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CNP Units 1 and 2 Improved Technical Specifications Conversion, Volume 14, Rev 0, ITS Section 3.9 Refueling Operations.
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Issue date:	04/06/2004
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Attachment 1, Volume 14, Rev. 0, Page 1 of 187 VOLUME 14 CNP UNITS 1 AND 2 IMPROVED TECHNICAL SPECIFICATIONS CONVERSION ITS SECTION 3.9 REFUELING OPERATIONS Revision 0 Attachment 1, Volume 14, Rev. 0, Page 1 of 187

Attachment 1, Volume 14, Rev. 0, Page 2 of 187 LIST OF ATTACHMENTS

1. ITS 3.9.1

2. ITS 3.9.2

3. ITS 3.9.3

4. ITS 3.9.4

5. ITS 3.9.5

6. ITS 3.9.6

7. Relocated/Deleted Current Technical Specifications (CTS)

8. Improved Standard Technical Specifications (ISTS) not adopted in the CNP ITS Attachment 1, Volume 14, Rev. 0, Page 2 of 187

, Volume 14, Rev. 0, Page 3 of 187 ATTACHMENT 1 ITS 3.9.1, Boron Concentration , Volume 14, Rev. 0, Page 3 of 187

, Volume 14, Rev. 0, Page 4 of 187 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 14, Rev. 0, Page 4 of 187

Attachment 1, Volume 14, Rev. 0, Page 5 of 187 ITS 3.9.1 A.1 ITS and the refueling cavity A.2 LCO 3.9.1 LA.1 within the limit specified in the COLR Add proposed Applicability Note L.1 ACTION A M.1 L.2 A.3 L.3 SR 3.9.1.1 LA.2 SR 3.9.1.2 Page 1 of 2 Attachment 1, Volume 14, Rev. 0, Page 5 of 187

Attachment 1, Volume 14, Rev. 0, Page 6 of 187 ITS 3.9.1 A.1 ITS and the refueling cavity A.2 LCO 3.9.1 LA.1 within the limit specified in the COLR Add proposed Applicability Note L.1 ACTION A M.1 L.2 A.3 L.3 SR 3.9.1.1 LA.2 SR 3.9.1.2 Page 2 of 2 Attachment 1, Volume 14, Rev. 0, Page 6 of 187

Attachment 1, Volume 14, Rev. 0, Page 7 of 187 DISCUSSION OF CHANGES ITS 3.9.1, BORON CONCENTRATION 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 3.9.1 provides requirements on the boron concentration of all filled portions of the Reactor Coolant System and the refueling canal. ITS 3.9.1 provides requirements on the boron concentration of the Reactor Coolant System, the refueling canal, and the refueling cavity. This changes the CTS by explicitly including the refueling cavity in the volumes required to have boron concentration maintained.

This change is acceptable because the technical requirements have not changed. The refueling cavity is considered to be governed by the CTS requirements because the refueling cavity is typically connected to the RCS, the refueling canal, or both. This change is designated as administrative because the technical requirements of the specifications have not changed.

A.3 CTS 3.9.1 Action b contains the statement, "The provisions of Specification 3.0.3 are not applicable." ITS 3.9.1 does not contain an equivalent statement. This changes the CTS by deleting the Specification 3.0.3 exception.

This change is acceptable because the technical requirements have not changed. ITS LCO 3.0.3 is not applicable in MODE 6. Therefore, the CTS LCO 3.0.3 exception is not needed. This change is designated as administrative because it does not result in a technical change to the CTS.

MORE RESTRICTIVE CHANGES M.1 CTS 3.9.1 Action a requires the immediate suspension of positive reactivity changes "except addition of water from the RWST, provided the boron concentration in the RWST is greater than the minimum required by Specification 3.1.2.7.b.2" (i.e., 2400 ppm). ITS 3.9.1 Required Action A.2 requires positive reactivity additions to be suspended, but does not provide any allowance for positive reactivity changes due to the addition of water from the RWST to continue. This changes the CTS by removing the allowance to allow a positive reactivity change from the addition of water from the RWST, provided the boron concentration of the RWST is greater than 2400 ppm.

The purpose of CTS 3.9.1 Action a is to provide assurance that an inadvertent criticality will not result when the boron concentration is not within limits in MODE 6. The CTS 3.9.1 Action requires the suspension of all operations involving CORE ALTERATIONS or positive reactivity changes and initiation of activities to restore boron concentration to within its limit. However, allowing a CNP Units 1 and 2 Page 1 of 4 Attachment 1, Volume 14, Rev. 0, Page 7 of 187

Attachment 1, Volume 14, Rev. 0, Page 8 of 187 DISCUSSION OF CHANGES ITS 3.9.1, BORON CONCENTRATION positive reactivity addition conflicts with the requirement to restore boron concentration to its limit. Therefore, this exception is deleted. This change is acceptable because the ITS requires actions that provide assurance that an inadvertent criticality will not result while boron concentration is not within limits in MODE 6, and requires initiation of activities to restore boron concentration to within its limit. This change is designated as more restrictive because it provides more restrictive corrective actions in the ITS than in the CTS.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 5 - Removal of Cycle-Specific Parameter Limits from the Technical Specifications to the Core Operating Limits Report) CTS 3.9.1 states that the boron concentration in MODE 6 shall be the more restrictive reactivity condition of a keff of 0.95 or less or a boron concentration of > 2400 ppm. ITS LCO 3.9.1 states that the boron concentration shall be within the limit specified in the COLR.

This changes the CTS by relocating the MODE 6 boron concentration limit, which must be confirmed on a cycle-specific basis, to the CORE OPERATING LIMITS REPORT (COLR).

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

ITS 3.9.1 continues to require that boron concentration limit is met. ITS SR 3.9.1.1 requires periodic verification that boron concentration is within the limits provided in the COLR. The method of determining or utilizing the boron concentration limit has not changed. Also, this change is acceptable because the removed information will be adequately controlled in the COLR under the requirements provided in ITS 5.6.5, "Core Operating Limits Report." ITS 5.6.5 ensures that the applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems limits, and nuclear limits such as SDM, transient analysis limits, and accident analysis limits) of the safety analyses are met. This change is designated as a less restrictive removal of detail change because information relating to cycle-specific parameter limits is being removed from the Technical Specifications.

LA.2 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 4.9.1.2 requires that the boron concentration of the Reactor Coolant System and the refueling canal be determined "by chemical analysis" at least once per 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . ITS SR 3.9.1.1 and SR 3.9.1.2 require verification that boron concentration is within the limit specified in the COLR. ITS CNP Units 1 and 2 Page 2 of 4 Attachment 1, Volume 14, Rev. 0, Page 8 of 187

Attachment 1, Volume 14, Rev. 0, Page 9 of 187 DISCUSSION OF CHANGES ITS 3.9.1, BORON CONCENTRATION SR 3.9.1.1 and SR 3.9.1.2 do not specify that the boron concentration be determined by chemical analysis. This changes the CTS by moving details of how the boron concentration is determined from the CTS to the Bases.

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

LESS RESTRICTIVE CHANGES L.1 (Category 2 - Relaxation of Applicability) CTS 3.9.1 provides limits on the boron concentration of all filled portions of the Reactor Coolant System and the refueling canal when in MODE 6. ITS 3.9.1 modifies this requirement with a Note which states "Only applicable to the refueling canal and refueling cavity when connected to the RCS." This changes the CTS by eliminating the applicability of the boron concentration limits on the refueling canal and refueling cavity when those volumes are not connected to the RCS. In addition, ITS SR 3.9.1.2 requires a verification that the boron is within the limit specified in the COLR once within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months prior to connecting the refueling canal and refueling cavity to the RCS.

The purpose of CTS 3.9.1 is to ensure the boron concentration of the water surrounding the reactor fuel is sufficient to maintain the required SHUTDOWN MARGIN. This change is acceptable because the requirements continue to ensure that process variables are maintained in the MODES and other specified conditions assumed in the safety analyses and licensing basis. If the refueling canal and refueling cavity are not connected to the RCS (such as when the reactor vessel head is on the reactor vessel), the boron concentration of those volumes cannot affect the SHUTDOWN MARGIN. In addition, prior to connecting the refueling canal and refueling cavity to the RCS, a boron concentration verification will be performed to ensure the newly connected portions cannot decrease the boron concentration below the limit. This change is designated as less restrictive because the LCO requirements are applicable in fewer operating conditions than in the CTS.

L.2 (Category 4 - Relaxation of Required Action) CTS 3.9.1 Action a states that when the boron concentration requirement is not met, initiate and continue boration at > 34 gpm of 6,550 ppm boric acid solution or its equivalent until keff is reduced to < 0.95 or the boron concentration is restored to > 2400 ppm, whichever is the more restrictive. ITS 3.9.1 Required Action A.3 requires initiation of action to restore boron concentration to within limit. This changes the CNP Units 1 and 2 Page 3 of 4 Attachment 1, Volume 14, Rev. 0, Page 9 of 187

Attachment 1, Volume 14, Rev. 0, Page 10 of 187 DISCUSSION OF CHANGES ITS 3.9.1, BORON CONCENTRATION CTS by eliminating the specific requirements for the boric acid solution to be used to restore compliance with the LCO.

The purpose of CTS 3.9.1 Action a is to restore the required SHUTDOWN MARGIN in a timely manner. 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. Specifying the boric acid solution requirements in the Action is not necessary, since the ITS requires that action to restore the boron concentration be initiated immediately. This prompt action will result in the boron concentration being restored as quickly, or more quickly, than the CTS requirement. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L.3 (Category 5 - Deletion of Surveillance Requirement) CTS 4.9.1.1 requires the LCO reactivity condition to be determined prior to removing or unbolting the reactor vessel head, and prior to withdrawal of any full length control rod in excess of 3 feet from its fully inserted position. ITS 3.9.1 does not contain this Surveillance Requirement.

The purpose of CTS 4.9.1.1 is to ensure that the LCO requirements are met prior to entering MODE 6 and that the reactor has sufficient SHUTDOWN MARGIN prior to withdrawing any control rods. This change is acceptable because the deleted Surveillance Requirement is not necessary to verify that the values used to meet the LCO are consistent with the safety analyses. Thus, appropriate values continue to be tested in a manner and at a frequency necessary to give confidence that the assumptions in the safety analyses are protected. ITS 3.9.1 requires that the boron concentration be met in MODE 6 or that action be immediately initiated to restore the boron concentration and that all positive reactivity additions be suspended. Therefore, verification that the boron concentration requirement is met must be performed prior to entering MODE 6 in order to avoid immediately entering into an Action and withdrawal of control rods is prohibited when the boron concentration requirement is not met. While the CTS Surveillance is not required, the level of protection provided is appropriate.

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

CNP Units 1 and 2 Page 4 of 4 Attachment 1, Volume 14, Rev. 0, Page 10 of 187

Attachment 1, Volume 14, Rev. 0, Page 11 of 187 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 14, Rev. 0, Page 11 of 187

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Attachment 1, Volume 14, Rev. 0, Page 13 of 187 3.9.1 2 INSERT 1 SR 3.9.1.2 Verify boron concentration of refueling canal and Once within 72 refueling cavity is within the limit specified in the hours prior to COLR. connecting the refueling canal and refueling cavity to the RCS Insert Page 3.9.1-1 Attachment 1, Volume 14, Rev. 0, Page 13 of 187

Attachment 1, Volume 14, Rev. 0, Page 14 of 187 JUSTIFICATION FOR DEVIATIONS ITS 3.9.1, BORON CONCENTRATION

1. Typographical/grammatical error corrected.

2. ISTS SR 3.9.1.1 requires a verification that the boron concentration is within limit every 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The Bases for the SR states that prior to re-connecting portions of the refueling canal or the refueling cavity to the RCS, this SR must be met per SR 3.0.4. SR 3.0.4 requires the SR to be met prior to entering a MODE or other specified condition in the Applicability. However, SR 3.0.4 is only applicable in MODES 1, 2, 3, and 4; it is not applicable in MODE 6, the MODE in which ISTS 3.9.1 is applicable. Therefore, to meet the intent of the Bases requirement, a new SR has been added, SR 3.9.1.2, which requires a verification that the boron concentration of the refueling canal and refueling cavity is within the limit specified in the COLR once within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months prior to connecting the refueling canal and refueling cavity to the RCS.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 14, Rev. 0, Page 14 of 187

Attachment 1, Volume 14, Rev. 0, Page 15 of 187 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

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Attachment 1, Volume 14, Rev. 0, Page 21 of 187 JUSTIFICATION FOR DEVIATIONS ITS 3.9.1 BASES, BORON CONCENTRATION

1. 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.

