ML041200407

CNP Units 1 and 2 Improved Technical Specifications Conversion, Volume 16, Rev 0, ITS Chapter 5.0 Administrative Controls.

ML041200407
Person / Time
Site:	Cook
Issue date:	04/06/2004
From:	Indiana Michigan Power Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
AEP:NRC:4901
Download: ML041200407 (256)

Text

Attachment 1, Volume 16, Rev. 0, Page 1 of 256 VOLUME 16 CNP UNITS 1 AND 2 IMPROVED TECHNICAL SPECIFICATIONS CONVERSION ITS CHAPTER 5.0 ADMINISTRATIVE CONTROLS Revision 0 Attachment 1, Volume 16, Rev. 0, Page 1 of 256

Attachment 1, Volume 16, Rev. 0, Page 2 of 256 LIST OF ATTACHMENTS

1. ITS 5.1

2. ITS 5.2

3. ITS 5.3

4. ITS 5.4

5. ITS 5.5

6. ITS 5.6

7. ITS 5.7

8. Relocated/Deleted Current Technical Specifications (CTS)

Attachment 1, Volume 16, Rev. 0, Page 2 of 256

, Volume 16, Rev. 0, Page 3 of 256 ATTACHMENT 1 ITS 5.1, Responsibility , Volume 16, Rev. 0, Page 3 of 256

, Volume 16, Rev. 0, Page 4 of 256 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 16, Rev. 0, Page 4 of 256

Attachment 1, Volume 16, Rev. 0, Page 5 of 256 ITS 5.1 A.1 ITS 5.1 5.1.1 LA.1 INSERT 1 M.1 5.1.2 M.2 A.2 See ITS 5.2 Page 1 of 4 Attachment 1, Volume 16, Rev. 0, Page 5 of 256

Attachment 1, Volume 16, Rev. 0, Page 6 of 256 ITS 5.1 M.1 ITS INSERT 1 5.1.1 The plant manager or his designee shall approve, prior to implementation, each proposed test, experiment, or modification to systems or equipment that affects nuclear safety.

Insert Page 6-1 Page 2 of 4 Attachment 1, Volume 16, Rev. 0, Page 6 of 256

Attachment 1, Volume 16, Rev. 0, Page 7 of 256 A.1 ITS 5.1 ITS 5.1 5.1.1 LA.1 INSERT 1 M.1 5.1.2 M.2 A.2 See ITS 5.2 Page 3 of 4 Attachment 1, Volume 16, Rev. 0, Page 7 of 256

Attachment 1, Volume 16, Rev. 0, Page 8 of 256 ITS 5.1 M.1 ITS INSERT 1 5.1.1 The plant manager or his designee shall approve, prior to implementation, each proposed test, experiment, or modification to systems or equipment that affects nuclear safety.

Insert Page 6-1 Page 4 of 4 Attachment 1, Volume 16, Rev. 0, Page 8 of 256

Attachment 1, Volume 16, Rev. 0, Page 9 of 256 DISCUSSION OF CHANGES ITS 5.1, RESPONSIBILITY 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 6.1.2 requires a management directive regarding delegation of the control room command function to be signed by the Site Vice President and issued to all station personnel on an annual basis. ITS 5.1.2 does not include this requirement. This changes the CTS by deleting the requirement to issue this management directive annually.

The purpose of CTS 6.1.2 is to specify the plant specific means of implementing the requirement to notify employees of the responsibilities of the Shift Manager.

This change is acceptable because CTS 6.1.2 and ITS 5.1.2 state who is responsible for the control room command function. This requirement appears to serve only as a reminder to personnel as to who is in charge. No where else in the CTS or the ITS is a management directive required to remind personnel of a Technical Specification requirement. In addition, this requirement is not considered to be one of the more important requirements since it does not directly impact safety. The Technical Specification control room command function requirement is not being changed. This change is designated as administrative because it does not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES M.1 ITS 5.1.1 requires that the plant manager or his designee approve, prior to implementation, each proposed test, experiment, or modification to systems or equipment that affects nuclear safety. The CTS does not include this requirement. This changes the CTS by adding an approved requirement for the plant manager or his designee.

