoperable as long as the volume of stored fuel oil is greater than a six day limit (i.e.,

> 39,500 gallons). In this situation, ITS 3.8.3 Required Action A.1 allows 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months to restore the fuel oil volume to within limits. If this Required Action and associated Completion Time is not met or if the DG fuel oil storage tank volume is < to 39,500 gallons, the associated DG must be declared inoperable immediately (ITS 3.8.3 ACTION D). In addition, a Note has been added to the ITS 3.8.3 ACTIONS that allows separate Condition entry for each DG. This changes the CTS by allowing each DG not to be declared inoperable with the fuel oil storage tank volume not within the specified Surveillance limit as long as each DG has enough fuel oil for 6 days (> 39,500 gallons) of operation at full load.

The purpose of ITS 3.8.3 ACTION A is to allow time to restore the stored diesel fuel oil volume to within the specified limit. 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 addition of ITS 3.8.3 ACTION A will allow the associated DG not to be declared inoperable with the stored diesel fuel oil volume not within the specified Surveillance limit as long as each DG has enough fuel oil for 6 days operation at full load. In this Condition, the 7 day fuel oil supply for a DG is not available. However, the Condition is restricted to fuel oil volume reductions that maintain at least a 6 day supply. These circumstances may be caused by events such as full load operation required after an inadvertent start while at minimum required level, or feed and bleed operations, which may be necessitated by increasing particulate levels or any number of other oil quality degradations. This restriction allows sufficient time for obtaining the requisite replacement volume and performing the analyses required prior to addition of diesel fuel oil to the tank. A period of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months is considered sufficient to complete restoration of the required volume prior to declaring the affected DG inoperable. This period is acceptable based on the remaining capacity

(> 6 days), the fact that procedures will be initiated to obtain replenishment, and the low probability of an event during this brief period. 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 7 - Relaxation Of Surveillance Frequency, Non-24 Month Type Change) CTS 4.8.1.1.2.a specifies that each DG shall be demonstrated OPERABLE in accordance with the frequency specified in Table 4.8-1 on a CNP Units 1 and 2 Page 5 of 7 Attachment 1, Volume 13, Rev. 0, Page 219 of 496

Attachment 1, Volume 13, Rev. 0, Page 220 of 496 DISCUSSION OF CHANGES ITS 3.8.3, DIESEL FUEL OIL STAGGERED TEST BASIS. CTS Table 4.8-1 specifies the test frequency based on the number of failures that have occurred in testing each DG during the previous 20 tests. If the number of failures do not exceed the specified limit, testing is to be performed every 31 days. If failure occurs above the specified limit, then testing is conducted every 7 days. CTS 4.8.1.1.2.a.2 requires the verification of the fuel level in the fuel storage tank. ITS SR 3.8.3.1 requires the verification that each fuel oil storage tank contains the specified volume limit every 31 days. This changes the CTS by deleting the requirement to verify the fuel oil storage tank level at an increasing frequency based on the number of DG failures. The deletion of the STAGGERED TEST BASIS requirement is discussed in DOC L.3.

The purpose of CTS 4.8.1.1.2.a.2 is to ensure the DG has the appropriate amount of diesel fuel oil for continuous operation for 7 days. This change is acceptable because the new Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability. The CTS test frequency has been changed by deleting the requirement to perform the Surveillance in accordance with the DG Test Schedule Table and includes a Frequency of 31 days. This change is acceptable because the DG failures that result in a more frequent DG test frequency have no impact on the fuel oil storage tanks ability to perform their intended functions because the fuel oil storage tank is normally maintained well above the minimum. The 31 day Frequency is adequate to ensure that a sufficient supply of diesel fuel oil is available, since low level alarms are provided and unit operators would be aware of any large uses of diesel fuel oil during this period. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

L.3 (Category 7 - Relaxation Of Surveillance Frequency, Non-24 Month Type Change) CTS 4.8.1.1.2.a states that each DG shall be demonstrate OPERABLE in accordance with the frequency specified in Table 4.8-1 "on a STAGGERED TEST BASIS." CTS 4.8.1.1.2.a.2 requires the verification of the fuel level in the fuel storage tank. ITS SR 3.8.3.1 requires the verification that each fuel oil storage tank contains the specified volume limit every 31 days. The Surveillance Frequency for ITS SR 3.8.3.1 is every 31 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 deletion to monitor the fuel oil storage tank volume more frequently based on the number of DG failures is discussed in DOC L.2.

The purpose of CTS 4.8.1.1.2.a is to demonstrate the OPERABILITY of the DG(s) and the associated support equipment (fuel oil day tank and fuel oil transfer system). The purpose of CTS 4.8.1.1.2.a.2 is to ensure the DG has the appropriate amount of diesel fuel oil for continuous operation for 7 days. This change is acceptable because the new Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability.

This change deletes the requirement to perform CTS 4.8.1.1.2.a.2 (SR 3.8.3.1) on a STAGGERED TEST BASIS. The intent of a requirement for staggered testing is to increase reliability of the component/system being tested. A number of studies have been performed that have demonstrated that staggered testing has negligible impact on component reliability. These analytical and subjective CNP Units 1 and 2 Page 6 of 7 Attachment 1, Volume 13, Rev. 0, Page 220 of 496

Attachment 1, Volume 13, Rev. 0, Page 221 of 496 DISCUSSION OF CHANGES ITS 3.8.3, DIESEL FUEL OIL 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 DG System staggered testing requirements have been deleted. This change is designated as less restrictive because the Surveillance is not required to be performed on a STAGGERED TEST BASIS in the ITS.

CNP Units 1 and 2 Page 7 of 7 Attachment 1, Volume 13, Rev. 0, Page 221 of 496

Attachment 1, Volume 13, Rev. 0, Page 222 of 496 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

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Attachment 1, Volume 13, Rev. 0, Page 225 of 496 JUSTIFICATION FOR DEVIATIONS ITS 3.8.3, DIESEL FUEL OIL

1. The ISTS 3.8.3 requirements for lube oil and starting air subsystems have not been included in ITS 3.8.3. The starting air subsystem requirements have been incorporated into ITS 3.8.1. Each DG has two air start receivers, and the pressure limit included in the ITS is the pressure needed for one DG start sequence. The ITS considers the DG to be OPERABLE when one air start receiver has the capacity for one DG start sequence. Therefore, CNP does not consider it appropriate to adopt the starting air subsystem allowances in ISTS 3.8.3. DG lube oil storage requirements are administratively controlled to ensure a sufficient supply of lube oil is available onsite to support at least 7 days of DG operation, similar to the ISTS requirements. Therefore, the ACTIONS and Surveillance Requirements for lube oil are not being retained in ITS 3.8.3. The ITS 3.8.3 title and requirements have been revised, and subsequent requirements are renumbered, as required, to reflect his change.

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 13, Rev. 0, Page 225 of 496

Attachment 1, Volume 13, Rev. 0, Page 226 of 496 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

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Attachment 1, Volume 13, Rev. 0, Page 228 of 496 B 3.8.3 3

INSERT 1 However, while each storage tank is separate between the DGs of a unit, each storage tank is shared with a DG on the other unit.

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Attachment 1, Volume 13, Rev. 0, Page 235 of 496 B 3.8.3 3

INSERT 2

, an API gravity of within 0.3 degrees at 60°F when compared to the supplier's certificate, or a specific gravity of within 0.0016 at 60/60° when compared to the supplier's certificate; (2) 3 INSERT 3 or Saybolt viscosity at 100°F of > 32.6 and < 40.1, if gravity was not determined by comparison with supplier's certification, when tested in accordance with ASTM 975-81 (Ref. 5) 3 INSERT 4 when tested in accordance with ASTM D975-81 (Ref. 5);

6 INSERT 5 within 31 days following addition of the new fuel oil to the fuel oil storage tank(s)

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Attachment 1, Volume 13, Rev. 0, Page 238 of 496 JUSTIFICATION FOR DEVIATIONS ITS 3.8.3 BASES, DIESEL FUEL OIL

1. Changes are made to the Bases to reflect changes made to the Specifications.

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

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. Editorial change made for enhanced clarity.

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

6. Changes are made to the Bases to reflect the actual Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 238 of 496

Attachment 1, Volume 13, Rev. 0, Page 239 of 496 Specific No Significant Hazards Considerations (NSHCs)

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Attachment 1, Volume 13, Rev. 0, Page 240 of 496 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.3, DIESEL FUEL OIL There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 240 of 496

, Volume 13, Rev. 0, Page 241 of 496 ATTACHMENT 4 ITS 3.8.4, DC Sources - Operating , Volume 13, Rev. 0, Page 241 of 496

, Volume 13, Rev. 0, Page 242 of 496 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 13, Rev. 0, Page 242 of 496

Attachment 1, Volume 13, Rev. 0, Page 243 of 496 ITS 3.8.4 ITS A.1 LA.1 See ITS electrical power subsystems 3.8.9 LCO 3.8.4.a See ITS B 3.8.9 LA.1 See ITS A

3.8.9 LA.1 Add proposed LCO 3.8.4.c A.2 See ITS 3.8.9 L.1 ACTIONS A and B ACTION C Add proposed ACTION E A.2 Add proposed SR Notes 1 and 2 M.1 See ITS 3.8.9 SR 3.8.4.1 See ITS 3.8.6 to the L.5 SR 3.8.4.1 minimum established float voltage Add proposed SR 3.8.4.4 M.1 Page 1 of 12 Attachment 1, Volume 13, Rev. 0, Page 243 of 496

Attachment 1, Volume 13, Rev. 0, Page 244 of 496 ITS 3.8.4 ITS A.1 See ITS 3.8.6 24 L.2 SR 3.8.4.2 L.3 SR 3.8.4.2 L.2 24 A.3 SR 3.8.4.3 L.4 LA.2 See ITS 3.8.6 Note 1 to SR 3.8.4.3 See ITS 3.8.6 Page 2 of 12 Attachment 1, Volume 13, Rev. 0, Page 244 of 496

Attachment 1, Volume 13, Rev. 0, Page 245 of 496 ITS 3.8.4 ITS A.1 Page 3 of 12 Attachment 1, Volume 13, Rev. 0, Page 245 of 496

Attachment 1, Volume 13, Rev. 0, Page 246 of 496 ITS 3.8.4 ITS A.1 LA.1 electrical power subsystems See ITS LCO 3.8.4.b 3.8.9 LA.1 ACTION D A.4 See ITS 3.8.9 SR 3.8.4.1 See ITS 3.8.6 to the minimum L.5 SR 3.8.4.1 established float voltage See ITS 3.8.6 Page 4 of 12 Attachment 1, Volume 13, Rev. 0, Page 246 of 496

Attachment 1, Volume 13, Rev. 0, Page 247 of 496 ITS 3.8.4 ITS A.1 24 L.2 SR 3.8.4.2 L.3 SR 3.8.4.2 L.2 24 A.3 SR 3.8.4.3 L.4 LA.2 See ITS 3.8.6 Note 1 to SR 3.8.4.3 See ITS 3.8.6 Page 5 of 12 Attachment 1, Volume 13, Rev. 0, Page 247 of 496

Attachment 1, Volume 13, Rev. 0, Page 248 of 496 ITS 3.8.4 ITS A.1 Page 6 of 12 Attachment 1, Volume 13, Rev. 0, Page 248 of 496

Attachment 1, Volume 13, Rev. 0, Page 249 of 496 ITS 3.8.4 ITS A.1 LA.1 See ITS electrical power subsystems 3.8.9 LCO 3.8.4.a See ITS B 3.8.9 LA.1 A See ITS 3.8.9 LA.1 Add proposed LCO 3.8.4.c A.2 See ITS 3.8.9 L.1 ACTIONS A and B ACTION C Add proposed ACTION E A.2 Add proposed SR Notes 1 and 2 M.1 See ITS 3.8.9 SR 3.8.4.1 See ITS 3.8.6 to the L.5 SR 3.8.4.1 minimum established float voltage Add proposed SR 3.8.4.4 M.1 Page 7 of 12 Attachment 1, Volume 13, Rev. 0, Page 249 of 496

Attachment 1, Volume 13, Rev. 0, Page 250 of 496 ITS 3.8.4 ITS A.1 See ITS 3.8.6 24 L.2 SR 3.8.4.2 L.3 SR 3.8.4.2 L.2 24 SR 3.8.4.3 A.3 L.4 LA.2 See ITS 3.8.6 Note 1 to SR 3.8.4.3 See ITS 3.8.6 Page 8 of 12 Attachment 1, Volume 13, Rev. 0, Page 250 of 496

Attachment 1, Volume 13, Rev. 0, Page 251 of 496 ITS 3.8.4 ITS A.1 Page 9 of 12 Attachment 1, Volume 13, Rev. 0, Page 251 of 496

Attachment 1, Volume 13, Rev. 0, Page 252 of 496 ITS 3.8.4 ITS A.1 LA.1 electrical power subsystems See ITS LCO 3.8.4.b 3.8.9 LA.1 ACTION D A.4 See ITS 3.8.9 SR 3.8.4.1 See ITS 3.8.6 to the minimum L.5 SR 3.8.4.1 established float voltage See ITS 3.8.6 Page 10 of 12 Attachment 1, Volume 13, Rev. 0, Page 252 of 496

Attachment 1, Volume 13, Rev. 0, Page 253 of 496 ITS 3.8.4 ITS A.1 24 L.2 SR 3.8.4.2 L.3 SR 3.8.4.2 L.2 24 A.3 SR 3.8.4.3 L.4 LA.2 See ITS 3.8.6 Note 1 to SR 3.8.4.3 See ITS 3.8.6 Page 11 of 12 Attachment 1, Volume 13, Rev. 0, Page 253 of 496

Attachment 1, Volume 13, Rev. 0, Page 254 of 496 ITS 3.8.4 ITS A.1 Page 12 of 12 Attachment 1, Volume 13, Rev. 0, Page 254 of 496

Attachment 1, Volume 13, Rev. 0, Page 255 of 496 DISCUSSION OF CHANGES ITS 3.8.4, DC SOURCES - OPERATING 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 3.8.2.3 only provides requirements for the unit DC Sources; it does not provide any requirements for the opposite unit DC Sources. CTS LCO 3.7.4.1 requires two independent essential service water loops to be OPERABLE. The CTS 3/4.7.4 Bases state that the LCO also ensures that an inoperable opposite unit ESW pump does not result in flow being diverted from an OPERABLE unit ESW pump sharing the same header. Therefore, if the header between the two units is not isolated, both ESW pumps on the same header support both units.

The CTS definition of OPERABILITY requires all attendant equipment (including both the normal and emergency electrical power sources) to be capable of performing its required function. Thus, the opposite unit DC Sources may be required to be OPERABLE. In addition, this would require declaring the affected ESW train inoperable when an associated opposite unit DC Source is inoperable.

ITS LCO 3.8.4.c requires opposite unit Train A and Train B 250 VDC electrical power subsystems capable of supplying the opposite unit Essential Service Water (ESW) components required by LCO 3.7.8, "Essential Service Water (ESW) System," to be OPERABLE. Also, ITS 3.8.4 ACTION E has been added and covers the situation when a required opposite unit Train A or Train B or both electrical power subsystems are inoperable. ITS 3.8.4 ACTION E requires the immediate declaration that the associated ESW train(s) are inoperable. This changes the CTS by providing an explicit LCO and ACTION for the opposite unit Train A and B 250 VDC Sources.

The purpose of ITS LCO 3.8.4.c is to ensure the appropriate DC Sources are available to support the ESW System when the ESW System headers between the units are not isolated. This change is acceptable because safety related equipment is shared between both units when an ESW header between the two units is open. The added LCO requirement is consistent with the CTS since the definition of OPERABLE - OPERABILITY requires all attendant equipment to be capable of performing its required function, and the added ACTION is also consistent with the CTS. This change is designated as administrative because the CTS requirements remain unchanged.

A.3 CTS 4.8.2.3.2.d requires the performance of a battery service test on the Train A and Train B batteries. CTS 4.8.2.5.2.d requires the performance of a battery service test on the Train N battery. These tests must be performed during shutdown (MODES 5 or 6). ITS SR 3.8.4.3 requires the verification that the battery capacity is adequate to supply, and maintain in OPERABLE status, the required emergency loads for the design duty cycle when subjected to a battery service test. Note 2 to ITS SR 3.8.4.3 specifies that this Surveillance shall not normally be performed in MODE 1, 2, 3, or 4. In addition, Note 2 states that CNP Units 1 and 2 Page 1 of 8 Attachment 1, Volume 13, Rev. 0, Page 255 of 496

Attachment 1, Volume 13, Rev. 0, Page 256 of 496 DISCUSSION OF CHANGES ITS 3.8.4, DC SOURCES - OPERATING credit may be taken for unplanned events that satisfy this SR. This changes the CTS by adding the allowance that credit may be taken for unplanned events that satisfy the associated SR. Additional changes to CTS 4.8.2.3.2.d and CTS 4.8.2.5.2.d are discussed in DOC L.4.

The ITS Note clearly presents the allowance of the current practice of taking credit for unplanned events, provided the necessary data is obtained. This change is designated as administrative because it does not result in technical changes to the CTS.

A.4 CTS 3.8.2.5 Action states that with the Train N 250 VDC battery and/or its charger inoperable, to declare the turbine driven auxiliary feedwater pump inoperable "and follow the Action statement of Specification 3.7.1.2." ITS 3.8.4 ACTION D covers the situation when the Train N 250 VDC electrical power subsystem is inoperable. ITS 3.8.4 Required Action D.1 is to immediately declare the turbine driven auxiliary feedwater train inoperable. This changes the CTS by deleting the detail to follow the Action statement of Specification 3.7.1.2.

The purpose of the CTS 3.8.2.5 Action to follow the Action Statement of Specification 3.7.1.2 is to alert the user of the appropriate Specification to enter when the turbine driven auxiliary feedwater train is declared inoperable. It is an ITS convention to not include these types of cross-references. This change is designated as administrative as it incorporates an ITS convention with no technical change to the CTS.

MORE RESTRICTIVE CHANGES M.1 CTS 4.8.2.3.2 specifies the DC Source Surveillance requirements associated with the given unit. It does not explicitly specify the Surveillance Requirements for the DC Sources associated with the opposite unit. CTS LCO 3.7.4.1 requires two independent essential service water loops to be OPERABLE. The CTS 3/4.7.4 Bases state that the LCO also ensures that an inoperable opposite unit ESW pump does not result in flow being diverted from an OPERABLE unit ESW pump sharing the same header. Therefore, if the header between the two units is not isolated, both ESW pumps on the same header support both units.

The CTS definition of OPERABLE - OPERABILITY requires all attendant equipment (including both the normal and emergency electrical power sources) to be capable of performing its required function. However, there are no specific requirements in the CTS requiring testing of the opposite unit DC Sources. ITS LCO 3.8.4.c requires opposite unit Train A and Train B 250 VDC electrical power subsystem(s) capable of supplying the opposite unit ESW components required by LCO 3.7.8, "Essential Service Water (ESW) System," to be OPERABLE. This change is discussed in DOC A.2. An explicit Surveillance Requirement has been added (ITS SR 3.8.4.4) that requires certain Surveillance Requirements to be met for the opposite unit 250 VDC Sources. This Surveillance specifies that the opposite unit Train A and Train B 250 VDC electrical power subsystem SRs are applicable. Two Notes have been added to the Surveillance Table to clarify which Surveillances apply to the unit DC Sources and which are applicable to the opposite unit DC Sources. This changes the CTS by adding explicit Surveillance Requirements for these opposite unit 250 VDC Sources.

CNP Units 1 and 2 Page 2 of 8 Attachment 1, Volume 13, Rev. 0, Page 256 of 496

Attachment 1, Volume 13, Rev. 0, Page 257 of 496 DISCUSSION OF CHANGES ITS 3.8.4, DC SOURCES - OPERATING The purpose of Surveillance Requirements is to ensure the OPERABILITY of required equipment. An explicit SR (ITS SR 3.8.4.4) has been added which requires the opposite unit DC Sources SRs to be applicable. The added Surveillance helps to ensure the required opposite unit 250 VDC electrical power subsystems remain OPERABLE. This change is designated as more restrictive because an additional Surveillance Requirement will be applicable 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 3.8.2.3 states that DC bus trains AB and CD shall be energized and OPERABLE with tie breakers between bus trains open. The details of what constitutes Train AB and Train CD are also listed. Train AB consists of 250 VDC bus AB, 250 VDC battery bank No. 1AB (Unit 1) and 2AB (Unit 2), and a full capacity charger. Train CD consists of 250 VDC bus CD, 250 VDC battery bank No. 1CD (Unit 1) and 2CD (Unit 2), and a full capacity charger. CTS 3.8.2.5 states that DC bus Train N shall be energized and OPERABLE. The details of what constitutes the N train are also listed. Train N consists of the 250 VDC bus N, 250 VDC battery bank N, and a full capacity charger. ITS LCO 3.8.4 requires the DC electrical power subsystems to be OPERABLE, which include the Train A and Train B 250 VDC electrical power subsystems (LCO 3.8.4.a), and the Train N 250 VDC electrical power subsystem (LCO 3.8.4.b). This changes the CTS by moving the details of the components of the DC Sources (battery and charger) from the CTS to the Bases. The 250 VDC buses are part of the Distribution System Specification (ITS 3.8.9) and all aspects of the buses are addressed in ITS 3.8.9.

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 OPERABILITY statement for the Train A and Train B 250 VDC electrical power subsystems and the Train N 250 VDC electrical power subsystem. 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 4.8.2.3.2.d requires the performance of a battery service test on the Train A and Train B batteries. CTS 4.8.2.5.2.d requires the performance of a battery service test on the Train N battery. Each of these Surveillance Requirements specifies that the battery charger must be CNP Units 1 and 2 Page 3 of 8 Attachment 1, Volume 13, Rev. 0, Page 257 of 496

Attachment 1, Volume 13, Rev. 0, Page 258 of 496 DISCUSSION OF CHANGES ITS 3.8.4, DC SOURCES - OPERATING disconnected throughout the test. ITS SR 3.8.4.3 requires the verification that the battery capacity is adequate to supply, and maintain in OPERABLE status, the required emergency loads for the design duty cycle when subjected to a battery service test. This changes the CTS by moving details concerning the status of the battery charger (disconnected throughout the test) from the CTS to the ITS Bases.

The removal of these details for performing Surveillance Requirements from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement to perform the battery service test on the Train A, Train B, and Train N batteries.

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 to the ITS Bases.