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

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

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

5. Editorial change made for clarity.

6. Changes have been made to be consistent with similar words in other places in the ITS Bases.

7. Changes made to be consistent with the Specification.

8. Typographical/grammatical error corrected.

9. The paragraph and associated reference have been deleted since it is discussing a MODE 5 analysis, and this Specification is applicable in MODE 6.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 14, Rev. 0, Page 21 of 187

Attachment 1, Volume 14, Rev. 0, Page 22 of 187 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 14, Rev. 0, Page 22 of 187

Attachment 1, Volume 14, Rev. 0, Page 23 of 187 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.9.1, BORON CONCENTRATION There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 14, Rev. 0, Page 23 of 187

, Volume 14, Rev. 0, Page 24 of 187 ATTACHMENT 2 ITS 3.9.2, Nuclear Instrumentation , Volume 14, Rev. 0, Page 24 of 187

, Volume 14, Rev. 0, Page 25 of 187 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 14, Rev. 0, Page 25 of 187

Attachment 1, Volume 14, Rev. 0, Page 26 of 187 ITS 3.9.2 A.1 ITS M.1 LA.1 OPERABLE L.1 LCO 3.9.2 M.1 count rate circuit shall be OPERABLE L.2 ACTION A M.2 A.2 Add proposed ACTION B M.3 Add proposed ACTION C L.3 L.4 M.4 SR 3.9.2.1 Add proposed SR 3.9.2.2 M.5 230 Page 1 of 2 Attachment 1, Volume 14, Rev. 0, Page 26 of 187

Attachment 1, Volume 14, Rev. 0, Page 27 of 187 ITS 3.9.2 A.1 ITS M.1 LA.1 OPERABLE L.1 LCO 3.9.2 M.1 count rate circuit shall be OPERABLE L.2 ACTION A M.2 A.2 Add proposed ACTION B M.3 Add proposed ACTION C L.3 L.4 M.4 SR 3.9.2.1 Add proposed SR 3.9.2.2 M.5 Page 2 of 2 Attachment 1, Volume 14, Rev. 0, Page 27 of 187

Attachment 1, Volume 14, Rev. 0, Page 28 of 187 DISCUSSION OF CHANGES ITS 3.9.2, NUCLEAR INSTRUMENTATION ADMINISTRATIVE CHANGES A.1 In the conversion of the CNP Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 2, "Standard Technical Specifications-Westinghouse Plants" (ISTS).

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

A.2 CTS 3.9.2 Action b contains the statement, "The provisions of Specification 3.0.3 are not applicable." ITS 3.9.2 does not contain an equivalent statement. This changes the CTS by deleting the Specification 3.0.3 exception.

This change is acceptable because the technical requirements have not changed. ITS LCO 3.0.3 is not applicable in MODE 6. Therefore, the CTS LCO 3.0.3 exception is not needed. This change is designated as administrative because it does not result in a technical change to the CTS.

MORE RESTRICTIVE CHANGES M.1 CTS 3.9.2 states, in part, that two source range neutron flux monitors shall be "operating" and that one has audible "indication." ITS 3.9.2 states that two source range neutron flux monitors shall be "OPERABLE" and one audible "count rate circuit shall be OPERABLE." This changes the CTS by requiring the source range neutron flux monitors to be OPERABLE, instead of just operating, and requiring the audible count rate circuit to be OPERABLE, instead of just being an indication.

The purpose of CTS 3.9.2 is to ensure that the source range neutron flux monitors are capable of performing the safety functions assumed in the accident analysis. However, as written, the CTS LCO wording could be interpreted to allow the source range neutron flux monitors to be operating in a location or condition that would prevent them from performing the assumed safety function and just provide an indication, in lieu of an OPERABLE count rate circuit. The ITS wording eliminates this possible misinterpretation. This change is acceptable because the source range neutron flux monitors must be OPERABLE (i.e.,

capable of performing their safety function) instead of just operating, and the count rate circuit must be OPERABLE. This change is designated as more restrictive because the ITS contains more specific requirements for a specific component.

M.2 CTS 3.9.1 Action a requires the immediate suspension of positive reactivity changes except for the addition of water from the RWST, provided the boron concentration in the RWST is greater than the minimum required by Specification 3.1.2.7.b.2 (i.e., 2400 ppm). ITS 3.9.2 Required Action A.2 requires suspension of operations that would cause introduction into the RCS, coolant with boron concentration less than required to meet the boron concentration of LCO 3.9.1. This changes the CTS by replacing the allowance to allow a positive CNP Units 1 and 2 Page 1 of 5 Attachment 1, Volume 14, Rev. 0, Page 28 of 187

Attachment 1, Volume 14, Rev. 0, Page 29 of 187 DISCUSSION OF CHANGES ITS 3.9.2, NUCLEAR INSTRUMENTATION reactivity change from the addition of water from the RWST, provided the boron concentration of the RWST is greater than 2400 ppm with a requirement that the boron concentration must meet the boron concentration of LCO 3.9.1.

The purpose of CTS 3.9.2 Action a is to provide assurance that activities that could result in reducing boron concentration such that the required SHUTDOWN MARGIN is not met will not occur when any source range neutron flux monitor is inoperable in MODE 6. Allowing positive reactivity additions from sources with boron concentrations meeting the requirements of ITS 3.9.1 preserves the required SHUTDOWN MARGIN. This change is acceptable because the ITS requires actions that prohibit activities that could result in reducing boron concentration such that the required SHUTDOWN MARGIN is not met. This change is designated as more restrictive because it provides more restrictive corrective actions in the ITS than in the CTS.

M.3 CTS 3.9.2 Action a states that with fewer than two source range channels operating, immediately suspend all operations involving CORE ALTERATIONS or positive reactivity changes except addition of water from the RWST, provided the boron concentration in the RWST is greater than the minimum required by Specification 3.1.2.7.b.2 (i.e., 2400 ppm). The ITS provides similar ACTIONS as the CTS (except where changed as described in DOCs M.2 and L.2). In addition, ITS 3.9.2 ACTION B requires additional actions when two source range neutron flux monitors are inoperable. The ITS requires immediate initiation of action to restore one source range neutron flux monitor to OPERABLE status and to perform a verification of boron concentration (per ITS SR 3.9.1.1) once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This changes the CTS requirements by requiring an additional verification of boron concentration every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months when both source ranges are inoperable and by requiring an additional action to initiate immediate action to restore one source range neutron flux monitor to OPERABLE status.

The purpose of this change is to provide necessary Required Actions that are appropriate for a possible condition that could be encountered. This change is acceptable because the proposed Required Actions are reasonable and necessary to ensure the reactor is maintained in a safe condition. This change is more restrictive because it provides for additional actions that the CTS does not require.

M.4 CTS 4.9.2.c requires a CHANNEL CHECK to be performed once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months during CORE ALTERATIONS. ITS SR 3.9.2.1 requires a CHANNEL CHECK to be performed every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This changes the CTS by requiring the CHANNEL CHECK to be performed every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months even if CORE ALTERATIONS are not in progress.

The purpose of this change is to routinely verify the OPERABILITY of the source range monitors in all conditions in which the LCO applies, not just during CORE ALTERATIONS. This change is acceptable because the Surveillance verifies OPERABILITY of both monitors to ensure the reactor is maintained in a safe condition. This change is more restrictive because it provides for additional testing that the CTS does not require.

CNP Units 1 and 2 Page 2 of 5 Attachment 1, Volume 14, Rev. 0, Page 29 of 187

Attachment 1, Volume 14, Rev. 0, Page 30 of 187 DISCUSSION OF CHANGES ITS 3.9.2, NUCLEAR INSTRUMENTATION M.5 CTS 4.9.2 specifies testing for the source range neutron flux instrumentation channels, but does not include a CHANNEL CALIBRATION. ITS SR 3.9.2.2 requires the performance of a CHANNEL CALIBRATION to be performed on the source range neutron flux monitors every 24 months. This changes the CTS by requiring a CHANNEL CALIBRATION every 24 months on each source range neutron flux monitor.

The purpose of this change is to ensure the proper testing is conducted at an appropriate Frequency. This change is acceptable because a CHANNEL CALIBRATION every 24 months will continue to ensure OPERABILITY and proper operation of the source range neutron flux monitors. This change is more restrictive because it provides for additional testing that the CTS does not require.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.9.2 states that two source range neutron flux monitors shall be operating, "each with continuous visual indication in the control room."

ITS 3.9.2 LCO states that two source range neutron flux monitors shall be OPERABLE. This changes the CTS by moving the requirement that each channel has a continuous visual indication in the control room from the CTS to the Bases.

The removal of this detail, which is related to system design, from the Technical Specifications, is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS retains the requirement that two channels be OPERABLE and continues to require the associated Surveillance to verify OPERABILITY. 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) Unit 1 CTS 3.9.2 states that two source range neutron flux monitors shall be operating, each with continuous visual indication in the control room and one with audible indication "in the containment." Unit 2 CTS 3.9.2 includes the same statement, but also states that audible indication must be in the "control room." ITS 3.9.2 states that two source CNP Units 1 and 2 Page 3 of 5 Attachment 1, Volume 14, Rev. 0, Page 30 of 187

Attachment 1, Volume 14, Rev. 0, Page 31 of 187 DISCUSSION OF CHANGES ITS 3.9.2, NUCLEAR INSTRUMENTATION range neutron flux monitors shall be OPERABLE and one source range audible count rate circuit shall be OPERABLE. This changes the CTS by deleting the requirement for an audible indication to be "in the containment" and in the "control room."

This change is acceptable because the LCO requirements continue to ensure that the source range neutron flux monitor channels are maintained consistent with the safety analyses and licensing basis. The boron dilution analysis assumes that the operator has prompt and definite indication from the audible indication. However, the analysis does not assume a location for the audible indication. The ITS ensures that an audible indication is available, while allowing flexibility in locating the audible indication. This change is designated as less restrictive because less stringent LCO requirements are being applied in the ITS than were applied in the CTS.

L.2 (Category 4 - Relaxation of Required Action) CTS 3.9.2 Action a states that with fewer than two source range neutron flux monitors operating, immediately suspend all operations involving positive reactivity changes except addition of water from the RWST, provided the boron concentration in the RWST is greater than the minimum required by Specification 3.1.2.7.b.2 (i.e., 2400 ppm).

ITS 3.9.2 Required Action A.2 states "Suspend operations that would cause introduction into the RCS, coolant with boron concentration less than required to meet the boron concentration of LCO 3.9.1, Boron Concentration." This allows positive reactivity changes provided they do not reduce the boron concentration below the refueling limit. This changes the CTS requirements by allowing limited positive reactivity additions from sources in addition to the RWST.

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 requirement to maintain refueling boron concentration within limits will continue to ensure the unit will be operated within the assumptions of the safety analyses. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L.3 (Category 4 - Relaxation of Required Action) CTS 3.9.2 Action a requires the immediate suspension of CORE ALTERATIONS or positive reactivity changes except for the addition of water from the RWST, provided the boron concentration in the RWST is greater than the minimum required by Specification 3.1.2.7.b.2, in the event one source range neutron flux monitor with audible indication in the containment is not operating. ITS 3.9.2 ACTION C requires initiation of action to isolate unborated water sources in the event the required source range audible count rate circuit is inoperable. This changes the CTS by replacing the Action to immediately suspend CORE ALTERATIONS or positive reactivity changes except for the addition of water from the RWST, provided the boron concentration in the RWST is greater than the minimum CNP Units 1 and 2 Page 4 of 5 Attachment 1, Volume 14, Rev. 0, Page 31 of 187

Attachment 1, Volume 14, Rev. 0, Page 32 of 187 DISCUSSION OF CHANGES ITS 3.9.2, NUCLEAR INSTRUMENTATION required by CTS 3.1.2.7.b.2, in the event one source range monitor with audible indication in the containment is not operating, with the Action to initiate action to isolate unborated water sources.

The purpose of CTS 3.9.2 Action a is to provide assurance that activities that could result in an inadvertent criticality will not occur when the required source range audible count rate circuit is inoperable in MODE 6. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the repair period. ITS 3.9.2 ACTION C requires actions to be taken to isolate sources of unborated water.

This provides assurance that rapid dilution of boron concentration, which could result in rapid reduction in shutdown margin, will not occur. This change preserves the assumptions and conclusions of the boron dilution analysis. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L.4 (Category 5 - Deletion of Surveillance Requirement) CTS 4.9.2.a and b state that a CHANNEL FUNCTIONAL TEST is required for the source range neutron flux monitors at least once per 7 days and within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months prior to the initial start of CORE ALTERATIONS, respectively. ITS 3.9.2 does not require the performance of similar tests for the source range neutron flux monitors. This changes the CTS by deleting the CHANNEL FUNCTIONAL TESTS every 7 days and within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months of CORE ALTERATIONS.

This change is acceptable because the deleted Surveillance Requirements are not necessary to verify that the equipment used to meet the LCO is consistent with the safety analysis. The source range neutron flux monitors continue to be tested in a manner and at a frequency necessary to give confidence that the assumptions in the safety analyses are protected. 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. This change is designated as less restrictive because Surveillances required in the CTS will not be required in the ITS.

CNP Units 1 and 2 Page 5 of 5 Attachment 1, Volume 14, Rev. 0, Page 32 of 187

Attachment 1, Volume 14, Rev. 0, Page 33 of 187 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 14, Rev. 0, Page 33 of 187

, Volume 14, Rev. 0, Page 34 of 187 , Volume 14, Rev. 0, Page 34 of 187

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Attachment 1, Volume 14, Rev. 0, Page 36 of 187 JUSTIFICATION FOR DEVIATIONS ITS 3.9.2, NUCLEAR INSTRUMENTATION

1. CNP has analyzed a boron dilution event in MODE 6. Therefore, ISTS 3.9.2 is not included in the ITS and ISTS 3.9.3 is renumbered as ITS 3.9.2.