The purpose of the ITS 5.1.1 requirement is to provide additional assurance that the plant manager has direct responsibility for overall unit operation. This change is acceptable because having the plant manager or his designee approve actions affecting nuclear safety is consistent with the CTS 6.2.1.b (ITS 5.2.1.b) requirement that the plant manager shall be responsible for overall unit safe operation and shall have control over those onsite activities necessary for safe operation and maintenance of the plant. This change is designated more restrictive because it adds a requirement for the plant manager or his designee to the CTS.

M.2 CTS 6.1.2 allows a designated individual to assume the responsibility for the control room command function when the Shift Manager is absent from the control room complex. ITS 5.1.2 provides the allowance for the designated CNP Units 1 and 2 Page 1 of 2 Attachment 1, Volume 16, Rev. 0, Page 9 of 256

Attachment 1, Volume 16, Rev. 0, Page 10 of 256 DISCUSSION OF CHANGES ITS 5.1, RESPONSIBILITY individual to assume the responsibility for the control room command function, but provides additional requirements for the designated individual. In MODE 1, 2, 3, or 4, ITS 5.1.2 requires the designated individual hold an active Senior Operator license. In MODE 5 or 6, ITS 5.1.2 requires the designated individual hold an active Senior Operator license or Operator license. This changes the CTS by adding qualification requirements for the designated individual that assumes the control room command function.

The purpose of the ITS 5.1.2 requirement is to ensure that the control room command function is maintained. This change is acceptable because the additional requirements ensure that the designated individual assuming the control room command functions meets the appropriate qualification requirements. This change is designated as more restrictive because it adds qualification requirements for the designated individual that assumes the control room command function to the CTS.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 6.1.1 uses the title "Plant Manager" and CTS 6.1.2 uses the title "Shift Manager." ITS 5.1.1 uses the generic title "plant manager" and ITS 5.1.2 uses the generic title "shift manager." This changes the CTS by moving the specific CNP organizational titles to the UFSAR and replacing them with generic titles.

The removal of these details, which are related to meeting Technical Specification requirements, from the Technical Specifications is acceptable because this type of information is not necessary to be included in Technical Specifications to provide adequate protection of public health and safety. The allowance to relocate the specific CNP organizational titles is out of the Technical Specifications is consistent with the NRC letter from C. Grimes to the Owners Groups Technical Specification Committee Chairmen, dated November 10, 1994.

The various requirements of the plant manager and shift manager are still retained in the ITS. Also, this change is acceptable because the removed information will be adequately controlled in the UFSAR. Any changes to the UFSAR are made under 10 CFR 50.59 or 10 CFR 50.71(e), which ensures changes are properly evaluated. This change is designated as a less restrictive removal of detail change because information related to meeting Technical Specification requirements are being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES None CNP Units 1 and 2 Page 2 of 2 Attachment 1, Volume 16, Rev. 0, Page 10 of 256

Attachment 1, Volume 16, Rev. 0, Page 11 of 256 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 16, Rev. 0, Page 11 of 256

, Volume 16, Rev. 0, Page 12 of 256 , Volume 16, Rev. 0, Page 12 of 256

Attachment 1, Volume 16, Rev. 0, Page 13 of 256 JUSTIFICATION FOR DEVIATIONS ITS 5.1, RESPONSIBILITY

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

2. Grammatical error corrected.

3. Typographical error corrected. The terms in 10 CFR 55.4 and 10 CFR 50.54(m) are "Senior Operator" and "Operator."

4. The term "control room" in ISTS 5.1.2 has been changed to "control room complex" to be consistent with the current licensing basis.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 16, Rev. 0, Page 13 of 256

Attachment 1, Volume 16, Rev. 0, Page 14 of 256 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 16, Rev. 0, Page 14 of 256