LESS RESTRICTIVE CHANGES L.1 (Category 4 - Relaxation of Required Action) CTS 3.8.2.3 Action b states that with one Train A or Train B 250 VDC battery and/or its charger inoperable, to restore the inoperable battery and/or charger to OPERABLE status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . ITS 3.8.4 ACTION A has been added which covers the condition for one required Train A or Train B battery charger inoperable. ITS 3.8.4 Required Action A.1 requires the restoration of the battery terminal voltage to greater than or equal to the minimum established float voltage within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . ITS 3.8.4 Required Action A.2 requires the verification that the battery float current is

< 2 amps once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and ITS 3.8.4 Required Action A.3 requires the restoration of the battery charger to OPERABLE status within 7 days. This changes the CTS by extending the time a required battery charger may be inoperable.

The purpose of CTS 3.8.2.3 is to ensure that the Train A and Train B DC Sources are capable of supplying the associated loads during a design bases accident. 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 proposed ITS 3.8.4 ACTION A provides a 7 day restoration time for an inoperable Train A or Train B battery charger. However, this time is contingent on a focused and tiered approach to assuring adequate battery capability is maintained. The first priority for the operator is to minimize the battery discharge, CNP Units 1 and 2 Page 4 of 8 Attachment 1, Volume 13, Rev. 0, Page 258 of 496

Attachment 1, Volume 13, Rev. 0, Page 259 of 496 DISCUSSION OF CHANGES ITS 3.8.4, DC SOURCES - OPERATING which is required to be terminated within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months (ITS 3.8.4 Required Action A.1).

Presuming that the battery discharge (if occurring) can be terminated and that the DC bus remains energized (as required by a separate LCO), there is reasonable basis for extending the restoration time for an inoperable charger beyond the 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months limit. The second tiered action proposes 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to establish that the battery has sufficient capacity to perform its assumed duty cycle (which may involve some recharging of lost capacity that occurred during the initial hours). Given the choice of a unit shutdown in this condition (as currently required) versus a 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months determination (at the end of which it is reasonable to assume the battery can be shown to have its assumed capacity) followed by a 7 day restoration period, this appears to be an acceptable relaxation. Since the focus of this allowance is that battery capacity be preserved and assured, the means of accomplishing this may be to utilize the spare battery charger that could be employed within the initial 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , while in other cases it may be the degraded inservice charger that can continue to float the battery. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L.2 (Category 10 - 18 to 24 Month Surveillance Frequency Change, Non-Channel Calibration Type) CTS 4.8.2.3.2.c.3 requires the verification that the required Train A and Train B battery chargers will supply at least 300 amperes at greater than or equal to 250 VDC for at least 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . CTS 4.8.2.3.2.d requires the performance of a battery service test on the Train A and Train B batteries by verifying that the battery capacity is adequate to supply and maintain in OPERABLE status the actual or simulated emergency loads for the design duty cycle. CTS 4.8.2.5.2.c.3 requires the verification that the Train N battery charger will supply at least 25 amperes at greater than or equal to 250 VDC for at least 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . CTS 4.8.2.5.2.d requires the performance of a battery service test on the Train N battery by verifying that the battery capacity is adequate to supply and maintain in OPERABLE status the actual or simulated emergency loads for the design duty cycle. The Frequency of performance of these Surveillances is every 18 months. ITS SR 3.8.4.2 requires the verification that each required Train A and Train B battery charger supplies > 300 amps and the required Train N battery charger supplies > 25 amps at > 250 VDC for > 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . ITS SR 3.8.4.3 requires the verification that the battery capacity is adequate to supply, and maintain in OPERABLE status, the required emergency loads for the design duty cycle when subjected to a battery service test. The Frequency of testing of ITS SR 3.8.4.2 and ITS SR 3.8.4.3 is once 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 4.8.2.3.2.c.3 and CTS 4.8.2.5.2.c.3 is to ensure the associated battery chargers can perform their associated design function. The purpose of CTS 4.8.2.3.2.d and CTS 4.8.2.5.2.d is to ensure the batteries can perform their associated design function. This change was evaluated in accordance with the guidance provided in NRC Generic Letter No. 91-04, "Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel Cycle," dated April 2, 1991. Reviews of historical surveillance CNP Units 1 and 2 Page 5 of 8 Attachment 1, Volume 13, Rev. 0, Page 259 of 496

Attachment 1, Volume 13, Rev. 0, Page 260 of 496 DISCUSSION OF CHANGES ITS 3.8.4, DC SOURCES - OPERATING 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 charger test and the battery service test is acceptable because the battery and charger are checked during the cycle by ensuring the battery terminal voltage is greater than or equal to the minimum established float voltage. Additional justification for extending the Surveillance test interval is that the 250 VDC Sources are designed to be single failure proof, therefore ensuring system availability in the event of a failure of a 250 VDC 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.3 (Category 5 - Deletion of Surveillance Requirement) CTS 4.8.2.3.2.c.1, for the Train A and Train B batteries, and CTS 4.8.2.5.2.c.1, for the Train N battery, require the verification that the cells, cell plates and battery racks show no visual indication of physical damage or abnormal deterioration that could degrade battery performance. CTS 4.8.2.3.2.c.2, for the Train A and Train B batteries, and CTS 4.8.2.5.2.c.2, for the Train N battery, require the removal of visible corrosion and verifying that the cell-to-cell and terminal connections are clean, tight, and coated with anti-corrosion material. ITS 3.8.4 does not include these requirements for battery inspections, the removal of visible corrosion, and the verification that the cell-to-cell and terminal connections are clean, tight, and coated with anti-corrosion material. This changes the CTS by deleting the explicit battery requirements from the Technical Specifications.

The purpose of CTS 4.8.2.3.2.c.1 and CTS 4.8.2.3.2.c.2, for the Train A and Train B batteries, and CTS 4.8.2.5.2.c.1 and CTS 4.8.2.5.2.c.2, for the Train N battery, is to ensure that the proper preventative maintenance type of battery activities are performed. In accordance with ITS SR 3.0.1, when any SR is not met, the LCO is not met. This is based on the premise that SRs represent the minimum acceptable requirements for OPERABILITY of the required equipment.

However, the failure to meet these specific Surveillances do not necessarily mean that the equipment is not capable of performing its safety function. When the Train A and Train B batteries are capable of meeting ITS SR 3.8.4.1, the battery terminal voltage verification and ITS SR 3.8.4.3, the battery capacity test, they are considered to be able to meet their safety function. This also applies to the equivalent Train N SRs. The Surveillances that are proposed to be deleted are considered preventative maintenance type activities and are not considered the minimum acceptable requirements for OPERABILITY of the batteries. This change is acceptable because the SR requirements proposed in ITS 3.8.4 continue to ensure that the batteries are maintained consistent with the safety analyses and licensing basis. In addition, ITS 5.5.15 "Battery Monitoring and Maintenance Program," requires a program for battery maintenance based on CNP Units 1 and 2 Page 6 of 8 Attachment 1, Volume 13, Rev. 0, Page 260 of 496

Attachment 1, Volume 13, Rev. 0, Page 261 of 496 DISCUSSION OF CHANGES ITS 3.8.4, DC SOURCES - OPERATING the recommendations of IEEE 450-1995. The requirement to perform these battery preventative maintenance activities are consistent with IEEE 450-1995, and as such, will be maintained in the CNP procedures implementing ITS 5.5.15.

This change is designated as less restrictive because Surveillances which are required in the CTS will not be required in the ITS.

L.4 (Category 12 - Deletion of Surveillance Requirement Shutdown Performance Requirements) CTS 4.8.2.3.2.d requires the performance of a battery service test on the Train A and Train B batteries. CTS 4.8.2.5.2.d requires the performance of a battery service test on the Train N battery. These tests must be performed during shutdown (MODES 5 or 6). ITS SR 3.8.4.3 requires the verification that the battery capacity is adequate to supply, and maintain in OPERABLE status, the required emergency loads for the design duty cycle when subjected to a battery service test. Note 2 to ITS SR 3.8.4.3 specifies that this Surveillance shall not normally be performed in MODE 1, 2, 3, or 4. However, portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the unit is maintained or enhanced. This changes the CTS by allowing the test to be performed in MODES other than MODE 5 or 6 as long as an assessment determines the safety of the unit is maintained or enhanced.

The purpose of the shutdown restrictions in CTS 4.8.2.3.2.d and CTS 4.8.2.5.2.d is to ensure the batteries are not tested in a condition that may compromise unit safety. 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 strict 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.

L.5 (Category 6 - Relaxation Of Surveillance Requirement Acceptance Criteria)

CTS 4.8.2.3.2.a.4 requires the Train A and Train B 250 VDC batteries to have an overall voltage of greater than or equal to 250 VDC. CTS 4.8.2.5.2.a.4 requires the Train N 250 VDC battery overall voltage to be greater than or equal is 250 VDC. ITS SR 3.8.4.1 requires the verification that the battery terminal voltage is greater than or equal to the minimum established float voltage. This changes the CTS by deleting the actual value for the minimum overall battery voltage.

The purpose of CTS 4.8.2.3.2.a.4 and 4.8.2.5.2.a.4 is to help ensure the effectiveness of the batteries to perform their intended function. This change is acceptable because it has been determined that the relaxed Surveillance Requirement acceptance criteria are not necessary for verification that the equipment used to meet the LCO can perform its required functions. This changes the CTS by deleting the actual battery terminal voltage limit (250 VDC) and replacing it with the minimum established design limit. This change is acceptable since the proposed value will continue to ensure that the battery CNP Units 1 and 2 Page 7 of 8 Attachment 1, Volume 13, Rev. 0, Page 261 of 496

Attachment 1, Volume 13, Rev. 0, Page 262 of 496 DISCUSSION OF CHANGES ITS 3.8.4, DC SOURCES - OPERATING remains OPERABLE to perform its specified safety function. 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 8 of 8 Attachment 1, Volume 13, Rev. 0, Page 262 of 496

Attachment 1, Volume 13, Rev. 0, Page 263 of 496 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 13, Rev. 0, Page 263 of 496

, Volume 13, Rev. 0, Page 264 of 496 , Volume 13, Rev. 0, Page 264 of 496

Attachment 1, Volume 13, Rev. 0, Page 265 of 496 3.8.4 1

INSERT 1 LCO 3.8.2.3 a. Train A and Train B 250 VDC electrical power subsystems; LCO 3.8.2.5

b. Train N 250 VDC electrical power subsystem; and DOC A.2 c. Unit 2 (Unit 1) and Unit 1 (Unit 2) Train A and Train B 250 VDC electrical power subsystems capable of supplying the Unit 2 (Unit 1) and Unit 1 (Unit 2) Essential Service Water System components required by LCO 3.7.8, Essential Service Water (ESW) System.

1 INSERT 2

-NOTE-Train N 250 VDC electrical power subsystem is not required to be OPERABLE in MODE 4.

1 INSERT 3 3.8.2.5 Action D. Train N DC electrical power D.1 Declare the Immediately subsystem inoperable. turbine driven auxiliary feedwater train inoperable.

DOC A.2 E. One or both required Unit 2 (Unit E.1 Declare the Immediately

1) and Unit 1 (Unit 2) Train A associated and Train B electrical power ESW train(s) subsystems inoperable. inoperable.

Insert Page 3.8.4-1 Attachment 1, Volume 13, Rev. 0, Page 265 of 496

, Volume 13, Rev. 0, Page 266 of 496 , Volume 13, Rev. 0, Page 266 of 496

Attachment 1, Volume 13, Rev. 0, Page 267 of 496 3.8.4 1

INSERT 4

-NOTES-DOC M.1 1. SR 3.8.4.1 though SR 3.8.4.3 are applicable only to Unit 1 (Unit 1) and Unit 2 (Unit 2) DC electrical power subsystems.

2. SR 3.8.4.4 is applicable only to the required Unit 2 (Unit 1) and Unit 1 (Unit 2) DC electrical power subsystem(s).

1 3 INSERT 4A required Train A and Train B 1 3 INSERT 4B and the required Train N battery charger supplies > 25 amps 5

INSERT 5 Credit may be taken for unplanned events that satisfy this SR.

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Attachment 1, Volume 13, Rev. 0, Page 268 of 496 3.8.4 1 INSERT 6 DOC M.1 SR 3.8.4.4 ---------------------------------------------------------------

-NOTE-When Unit 2 (Unit 1) and Unit 1 (Unit 2) is in MODE 5 or 6, or moving irradiated fuel assemblies in the containment or auxiliary building, the following Unit 2 (Unit 1) and Unit 1 (Unit 2) SRs are not required to be performed:

SR 3.8.4.3.

For the Unit 2 (Unit 1) and Unit 1 (Unit 2) Train In accordance with A and Train B 250 VDC electrical power applicable SRs subsystems, the SRs of the Unit 2 (Unit 1) and Unit 1 (Unit 2) Specification 3.8.4 are applicable.

Insert Page 3.8.4-2b Attachment 1, Volume 13, Rev. 0, Page 268 of 496

Attachment 1, Volume 13, Rev. 0, Page 269 of 496 JUSTIFICATION FOR DEVIATIONS ITS 3.8.4, DC SOURCES - OPERATING

1. Additional requirements were added to ISTS LCO 3.8.4 to ensure the appropriate DC Sources are OPERABLE during unit operation in MODES 1, 2, 3 and 4. The new requirements were added as LCO 3.8.4.b and LCO 3.8.4.c. LCO 3.8.4.b and the Applicability Note have been added to reflect existing requirements associated with the Train N 250 VDC Source, which supports the turbine driven auxiliary feedwater train. The Applicability of this DC electrical power subsystem is consistent with the turbine driven auxiliary feedwater train. LCO 3.8.4.c has been added due to a shared system (Essential Service Water System) between both units. ITS 3.8.4 Conditions A, B, and C have been modified to apply only for Train A and Train B 250 VDC Sources. ACTION D has been added to cover the condition when the Train N 250 VDC Source is inoperable and ACTION E has been added to cover inoperabilities associated with opposite unit DC Source inoperabilities. The Required Actions are to declare the associated components inoperable. This is consistent with the current licensing basis. Two Notes have been added to the Surveillance Requirements Table and an additional Surveillance (SR 3.8.4.4) has been added to clearly define the Applicability of the Surveillances for both units and to ensure the opposite unit DC Sources are OPERABLE, when required.

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

3. The term "required" has been added since each DC Source has two battery chargers, but only one is required to be OPERABLE.

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

5. TSTF-283, Rev. 3, was approved by the NRC on April 13, 2000. However, when NUREG-1431, Rev. 2, was issued, this TSTF was not completely included.

Therefore, changes approved by TSTF-283, Rev. 3, have been made.

6. The current licensing basis battery charger design voltage output is being provided, consistent with the current value in CTS 4.8.2.3.2.c.3 and CTS 4.8.2.5.2.c.3. In addition, the alternate charger testing method is not being included, consistent with current licensing basis.

7. The bracketed ISTS 3.8.4 ACTION B has been deleted since it is not necessary.

ISTS 3.8.4 ACTION C (ITS 3.8.4 ACTION B) covers the condition of an inoperable battery. Due to this deletion, the subsequent ACTIONS have been renumbered.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 269 of 496

Attachment 1, Volume 13, Rev. 0, Page 270 of 496 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

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INSERT 1 The DC electrical power system consists of the Train A and Train B 250 VDC electrical power subsystems and the Train N 250 VDC electrical power system. Unit 2 (Unit 1) and Unit 1 (Unit 2) also has an identical set of DC electrical power subsystems. When the Essential Service Water (ESW) trains are not isolated from Unit 2 (Unit 1) and Unit 1 (Unit 2) ESW trains, the associated Unit 2 (Unit 1) and Unit 1 (Unit 2) Train A and Train B 250 VDC electrical power distribution subsystems are required to support Unit 1 (Unit

2) and Unit 2 (Unit 1) ESW operation.

1 INSERT 2 The Train N 250 VDC electrical power subsystem provides a reliable source for power and control of the turbine driven auxiliary feedwater train.

1 INSERT 2A The Trains A and B 250 VDC electrical power subsystems are also redundant.

1 INSERT 2B supplying power to the associated bus within the train 1

INSERT 3 The Train N 250 VDC source is obtained by use of one 250 VDC battery consisting of 117 lead acid cells connected in series.

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INSERT 4 The Train N 250 VDC battery has adequate storage capacity to meet the duty cycle(s) discussed in the UFSAR Section 8.3.6 (Ref. 5).

1 INSERT 5 Also, the batteries are sized to provide the minimum required voltage for essential components in the system.

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INSERT 6 The DC electrical power subsystems with a) each Train A and Train B 250 VDC subsystem consisting of one 250 VDC battery, one battery charger and the corresponding control equipment and interconnecting cabling supplying power to the associated bus within the train, b) the Train N 250 VDC subsystem consisting of one 250 VDC battery, one battery charger, and the corresponding control equipment and interconnecting cabling supplying power to the associated bus, and c) the required Unit 2 (Unit 1) and Unit 1 (Unit 2) Train A and Train B 250 VDC electrical power subsystems capable of supplying the ESW System components when required by LCO 3.7.8, Essential Service Water (ESW)

System each consisting of one 250 VDC battery, one battery charger and the corresponding control equipment and interconnecting cabling supplying power to the associated bus within the train Insert Page B 3.8.4-3 Attachment 1, Volume 13, Rev. 0, Page 276 of 496

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INSERT 7 Train A and Train B 250 VDC electrical power subsystems and the Unit 2 (Unit 1) and Unit 1 (Unit 2) Train A and Train B DC electrical power subystems 3

INSERT 8 The Train N 250 VDC electrical power subsystem is required to be OPERABLE in MODES 1, 2, and 3 to support the turbine driven auxiliary feedwater train in the event that it is called upon to function when the Main Feedwater System is lost.

4 INSERT 9 and other conditions in which DC electrical power subsystems are required Insert Page B 3.8.4-4 Attachment 1, Volume 13, Rev. 0, Page 278 of 496

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INSERT 10 Train A or Train B 250 VDC electrical power subsystem Insert Page B 3.8.4-6 Attachment 1, Volume 13, Rev. 0, Page 281 of 496

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INSERT 11 any Required Action and associated Completion Time of Condition A or B is not met 3

INSERT 12 D.1 If the Train N DC electrical power subsystem is inoperable, the Train N powered system is not capable of performing its intended function. Immediately declaring the affected supported feature, e.g., the turbine driven AFW train, inoperable allows the ACTIONS of LCO 3.7.5, "Auxiliary Feedwater System (AFW)," to apply appropriate limitations on continued reactor operation.

E.1 If one or both required Unit 2 (Unit 1) and Unit 1 (Unit 2) Train A and Train B DC electrical power subsystems are inoperable, the associated ESW train(s) are not capable of performing their intended function. Immediately declaring the affected supported feature, e.g., ESW train, inoperable allows the ACTIONS of LCO 3.7.8 to apply appropriate limitations on continued reactor operation.

3 INSERT 13 The Surveillances are modified by two Notes to clearly identify how the Surveillances apply to the Unit 1 (Unit 1) and Unit 2 (Unit 2) DC electrical power subsystems. Note 1 states that SR 3.8.4.1 through SR 3.8.4.3 are applicable only to Unit 1 (Unit 1) and Unit 2 (Unit 2) DC electrical power subsystems and Note 2 states that SR 3.8.4.4 is applicable only to the Unit 2 (Unit 1) and Unit 1 (Unit 2) DC electrical power subsystems.

These Notes are necessary since Unit 2 (Unit 1) and Unit 1 (Unit 2) DC electrical power subsystems are not required to perform all of the Surveillances associated with the Unit 2 (Unit 1) and Unit 1 (Unit 2) DC electrical power subsystems (e.g., SR 3.8.4.3 is not required to be performed on the Unit 2 (Unit 1) and Unit 1 (Unit 2) batteries under certain conditions when not in MODE 1, 2, 3, or 4 for the Train A and B batteries and MODE 1, 2, or 3 for the Train N battery).

3 INSERT 14 of the Train A and Train B batteries and 2.20 Vpc or 257.4 VDC for the Train N battery.

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INSERT 15 and the Train N battery charger is capable of supplying > 25 amps at > 250 VDC for

> 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months 1 INSERT 15A to detect significant charger failures Insert Page B 3.8.4-8 Attachment 1, Volume 13, Rev. 0, Page 285 of 496

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INSERT 16 The battery charger must be disconnected throughout the performance of the battery service test.

1 INSERT 17 based on engineering judgement, taking into consideration unit conditions required to perform the Surveillance. Operating experience has shown that these components usually pass the SR when performed at the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

7 INSERT 18 Credit may be taken for unplanned events that satisfy this SR.

3 INSERT 19 SR 3.8.4.4 With the exception of this Surveillance, all other Surveillances of this Specification (SR 3.8.4.1 through 3.8.4.3) are applied to the Unit 1 (Unit 1) and Unit 2 (Unit 2) DC sources.

This Surveillance is provided to direct that appropriate Surveillances for the required Unit 2 (Unit 1) and Unit 1 (Unit 2) DC sources are governed by the applicable Unit 2 (Unit 1) and Unit 1 (Unit 2) Technical Specifications. Performance of the applicable opposite unit Surveillances will satisfy the opposite unit requirements as well as satisfy the given unit Surveillance Requirement.

The Frequency required by the applicable Unit 2 (Unit 1) and Unit 1 (Unit 2) SR also governs performance of that SR for Unit 1 (Unit 1) and Unit 2 (Unit 2).

As noted, when Unit 2 (Unit 1) and Unit 1 (Unit 2) is in MODE 5 or 6, or moving irradiated fuel assemblies in the containment or auxiliary building, SR 3.8.4.3 is not required to be performed. This ensures that a Unit 1 (Unit 1) and Unit 2 (Unit 2) SR will not require a Unit 2 (Unit 1) and Unit 1 (Unit 2) SR to be performed, when Unit 2 (Unit 1) and Unit 1 (Unit 2) Technical Specifications exempts performance of a Unit 2 (Unit 1) and Unit 1 (Unit 2) SR (however, as stated in the Unit 2 (Unit 1) and Unit 1 (Unit 2) SR 3.8.5.1 Bases, while performance of an SR is exempted, the SR must still be met).

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Attachment 1, Volume 13, Rev. 0, Page 289 of 496 JUSTIFICATION FOR DEVIATIONS ITS 3.8.4 BASES, DC SOURCES - OPERATING

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

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

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

4. Changes are made to be consistent with the actual Specification.

5. The Reviewers Note has been deleted since it is not intended to be included in the plant specific ITS submittals.

6. Grammatical/editorial/spelling error corrected.

7. TSTF-283, Rev. 3, was approved by the NRC on April 13, 2000. However, when NUREG-1431, Rev. 2, was issued, this TSTF was not completely included.

Therefore, changes approved by TSTF-283, Rev. 3, have been made.