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

3. Editorial correction to be consistent with the format of the ITS.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 14, Rev. 0, Page 36 of 187

Attachment 1, Volume 14, Rev. 0, Page 37 of 187 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 14, Rev. 0, Page 37 of 187

, Volume 14, Rev. 0, Page 38 of 187 , Volume 14, Rev. 0, Page 38 of 187

Attachment 1, Volume 14, Rev. 0, Page 39 of 187 B 3.9.2 3 INSERT 1 (i.e., the Westinghouse source range neutron flux monitors and the Thermo Gamma-Metrics neutron flux monitors) 3 INSERT 2 The Thermo Gamma-Metrics neutron flux monitors are part of the Thermo Gamma-Metrics Neutron Flux Monitoring System. Both of 3 INSERT 3 (selectable between proportional source range neutron flux monitors) 3 INSERT 4 There are two Thermo Gamma-Metrics neutron flux monitors. Each monitor includes two fission chamber detectors capable of monitoring a wide range from source level (shutdown) to full power reactor operation. In the source range, the detectors monitor the neutron flux in counts per second and are capable of detecting six decades of neutron flux. The detectors also provide continuous visual indication in the control room of source count rate and a source rate of change.

Insert Page B 3.9.3-1 Attachment 1, Volume 14, Rev. 0, Page 39 of 187

, Volume 14, Rev. 0, Page 40 of 187 , Volume 14, Rev. 0, Page 40 of 187

Attachment 1, Volume 14, Rev. 0, Page 41 of 187 B 3.9.2 3

INSERT 5 (any combination of Westinghouse source range neutron flux and Thermo Gamma-Metrics neutron flux monitors) 3 INSERT 6 (which must be a Westinghouse source range neutron flux monitor, since the Thermo Gamma-Metrics neutron flux monitors do not have an audible count rate function)

Insert Page B 3.9.3-2 Attachment 1, Volume 14, Rev. 0, Page 41 of 187

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Attachment 1, Volume 14, Rev. 0, Page 44 of 187 B 3.9.2 7

INSERT 7 CHANNEL CALIBRATION is a complete check of the instrument loop, except the detector.

Insert Page B 3.9.3-4 Attachment 1, Volume 14, Rev. 0, Page 44 of 187

Attachment 1, Volume 14, Rev. 0, Page 45 of 187 JUSTIFICATION FOR DEVIATIONS ITS 3.9.2 BASES, NUCLEAR INSTRUMENTATION

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

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

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

4. The specific accuracy of the source range neutron flux monitors is not part of the licensing basis of CNP and has been deleted.

5. Typographical/grammatical error corrected.

6. 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.

7. Changes are made to be consistent with similar words in other places in the ITS Bases.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 14, Rev. 0, Page 45 of 187

Attachment 1, Volume 14, Rev. 0, Page 46 of 187 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 14, Rev. 0, Page 46 of 187

Attachment 1, Volume 14, Rev. 0, Page 47 of 187 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.9.2, NUCLEAR INSTRUMENTATION There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 14, Rev. 0, Page 47 of 187

, Volume 14, Rev. 0, Page 48 of 187 ATTACHMENT 3 ITS 3.9.3, Containment Penetrations , Volume 14, Rev. 0, Page 48 of 187

, Volume 14, Rev. 0, Page 49 of 187 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 14, Rev. 0, Page 49 of 187

Attachment 1, Volume 14, Rev. 0, Page 50 of 187 ITS 3.9.3 A.1 ITS LCO 3.9.3 LCO 3.9.3.a LCO 3.9.3.b A.2 A.3 LA.1 LCO 3.9.3.c L.1 ACTION A A.4 L.2 SR 3.9.3.1, SR 3.9.3.2 L.1 L.3 LA.1 Page 1 of 8 Attachment 1, Volume 14, Rev. 0, Page 50 of 187

Attachment 1, Volume 14, Rev. 0, Page 51 of 187 ITS 3.9.3 A.1 ITS SR 3.9.3.1 SR 3.9.3.2 Page 2 of 8 Attachment 1, Volume 14, Rev. 0, Page 51 of 187

Attachment 1, Volume 14, Rev. 0, Page 52 of 187 ITS 3.9.3 A.1 ITS See ITS 3.6.3 Add proposed SR 3.9.3.2 Note L.3 SR 3.9.3.2 actual or simulated See ITS L.4 3.6.3 Page 3 of 8 Attachment 1, Volume 14, Rev. 0, Page 52 of 187

Attachment 1, Volume 14, Rev. 0, Page 53 of 187 ITS 3.9.3 A.1 ITS LCO 3.9.3.c.2 L.1 LCO 3.9.3.c.1 A.4 L.2 SR 3.9.3.2 L.1 See ITS 3.3.6 L.3 Page 4 of 8 Attachment 1, Volume 14, Rev. 0, Page 53 of 187

Attachment 1, Volume 14, Rev. 0, Page 54 of 187 ITS 3.9.3 A.1 ITS LCO 3.9.3 LCO 3.9.3.a LCO 3.9.3.b A.2 A.3 LA.1 LCO 3.9.3.c L.1 ACTION A A.4 L.2 SR 3.9.3.1, L.1 SR 3.9.3.2 L.3 LA.1 Page 5 of 8 Attachment 1, Volume 14, Rev. 0, Page 54 of 187

Attachment 1, Volume 14, Rev. 0, Page 55 of 187 ITS 3.9.3 A.1 ITS SR 3.9.3.1 SR 3.9.3.2 Page 6 of 8 Attachment 1, Volume 14, Rev. 0, Page 55 of 187

Attachment 1, Volume 14, Rev. 0, Page 56 of 187 ITS 3.9.3 A.1 ITS See ITS 3.6.3 Add proposed SR 3.9.3.2 Note L.3 SR 3.9.3.2 actual or simulated See ITS L.4 3.6.3 Page 7 of 8 Attachment 1, Volume 14, Rev. 0, Page 56 of 187

Attachment 1, Volume 14, Rev. 0, Page 57 of 187 ITS 3.9.3 A.1 ITS LCO 3.9.3.c.2 L.1 LCO 3.9.3.c.1 A.4 SR 3.9.3.2 L.2 L.1 See ITS 3.3.6 L.3 Page 8 of 8 Attachment 1, Volume 14, Rev. 0, Page 57 of 187

Attachment 1, Volume 14, Rev. 0, Page 58 of 187 DISCUSSION OF CHANGES ITS 3.9.3, CONTAINMENT PENETRATIONS 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 3.9.4.b requires a minimum of one door in each airlock to be closed or allows both airlock doors to be open provided one door in each airlock is OPERABLE, refueling cavity level is greater than 23 feet above the fuel, and a designated individual is available at all times to close the airlock if required. A footnote associated with CTS 3.9.4.b clarifies that for the purpose of this Specification, an OPERABLE air lock door is a door that is capable of being closed and secured. ITS 3.9.3 requires that one door in each air lock is capable of being closed. This changes the CTS by replacing the prescriptive requirements for control of the air lock doors with a more general requirement that the air lock doors must be capable of being closed. Other aspects of this change are discussed in DOC A.3 and DOC LA.1.

This change is acceptable because the CTS requirements have not changed. A door that is closed is a door that is also capable of being closed. The ITS requirements preserve the intent of the CTS. This change is designated as administrative because it does not result in technical changes to the CTS.

A.3 CTS 3.9.4.b.2.b allows both airlock doors to be open provided, in part, that the refueling cavity level is greater than 23 feet above the fuel. ITS 3.9.3 does not contain this restriction.

This change is acceptable because the requirement is duplicative of the requirements of ITS LCO 3.9.6, which requires that refueling cavity water level be maintained > 23 feet above the top of the reactor vessel flange during movement of irradiated fuel assemblies within containment. This change is designated as administrative because it does not result in technical changes to the CTS.

A.4 The CTS 3.9.4 and CTS 3.9.9 Actions state "The provisions of Specification 3.0.3 are not applicable." ITS 3.9.3 does not include this statement. This changes CTS by deleting the Specification 3.0.3 exception.

This change is acceptable because the technical requirements have not changed. ITS LCO 3.0.3 is not applicable in MODE 6. Therefore, the CTS LCO 3.0.3 exception is not needed. This change is designated as administrative because it does not result in a technical change to the CTS.

MORE RESTRICTIVE CHANGES None CNP Units 1 and 2 Page 1 of 4 Attachment 1, Volume 14, Rev. 0, Page 58 of 187

Attachment 1, Volume 14, Rev. 0, Page 59 of 187 DISCUSSION OF CHANGES ITS 3.9.3, CONTAINMENT PENETRATIONS RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 3.9.4.b.2.c allows both doors of each airlock to be open provided, in part, that a designated individual is available at all times to close an airlock door if required. A footnote associated with CTS 3.9.4.b clarifies that for the purpose of this Specification, an OPERABLE airlock door is a door that is capable of being closed and secured. The footnote also states that cables or hoses transversing the airlock shall be designed to allow for removal in a timely manner (e.g., quick disconnects). ITS 3.9.3.b requires that one door in each air lock is capable of being closed, but does not provide the level of description provided in the CTS. This changes the CTS by moving the requirement for a designated individual and the details on cables or hoses that transverse the air lock from the CTS to the Bases.

The removal of these details for compliance with the LCO 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 one door in each air lock be capable of being closed. Also, this change is acceptable because these types of procedural details will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L.1 (Category 2 - Relaxation of Applicability) CTS 3.9.4 and CTS 3.9.9 are applicable during CORE ALTERATIONS and movement of irradiated fuel within the containment. ITS 3.9.3 is applicable during movement of irradiated fuel assemblies within containment. References to CORE ALTERATIONS in CTS 3.9.4 are eliminated in the Applicability, Action, and Surveillances.

References to CORE ALTERATIONS in CTS 3.9.9 are eliminated in the Applicability and Surveillances. This changes the CTS by eliminating requirements for containment closure and the Containment Purge and Exhaust Isolation System during CORE ALTERATIONS.

The purpose of CTS 3.9.4 is to ensure the containment penetrations are in the condition assumed in the Fuel Handling Accident (FHA) inside containment analysis. The purpose of CTS 3.9.9 is to ensure the containment purge supply and exhaust valves are capable of being closed as assumed in the FHA inside containment analysis. This change is acceptable because the requirements CNP Units 1 and 2 Page 2 of 4 Attachment 1, Volume 14, Rev. 0, Page 59 of 187

Attachment 1, Volume 14, Rev. 0, Page 60 of 187 DISCUSSION OF CHANGES ITS 3.9.3, CONTAINMENT PENETRATIONS continue to ensure that the structures, systems, and components are maintained in the MODES and other specified conditions assumed in the safety analyses and licensing basis. There are no accidents postulated to occur during CORE ALTERATIONS that result in significant radioactive release except a FHA. The analysis for a FHA assumes that the accident is initiated only by movement of irradiated fuel. Therefore, imposing requirements during CORE ALTERATIONS in addition to during movement of irradiated fuel is unnecessary. This change is designated as less restrictive because the ITS LCO requirements are applicable in fewer operating conditions than in the CTS.

L.2 (Category 7 - Relaxation Of Surveillance Frequency, Non-24 Month Type Change) CTS 4.9.4 states that specified containment penetration Surveillances shall be performed, in part, "within 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months prior to the start of" the specified conditions in the Applicability. ITS SR 3.9.3.1 and ITS SR 3.9.3.2 do not include the "within 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months prior to the start of" Frequency. ITS SR 3.0.1 states "SRs shall be met during the MODES or other specified conditions in the Applicability for the individual LCOs, unless otherwise stated in the SR." Therefore, the ITS requires that the Surveillances must be met prior to the initiation of movement of irradiated fuel. This changes the CTS by eliminating the stipulation that the Surveillances be met within 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months prior to entering the conditions specified in the Applicability.

The purpose of CTS 4.9.4 is to verify the equipment required to meet the LCO is OPERABLE. This change is acceptable because the new Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability. For CTS 4.9.4, the periodic Surveillance Frequency for verifying containment penetrations are in the required status is acceptable during the conditions specified in the Applicability, and is also acceptable during the period prior to entering the conditions specified in the Applicability. 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 4.9.4 and CTS 4.9.9 include a Surveillance Frequency of "once per 7 days" during conditions specified in the Applicability for performing Surveillance of the Containment Purge Supply and Exhaust System. The ITS SR 3.9.3.2 Frequency for the same requirement is 24 months. ITS SR 3.9.3.2 is also modified by a Note that states that SR 3.9.3.2 is not required to be met for containment purge supply and exhaust valve(s) in penetrations that are closed to comply with LCO 3.9.3.c.1. This changes the CTS by changing the Surveillance Frequency from 7 days to 24 months and adding the Note that the SR is not required to be met for containment purge supply and exhaust valve(s) in penetrations that are closed to comply with ITS LCO 3.9.3.c.1.

The purpose of CTS 4.9.4 and CTS 4.9.9 is to verify the equipment required to meet the LCO is OPERABLE. This change is acceptable because the new Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability. Containment purge supply and exhaust valve testing is still required, but at a Frequency consistent with the testing Frequency for containment isolation valves required in MODES 1, 2, 3, and 4.

This Frequency provides an appropriate degree of assurance that the valves are CNP Units 1 and 2 Page 3 of 4 Attachment 1, Volume 14, Rev. 0, Page 60 of 187

Attachment 1, Volume 14, Rev. 0, Page 61 of 187 DISCUSSION OF CHANGES ITS 3.9.3, CONTAINMENT PENETRATIONS OPERABLE. When containment purge supply and exhaust valve(s) in penetrations are closed to comply with ITS LCO 3.9.3.c.1, the penetrations are in the expected condition (isolated) to mitigate the effects of a fuel handling accident inside containment. Therefore, there is no need for the actuation signal to reposition the valves to the closed position. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

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

CTS 4.6.3.1.2.c requires verification of the automatic actuation of the Containment Purge and Exhaust valves on a Containment Purge and Exhaust isolation signal (i.e., a test signal). ITS SR 3.9.3.2 specifies that the signal may be from either an "actual" or simulated (i.e., test) signal. This changes the CTS by explicitly allowing the use of either an actual or simulated signal for the test.

The purpose of CTS 4.6.3.1.2.c is to ensure that the containment purge and exhaust valves operate correctly upon receipt of an actuation signal. This change is acceptable because it has been determined that the relaxed Surveillance Requirement acceptance criteria are not necessary for verification that the equipment used to meet the LCO can perform its required functions.

Equipment can not discriminate between an "actual," "simulated," or "test" signal and, therefore, the results of the testing are unaffected by the type of signal used to initiate the test. This change allows taking credit for unplanned actuation if sufficient information is collected to satisfy the Surveillance test requirements.

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

CNP Units 1 and 2 Page 4 of 4 Attachment 1, Volume 14, Rev. 0, Page 61 of 187

Attachment 1, Volume 14, Rev. 0, Page 62 of 187 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 14, Rev. 0, Page 62 of 187

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Attachment 1, Volume 14, Rev. 0, Page 65 of 187 JUSTIFICATION FOR DEVIATIONS ITS 3.9.3, CONTAINMENT PENETRATIONS

1. CNP has analyzed a boron dilution event in MODE 6. Therefore, ISTS 3.9.2 is not included in the ITS and ISTS 3.9.4 is renumbered as ITS 3.9.3.

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

3. Typographical/grammatical error corrected.

4. The Note has been modified consistent with the current licensing basis.

5. Changes have been made to be consistent with changes made in another Specification and to be consistent with plant specific nomenclature.

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

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 14, Rev. 0, Page 65 of 187

Attachment 1, Volume 14, Rev. 0, Page 66 of 187 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 14, Rev. 0, Page 66 of 187

, Volume 14, Rev. 0, Page 67 of 187 , Volume 14, Rev. 0, Page 67 of 187

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, Volume 14, Rev. 0, Page 70 of 187 , Volume 14, Rev. 0, Page 70 of 187

Attachment 1, Volume 14, Rev. 0, Page 71 of 187 B 3.9.3 3 INSERT 1 A designated individual shall be available at all times during movement of irradiated fuel to close an air lock door if required. Cables or hoses transversing the air lock shall be designed to allow for removal in a timely manner (e.g., quick disconnects).

Insert Page B 3.9.4-4 Attachment 1, Volume 14, Rev. 0, Page 71 of 187

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Attachment 1, Volume 14, Rev. 0, Page 74 of 187 B 3.9.3 5 INSERT 2 The LCO 3.9.3.c.2 status requirement, which requires penetrations to be capable of being closed by an OPERABLE Containment Purge Supply and Exhaust System, can be verified by ensuring each required 3 INSERT 3 a small fraction of the guideline values specified in 10 CFR 100 3 INSERT 4 LCO 3.3.6, "Containment Purge Supply and Exhaust System Isolation Instrumentation,"

provides additional Surveillance Requirements for the containment purge supply and exhaust valve actuation circuitry.

Insert Page B 3.9.4-6 Attachment 1, Volume 14, Rev. 0, Page 74 of 187

, Volume 14, Rev. 0, Page 75 of 187 , Volume 14, Rev. 0, Page 75 of 187

Attachment 1, Volume 14, Rev. 0, Page 76 of 187 JUSTIFICATION FOR DEVIATIONS ITS 3.9.3 BASES, CONTAINMENT PENETRATIONS

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

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

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

4. The reference to a Fuel Handling Accident being initiated by CORE ALTERATIONS or the dropping of a heavy object onto irradiated fuel assemblies is deleted from the Applicable Safety Analyses section of the Bases. CORE ALTERATIONS other than irradiated fuel movement inside containment and dropping of a heavy object onto irradiated fuel assemblies are not assumed to initiate a Fuel Handling Accident. Only the dropping of an irradiated fuel assembly is assumed to initiate a Fuel Handling Accident.

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

6. Typographical/grammatical error corrected.

7. Editorial change for clarity.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 14, Rev. 0, Page 76 of 187

Attachment 1, Volume 14, Rev. 0, Page 77 of 187 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 14, Rev. 0, Page 77 of 187

Attachment 1, Volume 14, Rev. 0, Page 78 of 187 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.9.3, CONTAINMENT PENETRATIONS There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 14, Rev. 0, Page 78 of 187

Attachment 1, Volume 14, Rev. 0, Page 79 of 187 ATTACHMENT 4 ITS 3.9.4, Residual Heat Removal (RHR) and Coolant Circulation

- High Water Level Attachment 1, Volume 14, Rev. 0, Page 79 of 187

, Volume 14, Rev. 0, Page 80 of 187 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 14, Rev. 0, Page 80 of 187

Attachment 1, Volume 14, Rev. 0, Page 81 of 187 ITS 3.9.4 A.1 ITS M.1 OPERABLE and LCO 3.9.4 A.2 with the water level 23 ft above the top of the reactor vessel flange A.3 L.1 ACTION A L.2 Add proposed Required Action A.3 M.2 LCO 3.9.4 Note M.3 A.4 SR 3.9.4.1 12 M.4 L.1 Page 1 of 2 Attachment 1, Volume 14, Rev. 0, Page 81 of 187

Attachment 1, Volume 14, Rev. 0, Page 82 of 187 ITS 3.9.4 A.1 ITS M.1 OPERABLE and A.2 with the water level 23 ft above the top of the reactor LCO 3.9.4 vessel flange A.3 L.1 ACTION A L.2 Add proposed Required Action A.3 M.2 LCO 3.9.4 Note M.3 A.4 SR 3.9.4.1 12 M.4 L.1 Page 2 of 2 Attachment 1, Volume 14, Rev. 0, Page 82 of 187

Attachment 1, Volume 14, Rev. 0, Page 83 of 187 DISCUSSION OF CHANGES ITS 3.9.4, RESIDUAL HEAT REMOVAL (RHR) AND COOLANT CIRCULATION - HIGH WATER LEVEL 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 3.9.8.1 requires at least one residual heat removal loop to be in operation in MODE 6. ITS 3.9.4 requires one RHR loop to be OPERABLE and in operation in MODE 6 with the water level greater than or equal to 23 feet above the top of the reactor vessel flange. However, ITS 3.9.5 covers the Applicability of MODE 6 with water level less than 23 feet above the top of the reactor vessel flange. This changes the CTS by splitting the requirements associated with CTS 3.9.8.1 into two Applicabilities, one for MODE 6 with water level < 23 feet above the top of the reactor vessel flange, and one for MODE 6 with water level greater than of equal to 23 feet above the reactor vessel flange.

The purpose of CTS 3.9.8.1 is to ensure that adequate decay heat removal capability is in operation and that the coolant is circulated in MODE 6. This change is acceptable because the requirements continue to ensure that the process variables are maintained in the MODES and other specified conditions assumed in the safety analyses and licensing basis. MODE 6 RHR and coolant circulation requirements are governed by ITS 3.9.4, "Residual Heat Removal (RHR) and Coolant Circulation - High Water Level," and ITS 3.9.5, "Residual Heat Removal (RHR) and Coolant Circulation - Low Water Level." The combination of ITS 3.9.4 and ITS 3.9.5 ensures that the appropriate RHR loops are available in MODE 6 regardless of the water level. This change is designated as administrative because it does not result in technical changes to the CTS.

A.3 CTS 3.9.8.1 Action a states, in part, that with less than one RHR loop in operation, suspend all operations involving an increase in the reactor decay heat load of the Reactor Coolant System. ITS 3.9.4 Required Action A.2 states, in part, that with the RHR loop requirements not met, suspend loading irradiated fuel assemblies in the core. This changes the CTS by requiring that the loading of irradiated fuel assemblies be suspended instead of requiring that all operations involving an increase in the reactor decay heat load be suspended.

This change is acceptable because the requirements have not changed. The reactor decay heat load is generated only by irradiated fuel. The only method of increasing the decay heat load of a reactor in MODE 6 is to load additional irradiated fuel assemblies into the core. Therefore, the CTS and ITS requirements are equivalent. This change is designated as administrative because it does not result in technical changes to the CTS.

CNP Units 1 and 2 Page 1 of 5 Attachment 1, Volume 14, Rev. 0, Page 83 of 187

Attachment 1, Volume 14, Rev. 0, Page 84 of 187 DISCUSSION OF CHANGES ITS 3.9.4, RESIDUAL HEAT REMOVAL (RHR) AND COOLANT CIRCULATION - HIGH WATER LEVEL A.4 CTS 3.9.8.1 Action c states "The provisions of Specification 3.0.3 are not applicable." ITS 3.9.4 does not include this statement. This changes CTS by deleting the Specification 3.0.3 exception.

This change is acceptable because the technical requirements have not changed. ITS LCO 3.0.3 is not applicable in MODE 6. Therefore, the CTS LCO 3.0.3 exception is not needed. This change is designated as administrative because it does not result in a technical change to the CTS.

MORE RESTRICTIVE CHANGES M.1 CTS 3.9.8.1 requires that at least one residual heat removal loop be in operation.

ITS 3.9.4 requires that one RHR loop shall be OPERABLE and in operation.

This changes the CTS by requiring the RHR loop to be OPERABLE, instead of just in operation.

The purpose of CTS 3.9.8.1 is to ensure that adequate decay heat removal and coolant circulation are available in MODE 6. However, the CTS LCO could be interpreted as allowing an RHR loop to be placed in operation that was not OPERABLE. The ITS eliminates this possible misinterpretation. This change is acceptable because the RHR loop must be OPERABLE (i.e., capable of performing its safety function) instead of just being in operation. This change is designated as more restrictive because the ITS contains more specific requirements on a component.

M.2 The CTS 3.9.8.1 Actions do not include an action to immediately initiate action to satisfy the RHR loop requirements in the event the RHR loop requirements are not met. ITS 3.9.4 Required Action A.3 requires that action be immediately initiated to satisfy the RHR loop requirements. This changes the CTS by requiring that action be taken immediately to satisfy the RHR loop requirements.

The purpose of CTS 3.9.8.1 is to ensure that adequate decay heat removal and coolant circulation are available in MODE 6. Although decay heat is removed from the Reactor Coolant System via natural circulation to the bulk of water contained in the refueling canal, this method of heat transfer can continue for only a discrete amount of time before boiling would occur. This change is acceptable because it requires that action be initiated to restore the RHR loop requirements in order to restore forced coolant flow and heat removal. This change is designated as more restrictive because additional actions will be required in the ITS than are required in the CTS.

M.3 CTS 3.9.8.1 Action b states that the RHR loop may be removed from operation for up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period during the performance of CORE ALTERATIONS in the vicinity of the reactor pressure vessel hot legs. The ITS LCO 3.9.4 Note states that the required RHR loop may be removed from operation for < 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period, provided no operations are permitted that would cause introduction into the Reactor Coolant System, coolant with boron concentration less than that required to meet the minimum required boron concentration of LCO 3.9.1, "Boron Concentration." This results in two changes CNP Units 1 and 2 Page 2 of 5 Attachment 1, Volume 14, Rev. 0, Page 84 of 187

Attachment 1, Volume 14, Rev. 0, Page 85 of 187 DISCUSSION OF CHANGES ITS 3.9.4, RESIDUAL HEAT REMOVAL (RHR) AND COOLANT CIRCULATION - HIGH WATER LEVEL to the CTS. First, the allowance to remove RHR from operation is no longer restricted to CORE ALTERATIONS in the vicinity of the reactor pressure vessel hot legs. Second, the use of the allowance in the ITS is predicated on prohibiting operations that would cause introduction into the RCS, coolant with a boron concentration less than that required to meet the boron concentration of LCO 3.9.1.

This change is acceptable because it applies appropriate controls during periods when RHR is not in operation. The ITS requirement prohibiting operations which would cause a reduction in the RCS boron concentration below that required to maintain the required shutdown margin is necessary to avoid unexpected reactivity changes. Under the ITS definition of CORE ALTERATIONS, many activities that would be considered CORE ALTERATIONS in the CTS, such as core mapping, are not considered CORE ALTERATIONS in the ITS. Therefore, the application of the allowance is expanded in the ITS to cover other activities beyond CORE ALTERATIONS. This change is nominally less restrictive, but represents no practical operational change, and the overall change is considered more restrictive. This change is designated as more restrictive because it imposes a new condition to be met when an RHR loop is not in operation.