8. These two paragraphs have been deleted. ITS 3.8.4 ACTION A provides actions for when a battery charger is inoperable. The discussion provided in the two paragraphs is related to why a charger is inoperable if Required Action A.1 cannot be met, or if the charger is operating in the current limit mode, why Required Action A.2 might not be able to be met within the 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Completion Time. These two paragraphs are not necessary. ACTION A is applicable when a charger is inoperable; thus stating the charger is inoperable if the battery float voltage cannot be restored within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months is redundant. In addition, stating that Required Action A.2 might not be able to be met if the charger is in the current limit mode is unnecessary.

If the charger is OPERABLE and in service, then ACTION A is not applicable. Thus, Required Action A.2 does not have to be met and the discussion concerning the condition of the battery charger is moot. The remaining paragraphs in the Bases for ACTION A are sufficient to discuss the requirements of ITS 3.8.4 ACTION A.

9. 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.

10. These battery design values have been deleted, since they are more specific than necessary and are not required to provide sufficient background for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 289 of 496

Attachment 1, Volume 13, Rev. 0, Page 290 of 496 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 13, Rev. 0, Page 290 of 496

Attachment 1, Volume 13, Rev. 0, Page 291 of 496 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.4, DC SOURCES - OPERATING There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 291 of 496

, Volume 13, Rev. 0, Page 292 of 496 ATTACHMENT 5 ITS 3.8.5, DC Sources - Shutdown , Volume 13, Rev. 0, Page 292 of 496

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Attachment 1, Volume 13, Rev. 0, Page 294 of 496 ITS 3.8.5 ITS A.1 to support one train of the DC Electrical Power Distribution System required by LCO 3.8.10, M.1 Distribution Systems - Shutdown.

One power subsystem LCO 3.8.5 LA.1 See ITS 3.8.10 LA.1 A.4 Add ACTIONS Note A.2 ACTION A See ITS 3.8.10 that could result in loss of required SDM or boron concentration. L.1 See ITS 3.8.10 See ITS 3.8.10 SR 3.8.5.1 Add proposed Note to SR 3.8.5.1 L.2 Page 1 of 2 Attachment 1, Volume 13, Rev. 0, Page 294 of 496

Attachment 1, Volume 13, Rev. 0, Page 295 of 496 ITS 3.8.5 ITS A.1 to support one train of the DC Electrical Power Distribution System required by LCO 3.8.10, M.1 Distribution Systems - Shutdown.

One power subsystem LCO 3.8.5 LA.1 See ITS 3.8.10 LA.1 and during movement of irradiated fuel assemblies in the A.3 containment, auxiliary building, and Unit 1 containment Add ACTIONS Note A.2 ACTION A See ITS 3.8.10 that could result in loss of required SDM or boron concentration. L.1 See ITS 3.8.10 See ITS 3.8.10 SR 3.8.5.1 Add proposed Note to SR 3.8.5.1 L.2 Page 2 of 2 Attachment 1, Volume 13, Rev. 0, Page 295 of 496

Attachment 1, Volume 13, Rev. 0, Page 296 of 496 DISCUSSION OF CHANGES ITS 3.8.5, DC SOURCES - SHUTDOWN 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 3.8.2.4 (Unit 1) is applicable during MODES 5 and 6, and during the movement of irradiated fuel. CTS 3.8.2.4 (Unit 2) is applicable only during MODES 5 and 6, however CTS 3.8.2.4 Action a (Unit 2) requires movement of irradiated fuel assemblies to be suspended if the required DC electrical equipment is inoperable. ITS 3.8.5 is applicable in MODES 5 and 6, and during the movement of irradiated fuel assemblies in the containment, auxiliary building, and Unit 2 (Unit 1) and Unit 1 (Unit 2) containment. In addition, a Note has been added to the ACTIONS which states that LCO 3.0.3 is not applicable. This changes the CTS by adding the Note to the ACTIONS stating that LCO 3.0.3 is not applicable. The change to the Unit 1 Applicability is discussed in DOC A.4 and the change to the Unit 2 Applicability is discussed in DOC A.3.

The purpose of CTS 3.8.2.4 is to ensure that at least one 250 VDC battery bank and associated charger is OPERABLE to support equipment required to be OPERABLE. This change adds a clarification Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODES 5 or 6, LCO 3.0.3 is not applicable and would not specify any action. If moving irradiated fuel assemblies while in MODES 1, 2, 3, or 4, the fuel movement is independent of reactor operations and the inability to suspend movement in accordance with the ITS 3.8.5 Required Actions would not be sufficient reason to require a reactor shutdown. This Note has been added for clarification and is necessary since defaulting to LCO 3.0.3 would require the reactor to be shutdown it would not require suspension of the activities with a potential for releasing radioactive materials. This change is designated as administrative as it is a clarification of the intent of CTS LCO 3.0.3 that does not result in a technical change to the CTS.

A.3 (Unit 2 only) CTS 3.8.2.4 is applicable during MODES 5 and 6. However, CTS 3.8.2.4 Action a requires movement of irradiated fuel assemblies to be suspended if the required DC electrical equipment is inoperable. ITS 3.8.5 is applicable in MODES 5 and 6, and during the movement of irradiated fuel assemblies in the containment, auxiliary building, and Unit 1 containment. This changes the Unit 2 CTS by adding the explicit Applicability of during movement of irradiated fuel assemblies in the containment, auxiliary building, and Unit 1 containment.

The purpose of CTS 3.8.2.4 is to ensure that at least one 250 VDC battery bank and associated charger is OPERABLE to support equipment required to be OPERABLE. This change adds the explicit Applicability of during movement of irradiated fuel assemblies in the containment, auxiliary building, and Unit 1 CNP Units 1 and 2 Page 1 of 5 Attachment 1, Volume 13, Rev. 0, Page 296 of 496

Attachment 1, Volume 13, Rev. 0, Page 297 of 496 DISCUSSION OF CHANGES ITS 3.8.5, DC SOURCES - SHUTDOWN containment. This Applicability is consistent with the Applicability of Unit 1 CTS 3.8.2.4 and consistent with CTS 3.8.2.4 Action a of Unit 2, which states to suspend movement of irradiated fuel when the required 250 VDC battery bank and associated charger is inoperable. This change is designated as administrative as it is a clarification of the intent of Unit 2 CTS 3.8.2.4 that does not result in a technical change to the Unit 2 CTS.

A.4 (Unit 1 only) CTS 3.8.2.4 Applicability includes "during movement of irradiated fuel." ITS 3.8.5 Applicability includes "During movement of irradiated fuel assemblies in the containment, auxiliary building, and Unit 2 containment." This changes the Unit 1 CTS by clarifying the locations that fuel movement is taking place.

The purpose of CTS 3.8.2.4, with respect to fuel handling, is to ensure adequate DC Sources are available to power equipment required to mitigate a fuel handling accident. This protection is required during irradiated fuel movement in three locations: the unit containment, the auxiliary building, and the opposite unit containment. Therefore, for clarity, all three locations are specified in the ITS Applicability, in lieu of the current wording which just specifies irradiated fuel movement. This change is designated as administrative because it does not result in any technical changes to the Unit 1 CTS.

MORE RESTRICTIVE CHANGES M.1 CTS LCO 3.8.2.4 requires one 250 VDC battery bank and charger associated with the specified 250 VDC bus to be OPERABLE. ITS LCO 3.8.5 requires the Train A or Train B 250 VDC electrical power subsystem to be OPERABLE to support one train of the DC Electrical Power Distribution System required by LCO 3.8.10, "Distribution Systems - Shutdown." This changes the CTS by being specific as to what the required DC electrical power subsystem must be powering.

The purpose of CTS LCO 3.8.2.4 is to ensure the Train A or Train B 250 VDC electrical power subsystem is OPERABLE to support the specified 250 VDC bus.

The existing requirement of CTS LCO 3.8.2.4 is not specific as to what the 250 VDC bus must be powering. The requirement in ITS LCO 3.8.5 specifies that the DC electrical power subsystem must support one train of the DC Electrical Power Distribution System required by LCO 3.8.10, "Distribution Systems - Shutdown." This change is acceptable since the added restriction conservatively assures the required DC electrical power subsystem is capable of powering at least one required train to support equipment required by other LCOs. This change is designated as more restrictive because more explicit DC electrical power subsystem requirements are specified (i.e., supporting equipment required to be OPERABLE) in the ITS than in the CTS.

RELOCATED SPECIFICATIONS None CNP Units 1 and 2 Page 2 of 5 Attachment 1, Volume 13, Rev. 0, Page 297 of 496

Attachment 1, Volume 13, Rev. 0, Page 298 of 496 DISCUSSION OF CHANGES ITS 3.8.5, DC SOURCES - SHUTDOWN REMOVED DETAIL CHANGES LA.1 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS LCO 3.8.2.4 requires one "250 VDC battery bank and charger" associated with the specified 250 VDC bus to be OPERABLE. ITS LCO 3.8.5 requires one Train A or Train B 250 VDC electrical power subsystem to be OPERABLE to support one train of the DC Electrical Power Distribution System required by LCO 3.8.10, "Distribution Systems - Shutdown." This changes the CTS by moving the details of what constitutes the required Train A or Train B 250 VDC electrical power subsystem to the ITS Bases.

The removal of these details, which are related to system design, from the Technical Specifications, is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. ITS retains the requirement that the Train A or Train B 250 VDC electrical power subsystem to be OPERABLE to support one train of the DC Electrical Power Distribution System required by LCO 3.8.10, "Distribution Systems - Shutdown." 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 the system design is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L.1 (Category 4 - Relaxation of Required Action) CTS 3.8.2.4 Action a specifies the compensatory action for an inoperable required DC Source. One of the compensatory actions is the suspension of positive reactivity "changes except: 1) heatup or cooldown of the reactor coolant volume provided that SHUTDOWN MARGIN sufficient to accommodate the change in temperature is maintained in accordance with Specification 3.1.1.2 in MODE 5 or Specification 3.9.1 in MODE 6, and the heatup or cooldown rate is restricted to 50°F or less in any one-hour period in MODE 5, or 2) addition of water from the RWST, provided the boron concentration in the RWST is greater than or equal to the minimum required by Specification 3.1.2.7.b.2." ITS 3.8.5 Required Action A.3 requires the immediate suspension of operations involving positive reactivity "additions that could result in loss of required SDM or boron concentration." This changes the CTS compensatory actions by deleting the limitation on the heatup and cooldown rates of 50ºF or less in any one hour period in MODE 5 and allows the addition of water from any source including the RWST as long as SDM and boron concentration limitations are met.

The purpose of CTS 3.8.2.4 Action a is to suspend any positive reactivity additions that could affect the SDM of the reactor core. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair CNP Units 1 and 2 Page 3 of 5 Attachment 1, Volume 13, Rev. 0, Page 298 of 496

Attachment 1, Volume 13, Rev. 0, Page 299 of 496 DISCUSSION OF CHANGES ITS 3.8.5, DC SOURCES - SHUTDOWN 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 CTS allows two types of positive reactivity changes (heatup/cooldown and addition of water).

Heatup and cooldown of the reactor coolant volume are allowed provided SDM is sufficient to accommodate the change in temperature in accordance with CTS 3.1.1.2 in MODE 5 or CTS 3.9.1 in MODE 6. The requirements of these Specifications are included in ITS LCO 3.1.1, "SHUTDOWN MARGIN (SDM),"

and ITS LCO 3.9.1, "Boron Concentration," respectively. Therefore, there is no technical change in this portion of the change. The Bases provides the appropriate cross-reference to the appropriate LCOs. The CTS also allows positive reactivity changes by the addition of water from the RWST provided the boron concentration in the RWST is greater than or equal to the minimum required by CTS 3.1.2.7.b.2. CTS 3.1.2.7.b.2 has been relocated to the TRM as indicated in the Discussion of Changes for CTS LCO 3/4.1.2.7. CTS 3/4.1.2.7 is applicable during MODE 5 and 6 operations. The proposed Required Actions require the suspension of operations involving positive reactivity additions that could result in loss of required SDM or boron concentration. The requirements for SDM are specified in ITS LCO 3.1.1 while the requirements for boron concentration are specified in ITS LCO 3.9.1. The current and proposed actions may result in an overall reduction in SDM or RCS boron concentration, but provide acceptable margin to maintaining subcritical operation. The CTS compensatory action restricted the heatup and cooldown rates of the RCS to 50ºF or less in any one-hour period in MODE 5. This limitation has been deleted.

The proposed Required Action is to suspend operations involving positive reactivity additions that could result in loss of required SDM or boron concentration. These limitations are considered acceptable. The Bases also indicate that introduction of temperature changes including temperature increases when operating with a positive moderator temperature coefficient must be evaluated to ensure they do not result in a loss of required SDM. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L.2 (Category 7 - Relaxation Of Surveillance Frequency, Non-24 Month Type Change) CTS 4.8.2.4.2 requires the demonstration of the OPERABILITY of the 250 VDC battery and charger in accordance with the Surveillance Requirements of CTS 4.8.2.3.2. ITS SR 3.8.5.1 requires SR 3.8.4.1, SR 3.8.4.2, and SR 3.8.4.3 to be applicable. However, a Note has been added that states ITS SR 3.8.4.3 does not have to be performed. This changes the CTS by allowing a certain SR not to be performed. Changes to the Surveillances of CTS 4.8.2.3.2 are discussed in the Discussion of Changes for ITS 3.8.4, "DC Sources -

Operating."

The purpose of the ITS SR 3.8.5.1 Note is to ensure that required equipment is not made inoperable by testing when the equipment is the only OPERABLE equipment available to support unit operations. 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. ITS SR 3.8.4.3 is the battery CNP Units 1 and 2 Page 4 of 5 Attachment 1, Volume 13, Rev. 0, Page 299 of 496

Attachment 1, Volume 13, Rev. 0, Page 300 of 496 DISCUSSION OF CHANGES ITS 3.8.5, DC SOURCES - SHUTDOWN capacity test. The performance of SR 3.8.4.3 involve tests that would cause the only required OPERABLE Train A or Train B 250 VDC electrical power subsystem to be rendered inoperable. This condition presents a significant risk if an event were to occur during the test. The NRC has previously provided Surveillance exceptions in the CNP Unit 1 and Unit 2 CTS to avoid a similar condition for the AC Sources, but the exceptions have not been applied to DC Sources. In an effort to consistently address this concern, ITS SR 3.8.5.1 has a Note that excludes performance requirements of Surveillances that would require the required OPERABLE DC electrical power subsystem to be rendered inoperable. This allowance does not take exception to the requirement for the DC electrical power subsystem to be capable of performing the particular function, but just to the requirement to demonstrate that capability while that source of power is being relied on to support meeting the LCO. 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 13, Rev. 0, Page 300 of 496

Attachment 1, Volume 13, Rev. 0, Page 301 of 496 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 13, Rev. 0, Page 301 of 496

, Volume 13, Rev. 0, Page 302 of 496 , Volume 13, Rev. 0, Page 302 of 496

Attachment 1, Volume 13, Rev. 0, Page 303 of 496 3.8.5 2

INSERT 1 to support one train of the DC Electrical Power Distribution System required by LCO 3.8.10, "Distribution Systems - Shutdown."

6 INSERT 2 in the containment, auxiliary building, and Unit 2 (Unit 1) and Unit 1 (Unit 2) containment Insert Page 3.8.5-1 Attachment 1, Volume 13, Rev. 0, Page 303 of 496

, Volume 13, Rev. 0, Page 304 of 496 , Volume 13, Rev. 0, Page 304 of 496

, Volume 13, Rev. 0, Page 305 of 496 , Volume 13, Rev. 0, Page 305 of 496

Attachment 1, Volume 13, Rev. 0, Page 306 of 496 JUSTIFICATION FOR DEVIATIONS ITS 3.8.5, DC SOURCES - SHUTDOWN

1. The bracketed optional ISTS LCO 3.8.5 and Reviewers Note have been deleted since the current licensing basis only requires one DC electrical power subsystem to be OPERABLE. ISTS 3.8.5 ACTION A has been deleted since only one required DC electrical power subsystem is specified in the LCO. This allowance is only acceptable if the first option of the LCO is used. The subsequent Condition and Required Actions have been renumbered and modified, as applicable.

2. The second option of ISTS LCO 3.8.5 is not specific as to what the DC electrical power subsystem must be powering. The LCO has been modified to require the Train A or Train B 250 VDC electrical power subsystem to be powering a DC train required OPERABLE by LCO 3.8.10.

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

4. ISTS 3.8.5 Required Action B.1 provides an option to declare affected required feature(s) inoperable with one or more required DC electrical power subsystems inoperable. The ISTS Bases states that this is acceptable because the remaining train with DC power available may be capable of supporting sufficient features to allow continuation of CORE ALTERATIONS and fuel movement. Thus, this Required Action assumes two DC power sources are required by the LCO. This option has been deleted since only one Train A or Train B 250 VDC electrical power subsystem is required to be OPERABLE by the LCO. Subsequent Required Actions have been renumbered and modified, as applicable.

5. Change made to be consistent with the Writers Guide for the Improved Standard Technical Specifications, NEI 01-03.

6. The Applicability has been clarified, since CNP has two units and irradiated fuel movement can occur in three different locations.

7. The allowance to not perform SR 3.8.4.2 has been deleted. The CNP design includes two battery chargers per train. Therefore, the battery charger SR can be performed without making the train inoperable.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 306 of 496

Attachment 1, Volume 13, Rev. 0, Page 307 of 496 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 13, Rev. 0, Page 307 of 496

, Volume 13, Rev. 0, Page 308 of 496 , Volume 13, Rev. 0, Page 308 of 496

Attachment 1, Volume 13, Rev. 0, Page 309 of 496 B 3.8.5 O ~~INSERT I in the containment, auxiliary building, and Unit 2 (Unit 1) and Unit 1 (Unit 2) containment Insert Page B 3.8.5-I Attachment 1, Volume 13, Rev. 0, Page 309 of 496

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Attachment 1, Volume 13, Rev. 0, Page 311 of 496 B 3.8.5 5

INSERT 2 in the containment, auxiliary building, and Unit 2 (Unit 1) and Unit 1 (Unit 2) containment Insert Page B 3.8.5-2 Attachment 1, Volume 13, Rev. 0, Page 311 of 496

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Attachment 1, Volume 13, Rev. 0, Page 315 of 496 B 3.8.5 5

INSERT 3 With the required Train A or Train B 250 VDC electrical power subsystem inoperable, the minimum required DC power sources are not available. Therefore, suspension of 6

INSERT 4 8 7

loss of required SDM (Mode 5) specified in LCO 3.1.1, SHUTDOWN MARGIN (SDM),

or boron concentration (Mode 6) specified in LCO 3.9.1, Boron Concentration, Suspending positive reactivity additions that could result in failure to meet the minimum SDM or boron concentration limit is required to assure continued safe operation.

5 Insert Page B 3.8.5-5 Attachment 1, Volume 13, Rev. 0, Page 315 of 496

, Volume 13, Rev. 0, Page 316 of 496 , Volume 13, Rev. 0, Page 316 of 496

Attachment 1, Volume 13, Rev. 0, Page 317 of 496 JUSTIFICATION FOR DEVIATIONS ITS 3.8.5 BASES, DC SOURCES - SHUTDOWN

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

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

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

4. These punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, NEI 01-03, Section 3.2.2.

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

6. TSTF-286, Rev. 2, was approved by the NRC on April 13, 2000. However, when NUREG-1431, Rev. 2, was issued, this TSTF was not completely included.

Therefore, changes approved by TSTF-286, Rev. 2, have been made.