M.4 CTS 4.9.8.1 requires that a residual heat removal loop shall be determined to be in operation and circulating reactor coolant at a flow rate of greater than or equal to 2000 gpm at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . ITS SR 3.9.4.1 requires the same verification every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This changes the CTS by requiring that RHR loop operation and reactor coolant flow rate be verified every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months instead of every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

The purpose of CTS 4.9.8.1 is to ensure that adequate decay heat removal and coolant circulation are available in MODE 6. This change is acceptable since it results in an increased Frequency of performance. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency is consistent with similar CTS Surveillances in MODES 4 and 5, and with similar SRs in the ITS. This change is designated as more restrictive because the Surveillance will be performed at an increased Frequency in the ITS.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES L.1 (Category 4 - Relaxation of Required Action) CTS 3.9.8.1 Action a states, in part, that with less than one RHR loop in operation, suspend all operations involving a reduction in boron concentration of the Reactor Coolant System. This CNP Units 1 and 2 Page 3 of 5 Attachment 1, Volume 14, Rev. 0, Page 85 of 187

Attachment 1, Volume 14, Rev. 0, Page 86 of 187 DISCUSSION OF CHANGES ITS 3.9.4, RESIDUAL HEAT REMOVAL (RHR) AND COOLANT CIRCULATION - HIGH WATER LEVEL CTS Action is modified by a footnote which states that addition of water from the RWST does not constitute a dilution activity provided the boron concentration in the RWST is greater than the minimum required by Specification 3.1.2.7.b.2 (i.e.,

2400 ppm). ITS 3.9.4 Required Action A.1 states that with the RHR loop requirements not met, suspend operations that would cause introduction into the RCS, coolant with boron concentration less than required to meet the boron concentration of LCO 3.9.1, "Boron Concentration." ITS 3.9.1 requires boron concentration to be within limit. This changes the CTS by allowing coolant with boron concentration less than the RCS boron concentration, but greater than the boron concentration limit in ITS LCO 3.9.1, to be added to the RCS from sources other than the RWST when the RHR requirements are not met.

The purpose of CTS 3.9.8.1 Action a is to ensure that the required SHUTDOWN MARGIN is maintained during periods when the RHR requirements are not met.

This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABILITY status of the redundant systems of required features, the capacity and capability of remaining features, a reasonable time for repairs or replacement of required features, and the low probability of an accident occurring during the repair period.

The Required Actions ensure that the RCS boron concentration is maintained within the limits of ITS LCO 3.9.1, which is sufficient to ensure that adequate SHUTDOWN MARGIN is maintained. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L.2 (Category 4 - Relaxation of Required Action) CTS 3.9.8.1 Action a states, in part, that with less than one RHR loop in operation, close all containment penetrations providing direct access from the containment atmosphere to the outside atmosphere within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . ITS 3.9.4 Required Actions A.4, A.5, and A.6 state that with the RHR loop requirements not met, within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months close and secure the equipment hatch with at least four bolts, close one door in each air lock, and verify each penetration providing direct access from the containment atmosphere to the outside atmosphere is either closed with a manual or automatic isolation valve, blind flange, or equivalent, or is capable of being closed by an OPERABLE Containment Purge Supply and Exhaust System. This changes the CTS Actions by allowing penetrations capable of being closed by an OPERABLE Containment Purge Supply and Exhaust System to remain open when the RHR requirements are not met.

The purpose of CTS 3.9.8.1 Action a is to ensure that radioactive material does not escape the containment should the RHR requirements continue to not be met and boiling occurs in the core. Therefore, containment penetrations are closed to seal the containment. 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, CNP Units 1 and 2 Page 4 of 5 Attachment 1, Volume 14, Rev. 0, Page 86 of 187

Attachment 1, Volume 14, Rev. 0, Page 87 of 187 DISCUSSION OF CHANGES ITS 3.9.4, RESIDUAL HEAT REMOVAL (RHR) AND COOLANT CIRCULATION - HIGH WATER LEVEL considering the OPERABILITY status of the redundant systems of required features, the capacity and capability of remaining features, a reasonable time for repairs or replacement of required features, and the low probability of an accident occurring during the repair period. The Required Actions are consistent with the actions taken for containment closure in CTS 3.9.4 and ITS 3.9.3. Penetrations which can be closed by an OPERABLE Containment Purge Supply and Exhaust System do not need to be closed if RHR is inoperable, since the presence of radioactivity in the containment will cause the valves to close automatically, thus performing the isolation function. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

CNP Units 1 and 2 Page 5 of 5 Attachment 1, Volume 14, Rev. 0, Page 87 of 187

Attachment 1, Volume 14, Rev. 0, Page 88 of 187 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 14, Rev. 0, Page 88 of 187

, Volume 14, Rev. 0, Page 89 of 187 , Volume 14, Rev. 0, Page 89 of 187

, Volume 14, Rev. 0, Page 90 of 187 , Volume 14, Rev. 0, Page 90 of 187

Attachment 1, Volume 14, Rev. 0, Page 91 of 187 JUSTIFICATION FOR DEVIATIONS ITS 3.9.4, RESIDUAL HEAT REMOVAL (RHR) AND COOLANT CIRCULATION - HIGH WATER LEVEL

1. CNP has analyzed a boron dilution event in MODE 6. Therefore, ISTS 3.9.2 is not included in the ITS and ISTS 3.9.5 is renumbered as ITS 3.9.4.

2. Editorial correction to be consistent with the format of the ITS.

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

4. ISTS 3.9.5 Required Actions A.6.1 and A.6.2 are connected by an "OR" logical connector, such that either one can be performed to meet the requirements of the ACTION. However, the two Required Actions are applicable to all the penetrations; either Required Action A.6.1 or Required Action A.6.2 must be performed for all the penetrations. Thus, this will not allow one penetration to be isolated by use of a manual valve and another penetration to be capable of being closed by an OPERABLE Containment Purge Supply and Exhaust System. This is not the intent of the requirement. The requirement is based on ISTS LCO 3.9.4 (ITS LCO 3.9.3),

which requires each penetration to be either: a) closed by a manual or automatic isolation valve, blind flange, or equivalent; or b) capable of being closed by an OPERABLE Containment Purge Supply and Exhaust System. For consistency with the actual LCO requirement, ISTS 3.9.5 Required Actions A.6.1 and A.6.2 have been combined into a single Required Action in ITS 3.9.4 Required Action A.6.

5. Changes have been made to be consistent with changes made in another Specification and to be consistent with plant specific nomenclature.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 14, Rev. 0, Page 91 of 187

Attachment 1, Volume 14, Rev. 0, Page 92 of 187 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 14, Rev. 0, Page 92 of 187

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, Volume 14, Rev. 0, Page 94 of 187 , Volume 14, Rev. 0, Page 94 of 187

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, Volume 14, Rev. 0, Page 97 of 187 , Volume 14, Rev. 0, Page 97 of 187

Attachment 1, Volume 14, Rev. 0, Page 98 of 187 JUSTIFICATION FOR DEVIATIONS ITS 3.9.4 BASES, RESIDUAL HEAT REMOVAL (RHR) AND COOLANT CIRCULATION

- HIGH WATER LEVEL

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

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

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

3. 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 (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. The wording has been modified, as Section 3.5 does not provide requirements for the RHR Shutdown Cooling function.

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

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

8. Typographical/grammatical error corrected.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 14, Rev. 0, Page 98 of 187

Attachment 1, Volume 14, Rev. 0, Page 99 of 187 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 14, Rev. 0, Page 99 of 187

Attachment 1, Volume 14, Rev. 0, Page 100 of 187 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.9.4, RESIDUAL HEAT REMOVAL (RHR) AND COOLANT CIRCULATION -

HIGH WATER LEVEL There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 14, Rev. 0, Page 100 of 187

Attachment 1, Volume 14, Rev. 0, Page 101 of 187 ATTACHMENT 5 ITS 3.9.5, Residual Heat Removal (RHR) and Coolant Circulation

- Low Water Level Attachment 1, Volume 14, Rev. 0, Page 101 of 187

, Volume 14, Rev. 0, Page 102 of 187 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 14, Rev. 0, Page 102 of 187

Attachment 1, Volume 14, Rev. 0, Page 103 of 187 ITS 3.9.5 A.1 ITS L.3 LCO 3.9.5 Add proposed LCO Note 1 A.2 with the water level < 23 ft above the top of the reactor vessel flange A.3 ACTION B L.1 L.2 Add proposed Required Action B.2 See ITS M.1 3.9.4 A.4 SR 3.9.5.1 12 M.2 L.1 Page 1 of 4 Attachment 1, Volume 14, Rev. 0, Page 103 of 187

Attachment 1, Volume 14, Rev. 0, Page 104 of 187 ITS 3.9.5 A.1 ITS A.5 LCO 3.9.5 Add proposed LCO Note 2 L.3 ACTION A A.6 Add proposed Required Action A.2 A.4 L.4 Add proposed SR 3.9.5.2 and Note M.3 A.5 Page 2 of 4 Attachment 1, Volume 14, Rev. 0, Page 104 of 187

Attachment 1, Volume 14, Rev. 0, Page 105 of 187 ITS 3.9.5 A.1 ITS L.3 LCO 3.9.5 A.2 Add proposed LCO Note 1 with the water level < 23 ft above the top of the reactor vessel flange A.3 ACTION B L.1 L.2 Add proposed Required Action B.2 See ITS M.1 3.9.4 A.4 SR 3.9.5.1 12 M.2 L.1 Page 3 of 4 Attachment 1, Volume 14, Rev. 0, Page 105 of 187

Attachment 1, Volume 14, Rev. 0, Page 106 of 187 ITS 3.9.5 A.1 ITS A.5 LCO 3.9.5 Add proposed LCO Note 2 L.3 ACTION A A.6 Add proposed Required Action A.2 A.4 L.4 Add proposed SR 3.9.5.2 and Note M.3 A.5 Page 4 of 4 Attachment 1, Volume 14, Rev. 0, Page 106 of 187

Attachment 1, Volume 14, Rev. 0, Page 107 of 187 DISCUSSION OF CHANGES ITS 3.9.5, RESIDUAL HEAT REMOVAL (RHR) AND COOLANT CIRCULATION - LOW WATER LEVEL 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 3.9.8.1 requires at least one residual heat removal loop to be in operation in MODE 6. ITS 3.9.5 requires two RHR loops to be OPERABLE and one RHR loop to be in operation in MODE 6 with the water level less than 23 feet above the top of the reactor vessel flange. However, ITS 3.9.4 covers the Applicability of MODE 6 with water level greater than or equal to 23 feet above the top of the reactor vessel flange. This changes the CTS by splitting the requirements associated with CTS 3.9.8.1 into two Applicabilities, one for MODE 6 with water level < 23 feet above the top of the reactor vessel flange, and one for MODE 6 with water level > 23 feet above the reactor vessel flange.

The purpose of CTS 3.9.8.1 is to ensure that adequate decay heat removal capability is in operation and that the coolant is circulated in MODE 6. This change is acceptable because the requirements continue to ensure that the process variables are maintained in the MODES and other specified conditions assumed in the safety analyses and licensing basis. MODE 6 RHR and coolant circulation requirements are governed by ITS 3.9.4, "Residual Heat Removal (RHR) and Coolant Circulation - High Water Level," and ITS 3.9.5, "Residual Heat Removal (RHR) and Coolant Circulation - Low Water Level." The combination of ITS 3.9.4 and ITS 3.9.5 ensures that the appropriate RHR loops are available in MODE 6 regardless of the water level. This change is designated as administrative because it does not result in technical changes to the CTS.

A.3 CTS 3.9.8.1 Action a states, in part, that with less than one RHR loop in operation, suspend all operations involving an increase in the reactor decay heat load of the Reactor Coolant System. ITS 3.9.5 does not include this requirement.

This changes the CTS by eliminating the requirement to suspend operations involving an increase in reactor decay heat load.

This change is acceptable because the requirements have not changed. The reactor decay heat load is generated only by irradiated fuel. The only method of increasing the decay head load of a reactor in MODE 6 is to load additional irradiated fuel assemblies into the core. However, ITS LCO 3.9.6 prohibits loading of fuel assemblies into the reactor when the water level is less than 23 feet over the top of the reactor vessel flange. Therefore, when LCO 3.9.5 is applicable there is no method available to increase the reactor decay heat load, and the requirement can be deleted with no effect on plant operations. This change is designated as administrative because it does not result in technical changes to the CTS.

CNP Units 1 and 2 Page 1 of 5 Attachment 1, Volume 14, Rev. 0, Page 107 of 187

Attachment 1, Volume 14, Rev. 0, Page 108 of 187 DISCUSSION OF CHANGES ITS 3.9.5, RESIDUAL HEAT REMOVAL (RHR) AND COOLANT CIRCULATION - LOW WATER LEVEL A.4 CTS 3.9.8.1 Action c and CTS 3.9.8.2 Action c state, "The provisions of Specification 3.0.3 are not applicable." ITS 3.9.5 does not include this statement.

This changes CTS by deleting the Specification 3.0.3 exception.

This change is acceptable because the technical requirements have not changed. ITS LCO 3.0.3 is not applicable in MODE 6. Therefore, the CTS LCO 3.0.3 exception is not needed. This change is designated as administrative because it does not result in a technical change to the CTS.

A.5 CTS LCO 3.9.8.2 is modified by footnote *, which states that the normal or emergency power source may be inoperable for each RHR loop. ITS 3.9.5 does not include this statement. This changes the CTS by deleting an allowance already provided in a different portion of the ITS.

This change is acceptable because the ITS definition of OPERABLE contains the necessary requirements for a component to perform its safety function. The ITS definition of OPERABLE states that a component is OPERABLE if either the normal or emergency power source is OPERABLE. This change is designated as administrative because it does not result in technical changes to the CTS.

A.6 CTS 3.9.8.2 Action a states that with less than the required RHR loops OPERABLE, immediately initiate corrective action to return the required RHR loops to OPERABLE status as soon as possible. ITS 3.9.5 ACTION A includes the same requirement, but also includes an allowance (Required Action A.2) to immediately initiate action to establish > 23 feet of water above the top of reactor vessel flange. This changes the CTS by providing the option to exit the Applicability of the LCO.

This change is acceptable because the requirements have not changed. Exiting the Applicability of LCO is always an option to exit an ACTION. Therefore, stating this option explicitly does not change the requirements of the Specification. This change is designated as administrative because it does not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES M.1 The CTS 3.9.8.1 Actions do not include an action to immediately initiate action to restore one RHR loop to operation in the event the RHR loop requirements are not met. ITS 3.9.5 Required Action B.2 requires that action be immediately initiated to restore one RHR loop to operation. This changes the CTS by requiring that action be taken immediately to restore one RHR loop to operation.

The purpose of CTS 3.9.8.1 is to ensure that adequate decay heat removal and coolant circulation are available in MODE 6. Although decay heat is removed from the Reactor Coolant System via natural circulation to the bulk of water contained in the refueling canal, this method of heat transfer can continue for only a discrete amount of time before boiling would occur. This change is acceptable because it requires that action be initiated to restore one RHR loop to operation in order to restore forced coolant flow and heat removal. This change CNP Units 1 and 2 Page 2 of 5 Attachment 1, Volume 14, Rev. 0, Page 108 of 187

Attachment 1, Volume 14, Rev. 0, Page 109 of 187 DISCUSSION OF CHANGES ITS 3.9.5, RESIDUAL HEAT REMOVAL (RHR) AND COOLANT CIRCULATION - LOW WATER LEVEL is designated as more restrictive because additional actions will be required in the ITS than are required in the CTS.

M.2 CTS 4.9.8.1 requires that a residual heat removal loop shall be determined to be in operation and circulating reactor coolant at a flow rate of greater than or equal to 2000 gpm at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . ITS SR 3.9.5.1 requires the same verification every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This changes the CTS by requiring that RHR loop operation and reactor coolant flow rate be verified every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months instead of every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

The purpose of CTS 4.9.8.1 is to ensure that adequate decay heat removal and coolant circulation are available in MODE 6. This change is acceptable since it results in an increased Frequency of performance. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency is consistent with similar CTS Surveillances in MODES 4 and 5, and with similar SRs in the ITS. This change is designated as more restrictive because the Surveillance will be performed at an increased Frequency in the ITS.

M.3 CTS 3.9.8.2 requires two independent RHR loops to be OPERABLE and CTS 3.9.8.1 requires at least one RHR loop to be in operation. ITS SR 3.9.5.2 requires verification every seven days of correct breaker alignment and that indicated power is available to the required RHR pump not in operation. A Note states that the Surveillance Requirement is not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a required RHR pump is not in operation. This changes the CTS by adding a Surveillance Requirement.

The purpose of ITS 3.9.5 is to require one RHR loop to be in operation and one RHR loop to be held in readiness should it be needed. This change is acceptable because it verifies that the RHR loop that is in standby will be ready should it be needed. This change is designated as more restrictive because it adds a new Surveillance Requirement to the CTS.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES L.1 (Category 4 - Relaxation of Required Action) CTS 3.9.8.1 Action a states, in part, that with less than one RHR loop in operation, suspend all operations involving a reduction in boron concentration of the Reactor Coolant System. This CTS Action is modified by a footnote which states that addition of water from the RWST does not constitute a dilution activity provided the boron concentration in the RWST is greater than the minimum required by Specification 3.1.2.7.b.2 (i.e.,

CNP Units 1 and 2 Page 3 of 5 Attachment 1, Volume 14, Rev. 0, Page 109 of 187

Attachment 1, Volume 14, Rev. 0, Page 110 of 187 DISCUSSION OF CHANGES ITS 3.9.5, RESIDUAL HEAT REMOVAL (RHR) AND COOLANT CIRCULATION - LOW WATER LEVEL 2400 ppm). ITS 3.9.5 Required Action B.1 states that with no RHR loop in operation, suspend operations that would cause introduction into the RCS, coolant with boron concentration less than required to meet the boron concentration of LCO 3.9.1, "Boron Concentration." ITS 3.9.1 requires boron concentration to be within limit. This changes the CTS by allowing coolant with boron concentration less than the RCS boron concentration, but greater than the boron concentration limit in ITS LCO 3.9.1, to be added to the RCS from sources other than the RWST when the RHR loops are not in operation.

The purpose of CTS 3.9.8.1 Action a is to ensure that the required SHUTDOWN MARGIN is maintained during periods when the RHR requirements are not met.

This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABILITY status of the redundant systems of required features, the capacity and capability of remaining features, a reasonable time for repairs or replacement of required features, and the low probability of an accident occurring during the repair period.

The Required Actions ensure that the RCS boron concentration is maintained within the limits of ITS LCO 3.9.1, which is sufficient to ensure that adequate SHUTDOWN MARGIN is maintained. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L.2 (Category 4 - Relaxation of Required Action) CTS 3.9.8.1 Action a states, in part, that with less than one RHR loop in operation, close all containment penetrations providing direct access from the containment atmosphere to the outside atmosphere within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . ITS 3.9.5 Required Actions B.3, B.4, and B.5 state that with no RHR loop in operation, within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months close and secure the equipment hatch with at least four bolts, close one door in each air lock, and verify each penetration providing direct access from the containment atmosphere to the outside atmosphere is either closed with a manual or automatic isolation valve, blind flange, or equivalent, or is capable of being closed by an OPERABLE Containment Purge Supply and Exhaust System. This changes the CTS Actions by allowing penetrations capable of being closed by an OPERABLE Containment Purge Supply and Exhaust System to remain open when no RHR loop is in operation.

The purpose of CTS 3.9.8.1 Action a is to ensure that radioactive material does not escape the containment should the RHR requirements continue to not be met and boiling occurs in the core. Therefore, containment penetrations are closed to seal the containment. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABILITY status of the redundant systems of required features, the capacity and capability of remaining features, a reasonable time for repairs or replacement of required features, and the low probability of a DBA CNP Units 1 and 2 Page 4 of 5 Attachment 1, Volume 14, Rev. 0, Page 110 of 187

Attachment 1, Volume 14, Rev. 0, Page 111 of 187 DISCUSSION OF CHANGES ITS 3.9.5, RESIDUAL HEAT REMOVAL (RHR) AND COOLANT CIRCULATION - LOW WATER LEVEL occurring during the repair period. The Required Actions are consistent with the actions taken for containment closure in CTS 3.9.4 and ITS 3.9.3. Penetrations which can be closed by an OPERABLE Containment Purge Supply and Exhaust System do not need to be closed if RHR is inoperable, since the presence of radioactivity in the containment will cause the valves to close automatically, thus performing the isolation function. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L.3 (Category 1 - Relaxation of LCO Requirements) ITS 3.9.5 is modified by two LCO Notes. Note 1 allows all RHR pumps to be removed from operation for

< 15 minutes when switching from one loop to another, provided several conditions are met. Note 2 allows one required RHR loop to be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for Surveillance testing, provided that the other loop is OPERABLE and in operation. Neither CTS 3.9.8.1 nor CTS 3.9.8.2 contain these allowances.

This changes the CTS by allowing the LCO to not be met under certain situations.

The purpose of CTS 3.9.8.1 and CTS 3.9.8.2 is to ensure sufficient decay heat removal is available in the specified MODES and conditions. 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 ITS Notes allow normal operational evolutions, such as pump swapping and surveillance testing, to be performed while in the Applicability of the Specification. These evolutions are necessary to demonstrate RHR OPERABILITY. 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.4 (Category 5 - Deletion of Surveillance Requirement) CTS 4.9.8.2 requires verification that each RHR loop is OPERABLE per Specification 4.0.5. ITS 3.9.5 does not contain this Surveillance. This changes the CTS by deleting this specific Surveillance.

The purpose of CTS Specification 4.0.5 is to require inservice testing in accordance with 10 CFR 50.55a. The purpose of inservice testing of RHR is to detect gross degradation caused by impeller structural damage or other hydraulic component problems. 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 function. This Technical Specification will no longer tie RHR loop OPERABILITY to the Inservice Testing Program. This change is acceptable because it is not necessary to perform inservice testing of an RHR loop to determine if it is OPERABLE, as the system is routinely operated and the RHR loops are instrumented so that degradation can be observed. Significant degradation of the RHR System would be indicated by the RHR System flow and temperature instrumentation in the Control Room.

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

CNP Units 1 and 2 Page 5 of 5 Attachment 1, Volume 14, Rev. 0, Page 111 of 187

Attachment 1, Volume 14, Rev. 0, Page 112 of 187 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 14, Rev. 0, Page 112 of 187

, Volume 14, Rev. 0, Page 113 of 187 , Volume 14, Rev. 0, Page 113 of 187

, Volume 14, Rev. 0, Page 114 of 187 , Volume 14, Rev. 0, Page 114 of 187

, Volume 14, Rev. 0, Page 115 of 187 , Volume 14, Rev. 0, Page 115 of 187

Attachment 1, Volume 14, Rev. 0, Page 116 of 187 3.9.5 4 INSERT 1

-NOTE-Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a required RHR pump is not in operation.

Insert Page 3.9.6-3 Attachment 1, Volume 14, Rev. 0, Page 116 of 187

Attachment 1, Volume 14, Rev. 0, Page 117 of 187 JUSTIFICATION FOR DEVIATIONS ITS 3.9.5, RESIDUAL HEAT REMOVAL (RHR) AND COOLANT CIRCULATION - LOW WATER LEVEL

1. CNP has analyzed a boron dilution event in MODE 6. Therefore, ISTS 3.9.2 is not included in the ITS and ISTS 3.9.6 is renumbered as ITS 3.9.5.

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

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

4. TSTF-265 was previously approved and incorporated in NUREG-1431, Rev. 2, in similar SRs (e.g., ISTS SRs 3.4.5.3, 3.4.6.3, 3.4.7.3, and 3.4.8.2). Consistent with TSTF-265, a Note is added to ISTS SR 3.9.6.2 that permits the performance of the SR to verify correct breaker alignment and power availability to be delayed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a required pump is not in operation. This provision is required because when pumps are swapped under the current requirements, the Surveillance is immediately not met on the pump taken out of operation. This change avoids entering an Action for a routine operational occurrence. The change is acceptable because adequate assurance exists that the pump is aligned to the correct breaker with power available because, prior to being removed from operation, the applicable pump had been in operation. Allowing 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to perform the breaker alignment verification is acceptable because the pump was in operation, which demonstrated OPERABILITY, and because 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is currently allowed by invoking SR 3.0.3.

This is a new Surveillance Requirement not required in CTS 3.9.8.2.

5. Editorial change made to be consistent with the LCO statement.

6. Editorial change made to be consistent with the format of the ITS.

7. ISTS 3.9.6 Required Actions B.5.1 and B.5.2 are connected by an "OR" logical connector, such that either one can be performed to meet the requirements of the ACTION. However, the two Required Actions are applicable to all the penetrations; either Required Action B.5.1 or Required Action B.5.2 must be performed for all the penetrations. Thus, this will not allow one penetration to be isolated by use of a manual valve and another penetration to be capable of being closed by an OPERABLE Containment Purge Supply and Exhaust System. This is not the intent of the requirement. The requirement is based on ISTS LCO 3.9.4 (ITS LCO 3.9.3),

which requires each penetration to be either: a) closed by a manual or automatic isolation valve, blind flange, or equivalent; or b) capable of being closed by an OPERABLE Containment Purge Supply and Exhaust System. For consistency with the actual LCO requirement, ISTS 3.9.6 Required Actions B.5.1 and B.5.2 have been combined into a single Required Action in ITS 3.9.5 Required Action B.5.

8. Changes have been made to be consistent with changes made in another Specification and be consistent with plant specific nomenclature.