7. Typographical error corrected.

8. Changes made to be consistent with other places in the Bases.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 317 of 496

Attachment 1, Volume 13, Rev. 0, Page 318 of 496 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 13, Rev. 0, Page 318 of 496

Attachment 1, Volume 13, Rev. 0, Page 319 of 496 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.5, DC SOURCES - SHUTDOWN There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 319 of 496

, Volume 13, Rev. 0, Page 320 of 496 ATTACHMENT 6 ITS 3.8.6, Battery Parameters , Volume 13, Rev. 0, Page 320 of 496

, Volume 13, Rev. 0, Page 321 of 496 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 13, Rev. 0, Page 321 of 496

Attachment 1, Volume 13, Rev. 0, Page 322 of 496 ITS 3.8.6 A.1 ITS Add proposed LCO 3.8.6 A.2 See ITS 3.8.4 and 3.8.9 A.2 See ITS 3.8.9 See ITS 3.8.4 L.1 Add proposed ACTIONS A, B, C, D, E, and F See ITS 3.8.9 L.2 31 SR 3.8.6.2 L.3 Add proposed SR 3.8.6.1 M.1 L.3 L.4 2.07 SR 3.8.6.2 See ITS 3.8.4 Add proposed SR 3.8.6.4 M.1 Page 1 of 10 Attachment 1, Volume 13, Rev. 0, Page 322 of 496

Attachment 1, Volume 13, Rev. 0, Page 323 of 496 ITS 3.8.6 A.1 ITS M.2 31 days for electrolyte level L.4 2.07 SR 3.8.6.5 L.3 greater than or equal to minimum L.5 established SR 3.8.6.3 design limits See ITS 3.8.4 A.3 L.6 SR 3.8.6.6 See ITS 3.8.4 or modified performance discharge L.7 LA.1 Page 2 of 10 Attachment 1, Volume 13, Rev. 0, Page 323 of 496

Attachment 1, Volume 13, Rev. 0, Page 324 of 496 ITS 3.8.6 A.1 ITS A.2 Add proposed LCO 3.8.6 See ITS 3.8.5 and See ITS 3.8.10 3.8.10 See ITS 3.8.10 A.2 Add proposed ACTIONS A, B, C, D, E, and F L.1 See ITS 3.8.5 and 3.8.10 See ITS 3.8.10 See ITS 3.8.10 See CTS markup pages 1 of 10 and 2 of 10 Page 3 of 10 Attachment 1, Volume 13, Rev. 0, Page 324 of 496

Attachment 1, Volume 13, Rev. 0, Page 325 of 496 ITS 3.8.6 A.1 ITS Add proposed LCO 3.8.6 A.2 See ITS 3.8.4 and 3.8.9 A.2 Add proposed ACTIONS A, B, C, D, E, and F L.1 See ITS 3.8.4 and 3.8.9 See ITS 3.8.9 L.2 31 SR 3.8.6.2 L.3 Add proposed SR 3.8.6.1 M.1 L.3 2.07 L.4 SR 3.8.6.2 See ITS 3.8.4 31 days for electrolyte level M.2 L.4 2.07 SR 3.8.6.5 L.3 greater than or equal to minimum established L.5 design limits SR 3.8.6.3 Add proposed SR 3.8.6.4 M.1 Page 4 of 10 Attachment 1, Volume 13, Rev. 0, Page 325 of 496

Attachment 1, Volume 13, Rev. 0, Page 326 of 496 ITS 3.8.6 A.1 ITS See ITS 3.8.4 A.3 L.6 SR 3.8.6.6 See ITS or modified performance 3.8.4 discharge L.7 LA.1 Page 5 of 10 Attachment 1, Volume 13, Rev. 0, Page 326 of 496

Attachment 1, Volume 13, Rev. 0, Page 327 of 496 ITS 3.8.6 A.1 ITS Add proposed LCO 3.8.6 A.2 See ITS 3.8.4 and 3.8.9 A.2 See ITS 3.8.9 See ITS 3.8.4 L.1 Add proposed ACTIONS A, B, C, D, E, and F See ITS 3.8.9 L.2 31 SR 3.8.6.2 L.3 Add proposed SR 3.8.6.1 M.1 L.3 L.4 2.07 SR 3.8.6.2 See ITS 3.8.4 Add proposed SR 3.8.6.4 M.1 Page 6 of 10 Attachment 1, Volume 13, Rev. 0, Page 327 of 496

Attachment 1, Volume 13, Rev. 0, Page 328 of 496 ITS 3.8.6 A.1 ITS M.2 31 days for electrolyte level L.4 2.07 SR 3.8.6.5 L.3 greater than or equal to minimum L.5 established SR 3.8.6.3 design limits See ITS 3.8.4 A.3 L.6 SR 3.8.6.6 See ITS 3.8.4 or modified performance discharge L.7 LA.1 Page 7 of 10 Attachment 1, Volume 13, Rev. 0, Page 328 of 496

Attachment 1, Volume 13, Rev. 0, Page 329 of 496 ITS 3.8.6 A.1 ITS A.2 Add proposed LCO 3.8.6 See ITS 3.8.5 and See ITS 3.8.10 3.8.10 See ITS 3.8.5 A.2 Add proposed ACTIONS A, B, C, D, E, and F L.1 See ITS 3.8.5 and 3.8.10 See ITS 3.8.10 See ITS 3.8.10 See CTS markup pages 6 of 10 and 7 of 10 Page 8 of 10 Attachment 1, Volume 13, Rev. 0, Page 329 of 496

Attachment 1, Volume 13, Rev. 0, Page 330 of 496 ITS 3.8.6 A.1 ITS Add proposed LCO 3.8.6 A.2 See ITS 3.8.4 and 3.8.9 A.2 Add proposed ACTIONS A, B, C, D, E, and F L.1 See ITS 3.8.4 and 3.8.9 See ITS 3.8.9 L.2 31 SR 3.8.6.2 L.3 Add proposed SR 3.8.6.1 M.1 L.3 2.07 L.4 SR 3.8.6.2 See ITS 3.8.4 31 days for electrolyte level M.2 L.4 2.07 SR 3.8.6.5 L.3 L.5 greater than or equal to SR 3.8.6.3 minimum established design limits Add proposed SR 3.8.6.4 M.1 Page 9 of 10 Attachment 1, Volume 13, Rev. 0, Page 330 of 496

Attachment 1, Volume 13, Rev. 0, Page 331 of 496 ITS 3.8.6 A.1 ITS See ITS 3.8.4 A.3 L.6 SR 3.8.6.6 See ITS 3.8.4 or modified performance discharge L.7 LA.1 Page 10 of 10 Attachment 1, Volume 13, Rev. 0, Page 331 of 496

Attachment 1, Volume 13, Rev. 0, Page 332 of 496 DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS 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 3.8.2.3 is applicable during MODES 1, 2, 3, and 4. CTS 3.8.2.4 (Unit 1) is applicable during MODES 5 and 6 and during movement of irradiated fuel.

CTS 3.8.2.4 (Unit 2) is applicable during MODES 5 and 6. CTS 3.8.2.5 is applicable during MODES 1, 2, and 3. ITS LCO 3.8.6 requires the battery parameters for the Trains A, B, and N 250 VDC batteries, and opposite unit Trains A and B 250 VDC batteries to be within limits. ITS 3.8.6, which only covers the requirements for battery parameters, is applicable when the associated DC electrical power subsystems are required to be OPERABLE. This changes the CTS by combining the requirements for the Train A, B, and N 250 VDC battery parameters into one Specification and replacing the actual MODES with the phrase "When associated DC electrical power subsystems are required to be OPERABLE."

The purpose of ITS 3.8.6 is to cover the battery parameter requirements for the Trains A, B, and N 250 VDC batteries in one Specification. This change combines the CTS 3.8.2.3, 3.8.2.4, and 3.8.2.5 requirements for the Trains A, B, and N 250 VDC battery parameters into one Specification. There are no technical changes as a result of this change since it simply converts the Specifications into the format of the ITS. The proposed Applicability ensures the battery parameter requirements are met when the associated battery is required to be OPERABLE. Any technical changes to the battery parameters are discussed below. Any changes to the LCO and Applicability of the Trains A, B, and N 250 VDC, and opposite unit Trains A and B 250 VDC batteries are discussed in the Discussion of Changes for ITS 3.8.4 and 3.8.5. This change is designated as administrative because it does not result in technical changes to the CTS.

A.3 CTS 4.8.2.3.2.e requires the performance test of battery capacity on the Trains A and B 250 VDC batteries. CTS 4.8.2.5.2.e requires the performance test of battery capacity on the Train N 250 VDC battery. These tests must be performed during shutdown (MODES 5 or 6). ITS SR 3.8.6.6 requires the same test, but a Note to SR 3.8.6.6 specifies that this Surveillance shall not normally be performed in MODE 1, 2, 3, or 4. In addition, the Note states that credit may be taken for unplanned events that satisfy this SR. This changes the CTS by adding the allowance that credit may be taken for unplanned events that satisfy the associated SR. Additional changes to CTS 4.8.2.3.2.e and CTS 4.8.2.5.2.e are discussed in DOC L.6.

The ITS Note clearly presents the allowance of the current practice of taking credit for unplanned events, provided the necessary data is obtained. This CNP Units 1 and 2 Page 1 of 8 Attachment 1, Volume 13, Rev. 0, Page 332 of 496

Attachment 1, Volume 13, Rev. 0, Page 333 of 496 DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS change is designated as administrative because it does not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES M.1 CTS 4.8.2.3.2 specifies the Surveillances for the Trains A and B 250 VDC batteries while the unit is operating and CTS 4.8.2.4.2 specifies the Surveillances for the Trains A and B 250 VDC batteries during shutdown. CTS 4.8.2.5.2 specifies the Surveillances for the Train N 250 VDC battery. ITS 3.8.6 adds two new Surveillances. ITS SR 3.8.6.1 requires the verification every 7 days that each battery float current is < 2 amps. ITS SR 3.8.6.4 requires the verification every 31 days that each battery pilot cell temperature is greater than or equal to the minimum established design limits. This changes the CTS by adding explicit Surveillances for battery float current and pilot cell temperature.

The purpose of SR 3.8.6.1 is to assist in the determination of the state of charge of the battery while the purpose of SR 3.8.6.4 is to ensure the pilot cell electrolyte temperature is maintained above the limit to assure the battery can provide the required current and voltage to meet the design requirements. The specified float current is based on the float current that is indicative of a charged battery.

Temperatures lower than assumed in battery sizing calculations act to inhibit or reduce battery capacity. These Surveillances are consistent with IEEE 450-1995. This change is acceptable since the Surveillances are necessary to help ensure the batteries remain OPERABLE. This change is designated as more restrictive because explicit Surveillance Requirements have been added.

M.2 CTS 4.8.2.3.2.b.3 and CTS 4.8.2.5.2.b.3 require verification that electrolyte level of each battery connected cell be within limit every 92 days. ITS SR 3.8.6.3 requires verification of each battery connected cell electrolyte level is greater than or equal to the established limit every 31 days. This changes the CTS by increasing the Frequency of performance of the Surveillances from 92 days to 31 days.

The purpose of CTS 4.8.2.3.2.b.3 and CTS 4.8.2.5.2.b.3 is to ensure the electrolyte level is within the specified limit to ensure the battery plates suffer no physical damage and maintains adequate electron transfer capability. The applicable IEEE 450-1995 standard recommends a Surveillance Frequency of 31 days. The change is acceptable since it will help ensure the battery plates will not suffer physical damage and maintain adequate electron transfer capability.

This change is designated as more restrictive because the Surveillance Requirement Frequency has been increased.

RELOCATED SPECIFICATIONS None CNP Units 1 and 2 Page 2 of 8 Attachment 1, Volume 13, Rev. 0, Page 333 of 496

Attachment 1, Volume 13, Rev. 0, Page 334 of 496 DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS REMOVED DETAIL CHANGES LA.1 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 4.8.2.3.2.e and CTS 4.8.2.5.2.e require the performance of a battery performance test. The Surveillance requires a more frequent performance if the battery shows signs of "degradation" or has reached 85% of the service life expected for the application. The CTS further states that degradation is indicated when the battery capacity drops more than 10% from its capacity on the previous performance test, or is below 90% of the manufacturers rating. ITS SR 3.8.6.6 requires verification of the battery capacity when subjected to a performance discharge test or a modified performance discharge test. The Surveillance is also required more frequently when the battery shows degradation or has reached 85% of the expected life, but the definition of what constitutes "degradation" is not included. This changes the CTS by moving the detail on how degradation is determined from the CTS to the ITS Bases.

The removal of these details, which are related to system design, from the Technical Specifications, is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. ITS SR 3.8.6.6 retains the requirement to verify the battery capacity when subjected to a performance discharge test or a modified performance discharge test. The Surveillance also requires more frequent performance when the battery shows degradation or has reached 85%

of the expected life. This change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5.

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

LESS RESTRICTIVE CHANGES L.1 (Category 4 - Relaxation of Required Action) CTS 3.8.2.3 Action b specifies the compensatory actions for inoperable batteries associated with the Trains A and B 250 VDC electrical power subsystem during MODES 1, 2, 3, and 4. The compensatory action requires restoration within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months before commencing a reactor shutdown. CTS 3.8.2.4 Actions a and b specify the compensatory actions for inoperable batteries associated with the Trains A and B 250 VDC electrical power subsystem during MODES 5 and 6, and (for Unit 1 only) during movement of irradiated fuel. The compensatory actions require immediate actions to suspend certain activities and to commence actions to restore the inoperable equipment to OPERABLE status. CTS 3.8.2.5 Action specifies the compensatory actions for the battery associated with the Train N 250 VDC electrical power subsystem during MODES 1, 2, and 3. The compensatory action is to immediately declare the associated equipment inoperable and take the appropriate actions for an inoperable turbine driven auxiliary feedwater train.

In lieu of immediately declaring the associated battery inoperable, the ITS 3.8.6 ACTIONS provide compensatory actions for when battery parameters are not within limits that may be taken prior to declaring the associated battery CNP Units 1 and 2 Page 3 of 8 Attachment 1, Volume 13, Rev. 0, Page 334 of 496

Attachment 1, Volume 13, Rev. 0, Page 335 of 496 DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS inoperable. This changes the CTS by adding compensatory actions specifically designed for battery parameters.

The purpose of the ITS 3.8.6 ACTIONS is to allow a certain amount of time to restore battery parameters to within limits before declaring the associated battery inoperable. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the repair period.

ACTIONS have been added to allow a short time period to restore parameters to within limits. ITS 3.8.6 ACTION A covers the condition of one or more batteries with one or more battery cells float voltage less than the specified limit. ITS 3.8.6 ACTION A requires the performance of SR 3.8.4.1 in 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , the performance of SR 3.8.6.1 within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , and restoration of the affected cell voltage to within limits within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . ITS 3.8.6 ACTION B covers the condition of one or more batteries with float current not within the specified limit. ITS 3.8.6 ACTION B requires the performance of SR 3.8.4.1 in 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months and restoration of the battery float current to within limits within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . ITS 3.8.6 ACTION C covers the condition of one or more batteries with one or more cells electrolyte level less than minimum established design limits. ITS 3.8.6 ACTION C requires the restoration of electrolyte level to above top of plates within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , verification that there is no evidence of leakage within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , and restoration of electrolyte level to greater than or equal to the minimum established design limits within 31 days. ITS 3.8.6 ACTION D covers the condition of one or more batteries with pilot cell electrolyte temperature less than the minimum established design limits.

ITS 3.8.6 ACTION D requires the restoration of battery pilot cell temperature to greater than or equal to minimum established design limits within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

ITS 3.8.6 ACTION E covers the condition of batteries in redundant trains with battery parameters not within limits. ITS 3.8.6 ACTION E requires restoration of the battery parameters for battery in one train to within limits within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

ITS 3.8.6 ACTION F covers the condition when a Required Action and associated Completion Time of any of the above ACTIONS could not be met, or if one or more batteries with one or more battery cells float voltage and float current are not within limits, or if ITS SR 3.8.6.6 is not met. ITS 3.8.6 ACTION F requires the immediate declaration that the associated battery is inoperable. The allowances are considered acceptable since only a short time is allowed to exist with battery parameters not within limits. In addition, when redundant batteries have battery parameters not within limit, only 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months is allowed to restore at least one redundant train before declaring the battery inoperable. 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 7 - Relaxation Of Surveillance Frequency, Non-24 Month Type Change) CTS 4.8.2.3.2.a.3 and CTS 4.8.2.5.2.a.3 require the verification that the pilot cell voltage is greater than or equal to the specified limit every 7 days.

ITS SR 3.8.6.2 requires the verification of each pilot battery cell voltage every CNP Units 1 and 2 Page 4 of 8 Attachment 1, Volume 13, Rev. 0, Page 335 of 496

Attachment 1, Volume 13, Rev. 0, Page 336 of 496 DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS 31 days. This changes the CTS by extending the Surveillance interval for verification of pilot cell voltage from 7 days to 31 days.

The purpose of ITS 3.8.6.2 is to ensure the cell float voltages are equal to or greater than the short term absolute minimum voltage. This change is acceptable because the new Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability. This change extends the Surveillance Frequency from 7 days to 31 days for verification of pilot cell voltage. This change is acceptable since ITS 5.5.15, "Battery Monitoring and Maintenance Program," has been added which requires actions to be taken to restore battery cells with float voltage < 2.13 V. This program will help ensure the cell voltage will not approach the ITS SR 3.8.6.2 limit of 2.07 V.

Therefore, since the ITS 5.5.15 program has been added, this change in Frequency is considered acceptable. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

L.3 (Category 5 - Deletion of Surveillance Requirement) CTS 4.8.2.3.2.a.1 and CTS 4.8.2.5.2.a.1 require the verification that the electrolyte level of each pilot cell is between the minimum and maximum level indication marks.

CTS 4.8.2.3.2.a.2 and CTS 4.8.2.5.2.a.2 require the verification that the pilot cell specific gravity, corrected to 77°F and full electrolyte level (fluid at the bottom of the maximum level indication mark), is greater than or equal to 1.200.

CTS 4.8.2.3.2.b.2 and CTS 4.8.2.5.2.b.2 require the verification that the specific gravity, corrected to 77°F and full electrolyte level (fluid at the bottom of the maximum level indication mark), of each connected cell is greater than or equal to 1.200 and has not decreased more than 0.03 from the value observed during the previous test. ITS 3.8.6 does not include these Surveillances. This changes the CTS by deleting these Surveillances.

The purpose of CTS 4.8.2.3.2.a.1 and CTS 4.8.2.5.2.a.1, the electrolyte level verification, is to ensure the battery cells contain sufficient electrolyte level for electron transfer capability and the purpose of CTS 4.8.2.3.2.a.2, CTS 4.8.2.3.2.b.2, CTS 4.8.2.5.2.a.2, and CTS 4.8.2.5.2.b.2, the specific gravity verification, is to ensure the state of charge of each cell. This change is acceptable because the deleted Surveillance Requirements are 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. The specified Surveillances have been deleted, however other Surveillances are included which help to ensure the batteries will function as designed. ITS SR 3.8.6.1 (discussed in DOC M.1) requires the verification that each battery float current is < 2 amps every 7 days and ITS SR 3.8.6.3 requires the verification that each battery connected cell electrolyte level is greater than or equal to minimum established design limits every 31 days.

IEEE 450-1995, Section 4.5 states that the most accurate indicator of return to full charge is a stabilized charging or float current. Specific gravity readings may not be accurate when the battery is on charge following a discharge. The Frequency for verification of electrolyte level in CTS 4.8.2.3.2.b.3 and CTS 4.8.2.5.2.b.3, for each connected cell, has been increased from every CNP Units 1 and 2 Page 5 of 8 Attachment 1, Volume 13, Rev. 0, Page 336 of 496

Attachment 1, Volume 13, Rev. 0, Page 337 of 496 DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS 92 days to every 31 days as discussed in DOC M.2. These Surveillances give a better indication of the overall battery conditions. This change is designated as less restrictive because Surveillances which are required in the CTS will not be required in the ITS.

L.4 (Category 6 - Relaxation Of Surveillance Requirement Acceptance Criteria)

CTS 4.8.2.3.2.a.3 and CTS 4.8.2.5.2.a.3 require the verification that the pilot cell voltage is > 2.13 V. CTS 4.8.2.3.2.b.1 and CTS 4.8.2.5.2.b.1 require the verification that the connected cell voltage is > 2.13 V. ITS SR 3.8.6.2 requires the verification of each pilot cell voltage is > 2.07 V. ITS SR 3.8.6.5 requires the verification that each battery connected cell voltage is > 2.07 V. This changes the CTS by reducing the acceptance criteria for pilot cell and battery connected cell voltage limits from > 2.13 V to > 2.07 V.

The purpose of the proposed Surveillance limit in ITS SR 3.8.6.2 and SR 3.8.6.5 is to ensure the cell voltages are greater than or equal to the short term absolute minimum voltage. This change is acceptable because it has been determined that the relaxed Surveillance Requirement acceptance criteria are not necessary for verification that the equipment used to meet the LCO can perform its required functions. This changes the CTS by reducing the acceptance criteria for pilot cell and battery connected cell voltage limits from > 2.13 V to > 2.07 V. At this lower voltage the cell can still perform its function. The battery is considered OPERABLE when the battery voltage on float is greater than or equal to the minimum establish voltage of ITS SR 3.8.4.1. This change is acceptable since ITS 5.5.15, "Battery Monitoring and Maintenance Program," has been added and requires actions to be taken to restore battery cells with float voltage < 2.13 V.

This program will help ensure the cell voltage will not approach the limit of 2.07 V and that the minimum established voltage of ITS SR 3.8.4.1 is maintained. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

L.5 (Category 6 - Relaxation Of Surveillance Requirement Acceptance Criteria)

CTS 4.8.2.3.2.b.3 and CTS 4.8.2.5.2.b.3 require the verification that the battery electrolyte level of each connected cell is between the top of the minimum level indication mark and the bottom of the maximum level indication mark. ITS SR 3.8.6.3 requires the verification that the battery connected cell electrolyte level is greater than or equal to minimum established design limits. This changes the CTS by deleting the specific value for the lower electrolyte level limit and deleting the upper electrolyte level limit requirement.

The purpose of the proposed Surveillance limit in ITS SR 3.8.6.3 is to ensure the battery plates do not suffer physical damage and maintain adequate electron transfer capability. This change is acceptable because it has been determined that the relaxed Surveillance Requirement acceptance criteria are not necessary for verification that the equipment used to meet the LCO can perform its required functions. This changes the CTS by deleting the specific value for the lower electrolyte level limit and replacing it with the minimum established design limit and deleting the upper electrolyte level limit requirement. This change is acceptable since the proposed level will continue to ensure that the battery and the cells remain OPERABLE to perform its specified safety function. This CNP Units 1 and 2 Page 6 of 8 Attachment 1, Volume 13, Rev. 0, Page 337 of 496

Attachment 1, Volume 13, Rev. 0, Page 338 of 496 DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

L.6 (Category 12 - Deletion of Surveillance Requirement Shutdown Performance Requirements) CTS 4.8.2.3.2.e requires the performance of a battery performance test on the Trains A and B 250 VDC batteries. CTS 4.8.2.5.2.e requires the performance of a battery performance test on the Train N 250 VDC battery. These tests must be performed during shutdown (MODES 5 or 6). ITS SR 3.8.6.6 requires the same tests. A Note to SR 3.8.6.6 specifies that this Surveillance shall not normally be performed in MODE 1, 2, 3, or 4. However, portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the unit is maintained or enhanced. This changes the CTS by allowing the test to be performed in MODES other than MODE 5 or 6 as long as an assessment determines the safety of the unit is maintained or enhanced.

The purpose of the shutdown restriction in CTS 4.8.2.3.2.e and CTS 4.8.2.5.2.e is to ensure the batteries are not tested in a condition that can compromise unit safety. 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 strict 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.

L.7 (Category 6 - Relaxation Of Surveillance Requirement Acceptance Criteria)

CTS 4.8.2.3.2.e requires the performance of a battery performance test on the Trains A and B 250 VDC batteries. CTS 4.8.2.5.2.e requires the performance of a battery performance test on the Train N 250 VDC battery. ITS SR 3.8.6.6 requires the performance of a performance discharge test or a modified performance discharge test. This changes the CTS by adding the allowance to perform a modified performance discharge test instead of the performance discharge test.

The purpose of ITS SR 3.8.6.6 is to verify the capacity is > 80% of the manufacturers rating. This change is acceptable because it has been determined that the relaxed Surveillance Requirement acceptance criteria are not necessary for verification that the equipment used to meet the LCO can perform its required functions. This changes the CTS by adding the allowance to perform a modified performance discharge test instead of the performance discharge test.

The modified performance discharge test is performed by testing the battery using the service test profile for the first 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months followed by the performance discharge test profile for the remainder of the test. Since the amps removed during the first four hours can be accurately calculated, the test rate can be changed to that of the modified performance discharge test without compromising the results of the performance discharge test. This method is consistent with IEEE 450-2002, Annex I (Type 3). This change is designated as CNP Units 1 and 2 Page 7 of 8 Attachment 1, Volume 13, Rev. 0, Page 338 of 496

Attachment 1, Volume 13, Rev. 0, Page 339 of 496 DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS 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 8 of 8 Attachment 1, Volume 13, Rev. 0, Page 339 of 496

Attachment 1, Volume 13, Rev. 0, Page 340 of 496 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

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Attachment 1, Volume 13, Rev. 0, Page 346 of 496 3.8.6 4

INSERT 2 However, this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced.

unit 6

Insert Page 3.8.6-4 Attachment 1, Volume 13, Rev. 0, Page 346 of 496

Attachment 1, Volume 13, Rev. 0, Page 347 of 496 JUSTIFICATION FOR DEVIATIONS ITS 3.8.6, BATTERY PARAMETERS

1. The "Reviewer Note" has been deleted since it is not intended to be retained in the plant specific ITS submittal.

2. ISTS LCO 3.8.6 has been modified to be consistent with the requirements specified in ITS LCO 3.8.4. Additional requirements were added to ISTS LCO 3.8.6 to ensure the appropriate DC Sources are OPERABLE. In addition, due to the addition of these DC Sources, ISTS 3.8.6 Conditions A, B, C, D, and F have been modified to allow batteries in two trains to have battery parameters not within limits. ITS 3.8.6 ACTION E will ensure that if batteries in redundant trains have battery parameters not within limits, the restoration time is properly limited consistent with the intent of the ISTS 3.8.6 ACTIONS.