9. The limit has been changed to be consistent with the same limit provided in Notes to ISTS 3.4.6 and ISTS 3.4.7.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 14, Rev. 0, Page 117 of 187

Attachment 1, Volume 14, Rev. 0, Page 118 of 187 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 14, Rev. 0, Page 118 of 187

, Volume 14, Rev. 0, Page 119 of 187 , Volume 14, Rev. 0, Page 119 of 187

, Volume 14, Rev. 0, Page 120 of 187 , Volume 14, Rev. 0, Page 120 of 187

, Volume 14, Rev. 0, Page 121 of 187 , Volume 14, Rev. 0, Page 121 of 187

, Volume 14, Rev. 0, Page 122 of 187 , Volume 14, Rev. 0, Page 122 of 187

, Volume 14, Rev. 0, Page 123 of 187 , Volume 14, Rev. 0, Page 123 of 187

, Volume 14, Rev. 0, Page 124 of 187 , Volume 14, Rev. 0, Page 124 of 187

Attachment 1, Volume 14, Rev. 0, Page 125 of 187 JUSTIFICATION FOR DEVIATIONS ITS 3.9.5 BASES, RESIDUAL HEAT REMOVAL (RHR) AND COOLANT CIRCULATION

- LOW WATER LEVEL

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

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

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

3. The current wording implies specific restrictions not contained in LCO Note 2.

Therefore, the words have been modified to provide guidance on what should be considered in determining whether or not to use the Note allowance.

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

5. 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.

6. The wording has been modified, as Section 3.5 does not provide requirements for the RHR Shutdown Cooling function.

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

8. Typographical/grammatical error corrected.

9. Changes are made to be consistent with the ISTS.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 14, Rev. 0, Page 125 of 187

Attachment 1, Volume 14, Rev. 0, Page 126 of 187 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 14, Rev. 0, Page 126 of 187

Attachment 1, Volume 14, Rev. 0, Page 127 of 187 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.9.5, RESIDUAL HEAT REMOVAL (RHR) AND COOLANT CIRCULATION -

LOW WATER LEVEL There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 14, Rev. 0, Page 127 of 187

, Volume 14, Rev. 0, Page 128 of 187 ATTACHMENT 6 ITS 3.9.6, Refueling Cavity Water Level , Volume 14, Rev. 0, Page 128 of 187

, Volume 14, Rev. 0, Page 129 of 187 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 14, Rev. 0, Page 129 of 187

Attachment 1, Volume 14, Rev. 0, Page 130 of 187 ITS 3.9.6 A.1 ITS L.1 L.2 LCO 3.9.6 irradiated A.2 M.1 irradiated ACTION A L.1 L.2 A.3 M.1 SR 3.9.6.1 L.3 L.2 Page 1 of 2 Attachment 1, Volume 14, Rev. 0, Page 130 of 187

Attachment 1, Volume 14, Rev. 0, Page 131 of 187 ITS 3.9.6 A.1 ITS L.1 L.2 LCO 3.9.6 irradiated A.2 M.1 ACTION A irradiated L.1 L.2 A.3 M.1 SR 3.9.6.1 L.3 L.2 Page 2 of 2 Attachment 1, Volume 14, Rev. 0, Page 131 of 187

Attachment 1, Volume 14, Rev. 0, Page 132 of 187 DISCUSSION OF CHANGES ITS 3.9.6, REFUELING CAVITY WATER LEVEL 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 3.9.10 is applicable in MODE 6 during movement of fuel assemblies or control rods within the reactor pressure vessel. ITS 3.9.6 is applicable during movement of irradiated fuel assemblies within containment. This changes the CTS by eliminating the "MODE 6" portion of the Applicability. The change to "irradiated fuel assemblies" from "fuel assemblies" is discussed in DOC L.1. The change from within "the reactor pressure vessel" to within "containment" is discussed in DOC M.1. The change eliminating control rods is discussed in DOC L.2.

This change is acceptable because the technical requirements have not changed. Fuel movement in the containment only occurs in MODE 6. Therefore, specifying MODE 6 during movement of fuel is unnecessary. This change is designated as administrative because the technical requirements of the CTS have not changed.

A.3 The CTS 3.9.10 Action states "The provisions of Specification 3.0.3 are not applicable." ITS 3.9.6 does not include this statement. This changes the CTS by deleting the Specification 3.0.3 exception.

This change is acceptable because the technical requirements have not changed. ITS LCO 3.0.3 is not applicable in MODE 6. Therefore, the CTS LCO 3.0.3 exception is not needed. This change is designated as administrative because it does not result in a technical change to the CTS.

MORE RESTRICTIVE CHANGES M.1 CTS 3.9.10 is applicable during movement of fuel assemblies or control rods within the "reactor pressure vessel" while in MODE 6. The CTS 3.9.10 Action states that with the reactor vessel water level not within limit, suspend movement of fuel assemblies or control rods within the "pressure vessel." The ITS 3.9.6 Applicability is during movement of irradiated fuel assemblies within "containment." ITS 3.9.6 ACTION A states that with the refueling cavity water level not within limit, suspend movement of irradiated fuel assemblies within "containment." This changes the CTS by expanding the suspension of movement of fuel assemblies from within the "reactor pressure vessel" to within the "containment." The change to "irradiated fuel assemblies" from "fuel assemblies" is discussed in DOC L.1. The change eliminating MODE 6 is discussed in DOC A.2. The change eliminating control rods is discussed in DOC L.2.

CNP Units 1 and 2 Page 1 of 3 Attachment 1, Volume 14, Rev. 0, Page 132 of 187

Attachment 1, Volume 14, Rev. 0, Page 133 of 187 DISCUSSION OF CHANGES ITS 3.9.6, REFUELING CAVITY WATER LEVEL The purpose of CTS 3.9.10 is to ensure the refueling cavity water level is greater than or equal to that assumed in the fuel handling accident analysis. This change is acceptable because the fuel handling accident analysis assumes an irradiated fuel assembly is damaged within the containment, not only within the reactor vessel. In order to protect the initial assumptions of the fuel handling accident analysis, prohibition of irradiated fuel movement within the containment is required. This change is designated as more restrictive because it will prohibit operations that are not prohibited in the CTS.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES L.1 (Category 2 - Relaxation of Applicability) CTS 3.9.10 states that at least 23 feet of water must be maintained over the reactor pressure vessel flange in MODE 6 during movement of fuel assemblies or control rods within the reactor pressure vessel. The CTS 3.9.10 Action requires suspension of movement of fuel assemblies or control rods within the pressure vessel if the water level requirement is not met. ITS 3.9.6 states the refueling cavity water level shall be maintained > 23 feet above the top of the reactor vessel flange during movement of irradiated fuel assemblies within containment. ITS 3.9.6 Required Action A.1 requires the suspension of movement of irradiated fuel assemblies within containment. This changes the CTS restricting the Applicability and ACTIONS from movement of any "fuel assemblies" within the reactor pressure vessel to movement of "irradiated fuel assemblies" within containment. The change eliminating MODE 6 is discussed in DOC A.2. The change from within "the reactor pressure vessel to within "containment is discussed in DOC M.1. The change eliminating control rods is discussed in DOC L.2.

The purpose of CTS 3.9.10 is to ensure that the refueling cavity water level is greater than or equal to that assumed in the fuel handling accident analysis. This change is acceptable because the requirements continue to ensure that the process variables are maintained in the MODES and other specified conditions assumed in the safety analyses and licensing basis. The fuel handling accident analysis is based on damaging a single irradiated fuel assembly. An unirradiated fuel assembly does not contain the radioactive materials generated by fission and does not result in significant offsite doses if damaged. This change is designated as less restrictive because the LCO requirements are applicable in fewer operating conditions than in the CTS.

L.2 (Category 2 - Relaxation of Applicability) CTS 3.9.10 requires the refueling cavity water level to be maintained at least 23 feet over the top of the reactor CNP Units 1 and 2 Page 2 of 3 Attachment 1, Volume 14, Rev. 0, Page 133 of 187

Attachment 1, Volume 14, Rev. 0, Page 134 of 187 DISCUSSION OF CHANGES ITS 3.9.6, REFUELING CAVITY WATER LEVEL pressure vessel flange during movement of fuel assemblies or control rods within the reactor pressure vessel while in MODE 6. The CTS 3.9.10 Action requires suspension of all operations involving movement of the fuel assemblies or control rods within the pressure vessel in the event the LCO is not met. CTS 4.9.10 requires a determination of the refueling canal water level during the movement of fuel assemblies or control rods. ITS 3.9.6 requires the refueling cavity water level to be maintained greater than or equal to 23 feet above the top of the reactor vessel flange during movement of irradiated fuel assemblies within containment. This changes the CTS by deleting the requirement that the LCO, ACTIONS, and Surveillance is applicable during control rod movement. The change to "irradiated fuel assemblies" from "fuel assemblies" is discussed in DOC L.1. The change eliminating MODE 6 is discussed in DOC A.2. The change from within "the reactor pressure vessel" to within "containment" is discussed in DOC M.1.

The purpose of CTS 3.9.10 is to ensure that the refueling cavity water level is greater than or equal to that assumed in the fuel handling accident analysis. This change is acceptable because the requirements continue to ensure that the process variables are maintained in the MODES and other specified conditions assumed in the safety analyses and licensing basis. The fuel handling accident is based on damaging a single irradiated fuel assembly. Movement of control rods is not assumed to result in a fuel handling accident. This change is designated as less restrictive because the LCO requirements are applicable in fewer operating conditions than in the CTS.

L.3 (Category 7 - Relaxation Of Surveillance Frequency, Non-24 Month Type Change) CTS 4.9.10 requires the refueling cavity water level to be determined to be within limit "within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months prior to the start of" and at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter during movement of fuel assemblies or control rods. ITS SR 3.9.6.1 requires verification that the refueling cavity water level is within limit every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . This changes the CTS by reducing the Frequency for verifying refueling cavity water level from 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months before entering the Applicability of the LCO to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months before entering the Applicability of the LCO.

The purpose of CTS 4.9.10 is to ensure that the refueling cavity water level is greater than or equal to that assumed in the fuel handling accident analysis. This change is acceptable because the new Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability.

The Frequency of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is sufficient during the movement of fuel assemblies, therefore it is sufficient before fuel assemblies are moved. ITS SR 3.0.1 requires the SR to be met during the MODES or other specified conditions in the Applicability. Therefore, the water level must be met when fuel assemblies are moved or fuel assembly movement must be suspended immediately (thereby exiting the Applicability of the Specification). Therefore, changing the Frequency from 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months before moving fuel assemblies to within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months before moving fuel assemblies has no effect on plant safety. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

CNP Units 1 and 2 Page 3 of 3 Attachment 1, Volume 14, Rev. 0, Page 134 of 187

Attachment 1, Volume 14, Rev. 0, Page 135 of 187 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 14, Rev. 0, Page 135 of 187

, Volume 14, Rev. 0, Page 136 of 187 , Volume 14, Rev. 0, Page 136 of 187

Attachment 1, Volume 14, Rev. 0, Page 137 of 187 JUSTIFICATION FOR DEVIATIONS ITS 3.9.6, REFUELING CAVITY WATER LEVEL

1. CNP has analyzed a boron dilution event in MODE 6. Therefore, ISTS 3.9.2 is not included in the ITS and ISTS 3.9.7 is renumbered as ITS 3.9.6.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 14, Rev. 0, Page 137 of 187

Attachment 1, Volume 14, Rev. 0, Page 138 of 187 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 14, Rev. 0, Page 138 of 187

, Volume 14, Rev. 0, Page 139 of 187 , Volume 14, Rev. 0, Page 139 of 187

, Volume 14, Rev. 0, Page 140 of 187 , Volume 14, Rev. 0, Page 140 of 187

, Volume 14, Rev. 0, Page 141 of 187 , Volume 14, Rev. 0, Page 141 of 187

Attachment 1, Volume 14, Rev. 0, Page 142 of 187 JUSTIFICATION FOR DEVIATIONS ITS 3.9.6 BASES, REFUELING CAVITY WATER LEVEL

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

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

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

4. Typographical/grammatical error corrected.

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

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 14, Rev. 0, Page 142 of 187

Attachment 1, Volume 14, Rev. 0, Page 143 of 187 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 14, Rev. 0, Page 143 of 187

Attachment 1, Volume 14, Rev. 0, Page 144 of 187 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.9.6, REFUELING CAVITY WATER LEVEL There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 14, Rev. 0, Page 144 of 187

Attachment 1, Volume 14, Rev. 0, Page 145 of 187 ATTACHMENT 7 Relocated/Deleted Current Technical Specifications (CTS)

Attachment 1, Volume 14, Rev. 0, Page 145 of 187

, Volume 14, Rev. 0, Page 146 of 187 CTS 3/4.9.3, Decay Time , Volume 14, Rev. 0, Page 146 of 187

, Volume 14, Rev. 0, Page 147 of 187 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 14, Rev. 0, Page 147 of 187

, Volume 14, Rev. 0, Page 148 of 187 CTS 3/4.9.3 LA.1 Page 1 of 2 , Volume 14, Rev. 0, Page 148 of 187

, Volume 14, Rev. 0, Page 149 of 187 CTS 3/4.9.3 LA.1 Page 2 of 2 , Volume 14, Rev. 0, Page 149 of 187