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

4. TSTF-283, Rev. 3, was approved by the NRC on April 13, 2000. However, when NUREG-1431, Rev. 2, was issued, this TSTF was not completely included.

Therefore, changes approved by TSTF-283, Rev. 3, have been made.

5. ISTS SR 3.8.6.6 requires a battery performance discharge or modified performance discharge test to be performed and provides acceptance criteria. However, no ACTION is provided in the ISTS 3.8.6 ACTIONS for when this SR is not met. Thus in the ISTS, LCO 3.0.3 would have to be entered. To preclude an LCO 3.0.3 entry, ISTS 3.8.6 Condition F has been modified to cover the case when SR 3.8.6.6 is not met. ACTION F will require the associated battery to be declared inoperable. This is also consistent with the current licensing basis.

6. 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 13, Rev. 0, Page 347 of 496

Attachment 1, Volume 13, Rev. 0, Page 348 of 496 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 13, Rev. 0, Page 348 of 496

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Attachment 1, Volume 13, Rev. 0, Page 350 of 496 B 3.8.6 1

INSERT 1 Battery Monitoring and Maintenance Program 8

INSERT 2 The specific Applicable Safety Analyses for the DC Electrical Power System are provided in the Bases for LCO 3.8.4 and LCO 3.8.5.

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Attachment 1, Volume 13, Rev. 0, Page 352 of 496 B 3.8.6 O ~INSERT 3 Battery Monitoring and Maintenance Program Insert Page B 3.8.6-2 Attachment 1, Volume 13, Rev. 0, Page 352 of 496

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Attachment 1, Volume 13, Rev. 0, Page 356 of 496 B 3.8.6 3

INSERT 3A or failure of the battery performance discharge test (SR 3.8.6.6),

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Attachment 1, Volume 13, Rev. 0, Page 358 of 496 B 3.8.6 1

INSERT 4 257.5 V for a 116 cell battery and 259.7 V for a 117 cell battery 2 INSERT 4A (i.e., greater than or equal to the low level mark) 1 INSERT 5 60ºF for the Train A and Train B 250 VDC batteries and 45ºF for the Train N 250 VDC battery Insert Page B 3.8.6-6 Attachment 1, Volume 13, Rev. 0, Page 358 of 496

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Attachment 1, Volume 13, Rev. 0, Page 360 of 496 B 3.8.6 Q ~INSERT 6 However, currently the modified performance discharge test is performed by testing the battery using the service test profile for the first 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months followed by the performance discharge test profile for the remainder of the test.

Insert Page B 3.8.6-7 Attachment 1, Volume 13, Rev. 0, Page 360 of 496

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Attachment 1, Volume 13, Rev. 0, Page 362 of 496 B 3.8.6 Q ~~INSERT 7 The 24 month Frequency is derived from the recommendations of IEEE-450 (Ref. 1).

Q ~~INSERT 8 Credit may be taken for unplanned events that satisfy this SR.

Insert Page B 3.8.6-8 Attachment 1, Volume 13, Rev. 0, Page 362 of 496

Attachment 1, Volume 13, Rev. 0, Page 363 of 496 JUSTIFICATION FOR DEVIATIONS ITS 3.8.6 BASES, BATTERY PARAMETERS

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

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

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

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

5. Grammatical/editorial/spelling error corrected.

6. TSTF-283, Rev. 3, was approved by the NRC on April 13, 2000. However, when NUREG-1431, Rev. 2, was issued, this TSTF was not completely included.

Therefore, changes approved by TSTF-283, Rev. 3, have been made.

7. Changes are made to reflect the Specification.

8. ISTS 3.8.6 is applicable when associated DC electrical power subsystems are required to be OPERABLE. The DC electrical power subsystems are required to be OPERABLE in MODES 1, 2, 3, and 4 (ISTS 3.8.4) and in MODES 5 and 6 and during movement of irradiated fuel assemblies (ISTS 3.8.5). The Applicable Safety Analyses Bases only discusses accident analyses related to MODES 1, 2, 3, and 4; it does not discuss events in MODES 5 and 6 and during movement of irradiated fuel assemblies. Therefore, for completeness, the Applicable Safety Analyses for MODES 5 and 6 and during movement of irradiated fuel assemblies needs to be discussed. However, in lieu of adding this large description from the ISTS 3.8.5 Bases, the MODES 1, 2, 3, and 4 description has been deleted and in its place a statement has been added referencing the Applicable Safety Analyses Bases for ITS 3.8.4 and ITS 3.8.5. This is consistent with the manner in which similar information in one ISTS Bases is referenced in another ISTS Bases (e.g., the ISTS 3.8.5 Background Bases references ISTS 3.8.4 Background Bases).

9. These battery design values have been deleted because they are more specific than necessary and are not required to provide sufficient background for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 363 of 496

Attachment 1, Volume 13, Rev. 0, Page 364 of 496 Specific No Significant Hazards Considerations (NSHCs)

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Attachment 1, Volume 13, Rev. 0, Page 365 of 496 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.6, BATTERY PARAMETERS There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 365 of 496

, Volume 13, Rev. 0, Page 366 of 496 ATTACHMENT 7 ITS 3.8.7, Inverters - Operating , Volume 13, Rev. 0, Page 366 of 496

, Volume 13, Rev. 0, Page 367 of 496 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 13, Rev. 0, Page 367 of 496

Attachment 1, Volume 13, Rev. 0, Page 368 of 496 ITS 3.8.7 A.1 ITS See ITS 3.8.9 See ITS 3.8.9 M.1 One Add proposed Required Action A.1 Note 24 L.1 ACTION A ACTION C Add proposed ACTION B M.1 M.2 SR 3.8.7.1 Train A and B s shall be OPERABLE LCO 3.8.7 LA.1 Page 1 of 2 Attachment 1, Volume 13, Rev. 0, Page 368 of 496

Attachment 1, Volume 13, Rev. 0, Page 369 of 496 ITS 3.8.7 A.1 ITS See ITS 3.8.9 See ITS 3.8.9 M.1 One Add proposed Required Action A.1 Note 24 L.1 ACTION A ACTION C Add proposed ACTION B M.1 SR 3.8.7.1 M.2 Train A and B LCO 3.8.7 s shall be OPERABLE LA.1 Page 2 of 2 Attachment 1, Volume 13, Rev. 0, Page 369 of 496

Attachment 1, Volume 13, Rev. 0, Page 370 of 496 DISCUSSION OF CHANGES ITS 3.8.7, INVERTERS - OPERATING 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 3.8.2.1 Action specifies the compensatory actions for one or more inoperable 120 VAC inverters. The compensatory action is to restore the inoperable inverters to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . ITS 3.8.7 ACTION A covers the condition of one inoperable Train A or Train B inverter. ITS 3.8.7 ACTION A requires the restoration of the inoperable inverter to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . ITS 3.8.7 ACTION B covers the condition of two inverters in one train inoperable, and requires restoration of one inverter to OPERABLE status within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . This changes the CTS by: a) requiring one inverter to be restored to OPERABLE status within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months instead of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months when two inverters are inoperable in the same train; and b) requiring entry into LCO 3.0.3 with two or more inverters in different trains inoperable. The change covering the extension in time for restoration of one inoperable inverter is discussed in DOC L.1.

The purpose of ITS 3.8.7 ACTIONS A and B is to limit the time the unit may operate with inoperable inverters. With inverters in different trains inoperable, the associated 120 VAC vital buses may be powered by its auxiliary power system source or its associated regulated 600/120 VAC transformer via the inverter. These sources will not provide an uninterrruptible source for the required equipment during a loss of offsite power. In this situation, an immediate shutdown is appropriate. This change is designated as more restrictive because when one or more inverters in different trains are found to be inoperable, LCO 3.0.3 must be entered immediately.

M.2 CTS 4.8.2.1 requires the specified AC buses to be determined OPERABLE every 7 days and energized by verifying correct breaker alignment and indicated power availability. ITS SR 3.8.7.1 requires the verification of correct inverter voltage, frequency, and alignment to the associated 120 VAC vital buses every 7 days.

This changes the CTS by requiring the specific verification of the inverter voltage and frequency every 7 days.

The purpose of this change is to ensure the instrumentation channels are provided with proper voltage from the AC vital bus when powered by the associated inverter. This change is acceptable because the Surveillance will continue to verify OPERABILITY of the required inverters. Proper voltage and frequency from the inverters to the vital AC buses ensures proper voltage and frequency is supplied to the instrumentation channels that provide inputs to the CNP Units 1 and 2 Page 1 of 3 Attachment 1, Volume 13, Rev. 0, Page 370 of 496

Attachment 1, Volume 13, Rev. 0, Page 371 of 496 DISCUSSION OF CHANGES ITS 3.8.7, INVERTERS - OPERATING Reactor Trip System and Engineered Safety Features Actuation System. This change is designated as more restrictive because the ITS requires verification of the correct voltage and frequency, where the CTS does not provide explicit requirements for the inverter.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS LCO 3.8.2.1 footnote

states that each 120 VAC vital bus must be energized from its associated inverter connected to a DC bus.

ITS LCO 3.8.7 requires the Train A and Train B inverters to be OPERABLE. This changes the CTS by moving the procedural detail that the inverters must be "connected to a DC bus" and that they must be energizing the associated 120 VAC vital buses from the CTS to the ITS Bases.

The removal of these details for meeting Technical Specifications 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 (LCO 3.8.7) that the Train A and Train B inverters shall be OPERABLE and ITS SR 3.8.7.1 requires correct inverter voltage, frequency, and alignment to the associated 120 VAC vital buses. The Bases includes the detail that the inverters must be supplied by the associated Train A or Train B 250 VDC bus and that the 120 VAC vital buses must be energized from the inverters.

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

LESS RESTRICTIVE CHANGES L.1 (Category 4 - Relaxation of Required Action) The CTS 3.8.2.1 Action specifies the compensatory for one or more inoperable 120 VAC inverters. The compensatory action is to restore the inoperable inverters to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . ITS 3.8.7 ACTION A covers the condition of one Train A or Train B inoperable inverter. ITS 3.8.7 ACTION A requires the restoration of the inoperable inverter within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . However, the additional 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months is only allowed if the associated 120 VAC vital bus remains energized. This changes the CTS by allowing one inverter to be inoperable for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , provided the associated 120 VAC vital bus remains energized. The change to the number of inverters that can be inoperable is discussed in DOC M.1.

CNP Units 1 and 2 Page 2 of 3 Attachment 1, Volume 13, Rev. 0, Page 371 of 496

Attachment 1, Volume 13, Rev. 0, Page 372 of 496 DISCUSSION OF CHANGES ITS 3.8.7, INVERTERS - OPERATING The purpose of the CTS 3.8.2.1 Action is to limit the time the 120 VAC inverters can be inoperable. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the repair period. This change extends the time an inverter can be inoperable from 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Experience has shown that a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months restoration time for an inoperable inverter is appropriate, as long as the associated 120 VAC vital bus can be energized from an auxiliary power system source or the regulated 600/120 VAC transformer via the inverter. This is ensured by the added Note to ACTION A, which requires entry into applicable Conditions and Required Actions of LCO 3.8.9, "Distribution Systems -

Operating," if the 120 VAC vital bus is de-energized. During this additional 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months , the 120 VAC vital bus is energized and can perform its design function during a LOCA event, assuming no loss of offsite power. If the associated 120 VAC vital bus is de-energized, ITS 3.8.9 ACTION B will require it to be re-energized within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , consistent with the time required in the CTS 3.8.2.1 Action. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

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Attachment 1, Volume 13, Rev. 0, Page 373 of 496 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

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Attachment 1, Volume 13, Rev. 0, Page 377 of 496 JUSTIFICATION FOR DEVIATIONS ITS 3.8.7, INVERTERS - OPERATING

1. The word "required" has been deleted from the LCO and Condition A since all Train A and Train B inverters are required.

2. This allowance of the ISTS LCO 3.8.7 Note has been deleted because CNP does not need to disconnect the 120 VAC vital bus during an equalizing charge.

3. Changes made to be consistent with changes made in another Specification.

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

5. The SR has been modified to reflect that each inverter must have proper voltage, frequency, and alignment to its associated 120 VAC vital bus.

6. ITS 3.8.7 Condition B has been added to allow two inverters on the same train to be inoperable for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The CNP design incorporates two 120 VAC inverters on each train. As written, ISTS 3.8.7 requires entry into LCO 3.0.3 when two inverters in the same train are inoperable since no ACTION exists for when more than one inverter is inoperable. The inoperability of two inverters in the same train does not place the unit outside of its design basis because the other train remains OPERABLE to support safeguards operation. Therefore, entry into LCO 3.0.3 is not necessary in this condition. An allowed outage time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months has been selected to be consistent with the allowed outage time in ISTS 3.3.1 for a single inoperable Reactor Trip System train. This is also more conservative than the 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months allowed in the CTS when two inverters are inoperable. In addition, the subsequent ACTION has been renumbered.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 377 of 496

Attachment 1, Volume 13, Rev. 0, Page 378 of 496 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 13, Rev. 0, Page 378 of 496

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Attachment 1, Volume 13, Rev. 0, Page 380 of 496 B 3.8.7 1

INSERT 1 bus electrical power distribution subsystems 1

INSERT 2 There are two inverters per train (i.e., Train A and Train B), for a total of four inverters.

1 INSERT 3 Train A or Train B 250 VDC bus or a regulated 600/120 VAC transformer 1

INSERT 4 Each inverter is normally supplied from the Train A or Train B 250 VDC bus. If the associated Train A or Train B 250 VDC bus fails or if the DC to AC section of the inverter fails, the AC vital bus is transferred to the regulated 600/120 VAC transformer.

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Attachment 1, Volume 13, Rev. 0, Page 384 of 496 B 3.8.7 5

INSERT 6 and other conditions in which the inverters are required 2

INSERT 7 regulated 600/120 VAC transformer via the inverter 1

INSERT 8 LCO 3.8.9, Distribution Systems - Operating addresses this action however, pursuant to LCO 3.0.6, this action would not be entered even if the 120 VAC vital bus were de-energized.

1 INSERT 8A proper action for a de-energized 120 VAC 1

INSERT 8B regulated 600/120 VAC transformer Insert Page B 3.8.7-3a Attachment 1, Volume 13, Rev. 0, Page 384 of 496

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Attachment 1, Volume 13, Rev. 0, Page 387 of 496 JUSTIFICATION FOR DEVIATIONS ITS 3.8.7 BASES, INVERTERS - OPERATING

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

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

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

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

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

6. Editorial correction made.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 387 of 496

Attachment 1, Volume 13, Rev. 0, Page 388 of 496 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 13, Rev. 0, Page 388 of 496

Attachment 1, Volume 13, Rev. 0, Page 389 of 496 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.7, INVERTERS - OPERATING There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 389 of 496

, Volume 13, Rev. 0, Page 390 of 496 ATTACHMENT 8 ITS 3.8.8, Inverters - Shutdown , Volume 13, Rev. 0, Page 390 of 496

, Volume 13, Rev. 0, Page 391 of 496 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 13, Rev. 0, Page 391 of 496

Attachment 1, Volume 13, Rev. 0, Page 392 of 496 ITS 3.8.8 ITS A.1 See ITS 3.8.10 A.4 Add proposed ACTIONS NOTE A.2 ACTION A L.1 additions that could result in loss of required SDM or boron concentration See ITS 3.8.10 SR 3.8.8.1 M.1 LA.1 Two s shall be OPERABLE LCO 3.8.8 Page 1 of 2 Attachment 1, Volume 13, Rev. 0, Page 392 of 496

Attachment 1, Volume 13, Rev. 0, Page 393 of 496 ITS 3.8.8 ITS A.1 See ITS 3.8.10 A.3 During movement of irradiated fuel assemblies in the containment, auxiliary building, and Unit 1 containment Add proposed ACTIONS NOTE A.2 ACTION A L.1 additions that could result in loss of required SDM or boron concentration See ITS 3.8.10 SR 3.8.8.1 M.1 LA.1 Two s shall be OPERABLE LCO 3.8.8 Page 2 of 2 Attachment 1, Volume 13, Rev. 0, Page 393 of 496

Attachment 1, Volume 13, Rev. 0, Page 394 of 496 DISCUSSION OF CHANGES ITS 3.8.8, INVERTERS - SHUTDOWN ADMINISTRATIVE CHANGES A.1 In the conversion of the CNP Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 2, "Standard Technical Specifications-Westinghouse Plants" (ISTS).

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

A.2 Unit 1 CTS 3.8.2.2 is applicable during MODES 5 and 6, and during the movement of irradiated fuel. Unit 2 CTS 3.8.2.2 is applicable during MODES 5 and 6. ITS 3.8.8 is applicable in MODES 5 and 6, and during the movement of irradiated fuel assemblies in the containment, auxiliary building, and Unit 2 (Unit 1) and Unit 1 (Unit 2) containment. However, a Note has been added to the ACTIONS which states that LCO 3.0.3 is not applicable. This changes the CTS by adding the Note to the ACTIONS stating that LCO 3.0.3 is not applicable.

The change in the Applicability is discussed in DOCs A.3 and A.4.

The purpose of CTS 3.8.2.2 is to ensure that at least two inverters are OPERABLE to support equipment required to be OPERABLE. This change adds a clarification Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODES 5 or 6, LCO 3.0.3 is not applicable and would not specify any action. If moving irradiated fuel assemblies while in MODES 1, 2, 3, or 4, the fuel movement is independent of reactor operations and the inability to suspend movement in accordance with the ITS 3.8.8 Required Actions would not be sufficient reason to require a reactor shutdown. This Note has been added for clarification and is necessary since defaulting to LCO 3.0.3 would require the reactor to be shutdown, but would not require suspension of the activities with a potential for releasing radioactive materials. This change is designated as administrative as it is a clarification of the intent of CTS 3.0.3 that does not result in a technical change to the CTS.

A.3 (Unit 2 only) CTS 3.8.2.2 is applicable during MODES 5 and 6. However, CTS 3.8.2.2 Action a requires movement of irradiated fuel assemblies to be suspended if the required inverter(s) are inoperable. ITS 3.8.8 is applicable in MODES 5 and 6, and during the movement of irradiated fuel assemblies in the containment, auxiliary building, and Unit 1 containment. This changes the Unit 2 CTS by adding the explicit Applicability of during movement of irradiated fuel assemblies in the containment, auxiliary building, and Unit 1 containment.

The purpose of CTS 3.8.2.2 is to ensure that at least two inverters are OPERABLE to support equipment required to be OPERABLE. This change adds the explicit Applicability of during movement of irradiated fuel assemblies in the containment, auxiliary building, and Unit 1 containment. This Applicability is consistent with the Applicability of CTS 3.8.2.2 for Unit 1 and consistent with the CTS 3.8.2.2 Actions of Unit 2, which states to suspend movement of irradiated fuel when the required inverters are inoperable. This change is designated as administrative as it is a clarification of the intent of Unit 2 CTS 3.8.2.2 that does not result in a technical change to the Unit 2 CTS.

CNP Units 1 and 2 Page 1 of 4 Attachment 1, Volume 13, Rev. 0, Page 394 of 496

Attachment 1, Volume 13, Rev. 0, Page 395 of 496 DISCUSSION OF CHANGES ITS 3.8.8, INVERTERS - SHUTDOWN A.4 (Unit 1 only) CTS 3.8.2.2 Applicability includes "during movement of irradiated fuel." ITS 3.8.8 Applicability includes "During movement of irradiated fuel assemblies in the containment, auxiliary building, and Unit 2 containment." This changes the Unit 1 CTS by clarifying the locations that fuel movement is taking place.

The purpose of CTS 3.8.2.2, with respect to fuel handling, is to ensure adequate inverters are available to power equipment required to mitigate a fuel handling accident. This protection is required during irradiated fuel movement in three locations: the unit containment, the auxiliary building, and the opposite unit containment. Therefore, for clarity, all three locations are specified in the ITS Applicability, instead of the current wording which just specifies irradiated fuel movement. This change is designated as administrative because it does not result in any technical changes to the Unit 1 CTS.

MORE RESTRICTIVE CHANGES M.1 CTS 4.8.2.2 requires the specified 120 VAC vital buses to be determined OPERABLE every 7 days and energized by verifying correct breaker alignment and indicated power availability. ITS SR 3.8.8.1 requires the verification of correct required voltage, frequency, and alignment to the associated 120 VAC vital bus every 7 days. This changes the CTS by requiring the specific verification of the inverter voltage and frequency every 7 days.

The purpose of this change is to ensure the instrumentation channels are provided with proper voltage and frequency from the AC vital bus when powered by the associated inverter. This change is acceptable because the Surveillance will continue to verify OPERABILITY of the required inverters. Proper voltage from the inverters to the vital AC buses ensures proper voltage is supplied to the instrumentation channels. This change is designated as more restrictive because the ITS requires verification of the correct voltage and frequency, where the CTS does not specify these requirements for the inverters.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS LCO 3.8.2.2 footnote

states that each required 120 VAC vital bus must be energized from its associated inverter connected to a DC bus. ITS LCO 3.8.8 requires two inverters to be OPERABLE to support one train of the 120 VAC vital electrical distribution subsystem(s) required by LCO 3.8.10, "Distribution Systems - Shutdown." This changes the CTS by moving the procedural detail that the inverters must be "connected to a DC bus" and that they must be energizing the associated 120 VAC vital buses from the CTS to the ITS Bases.

CNP Units 1 and 2 Page 2 of 4 Attachment 1, Volume 13, Rev. 0, Page 395 of 496

Attachment 1, Volume 13, Rev. 0, Page 396 of 496 DISCUSSION OF CHANGES ITS 3.8.8, INVERTERS - SHUTDOWN The removal of these details for meeting Technical Specification requirements from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. ITS LCO 3.8.8 still retains the requirement that two inverters must be OPERABLE to support one train of the 120 VAC vital electrical distribution subsystem(s) required by LCO 3.8.10, "Distribution Systems - Shutdown," and ITS SR 3.8.8.1 requires correct inverter voltage, frequency, and alignment to the associated 120 VAC vital bus. The Bases include the detail that the inverters must be supplied by the associated Train A or Train B 250 VDC bus and that the 120 VAC vital buses must be energized from the inverters. Also, this change is acceptable because these types of procedural details will be adequately controlled in the ITS Bases.

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

LESS RESTRICTIVE CHANGES L.1 (Category 4 - Relaxation of Required Action) CTS 3.8.2.2 Action a specifies the compensatory actions for a required inoperable AC electrical distribution subsystem. These actions apply to one or more required inoperable inverters.

One of the compensatory actions is the suspension of positive reactivity "changes except: 1) heatup or cooldown of the reactor coolant volume provided that SHUTDOWN MARGIN sufficient to accommodate the change in temperature is maintained in accordance with Specification 3.1.1.2 in MODE 5 or Specification 3.9.1 in MODE 6, and the heatup or cooldown rate is restricted to 50°F or less in any one-hour period in MODE 5, or 2) addition of water from the RWST, provided the boron concentration in the RWST is greater than or equal to the minimum required by Specification 3.1.2.7.b.2." ITS 3.8.8 Required Action A.3 requires the immediate suspension of operations involving positive reactivity "additions that could result in loss of required SDM or boron concentration." This changes the CTS compensatory actions by deleting the limitation on the heatup and cooldown rates of 50ºF or less in any one hour period in MODE 5 and allows the addition of water from any source including the RWST as long as SDM and boron concentration limitations are met.

The purpose of the CTS 3.8.2.2 Action a is to suspend any positive reactivity additions that could affect the SDM of the reactor core. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, 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 CTS allows two types of positive reactivity changes (heatup/cooldown and addition of water).

CNP Units 1 and 2 Page 3 of 4 Attachment 1, Volume 13, Rev. 0, Page 396 of 496

Attachment 1, Volume 13, Rev. 0, Page 397 of 496 DISCUSSION OF CHANGES ITS 3.8.8, INVERTERS - SHUTDOWN Heatup and cooldown of the reactor coolant volume are allowed provided SDM is sufficient to accommodate the change in temperature in accordance with CTS 3.1.1.2 in MODE 5 or CTS 3.9.1 in MODE 6. The requirements of these Specifications are included in ITS LCO 3.1.1, "SHUTDOWN MARGIN (SDM),"

and ITS LCO 3.9.1, "Boron Concentration," respectively. Therefore, there is no technical change in this portion of the change. The Bases provides the appropriate cross-reference to the appropriate LCOs. The CTS also allows positive reactivity changes by the addition of water from the RWST provided the boron concentration in the RWST is greater than or equal to the minimum required by CTS 3.1.2.7.b.2. CTS 3.1.2.7.b.2 has been relocated to the TRM as indicated in the Discussion of Changes for CTS 3/4.1.2.7. CTS 3/4.1.2.7 is applicable during MODE 5 and 6 operations. The proposed Required Actions require the suspension of operations involving positive reactivity additions that could result in loss of required SDM or boron concentration. The requirements for SDM are specified in ITS LCO 3.1.1 while the requirements for boron concentration are specified in ITS LCO 3.9.1. The current and proposed actions may result in an overall reduction in SDM or RCS boron concentration, but provide acceptable margin to maintaining subcritical operation. The CTS compensatory action restricted the heatup and cooldown rates of the RCS to 50ºF or less in any one-hour period in MODE 5. This limitation has been deleted.

The proposed Required Action is to suspend operations involving positive reactivity additions that could result in loss of required SDM or boron concentration. These limitations are considered acceptable. The Bases also indicate that introduction of temperature changes including temperature increases when operating with a positive moderator temperature coefficient must be evaluated to ensure they do not result in a loss of required SDM. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

CNP Units 1 and 2 Page 4 of 4 Attachment 1, Volume 13, Rev. 0, Page 397 of 496

Attachment 1, Volume 13, Rev. 0, Page 398 of 496 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 13, Rev. 0, Page 398 of 496

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, Volume 13, Rev. 0, Page 400 of 496 , Volume 13, Rev. 0, Page 400 of 496

, Volume 13, Rev. 0, Page 401 of 496 , Volume 13, Rev. 0, Page 401 of 496

Attachment 1, Volume 13, Rev. 0, Page 402 of 496 JUSTIFICATION FOR DEVIATIONS ITS 3.8.8, INVERTERS - SHUTDOWN

1. The bracketed optional ISTS LCO 3.8.8 and Reviewers Note have been deleted because the current licensing basis only requires two inverters to be OPERABLE.

ISTS 3.8.8 Required Action A.1 provides an option to declare affected required feature(s) inoperable with one or more required inverters inoperable. The ISTS Bases states that this is acceptable since the remaining inverters may be capable of supporting sufficient features to allow continuation of CORE ALTERATIONS and fuel movement. Therefore, this Required Action assumes all four inverters are required by the LCO. This option has been deleted since only two Train A or two Train B inverters are required to be OPERABLE by the LCO. The subsequent Required Actions have been renumbered and modified, as applicable.

2. The second option of ISTS LCO 3.8.8 is not specific as to what the 120 VAC inverters must be powering. The LCO has been modified to require two inverters to be powering one train of the 120 VAC vital bus(es) required by LCO 3.8.10. In addition, SR 3.8.8.1 has been modified to reflect that all inverters at the unit are not required to be OPERABLE and that each required inverter must be aligned to the associated 120 VAC vital bus.

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

4. The Applicability has been clarified, since CNP has two units and irradiated fuel movement can occur in three different locations.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 402 of 496

Attachment 1, Volume 13, Rev. 0, Page 403 of 496 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 13, Rev. 0, Page 403 of 496

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, Volume 13, Rev. 0, Page 405 of 496 , Volume 13, Rev. 0, Page 405 of 496

, Volume 13, Rev. 0, Page 406 of 496 , Volume 13, Rev. 0, Page 406 of 496

, Volume 13, Rev. 0, Page 407 of 496 , Volume 13, Rev. 0, Page 407 of 496

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, Volume 13, Rev. 0, Page 409 of 496 , Volume 13, Rev. 0, Page 409 of 496

Attachment 1, Volume 13, Rev. 0, Page 410 of 496 B 3.8.8 4

INSERT 3 specified in LCO 3.1.1, "SHUTDOWN MARGIN (SDM),"

4 INSERT 4 specified in LCO 3.9.1, "Boron Concentration,"

1 INSERT 5 the regulated 600/120 VAC transformer via the inverter Insert Page B 3.8.8-4 Attachment 1, Volume 13, Rev. 0, Page 410 of 496

Attachment 1, Volume 13, Rev. 0, Page 411 of 496 JUSTIFICATION FOR DEVIATIONS ITS 3.8.8 BASES, INVERTERS - SHUTDOWN

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

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

3. These punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, NEI 01-03, Section 3.2.2.

4. Changes are made to be consistent with other places in the Bases.

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

6. Grammatical/spelling error corrected.

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

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 411 of 496

Attachment 1, Volume 13, Rev. 0, Page 412 of 496 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 13, Rev. 0, Page 412 of 496

Attachment 1, Volume 13, Rev. 0, Page 413 of 496 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.8, INVERTERS - SHUTDOWN There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 413 of 496

, Volume 13, Rev. 0, Page 414 of 496 ATTACHMENT 9 ITS 3.8.9, Distribution Systems - Operating , Volume 13, Rev. 0, Page 414 of 496

, Volume 13, Rev. 0, Page 415 of 496 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 13, Rev. 0, Page 415 of 496

Attachment 1, Volume 13, Rev. 0, Page 416 of 496 ITS 3.8.9 A.1 ITS power distribution subsystem LA.2 LCO 3.8.9 LA.1 Train A and Train B AC distribution subsystems LA.2 LCO 3.8.9.a L.1 LA.2 Train A and Train B 120 VAC vital distribution LCO 3.8.9.b A.2 Add proposed LCO 3.8.9.e A.3 Add proposed Required Actions A.1 M.1 Add proposed ACTION A Note and B.1 second Completion Time ACTIONS A and B A.2 ACTION E Add proposed ACTION F Add proposed ACTION G M.2 SR 3.8.9.1 LA.1 M.3 voltage Add SR 3.8.9.1 for Unit 2 electrical M.4 power distribution subsystems See ITS 3.8.7 Page 1 of 6 Attachment 1, Volume 13, Rev. 0, Page 416 of 496

Attachment 1, Volume 13, Rev. 0, Page 417 of 496 ITS 3.8.9 A.1 ITS LA.2 Train A and Train B 250 VDC distribution subsystems LA.1 LCO 3.8.9 LA.2 See ITS B 3.8.4 LA.2 LCO 3.8.9.c A

See ITS 3.8.4 Add proposed LCO 3.8.9.e A.2 Add proposed Required Action C.1 second Completion Time M.1 ACTION C A.2 ACTION E Add proposed ACTION F Add proposed ACTION G M.2 See ITS 3.8.4 LA.1 SR 3.8.9.1 M.3 voltage Add SR 3.8.9.1 for Unit 2 electrical power distribution subsystems M.4 See ITS 3.8.4 and 3.8.6 See ITS 3.8.6 See ITS 3.8.4 Page 2 of 6 Attachment 1, Volume 13, Rev. 0, Page 417 of 496

Attachment 1, Volume 13, Rev. 0, Page 418 of 496 ITS 3.8.9 A.1 ITS LA.2 LA.1 electrical power distribution subsystem LA.2 LCO 3.8.9 See ITS LCO 3.8.9.d 3.8.4 A.4 ACTION E Add proposed ACTION G M.2 SR 3.8.9.1 LA.1 voltage See ITS 3.8.4 and M.3 3.8.6 See ITS 3.8.6 See ITS 3.8.4 See ITS 3.8.6 Page 3 of 6 Attachment 1, Volume 13, Rev. 0, Page 418 of 496

Attachment 1, Volume 13, Rev. 0, Page 419 of 496 ITS 3.8.9 A.1 ITS power distribution subsystem LA.2 LCO 3.8.9 LA.1 Train A and Train B AC distribution subsystems LA.2 LCO 3.8.9.a L.1 LA.2 Train A and Train B 120 VAC vital distribution LCO 3.8.9.b A.2 Add proposed LCO 3.8.9.e A.3 Add proposed Required Actions A.1 M.1 Add proposed ACTION A Note and B.1 second Completion Time ACTIONS A and B A.2 ACTION E Add proposed ACTION F Add proposed ACTION G M.2 SR 3.8.9.1 LA.1 M.3 voltage Add SR 3.8.9.1 for Unit 2 electrical power distribution subsystems M.4 See ITS 3.8.7 Page 4 of 6 Attachment 1, Volume 13, Rev. 0, Page 419 of 496

Attachment 1, Volume 13, Rev. 0, Page 420 of 496 ITS 3.8.9 A.1 ITS LA.2 Train A and Train B 250 VDC distribution subsystems LA.1 LCO 3.8.9 LA.2 See ITS B 3.8.4 LCO 3.8.9.c LA.2 A

See ITS 3.8.4 Add proposed LCO 3.8.9.e A.2 Add proposed Required Action C.1 second Completion Time M.1 ACTION C A.2 ACTION E Add proposed ACTION F Add proposed ACTION G M.2 See ITS 3.8.4 LA.1 SR 3.8.9.1 voltage M.3 Add SR 3.8.9.1 for Unit 2 electrical power distribution subsystems See ITS M.4 3.8.4 and 3.8.6 See ITS 3.8.6 See ITS 3.8.4 Page 5 of 6 Attachment 1, Volume 13, Rev. 0, Page 420 of 496

Attachment 1, Volume 13, Rev. 0, Page 421 of 496 ITS 3.8.9 A.1 ITS LA.2 LA.1 electrical power distribution subsystem LA.2 LCO 3.8.9 See ITS LCO 3.8.9.d 3.8.4 A.4 ACTION E Add proposed ACTION G M.2 SR 3.8.9.1 LA.1 voltage See ITS 3.8.4 and M.3 3.8.6 See ITS 3.8.6 See ITS 3.8.4 See ITS 3.8.6 Page 6 of 6 Attachment 1, Volume 13, Rev. 0, Page 421 of 496

Attachment 1, Volume 13, Rev. 0, Page 422 of 496 DISCUSSION OF CHANGES ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING 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 3.8.2.1 only provides the requirements for the unit AC electrical power distribution subsystems. CTS 3.8.2.3 only provides the requirements for the unit DC electrical power distribution subsystems. Neither of these Specifications provide any requirements for the opposite unit electrical power distribution subsystems. CTS LCO 3.7.4.1 requires two independent essential service water loops to be OPERABLE. The CTS 3/4.7.4 Bases states that the LCO also ensures that an inoperable opposite unit ESW pump does not result in flow being diverted from an OPERABLE unit ESW pump sharing the same header.

Therefore, if the header between the two units is not isolated, both ESW pumps on the same header support both units. The CTS definition of OPERABLE-OPERABILITY requires all attendant equipment to be capable of performing its required function which includes necessary electrical power distribution requirements. Thus, the opposite unit electrical power distribution subsystems may be required to be OPERABLE. In addition, this would require declaring the affected ESW train inoperable when a required opposite unit bus is inoperable.

ITS LCO 3.8.9.e requires the Unit 2 (Unit 1) and Unit 1 (Unit 2) Train A and Train B AC electrical power distribution subsystem(s) and the Train A and Train B 250 VDC electrical power distribution subsystem(s) required to support the equipment required to be OPERABLE by LCO 3.7.8, "Essential Service Water (ESW) System," to be OPERABLE. ITS 3.8.9 ACTION F has been added to cover the situation when LCO 3.8.9.e is not met. ITS 3.8.9 ACTION F requires the immediate declaration that the associated ESW train(s) are inoperable. This changes the CTS by providing an explicit LCO and ACTION for the opposite unit electrical power distribution subsystems.

The opposite unit electrical power distribution subsystems are needed to support the opposite unit ESW trains when the Essential Service Water (ESW) System headers between the units are not isolated. This change is acceptable because safety related equipment is shared between both units when an ESW header between the two units is opened. The added LCO requirement is consistent with the CTS because the definition of OPERABLE - OPERABILTY requires all attendant equipment to be capable of performing its required function, and the added ACTION is also consistent with the CTS. This change is designated as administrative because the CTS requirements are unchanged.

A.3 CTS 3.8.2.1 Action states that with less than the above complement of AC buses OPERABLE, to restore the inoperable bus to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

ITS 3.8.9 Required Action A.1 allows 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to restore the Train A and Train B AC electrical power distribution subsystem(s) to OPERABLE status. In addition, a Note has been added (ITS 3.8.9, Note to ACTION A) that requires entry into CNP Units 1 and 2 Page 1 of 7 Attachment 1, Volume 13, Rev. 0, Page 422 of 496

Attachment 1, Volume 13, Rev. 0, Page 423 of 496 DISCUSSION OF CHANGES ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING applicable Conditions and Required Action of LCO 3.8.4, "DC Sources -

Operating," for DC Sources made inoperable by inoperable power distribution subsystems. This changes the CTS by requiring the compensatory actions for DC Sources to be taken if a DC Source is made inoperable by inoperable power distribution subsystems.

This change is acceptable because no changes are made to CTS requirements.

The change in format from the CTS to the ITS maintains all technical requirements. The addition of the Note only acts as a reminder to enter the appropriate actions if the emergency bus which supplies the Train A or Train B 250 VDC battery charger becomes de-energized. In the event an emergency bus is inoperable such that a Train A or Train B 250 VDC battery charger were inoperable, ITS LCO 3.0.6 would allow taking only the Distribution System -

Operating ACTIONS; taking exception to complying with the DC Sources -

Operating ACTIONS. Since the Distribution System - Operating ACTIONS may not be sufficiently conservative in this event (i.e., a battery charger may be without power), specific direction to take appropriate ACTIONS for the DC Sources - Operating is added (ITS 3.8.9, Note to ACTION A) when there is no power to support the associated required 250 VDC battery charger. This format and construction implements the existing treatment of this condition within the framework of the CNP Units 1 and 2 Improved Technical Specification methods.

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

A.4 The CTS 3.8.2.5 Action states that with the Train N 250 VDC battery and/or its charger inoperable, to declare the turbine driven auxiliary feedwater pump inoperable "and follow the Action statement of Specification 3.7.1.2." ITS 3.8.9 ACTION E covers the situation when the Train N 250 VDC electrical power distribution subsystem is inoperable. ITS 3.8.9 Required Action E.1 is to declare the turbine driven auxiliary feedwater train inoperable. This changes the CTS by deleting the detail to follow the Action statement of Specification 3.7.1.2.

The purpose of the CTS 3.8.2.5 Action to follow the Action Statement of Specification 3.7.1.2 is to alert the user of the appropriate Specification to enter when the turbine driven auxiliary feedwater train is declared inoperable. It is an ITS convention to not include these types of cross-references. This change is designated as administrative as it incorporates an ITS convention with no technical change to the CTS.

MORE RESTRICTIVE CHANGES M.1 CTS 3.8.2.1 Action states that with less than the above complement of AC buses OPERABLE, to restore the inoperable bus to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

CTS 3.8.2.3 Action a states that with one 250 VDC bus inoperable, to restore the inoperable bus to OPERABLE status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . ITS 3.8.9 ACTION A covers the situation when one or both Train A and Train B AC electrical power distribution subsystems are inoperable. ITS 3.8.9 Required Action A.1 allows 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of failure to meet LCO 3.8.9.a, b, or c to restore the Train A and Train B AC electrical power distribution subsystem(s) to OPERABLE status. ITS 3.8.9 ACTION B covers the situation when one or both CNP Units 1 and 2 Page 2 of 7 Attachment 1, Volume 13, Rev. 0, Page 423 of 496

Attachment 1, Volume 13, Rev. 0, Page 424 of 496 DISCUSSION OF CHANGES ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING Train A and Train B 120 VAC vital electrical power distribution subsystems are inoperable. ITS 3.8.9 Required Action B.1 allows 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of failure to meet LCO 3.8.9.a, b, or c to restore the Train A and Train B 120 VAC vital electrical power distribution subsystem(s) to OPERABLE status. ITS 3.8.9 ACTION C covers the situation when one or both Train A and Train B 250 VDC electrical power distribution subsystems are inoperable.

ITS 3.8.9 Required Action C.1 allows 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months and 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of failure to meet LCO 3.8.9.a, b, or c to restore the Train A and Train B 250 VDC electrical power distribution subsystem(s) to OPERABLE status. This changes the CTS by establishing a maximum time allowed for any combination of distribution subsystems listed in ITS LCO 3.8.9.a, b, and c to be inoperable during any single contiguous occurrence of failing to meet the LCO.

The purpose of the CTS 3.8.2.1 is to limit the time AC buses can be inoperable.

The purpose of CTS 3.8.2.3 is to limit the time the DC buses can be inoperable.

The Completion Times of ITS 3.8.9 ACTIONS A, B, and C have a limitation in addition to the 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months limit of the CTS 3.8.2.1 Action or the 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months limit of CTS 3.8.2.3 Action a. This additional limit establishes a maximum time allowed for any combination of electrical power distribution subsystems listed in ITS LCO 3.8.9.a, b and c to be inoperable during any single contiguous occurrence of failing to meet the LCO. For example, if a Train A AC electrical distribution subsystem is inoperable while, for instance, a Train A DC electrical distribution subsystem is inoperable and subsequently returned to OPERABLE status, the LCO may already have been not met for up to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . This situation could lead to a total duration of 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months since initial failure of the LCO to restore the Train A DC electrical distribution system. Then, a Train A AC subsystem could again become inoperable, and the Train A DC electrical distribution subsystem restored to OPERABLE status. This could continue indefinitely. Therefore, to preclude this situation and place an appropriate restriction on any such unusual situation, the additional Completion Time of "16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of failure to meet LCO 3.8.9.a, b, or c" is proposed. This change is designated as more restrictive because an additional limitation has been placed on the Completion Times for electrical distribution subsystems.

M.2 CTS 3.8.2.1 Action states that with less than the above complement of AC buses OPERABLE, to restore the inoperable bus to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

CTS 3.8.2.3 Action a states that with one 250 VDC bus inoperable, to restore the inoperable bus to OPERABLE status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . CTS 3.8.2.5 Action states that with the Train N battery system inoperable, to declare the turbine driven auxiliary feedwater pump inoperable. However, there are no limitations to preclude a loss of function due to numerous concurrently inoperable AC and DC buses. ITS 3.8.9 ACTION G has been added, requiring entry into ITS 3.0.3 if the loss of two or more electrical power distribution subsystems results in a loss of safety function.

The purpose of the CTS Actions are to limit the time the unit can operate under these conditions. CTS 3.8.2.3 Action a specifies the compensatory actions for one inoperable DC bus. With two inoperable DC buses, CTS 3.8.2.3 does not provide any actions and entry into LCO 3.0.3 would be required. CTS 3.8.2.1 Action is applicable to all inoperable AC buses even if there is a loss of safety function. Certain combinations of inoperable AC and DC electrical power CNP Units 1 and 2 Page 3 of 7 Attachment 1, Volume 13, Rev. 0, Page 424 of 496

Attachment 1, Volume 13, Rev. 0, Page 425 of 496 DISCUSSION OF CHANGES ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING distribution subsystems will result in a loss of safety function (e.g., an inoperable Train A AC electrical power distribution subsystem in combination with an inoperable Train B 250 VDC electrical power distribution subsystem). ITS 3.8.9 includes ACTION G, which requires immediate entry into LCO 3.0.3 if the loss of one or more electrical power distribution subsystems results in a loss of safety function. ITS 3.8.9 Required Action G.1 preserves the intent of ITS LCO 3.0.3 and reflects an additional restriction on plant operation. This change is designated as more restrictive because an explicit action has been added which requires entry into LCO 3.0.3 with any combination of AC and/or DC buses inoperable that result in a loss of safety function.

M.3 CTS 4.8.2.1 states the specified AC buses shall be determined OPERABLE by verifying correct breaker alignment and "indicated power availability."

CTS 4.8.2.3.1 states that each DC bus train shall be demonstrated OPERABLE by verifying correct breaker alignment and "indicated power availability."

CTS 4.8.2.5.1 states that the DC bus Train N shall be determined OPERABLE by verifying correct breaker alignment and "indicated power availability." ITS SR 3.8.9.1 requires the verification of correct breaker alignments and "voltage" to required AC, DC, and 120 VAC vital bus electrical power distribution subsystems.