Attachment 1, Volume 14, Rev. 0, Page 150 of 187 DISCUSSION OF CHANGES CTS 3/4.9.3, DECAY TIME ADMINISTRATIVE CHANGES None MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Category 6 - Relocation of LCO or SR to the TRM) CTS LCO 3.9.3 requires the reactor to be subcritical for a required period of time (100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months from September 15 through June 15 and 148 hours0.00171 days 0.0411 hours 2.44709e-4 weeks 5.6314e-5 months from June 16 through September 14) prior to movement of irradiated fuel in the reactor pressure vessel. ITS 3.9 does not include the requirements for decay time. This changes the CTS by moving the explicit decay time 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 LCO 3.9.3 to ensure that sufficient time has elapsed to allow the radioactive decay of the short-lived fission products in the irradiated fuel consistent with the assumptions used in the fuel handling accident analysis. Additionally, two time limits are currently provided to account for decay heat load capacity of the spent fuel storage pool. Although CTS LCO 3.9.3 satisfies Criterion 2 of the Technical Specifications Selection Criteria in 10 CFR 50.36 (c)(2)(ii) (for the radioactive decay assumptions in the fuel handling accident), the requirements for decay time following subcriticality will always be met for a refueling outage because of the operations required prior to moving irradiated fuel in the reactor vessel (e.g., containment entry, removal of vessel head, removal of vessel internals, etc.). 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 a requirement is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES None CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 14, Rev. 0, Page 150 of 187

Attachment 1, Volume 14, Rev. 0, Page 151 of 187 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 14, Rev. 0, Page 151 of 187

Attachment 1, Volume 14, Rev. 0, Page 152 of 187 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS CTS 3/4.9.3, DECAY TIME There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 14, Rev. 0, Page 152 of 187

, Volume 14, Rev. 0, Page 153 of 187 CTS 3/4.9.5, Communications , Volume 14, Rev. 0, Page 153 of 187

, Volume 14, Rev. 0, Page 154 of 187 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 14, Rev. 0, Page 154 of 187

, Volume 14, Rev. 0, Page 155 of 187 CTS 3/4.9.5 R.1 Page 1 of 2 , Volume 14, Rev. 0, Page 155 of 187

, Volume 14, Rev. 0, Page 156 of 187 CTS 3/4.9.5 R.1 Page 2 of 2 , Volume 14, Rev. 0, Page 156 of 187

Attachment 1, Volume 14, Rev. 0, Page 157 of 187 DISCUSSION OF CHANGES CTS 3/4.9.5, COMMUNICATIONS ADMINISTRATIVE CHANGES None MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS R.1 CTS 3.9.5 states that direct communications shall be maintained between the control room and personnel at the refueling station during CORE ALTERATIONS. This ensures that refueling station personnel can be promptly informed of significant changes in the facility status or core reactivity conditions during CORE ALTERATIONS. The prompt notification of the control room of a fuel handling accident is not an assumption in the fuel handling accident analysis.

While notification is necessary to ensure that the control room is isolated to meet the control room operator dose limits in General Design Criteria 19, the fuel handling accident analysis does not take credit for direct communications between the refueling station and the control room (30 minutes is assumed before control room operator actions are taken). This LCO does not meet the criteria for retention in the ITS; therefore, it will be retained in the Technical Requirements Manual (TRM).

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

1. Communications are not installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary. The Communications Specification does not satisfy criterion 1.

2. Communications are not a process variable, design feature, or operating restriction that is an initial condition of a DBA or Transient Analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. The Communications Specification does not satisfy criterion 2.

3. Communications are part of the primary success path and are assumed in the mitigation of a DBA which assumes the failure of a fission product barrier. However, communications are not a structure, system or component. The Communications Specification does not satisfy criterion 3.

4. Communications are not a structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety. As discussed in Section 4.0, (Appendix A, page A-67) and Table 1 of WCAP-11618, communications was found to be a non-significant risk contributor to core damage frequency and offsite releases. I&M has reviewed this evaluation, CNP Units 1 and 2 Page 1 of 2 Attachment 1, Volume 14, Rev. 0, Page 157 of 187

Attachment 1, Volume 14, Rev. 0, Page 158 of 187 DISCUSSION OF CHANGES CTS 3/4.9.5, COMMUNICATIONS considers it applicable to CNP Units 1 and 2, and concurs with this assessment. The Communications Specification does not meet criterion 4.

Since the 10 CFR 50.36(c)(2)(ii) criteria have not been met, the communications LCO and associated Surveillances may be relocated out of the Technical Specifications. The communications specification will be relocated to the TRM.

Changes to the TRM will be controlled by the provisions of 10 CFR 50.59. This change is designated as a relocation because the LCO did not meet the criteria in 10 CFR 50.36(c)(2)(ii) and has been relocated to the TRM.

REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES None CNP Units 1 and 2 Page 2 of 2 Attachment 1, Volume 14, Rev. 0, Page 158 of 187

Attachment 1, Volume 14, Rev. 0, Page 159 of 187 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 14, Rev. 0, Page 159 of 187

Attachment 1, Volume 14, Rev. 0, Page 160 of 187 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS CTS 3/4.9.5, COMMUNICATIONS There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 14, Rev. 0, Page 160 of 187

, Volume 14, Rev. 0, Page 161 of 187 CTS 3/4.9.13, Spent Fuel Cask Movement , Volume 14, Rev. 0, Page 161 of 187

, Volume 14, Rev. 0, Page 162 of 187 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 14, Rev. 0, Page 162 of 187

, Volume 14, Rev. 0, Page 163 of 187 CTS 3/4.9.13 LA.1 Page 1 of 2 , Volume 14, Rev. 0, Page 163 of 187

, Volume 14, Rev. 0, Page 164 of 187 CTS 3/4.9.13 LA.1 Page 2 of 2 , Volume 14, Rev. 0, Page 164 of 187

Attachment 1, Volume 14, Rev. 0, Page 165 of 187 DISCUSSION OF CHANGES CTS 3/4.9.13, SPENT FUEL CASK MOVEMENT 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, QAPP, or IIP) CTS LCO 3.9.13 requires the movement of the spent fuel cask above elevation 620 feet to be done with the spent fuel cask handling crane operating in the Controlled Path Mode of operation. The ITS does not include the requirements for the movement of the spent fuel cask above elevation 620 feet. This changes the CTS by moving the explicit requirements for movement of the spent fuel cask above elevation 620 feet, 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 3.9.13 to ensure that, during insertion or removal of spent fuel casks from the spent fuel pool; fuel cask movement will be constrained to the path and lift height assumed in the Cask Drop Protection System safety analysis. Restricting the spent fuel cask movement within these requirements provides protection for the spent fuel pool and stored fuel from the effects of a fuel cask drop accident. These requirements are proposed to be relocated to the TRM since the movement of loads other than fuel assemblies is controlled based on the heavy loads analysis. The bounding design basis fuel handling accident in the auxiliary building assumes a single irradiated fuel assembly is damaged. In addition, as stated in the NRC Safety Evaluation for License Amendments 197 (Unit 1) and 182 (Unit 2), dated July 12, 1995, the controls in place ensure that the potential for other, more severe events that could occur, such as a heavy load drop on irradiated fuel, need not be postulated and analyzed. 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 a requirement is being removed from the Technical Specifications.

CNP Units 1 and 2 Page 1 of 2 Attachment 1, Volume 14, Rev. 0, Page 165 of 187

Attachment 1, Volume 14, Rev. 0, Page 166 of 187 DISCUSSION OF CHANGES CTS 3/4.9.13, SPENT FUEL CASK MOVEMENT LESS RESTRICTIVE CHANGES None CNP Units 1 and 2 Page 2 of 2 Attachment 1, Volume 14, Rev. 0, Page 166 of 187

Attachment 1, Volume 14, Rev. 0, Page 167 of 187 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 14, Rev. 0, Page 167 of 187

Attachment 1, Volume 14, Rev. 0, Page 168 of 187 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS CTS 3/4.9.13, SPENT FUEL CASK MOVEMENT There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 14, Rev. 0, Page 168 of 187

Attachment 1, Volume 14, Rev. 0, Page 169 of 187 CTS 3/4.9.14, Spent Fuel Cask Drop Protection System Attachment 1, Volume 14, Rev. 0, Page 169 of 187

, Volume 14, Rev. 0, Page 170 of 187 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 14, Rev. 0, Page 170 of 187

, Volume 14, Rev. 0, Page 171 of 187 CTS 3/4.9.14 LA.1 Page 1 of 2 , Volume 14, Rev. 0, Page 171 of 187

, Volume 14, Rev. 0, Page 172 of 187 CTS 3/4.9.14 LA.1 Page 2 of 2 , Volume 14, Rev. 0, Page 172 of 187

Attachment 1, Volume 14, Rev. 0, Page 173 of 187 DISCUSSION OF CHANGES CTS 3/4.9.14, SPENT FUEL CASK DROP PROTECTION SYSTEM 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, QAPP, or IIP) CTS LCO 3.9.14 specifies that the maximum weight of a spent fuel cask used with the Cask Drop Protection System be limited to 110 tons (nominal). The ITS does not include this spent fuel cask weight limitation associated with the Cask Drop Protection System. This changes the CTS by moving the explicit spent fuel cask weight limitation associated with the Cask Drop Protection System, 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 3.9.14 is to ensure that limitations on the use of spent fuel casks weighing in excess of 110 tons (nominal) are in effect to provide assurance that the spent fuel pool would not be damaged by a dropped fuel cask since this weight is consistent with the assumptions used in the safety analyses for the performance of the Cask Drop Protections System. These requirements are proposed to be relocated to the TRM since the movement of loads other than fuel assemblies is controlled based on the heavy loads analysis. The bounding design basis fuel handling accident in the auxiliary building assumes a single irradiated fuel assembly is damaged.

In addition, as stated in the NRC Safety Evaluation for License Amendments 197 (Unit 1) and 182 (Unit 2), dated July 12, 1995, the controls in place ensure that the potential for other, more severe events that could occur, such as a heavy load drop on irradiated fuel, need not be postulated and analyzed. 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 a requirement is being removed from the Technical Specifications.

CNP Units 1 and 2 Page 1 of 2 Attachment 1, Volume 14, Rev. 0, Page 173 of 187

Attachment 1, Volume 14, Rev. 0, Page 174 of 187 DISCUSSION OF CHANGES CTS 3/4.9.14, SPENT FUEL CASK DROP PROTECTION SYSTEM LESS RESTRICTIVE CHANGES None CNP Units 1 and 2 Page 2 of 2 Attachment 1, Volume 14, Rev. 0, Page 174 of 187

Attachment 1, Volume 14, Rev. 0, Page 175 of 187 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 14, Rev. 0, Page 175 of 187

Attachment 1, Volume 14, Rev. 0, Page 176 of 187 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS CTS 3/4.9.14, SPENT FUEL CASK DROP PROTECTION SYSTEM There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 14, Rev. 0, Page 176 of 187

Attachment 1, Volume 14, Rev. 0, Page 177 of 187 ATTACHMENT 8 Improved Standard Technical Specifications (ISTS) not adopted in the CNP ITS Attachment 1, Volume 14, Rev. 0, Page 177 of 187

Attachment 1, Volume 14, Rev. 0, Page 178 of 187 ISTS 3.9.2, Unborated Water Source Isolation Valves Attachment 1, Volume 14, Rev. 0, Page 178 of 187

Attachment 1, Volume 14, Rev. 0, Page 179 of 187 ISTS 3.9.2 Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 14, Rev. 0, Page 179 of 187

, Volume 14, Rev. 0, Page 180 of 187 , Volume 14, Rev. 0, Page 180 of 187

, Volume 14, Rev. 0, Page 181 of 187 , Volume 14, Rev. 0, Page 181 of 187

Attachment 1, Volume 14, Rev. 0, Page 182 of 187 JUSTIFICATION FOR DEVIATIONS ISTS 3.9.2, UNBORATED WATER SOURCE ISOLATION VALVES

1. CNP has analyzed a boron dilution event in MODE 6. Isolation of all unborated water sources in MODE 6 is not required. Therefore, ISTS 3.9.2 is not included in the ITS.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 14, Rev. 0, Page 182 of 187

Attachment 1, Volume 14, Rev. 0, Page 183 of 187 ISTS 3.9.2 Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 14, Rev. 0, Page 183 of 187

, Volume 14, Rev. 0, Page 184 of 187 , Volume 14, Rev. 0, Page 184 of 187

, Volume 14, Rev. 0, Page 185 of 187 , Volume 14, Rev. 0, Page 185 of 187

, Volume 14, Rev. 0, Page 186 of 187 , Volume 14, Rev. 0, Page 186 of 187

Attachment 1, Volume 14, Rev. 0, Page 187 of 187 JUSTIFICATION FOR DEVIATIONS ISTS 3.9.2 BASES, UNBORATED WATER SOURCE ISOLATION VALVES

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

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 14, Rev. 0, Page 187 of 187

v t e Letter Sequence Request
TAC:MC2474, Missed Surveillance Requirements, Revise Containment Requirements During Handling Irradiated Fuel and Core Alterations (Open)
Initiation Request, Request, Request Acceptance... Administration Questions 20 May 2004 Answers Results Approval... Other: ML042300612, ML042720297
MONTHYEAR2004-05-20 [Table View]

ML041200392

Text

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