This changes the CTS by requiring the verification of the correct voltages to the required AC, DC, and 120 VAC vital bus electrical power distribution subsystems, whereas the CTS only requires verification of indicated power.

The purpose of this change is to ensure proper voltage is supplied to the required AC, DC, and 120 VAC vital bus electrical power distribution subsystems. This change is acceptable because the Surveillance will continue to verify OPERABILITY of the required AC, DC, and 120 VAC vital bus electrical power distribution subsystems. Proper voltage from the required subsystems ensures proper voltage is supplied to the required safety features. This change is designated as more restrictive because the ITS requires verification of the correct voltage, whereas the CTS only requires a verification of indicated power availability.

M.4 CTS 3.8.2.1 only specifies the AC electrical power distribution subsystem requirements for the given unit. It does not explicitly specify the requirements for the AC electrical power distribution subsystem requirements associated with the opposite unit. CTS 3.8.2.3 only specifies the DC electrical power distribution system requirements for the given unit. It does not explicitly specify the requirements for the DC electrical power distribution subsystem requirements associated with the opposite unit. CTS LCO 3.7.4.1 requires two independent essential service water (ESW) loops to be OPERABLE. The CTS 3/4.7.4 Bases state that the LCO also ensures that an inoperable opposite unit ESW pump does not result in flow being diverted from an OPERABLE unit ESW pump sharing the same header. Therefore, if the header between the two units is not isolated, both ESW pumps on the same header support both units. The CTS definition of OPERABLE - OPERABILITY requires all attendant equipment to be capable of performing its required function, which includes electrical power distribution subsystems. However, there are no specific requirements in the CTS requiring the testing of the opposite unit electrical power distribution subsystems.

ITS LCO 3.8.9.e requires the opposite unit Train A and Train B AC electrical power distribution subsystem(s) and the Train A and Train B 250 VDC electrical CNP Units 1 and 2 Page 4 of 7 Attachment 1, Volume 13, Rev. 0, Page 425 of 496

Attachment 1, Volume 13, Rev. 0, Page 426 of 496 DISCUSSION OF CHANGES ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING power distribution subsystem(s) required to support the equipment required to be OPERABLE by LCO 3.7.8, "Essential Service Water (ESW) System," to be OPERABLE. This change is discussed in DOC A.2. An explicit Surveillance Requirement has been added (SR 3.8.9.1) which requires the verification of correct breaker alignments and voltage to required opposite unit electrical power distribution subsystems. This changes the CTS by adding an explicit Surveillance Requirement for the opposite unit electrical power distribution subsystems to be applicable to the given unit Technical Specifications.

The purpose of Surveillance Requirements is to ensure the OPERABILITY of required equipment. An explicit SR (ITS SR 3.8.9.1) has been added that requires the verification of correct breaker alignments and voltage to required opposite unit AC and DC electrical power subsystems. The added Surveillance helps to ensure the required opposite unit AC and DC electrical power distribution subsystems remain OPERABLE. This change is designated as more restrictive because an additional Surveillance Requirement will be applicable to the CTS.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS LCO 3.8.2.1 requires the AC electrical buses to be OPERABLE "and energized with tie breakers open between redundant busses." CTS 4.8.2.1 also requires the AC buses to be determined OPERABLE "and energized from AC sources with tie breakers open between redundant busses" by verifying correct breaker alignment and indicated power availability.

CTS LCO 3.8.2.3 requires the DC bus trains to be "energized" and OPERABLE "with tie breakers between bus trains open." CTS 4.8.2.3.1 requires the DC bus trains to be determined OPERABLE "and energized with tie breakers between bus trains open" by verifying correct breaker alignment and indicated power availability. CTS 3.8.2.5 requires the Train N bus to be "energized" and OPERABLE. CTS 4.8.2.5.1 also requires the Train N bus to be OPERABLE and "energized" by verifying correct breaker alignment and indicated power availability. ITS LCO 3.8.9 requires the applicable electrical power distribution subsystems to be OPERABLE and ITS SR 3.8.9.1 requires the verification of correct breaker alignments and voltage to required AC, DC, and 120 VAC vital bus electrical power distribution subsystems. This changes the CTS by moving the procedural detail that the buses must be energized with tie breakers open between redundant buses from the CTS to the ITS Bases.

The removal of these details for meeting Technical Specification requirements from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement for the electrical power distribution subsystems to be OPERABLE CNP Units 1 and 2 Page 5 of 7 Attachment 1, Volume 13, Rev. 0, Page 426 of 496

Attachment 1, Volume 13, Rev. 0, Page 427 of 496 DISCUSSION OF CHANGES ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING and requires the verification of correct breaker alignments and voltage to required AC, DC, and 120 VAC vital bus electrical power distribution subsystems.

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

LA.2 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS LCO 3.8.2.1 requires the AC electrical buses to be OPERABLE and lists the specific AC and 120 VAC vital buses, including the applicable nominal bus voltage. CTS LCO 3.8.2.3 requires the Trains AB (Train B) and CD (Train A) DC buses to be OPERABLE and lists the specific buses. CTS LCO 3.8.2.5 requires the Train N bus (Bus N) to be OPERABLE.

ITS LCO 3.8.9 requires the applicable electrical power distribution subsystems to be OPERABLE, and lists the Train A and Train B AC electrical power distribution subsystems; Train A and Train B 120 VAC vital bus electrical power distribution subsystems; Train A and Train B 250 VDC distribution subsystems; and the Train N 250 VDC distribution subsystem. This changes the CTS by moving the specific names of the buses and the associated nominal bus voltages (i.e.,

4160 V and 600 V) from the CTS to the ITS Bases.

The removal of these details, which are related to system design, from the Technical Specifications, is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. ITS 3.8.9 still retains the requirement for the required buses to be OPERABLE. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases.

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

LESS RESTRICTIVE CHANGES L.1 (Category 1 - Relaxation of LCO Requirements) CTS LCO 3.8.2.1 footnote

requires the 120 VAC vital buses to be energized from their associated inverters connected to a DC bus. There is no other LCO requirement for the inverters to be OPERABLE. In the ITS, the inverters are placed in a separate Specification (either ITS 3.8.7 for MODES 1, 2, 3, and 4 or ITS 3.8.8 for the MODES 5 and 6, and during movement of irradiated fuel assemblies in the containment, auxiliary building, and opposite unit containment). The 120 VAC vital buses remain in their own separate Specifications during these same conditions (ITS 3.8.9 and ITS 3.8.10, respectively). When an inverter is inoperable, a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months allowed time is provided to restore the inverter to OPERABLE status. During this 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , the 120 VAC vital bus remains OPERABLE provided it is energized. In the ISTS Bases, the 120 VAC vital buses remain OPERABLE as long as they can be CNP Units 1 and 2 Page 6 of 7 Attachment 1, Volume 13, Rev. 0, Page 427 of 496

Attachment 1, Volume 13, Rev. 0, Page 428 of 496 DISCUSSION OF CHANGES ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING energized from a qualified source. The CNP ITS 3.8.9 Bases state that the qualified sources are the inverter powered from DC Sources and the Class 1E regulated 600/120 VAC transformer via the inverter. This changes the CTS by allowing the 120 VAC vital buses to be called OPERABLE when powered from a source other than the inverter connected to a DC bus.

The purpose of CTS LCO 3.8.2.1 footnote

is to provide requirements for the inverters. This requirement is maintained in ITS LCO 3.8.7 and LCO 3.8.8. For the 120 VAC vital buses to be OPERABLE, they only need to be powered from a qualified source (i.e., each of the allowed sources can carry the required loads on the associated vital bus). This change is acceptable because both the DC Source and the 120 VAC Class 1E regulated 600/120 VAC transformer are qualified sources capable of providing the necessary voltage, frequency, and capacity to the associated 120 VAC vital bus. 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 7 of 7 Attachment 1, Volume 13, Rev. 0, Page 428 of 496

Attachment 1, Volume 13, Rev. 0, Page 429 of 496 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

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Attachment 1, Volume 13, Rev. 0, Page 431 of 496 3.8.9 1

INSERT 1 LCO 3.8.2.1 a. Train A and Train B AC electrical power distribution subsystems; LCO 3.8.2.1 b. Train A and Train B 120 VAC vital bus electrical power distribution subsystems; LCO 3.8.2.3 c. Train A and Train B 250 VDC electrical power distribution subsystems; LCO 3.8.2.5 d. Train N 250 VDC electrical power distribution subsystem; and DOC A.2 e. The Unit 2 (Unit 1) and Unit 1 (Unit 2) Train A and Train B AC electrical power distribution subsystem(s) and Train A and Train B 250 VDC electrical power distribution subsystem(s) required to support the equipment required to be OPERABLE by LCO 3.7.8, "Essential Service Water (ESW) System."

1 INSERT 2

-NOTE-Train N 250 VDC electrical power distribution subsystem is not required to be OPERABLE in MODE 4.

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Attachment 1, Volume 13, Rev. 0, Page 433 of 496 3.8.9 1

INSERT 3 3.8.2.5 Action E. Required Train N 250 E.1 Declare the turbine Immediately VDC electrical power driven auxiliary distribution subsystem feedwater train inoperable. inoperable.

DOC A.2 F. One or more required F.1 Declare associated Immediately Unit 2 (Unit 1) and Unit 1 ESW train(s)

(Unit 2) electrical inoperable.

distribution subsystems inoperable.

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Attachment 1, Volume 13, Rev. 0, Page 434 of 496 JUSTIFICATION FOR DEVIATIONS ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING

1. ISTS LCO 3.8.9 and Applicability have been revised to reflect the plant specific design for CNP Units 1 and 2. Additional requirements were added as ITS LCO 3.8.9 to ensure the appropriate electrical power distribution subsystems of the opposite unit are OPERABLE to support unit operation. This change was necessary due to a shared system (Essential Service Water System) between both units. In addition, ITS 3.8.9 ACTION F has been added to declare the associated Essential Service Water train inoperable when an opposite unit electrical power distribution subsystem is inoperable, since this is the only system affected by the inoperable opposite unit electrical power distribution subsystems. Due to this change and the Train N 250 VDC requirements, the second Completion Times for Required Actions A.1, B.1, and C.1 have been revised to not reflect the LCO 3.8.9.d and e requirements, since the associated system could be declared inoperable. Finally, the allowance in ISTS 3.8.9 ACTION C to have one or more DC electrical power distribution subsystems inoperable for 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months has been changed to address only the inoperability of one Train A or Train B 250 V DC subsystem, since if both the Train A and Train B buses were inoperable, then a loss of safety function would exist and entry into ACTION G would be necessary.

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

3. Change made to be consistent with another Specification.

4. The current licensing basis time allowed to restore an inoperable 120 VAC vital bus electrical power distribution subsystem is 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . Therefore, this time has been maintained.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 434 of 496

Attachment 1, Volume 13, Rev. 0, Page 435 of 496 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

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Attachment 1, Volume 13, Rev. 0, Page 437 of 496 B 3.8.9 2

INSERT 1

, as required by Safety Guide 6 (Ref. 1). The exception is the Train N DC electrical power distribution subsystem which supports the turbine driven auxiliary feedwater (AFW) train.

Unit 2 (Unit 1) and Unit 1 (Unit 2) also has an identical electrical power distribution system. When the Essential Service Water (ESW) trains are not isolated from Unit 2 (Unit 1) and Unit 1 (Unit 2), the associated Unit 2 (Unit 1) and Unit 1 (Unit 2) electrical power distribution subsystems (except for the Train N DC electrical power distribution subsystem) are required to support Unit 1 (Unit 1) and Unit 2 (Unit 2) operation.

2 INSERT 2 the main generator via the unit auxiliary transformer.

2 INSERT 3 by a main generator trip signal. A 4.16 kV emergency bus can be manually transferred to the alternate offsite source.

2 INSERT 4 The Unit 2 (Unit 1) and Unit 1 (Unit 2) AC electrical power distribution subsystems are also included in the table since they are required to support Unit 1 (Unit 1) and Unit 2 (Unit 2) operations when the associated ESW train is not isolated.

2 INSERT 5 The Train N 250 VDC electrical power subsystem consists of one bus and supports the operation of the turbine driven auxiliary feedwater train.

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Attachment 1, Volume 13, Rev. 0, Page 438 of 496 B 3.8.9 2 INSERT 6 The Unit 2 (Unit 1) and Unit 1 (Unit 2) Train A and Train B 250 V DC electrical power distribution subsystem buses are also included in the table since they are required to support Unit 1 (Unit 1) and Unit 2 (Unit 2) operations when the associated ESW train is not isolated. The Unit 2 (Unit 1) and Unit 1 (Unit 2) Train N 250 VDC electrical power distribution subsystem is not required to support Unit 1 (Unit 1) and Unit 2 (Unit 2) operations.

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Attachment 1, Volume 13, Rev. 0, Page 442 of 496 B 3.8.9 2

INSERT 8A Based on the number of safety significant electrical loads associated with each bus listed in Table B 3.8.9-1, if one or more of the buses becomes inoperable, entry into the appropriate ACTIONS of LCO 3.8.9 is required. Some buses, such as distribution panels, which help comprise the AC and DC distribution systems, are not listed in Table B 3.8.9-1. The loss of electrical loads associated with these buses may not result in a complete loss of a redundant safety function necessary to shut down the reactor and maintain it in a safe condition. Therefore, should one or more of these buses become inoperable due to a failure not affecting the OPERABILITY of a bus listed in Table B 3.8.9-1 (e.g., a breaker supplying a single distribution panel fails open), the individual loads on the bus would be declared inoperable, and the appropriate Conditions and Required Actions of the LCOs governing the individual loads would be entered.

However, if one or more of these buses is inoperable due to a failure also affecting the OPERABILITY of a bus listed in Table B 3.8.9-1 (e.g., loss of 4.16 kV emergency bus, which results in de-energization of all buses powered from the 4.16 kV emergency bus),

then although the individual loads are still considered inoperable, the Conditions and Required Actions of the LCO for the individual loads are not required to be entered, since LCO 3.0.6 allows this exception (i.e., the loads are inoperable due to the inoperability of a support system governed by a Technical Specification; the 4.16 kV emergency bus).

2 INSERT 8B that are not being powered from their normal source (i.e., they are being powered from their redundant electrical power distribution subsystem) 4 INSERT 9 The Train A and Train B AC, Train A and Train B 120 VAC vital bus, Train A and Train B 250 VDC, and the Unit 2 (Unit 1) and Unit 1 (Unit 2) Train A and Train B AC and Train A and Train B 250 VDC 4

INSERT 10 The Train N 250 VDC electrical power distribution subsystem is required to be OPERABLE in MODES 1, 2, and 3 to support the turbine driven auxiliary feedwater train in the event that it is called upon to function when the Main Feedwater System is lost.

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INSERT 12 electrical power distribution subsystem(s) 4 INSERT 13 Train A or Train B 250 V 4

INSERT 14 electrical power distribution subsystem Insert Page B 3.8.9-6 Attachment 1, Volume 13, Rev. 0, Page 447 of 496

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INSERT 15 If any Required Action and associated Completion Time of Condition A, B, or C is not

met, 4

INSERT 16 E.1 With the required Train N 250 VDC electrical power distribution system inoperable, the Train N powered system is not capable of performing its intended function. Immediately declaring the affected supported feature (e.g., the turbine driven AFW System) inoperable allows the ACTIONS of LCO 3.7.5, "Auxiliary Feedwater System (AFW)," to apply appropriate limitations on continued reactor operation.

F.1 With the required portions of the Unit 2 (Unit 1) and Unit 1 (Unit 2) Train A and Train B AC electrical power distribution subsystems and Train A and Train B 250 VDC electrical power distribution subsystems inoperable, the associated ESW train is not capable of performing its intended function. Immediately declaring the affected supported feature (i.e., the ESW train) inoperable allows the ACTIONS of LCO 3.7.8 to apply appropriate limitations on continued reactor operation.

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INSERT 17 (UNIT 2 only)

Table B 3.8.9-1 (page 1 of 1)

AC, DC, and 120 VAC Vital Bus Electrical Power Distribution Systems TYPE VOLTAGE TRAIN A(a),(b) TRAIN B(a),(b) TRAIN N(a)

AC Buses 4.16kV Emergency Bus Emergency Bus Not Applicable T 21C, T 21D T 21A, T 21B 600 V Emergency Bus Emergency bus 21C, 21D 21A, 21B DC Buses 250 V Main Distribution Main Distribution Battery Distribution Cabinet CD Cabinet AB Cabinet N AC Vital 120 V Instrument Instrument Not Applicable Buses Distribution Cabinet Distribution Cabinet Channels I and II Channels III and IV (a) Each train of the AC, DC, and 120 VAC Vital Bus Electrical Power Distribution Systems is a subsystem.

(b) If the ESW crosstie header associated with Train A ESW pump is not isolated, the following Unit 1 buses are required to be OPERABLE: 4.16 kV Emergency Bus T 11A and 250 V Main Distribution Cabinet AB. If the ESW crosstie header associated with Train B ESW pump is not isolated the following Unit 1 buses are required to be OPERABLE: 4.16 kV Emergency Bus T 11D and 250 V Main Distribution Cabinet CD.

Insert Page B 3.8.9-9 (Unit 2 only)

Attachment 1, Volume 13, Rev. 0, Page 453 of 496

Attachment 1, Volume 13, Rev. 0, Page 454 of 496 JUSTIFICATION FOR DEVIATIONS ITS 3.8.9 BASES, DISTRIBUTION SYSTEMS - OPERATING

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

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

3. Changes are made to be consistent with the Applicability of ITS LCO 3.8.10.

4. Changes are made to the Bases which reflect changes made to the Specifications.

5. Editorial change made for enhanced clarity or to be consistent with the Writer's Guide for the Improved Standard Technical Specification, NEI 01-03.

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

7. Typographical/grammatical error corrected.

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

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 454 of 496

Attachment 1, Volume 13, Rev. 0, Page 455 of 496 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 13, Rev. 0, Page 455 of 496

Attachment 1, Volume 13, Rev. 0, Page 456 of 496 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 456 of 496

, Volume 13, Rev. 0, Page 457 of 496 ATTACHMENT 10 ITS 3.8.10, Distribution Systems - Shutdown , Volume 13, Rev. 0, Page 457 of 496

, Volume 13, Rev. 0, Page 458 of 496 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 13, Rev. 0, Page 458 of 496

Attachment 1, Volume 13, Rev. 0, Page 459 of 496 ITS 3.8.10 ITS A.1 M.1 LA.1 The necessary portions of the LCO 3.8.10 distribution subsystem LA.2 A.5 Add proposed ACTIONS Note A.2 ACTION A Add proposed Required Action A.1 M.1 L.1 additions that could result in loss of required SDM or boron concentration LA.1 SR 3.8.10.1 voltage M.2 See ITS 3.8.8 Page 1 of 4 Attachment 1, Volume 13, Rev. 0, Page 459 of 496

Attachment 1, Volume 13, Rev. 0, Page 460 of 496 ITS 3.8.10 ITS A.1 M.1 LA.1 The necessary portions of the LA.2 LCO 3.8.10 See ITS See ITS distribution subsystem 3.8.5 3.8.5 A.5 Add proposed ACTIONS Note A.2 See ITS 3.8.5 ACTION A Add proposed Required Action A.1 M.1 L.1 additions that could result in loss of required SDM or boron concentration See ITS 3.8.5 LA.1 SR 3.8.10.1 M.2 voltage See ITS 3.8.5 and 3.8.6 Page 2 of 4 Attachment 1, Volume 13, Rev. 0, Page 460 of 496

Attachment 1, Volume 13, Rev. 0, Page 461 of 496 ITS 3.8.10 ITS A.1 M.1 The necessary portions of the LA.1 distribution subsystem LA.2 Unit 1 electrical power distribution A.3 subsystem requirements During movement of irradiated fuel assemblies in the A.4 containment, auxiliary building, and Unit 1 containment Add proposed ACTIONS Note A.2 ACTION A Add proposed Required Action A.1 M.1 L.1 additions that could result in loss of required SDM or boron concentration A.3 Add proposed ACTION B LA.1 SR 3.8.10.1 voltage M.2 Add proposed SR 3.8.10.1 M.3 for Unit 1 electrical power distribution subsystem requirements See ITS 3.8.8 Page 3 of 4 Attachment 1, Volume 13, Rev. 0, Page 461 of 496

Attachment 1, Volume 13, Rev. 0, Page 462 of 496 ITS 3.8.10 ITS A.1 M.1 LA.1 The necessary portions of the LA.2 LCO 3.8.10 See ITS distribution subsystem See ITS 3.8.5 3.8.5 A.4 During movement of irradiated fuel assemblies in the containment, auxiliary building, and Unit 1 containment A.2 Add ACTIONS Note See ITS 3.8.5 ACTION A Add proposed Required Action A.1 M.1 L.1 additions that could result in loss of required SDM or boron concentration See ITS 3.8.5 LA.1 SR 3.8.10.1 M.2 voltage See ITS 3.8.5 and 3.8.6 Page 4 of 4 Attachment 1, Volume 13, Rev. 0, Page 462 of 496

Attachment 1, Volume 13, Rev. 0, Page 463 of 496 DISCUSSION OF CHANGES ITS 3.8.10, DISTRIBUTION SYSTEMS - SHUTDOWN ADMINISTRATIVE CHANGES A.1 In the conversion of the CNP Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 2, "Standard Technical Specifications-Westinghouse Plants" (ISTS).

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

A.2 Unit 1 CTS 3.8.2.2 and CTS 3.8.2.4 are applicable during MODES 5 and 6, and during the movement of irradiated fuel. Unit 2 CTS 3.8.2.2 and CTS 3.8.2.4 are applicable during MODES 5 and 6. ITS 3.8.10 is applicable in MODES 5 and 6, and during the movement of irradiated fuel assemblies in the containment, auxiliary building, and Unit 2 (Unit 1) and Unit 1 (Unit 2) containment. However, a Note has been added to the ACTIONS which states that LCO 3.0.3 is not applicable. This changes the CTS by adding the Note to the ACTIONS stating that LCO 3.0.3 is not applicable.

The purpose of CTS 3.8.2.2 and 3.8.2.4 is to ensure that at least one train of AC and DC electrical distribution buses are OPERABLE to support equipment required to be OPERABLE. This change adds a clarification Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODES 5 or 6, LCO 3.0.3 is not applicable and would not specify any action. If moving irradiated fuel assemblies while in MODES 1, 2, 3, or 4, the fuel movement is independent of reactor operations and the inability to suspend movement in accordance with the ITS 3.8.10 Required Actions would not be sufficient reason to require a reactor shutdown. This Note has been added for clarification and is necessary since defaulting to LCO 3.0.3 would require the reactor to be shutdown, but would not require suspension of the activities with a potential for releasing radioactive materials. This change is designated as administrative as it is a clarification of the intent of CTS 3.0.3 that does not result in a technical change to the CTS.

A.3 (Unit 2 only) CTS 3.8.2.2 only provides the requirements for the unit AC electrical power distribution subsystems. The Specification does not provide any requirements for the Unit 1 AC electrical power distribution subsystems.

CTS 3.9.12 requires the Fuel Handling Area Exhaust Ventilation (FHAEV)

System to be OPERABLE whenever irradiated fuel is in the storage pool. The CTS definition of OPERABLE - OPERABILITY requires all attendant equipment to be capable of performing its required function, and includes necessary electrical power distribution requirements. Thus, a Unit 1 AC electrical power distribution subsystem may be required to be OPERABLE. In addition, this would require declaring the FHAEV System inoperable when a required Unit 1 bus is inoperable. Unit 2 ITS LCO 3.8.10 requires a Unit 1 electrical power distribution subsystem to be OPERABLE to support equipment required to be OPERABLE. ITS 3.8.10 ACTION B has been added to immediately declare associated Fuel Handling Area Exhaust Ventilation (FHAEV) System inoperable when a required Unit 1 AC electrical power distribution subsystem is inoperable.

CNP Units 1 and 2 Page 1 of 7 Attachment 1, Volume 13, Rev. 0, Page 463 of 496

Attachment 1, Volume 13, Rev. 0, Page 464 of 496 DISCUSSION OF CHANGES ITS 3.8.10, DISTRIBUTION SYSTEMS - SHUTDOWN This changes the Unit 2 CTS by providing an explicit LCO and ACTION for the Unit 1 AC electrical power distribution subsystem.

The purpose of CTS 3.8.2.2 is to ensure at least one train of electrical power distribution system is OPERABLE. The explicit requirements for a Unit 1 electrical power distribution subsystem are not included in CTS 3.8.2.2.

However, the FHAEV System, a shared system between the Units, is powered from Unit 1. The added LCO requirement is consistent with the CTS since the definition of OPERABLE-OPERABILITY requires all attendant equipment to be capable of performing its required function, and the added ACTION is also consistent with the CTS. This change is designated as administrative because the Unit 2 CTS requirements are unchanged.

A.4 (Unit 2 only) CTS 3.8.2.2 and CTS 3.8.2.4 are applicable during MODES 5 and 6.

However, the CTS 3.8.2.2 Action and CTS 3.8.2.4 Action require movement of irradiated fuel assemblies to be suspended if the required AC or DC electrical equipment is inoperable. ITS 3.8.10 is applicable in MODES 5 and 6, and during the movement of irradiated fuel assemblies in the containment, auxiliary building, and Unit 1 containment. This changes the Unit 2 CTS by adding the explicit Applicability of during movement of irradiated fuel assemblies in the containment, auxiliary building, and Unit 1 containment.

The purpose of CTS 3.8.2.2 and CTS 3.8.2.4 is to ensure that the appropriate AC and DC buses are OPERABLE to support equipment required to be OPERABLE.

This change adds the explicit Applicability of during movement of irradiated fuel assemblies in the containment, auxiliary building, and Unit 1 containment. This Applicability is consistent with the Applicability of Unit 1 CTS 3.8.2.2 and CTS 3.8.2.4, and consistent with the Unit 2 CTS 3.8.2.2 and 3.8.2.4 Actions, which state to suspend movement of irradiated fuel when the AC and DC buses are inoperable. This change is designated as administrative as it is a clarification of the intent of Unit 2 CTS 3.8.2.2 and Unit 2 CTS 3.8.2.4 that does not result in a technical change to the Unit 2 CTS.

A.5 (Unit 1 only) CTS 3.8.2.2 Applicability and CTS 3.8.2.4 Applicability include "during movement of irradiated fuel." ITS 3.8.10 Applicability includes "During movement of irradiated fuel assemblies in the containment, auxiliary building, and Unit 2 containment." This changes the Unit 1 CTS by clarifying the locations that fuel movement is taking place.

The purpose of CTS 3.8.2.2 and CTS 3.8.2.4, with respect to fuel handling, is to ensure adequate AC and DC buses are available to power equipment required to mitigate a fuel handling accident event. This protection is required during irradiated fuel movement in three locations: the unit containment, the auxiliary building, and the opposite unit containment. Therefore, for clarity, all three locations are specified in the ITS Applicability, in lieu of the current wording which just specifies irradiated fuel movement. This change is designated as administrative because it does not result in any technical changes to the Unit 1 CTS.

CNP Units 1 and 2 Page 2 of 7 Attachment 1, Volume 13, Rev. 0, Page 464 of 496

Attachment 1, Volume 13, Rev. 0, Page 465 of 496 DISCUSSION OF CHANGES ITS 3.8.10, DISTRIBUTION SYSTEMS - SHUTDOWN MORE RESTRICTIVE CHANGES M.1 CTS LCO 3.8.2.2 requires a minimum of one 4160 V emergency bus, one 600 V emergency bus, and two 120 VAC vital buses to be OPERABLE. CTS LCO 3.8.2.4 requires one 250 VDC bus to be OPERABLE. The existing requirement of CTS LCO 3.8.2.2 and LCO 3.8.2.4 for distribution buses to be OPERABLE during shutdown conditions is not specific as to what the system must be powering. ITS 3.8.10 specifies that the necessary portions of Train A and Train B AC, Train A and Train B 250 VDC, and Train A and Train B 120 VAC vital bus electrical power distribution subsystems must be OPERABLE to support equipment required to be OPERABLE. In addition, an optional Required Action (ITS 3.8.10 Required Action A.1) has been added which allows the associated supported required feature(s) to be declared inoperable. This change adds a requirement that the applicable portions of Train A and Train B AC, Train A and Train B 250 VDC, and Train A and Train B 120 VAC vital bus electrical power distribution subsystems must be OPERABLE when required to support equipment required to be OPERABLE by the Technical Specifications. This could require more buses to be OPERABLE than is currently required. In addition, an action has been added to allow an option to the existing actions.

The purpose of CTS 3.8.2.2 and CTS 3.8.2.4 is to ensure that at least one train of AC, DC and 120 VAC vital bus electrical power distribution systems are OPERABLE. This change adds a requirement that the applicable portions of Train A and Train B AC, Train A and Train B 250 VDC, and Train A and Train B 120 VAC vital bus electrical power distribution subsystems must be OPERABLE when required to support equipment required to be OPERABLE by the Technical Specifications. This added restriction conservatively assures the needed electrical power distribution buses are OPERABLE, even if this results in both the trains of one or more of the electrical power distribution systems being required.

Since the ITS 3.8.10 electrical power distribution subsystem OPERABILITY requirements require the necessary portions of the distribution subsystems to be OPERABLE to support equipment required to be OPERABLE, if a portion of the electrical power distribution subsystem cannot supply any required equipment, that electrical power distribution subsystem is inoperable. In this event it may not be necessary to suspend all CORE ALTERATIONS, irradiated fuel handling, and positive reactivity additions. Conservative actions can be assured if all required equipment without the necessary power is declared inoperable, and the associated ACTIONS of the individual equipment is taken (ITS 3.8.10 Required Action A.1). Therefore, along with the conservative additional requirements placed on the electrical power distribution subsystems, Required Action A.1, which requires the associated supported equipment to be declared inoperable, is also added. These changes are acceptable since the additions represent restrictions consistent with implicit assumptions for operation in shutdown conditions (required equipment receiving the necessary required power), and these restrictions are not currently imposed by the Technical Specifications. This change is designated as more restrictive because it adds a new requirement to the CTS.

M.2 CTS 4.8.2.2 and CTS 4.8.2.4.1 state the specified buses shall be determined OPERABLE by verifying correct breaker alignment and "indicated power availability." ITS SR 3.8.10.1 requires the verification of correct breaker CNP Units 1 and 2 Page 3 of 7 Attachment 1, Volume 13, Rev. 0, Page 465 of 496

Attachment 1, Volume 13, Rev. 0, Page 466 of 496 DISCUSSION OF CHANGES ITS 3.8.10, DISTRIBUTION SYSTEMS - SHUTDOWN alignments and "voltage" to required AC, DC, and 120 VAC vital buses electrical power distribution subsystems. This changes the CTS by requiring the verification of the correct voltages to the required AC, DC, and 120 VAC vital bus electrical power distribution subsystems, whereas the CTS only requires verification of indicated power availability.

The purpose of this change is to ensure proper voltage is supplied to the required AC, DC, and 120 VAC vital buses electrical power distribution subsystems. This change is acceptable because the Surveillance will continue to verify OPERABILITY of the required AC, DC, and 120 VAC vital bus electrical power distribution subsystems. Proper voltage from the required subsystems ensures proper voltage is supplied to the required safety features. This change is designated as more restrictive because the ITS requires verification of the correct voltage, whereas the CTS only requires a verification of indicated power availability.

M.3 (Unit 2 only) CTS 3.8.2.2 requires one AC electrical power distribution subsystem to be OPERABLE. The required AC electrical power distribution subsystem buses are Unit 2 buses. CTS 3.9.12 requires the Fuel Handling Area Exhaust Ventilation (FHAEV) System (which is powered from Unit 1 AC buses) to be OPERABLE whenever irradiated fuel is in the storage pool. The CTS definition of "OPERABLE-OPERABILITY" requires all attendant equipment to be capable of performing its required function. However, there are no specific requirements in CTS 3.8.2.2 requiring the testing of the Unit 1 AC electrical power distribution subsystem buses that support the FHAEV System. Unit 2 ITS LCO 3.8.10 requires a Unit 1 electrical power distribution subsystem to support equipment required to be OPERABLE. This change is discussed in DOC A.3. An explicit SR (ITS SR 3.8.10.1) has been added which requires the verification of correct breaker alignments and voltage to the required Unit 1 electrical power distribution subsystem. This changes the Unit 2 CTS by explicitly requiring a Surveillance Requirement for the Unit 1 AC electrical power distribution subsystem required to be OPERABLE to support Unit 2 operation.

The purpose of Surveillance Requirements is to ensure the OPERABILITY of required equipment. An explicit SR (ITS SR 3.8.10.1) has been added which requires the verification of correct breaker alignments and voltage to required Unit 1 AC electrical power distribution subsystem. The added Surveillance helps to ensure the required Unit 1 AC electrical power distribution subsystem remains OPERABLE. This change is designated as more restrictive because an additional Surveillance Requirement will be applicable to the Unit 2 Technical Specifications.

RELOCATED SPECIFICATIONS None CNP Units 1 and 2 Page 4 of 7 Attachment 1, Volume 13, Rev. 0, Page 466 of 496

Attachment 1, Volume 13, Rev. 0, Page 467 of 496 DISCUSSION OF CHANGES ITS 3.8.10, DISTRIBUTION SYSTEMS - SHUTDOWN REMOVED DETAIL CHANGES LA.1 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS LCO 3.8.2.2 requires the AC electrical buses to be OPERABLE and "energized." CTS 4.8.2.2 also requires the AC buses to be demonstrated OPERABLE and "energized" by verifying correct breaker alignment and indicated power availability. CTS LCO 3.8.2.4 requires the DC bus to be "energized" and OPERABLE. CTS 4.8.2.4.1 requires the verification that the DC bus is determined OPERABLE and "energized" by verifying correct breaker alignment and indicated power availability. ITS LCO 3.8.10 requires the applicable electrical power distribution subsystems to be OPERABLE and ITS SR 3.8.10.1 requires the verification of correct breaker alignments and voltage to each required AC, DC, and 120 VAC vital bus electrical power distribution subsystems. This changes the CTS by moving the procedural detail that the buses must be energized from the CTS to the ITS Bases.

The removal of these details for meeting Technical Specification requirements from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement for the electrical power distribution subsystems to be OPERABLE and requires the verification of correct breaker alignment and voltage to required AC, DC, and 120 VAC vital bus electrical power distribution subsystems. Also, this change is acceptable because these types of procedural details will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications.

LA.2 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS LCO 3.8.2.2 requires AC electrical buses to be OPERABLE and specifies nominal bus voltages. CTS LCO 3.8.2.4 requires a 250 VDC bus to be OPERABLE and specifies bus voltage. ITS LCO 3.8.10 requires necessary portions of the AC, DC, and 120 VAC vital bus electrical power distribution subsystems to be OPERABLE to support equipment required to be OPERABLE.

ITS SR 3.8.10.1 requires the verification of correct breaker alignment and voltage to each required AC, DC, and 120 VAC vital bus electrical power distribution subsystems. This changes the CTS by moving description of the buses (including the nominal bus voltages) from the Specification to the Bases. Other changes to CTS LCO 3.8.2.2 and CTS LCO 3.8.2.4 are discussed in DOCs M.1 and LA.1.

The removal of these details, which are related to system design, from the Technical Specifications, is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement for the electrical power distribution subsystems to be OPERABLE and requires the verification of correct breaker alignment and voltage to required AC and DC electrical power distribution subsystems. This change is acceptable because the CNP Units 1 and 2 Page 5 of 7 Attachment 1, Volume 13, Rev. 0, Page 467 of 496

Attachment 1, Volume 13, Rev. 0, Page 468 of 496 DISCUSSION OF CHANGES ITS 3.8.10, DISTRIBUTION SYSTEMS - SHUTDOWN removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L.1 (Category 4 - Relaxation of Required Action) CTS 3.8.2.2 Action a specifies the compensatory actions for a required inoperable AC electrical power distribution subsystem. CTS 3.8.2.4 Action a specifies the compensatory actions for an inoperable required DC electrical power distribution subsystem. The compensatory actions for both Specifications are identical. One of the compensatory actions is the suspension of positive reactivity "changes except: 1) heatup or cooldown of the reactor coolant volume provided that SHUTDOWN MARGIN sufficient to accommodate the change in temperature is maintained in accordance with Specification 3.1.1.2 in MODE 5 or Specification 3.9.1 in MODE 6, and the heatup or cooldown rate is restricted to 50°F or less in any one-hour period in MODE 5, or 2) addition of water from the RWST, provided the boron concentration in the RWST is greater than or equal to the minimum required by Specification 3.1.2.7.b.2." ITS 3.8.10 Required Action A.2.3 requires the immediate suspension of operations involving positive reactivity "additions that could result in loss of required SDM or boron concentration." This changes the CTS compensatory actions by deleting the limitation on the heatup and cooldown rates of 50ºF or less in any one hour period in MODE 5 and allows the addition of water from any source including the RWST as long as SDM and boron concentration limitations are met.

The purpose of the CTS 3.8.2.2 Action a and CTS 3.8.2.4 Action a is to suspend any positive reactivity additions that could affect the SDM of the reactor core.

This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, 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 CTS allows two types of positive reactivity changes (heatup/cooldown and addition of water).

Heatup and cooldown of the reactor coolant volume are allowed provided SDM is sufficient to accommodate the change in temperature in accordance with CTS 3.1.1.2 in MODE 5 or CTS 3.9.1 in MODE 6. The requirements of these Specifications are included in ITS LCO 3.1.1, "SHUTDOWN MARGIN (SDM),"

and ITS LCO 3.9.1, "Boron Concentration," respectively. Therefore, there is no technical change in this portion of the change. The Bases provides the appropriate cross-reference to the appropriate LCOs. The CTS also allows positive reactivity changes by the addition of water from the RWST provided the boron concentration in the RWST is greater than or equal to the minimum required by CTS 3.1.2.7.b.2. CTS 3.1.2.7.b.2 has been relocated to the TRM as CNP Units 1 and 2 Page 6 of 7 Attachment 1, Volume 13, Rev. 0, Page 468 of 496

Attachment 1, Volume 13, Rev. 0, Page 469 of 496 DISCUSSION OF CHANGES ITS 3.8.10, DISTRIBUTION SYSTEMS - SHUTDOWN indicated in the Discussion of Changes for CTS LCO 3/4.1.2.7. CTS 3/4.1.2.7 is applicable during MODE 5 and 6 operations. The proposed Required Actions require the suspension of operations involving positive reactivity additions that could result in loss of required SDM or boron concentration. The requirements for SDM are specified in ITS LCO 3.1.1 while the requirements for boron concentration are specified in ITS LCO 3.9.1. The current and proposed actions may result in an overall reduction in SDM or RCS boron concentration, but provide acceptable margin to maintaining subcritical operation. The CTS compensatory action restricted the heatup and cooldown rates of the RCS to 50ºF or less in any one-hour period in MODE 5. This limitation has been deleted.

The proposed Required Action is to suspend operations involving positive reactivity additions that could result in loss of required SDM or boron concentration. These limitations are considered acceptable. The Bases also indicate that introduction of temperature changes including temperature increases when operating with a positive moderator temperature coefficient must be evaluated to ensure they do not result in a loss of required SDM. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

CNP Units 1 and 2 Page 7 of 7 Attachment 1, Volume 13, Rev. 0, Page 469 of 496

Attachment 1, Volume 13, Rev. 0, Page 470 of 496 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

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Attachment 1, Volume 13, Rev. 0, Page 475 of 496 JUSTIFICATION FOR DEVIATIONS ITS 3.8.10, DISTRIBUTION SYSTEMS - SHUTDOWN

1. Typographical/grammatical error corrected.

2. Changes have been made to be consistent with changes made in other Specifications.

3. Additional requirements have been added to ISTS LCO 3.8.10 for Unit 2 to ensure that the appropriate Unit 1 electrical power distribution subsystem is OPERABLE during the movement of irradiated fuel assemblies in the auxiliary building. This modification was necessary since the Fuel Handling Area Exhaust Ventilation (FHAEV) System is powered by Unit 1 AC electrical power distribution subsystems.

In addition, ITS 3.8.10 ACTION B for Unit 2 has been added to cover the situation when the required Unit 1 AC electrical power distribution subsystem is inoperable.

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

5. The Applicability has been clarified, since CNP has two units and irradiated fuel movement can occur in three different locations.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 475 of 496

Attachment 1, Volume 13, Rev. 0, Page 476 of 496 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

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Attachment 1, Volume 13, Rev. 0, Page 482 of 496 B 3.8.10 8

INSERT 5 specified in LCO 3.1.1, "SHUTDOWN MARGIN (SDM),"

8 INSERT 6 specified in LCO 3.9.1, "Boron Concentration,"

Insert Page B 3.8.10-3 Attachment 1, Volume 13, Rev. 0, Page 482 of 496

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Attachment 1, Volume 13, Rev. 0, Page 485 of 496 JUSTIFICATION FOR DEVIATIONS ITS 3.8.10 BASES, DISTRIBUTION SYSTEMS - SHUTDOWN

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

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

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

4. These punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, NEI 01-03, Section 3.2.2.

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

6. Grammatical/spelling error corrected.

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

8. Changes are made to be consistent with other places in the Bases.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 485 of 496

Attachment 1, Volume 13, Rev. 0, Page 486 of 496 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 13, Rev. 0, Page 486 of 496

Attachment 1, Volume 13, Rev. 0, Page 487 of 496 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.10, DISTRIBUTION SYSTEMS - SHUTDOWN There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 487 of 496

Attachment 1, Volume 13, Rev. 0, Page 488 of 496 ATTACHMENT 11 Relocated/Deleted Current Technical Specifications (CTS)

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, Volume 13, Rev. 0, Page 489 of 496 CTS 3/4.8.3, Alternative AC Power Sources , Volume 13, Rev. 0, Page 489 of 496

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Attachment 1, Volume 13, Rev. 0, Page 493 of 496 DISCUSSION OF CHANGES CTS 3/4.8.3, ALTERNATIVE A.C. POWER SOURCES ADMINISTRATIVE CHANGES None MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 6 - Relocation of LCO, SR, or other TS requirement to the TRM, UFSAR, ODCM, QAPD, or IIP) CTS LCO 3.8.3.1 requires the steady state bus voltage for the manual alternate reserve source (i.e., a qualified offsite source) to be greater than or equal to 90% of the nominal bus voltage whenever the manual alternate reserve source (69 kV) is connected to more than two buses. The CTS 3.8.3.1 Action covers the situation when the bus voltage is less than 90%

nominal. The action is to adjust the load on the remaining buses to maintain steady state bus voltage greater than or equal to 90% limit. The ITS does not include the requirements for the steady state bus voltage for the manual alternate reserve source. This changes the CTS by moving the explicit requirements for the steady state bus voltage for the manual alternate reserve source, including the Action and Surveillance Requirement, from the Technical Specifications to the Technical Requirements Manual (TRM).

The removal of these details from the Technical Specifications is acceptable because this type of information is not necessary to provide adequate protection of public health and safety. The purpose of CTS LCO 3.8.3.1 is to ensure the steady state bus voltage for the manual alternate reserve source is greater than 90% of the nominal bus voltage whenever the manual alternate reserve source (69 kV) is connected to more than two buses. ITS SR 3.8.9.1 and SR 3.8.10.1 require the verification of correct breaker alignments and voltage to each required 4.16 kV emergency bus every 7 days. This Surveillance will continue to ensure the proper voltage is available on each bus when the auxiliary, preferred, or alternate reserve source is supplying the associated bus. If the bus voltage is not adequate, then the bus will be declared inoperable and the appropriate Technical Specification Conditions and Required Action will be entered. These Technical Specification requirements are sufficient to ensure the buses are OPERABLE with the appropriate voltages regardless of the source of supply.

These requirements are proposed to be relocated to the TRM since the Technical Specifications provides the appropriate requirements on AC Sources and the distribution system to ensure the 4.16 kV emergency buses are energized to the appropriate voltage. This change is acceptable because the removed information will be adequately controlled in the TRM. The TRM is incorporated by reference into the UFSAR and any changes to the TRM are CNP Units 1 and 2 Page 1 of 2 Attachment 1, Volume 13, Rev. 0, Page 493 of 496

Attachment 1, Volume 13, Rev. 0, Page 494 of 496 DISCUSSION OF CHANGES CTS 3/4.8.3, ALTERNATIVE A.C. POWER SOURCES made under 10 CFR 50.59, which ensures changes are properly evaluated. This change is designated as a less restrictive removal of detail change because information is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES None CNP Units 1 and 2 Page 2 of 2 Attachment 1, Volume 13, Rev. 0, Page 494 of 496

Attachment 1, Volume 13, Rev. 0, Page 495 of 496 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 13, Rev. 0, Page 495 of 496

Attachment 1, Volume 13, Rev. 0, Page 496 of 496 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS CTS 3/4.8.3, ALTERNATIVE A.C. POWER SOURCES There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 13, Rev. 0, Page 496 of 496

ML041200385

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