Attachment 1, Volume 16, Rev. 0, Page 15 of 256 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 5.1, RESPONSIBILITY There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 16, Rev. 0, Page 15 of 256

, Volume 16, Rev. 0, Page 16 of 256 ATTACHMENT 2 ITS 5.2, Organization , Volume 16, Rev. 0, Page 16 of 256

, Volume 16, Rev. 0, Page 17 of 256 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 16, Rev. 0, Page 17 of 256

Attachment 1, Volume 16, Rev. 0, Page 18 of 256 ITS 5.2 A.1 ITS See ITS 5.1 5.2 5.2.1 M.1 5.2.1.a INSERT 1 A.2 5.2.1.b LA.1 A specified corporate officer 5.2.1.c LA.1 5.2.1.d Page 1 of 12 Attachment 1, Volume 16, Rev. 0, Page 18 of 256

Attachment 1, Volume 16, Rev. 0, Page 19 of 256 ITS 5.2 ITS M.1 INSERT 1 5.2.1.a requirements including the plant-specific titles of those personnel fulfilling the responsibilities of the positions delineated in these Technical Specifications Insert Page 6-1 Page 2 of 12 Attachment 1, Volume 16, Rev. 0, Page 19 of 256

Attachment 1, Volume 16, Rev. 0, Page 20 of 256 ITS 5.2 A.1 ITS 5.2.2 LA.2 A.3 5.2.2.c A.3 5.2.2.d LA.3 operations manager LA.1 5.2.2.e A.1 operations manager LA.1 5.2.2.c Page 3 of 12 Attachment 1, Volume 16, Rev. 0, Page 20 of 256

Attachment 1, Volume 16, Rev. 0, Page 21 of 256 ITS 5.2 A.1 ITS LA.2 5.2.2.a 5.2.2.f INSERT 2 M.2 LA.2 5.2.2.b 5.2.2.f Page 4 of 12 Attachment 1, Volume 16, Rev. 0, Page 21 of 256

Attachment 1, Volume 16, Rev. 0, Page 22 of 256 ITS 5.2 ITS M.2 INSERT 2 5.2.2.f An individual shall provide advisory technical support to unit operations shift crew in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to safe operation of the unit.

Insert Page 6-3 Page 5 of 12 Attachment 1, Volume 16, Rev. 0, Page 22 of 256

Attachment 1, Volume 16, Rev. 0, Page 23 of 256 ITS 5.2 A.1 ITS See ITS 5.3 A.4 5.2.2.f See ITS 5.3 See CTS 6.0 Page 6 of 12 Attachment 1, Volume 16, Rev. 0, Page 23 of 256

Attachment 1, Volume 16, Rev. 0, Page 24 of 256 ITS 5.2 A.1 ITS See ITS 5.1 5.2 5.2.1 M.1 5.2.1.a INSERT 1 A.2 5.2.1.b LA.1 A specified corporate officer 5.2.1.c LA.1 5.2.1.d Page 7 of 12 Attachment 1, Volume 16, Rev. 0, Page 24 of 256

Attachment 1, Volume 16, Rev. 0, Page 25 of 256 ITS 5.2 ITS M.1 INSERT 1 5.2.1.a requirements including the plant-specific titles of those personnel fulfilling the responsibilities of the positions delineated in these Technical Specifications Insert Page 6-1 Page 8 of 12 Attachment 1, Volume 16, Rev. 0, Page 25 of 256

Attachment 1, Volume 16, Rev. 0, Page 26 of 256 ITS 5.2 A.1 ITS 5.2.2 LA.2 A.3 5.2.2.c A.3 5.2.2.d LA.3 operations manager LA.1 5.2.2.e A.1 operations manager LA.1 5.2.2.c Page 9 of 12 Attachment 1, Volume 16, Rev. 0, Page 26 of 256

Attachment 1, Volume 16, Rev. 0, Page 27 of 256 ITS 5.2 A.1 ITS LA.2 5.2.2.a 5.2.2.f INSERT 2 M.2 LA.2 5.2.2.b 5.2.2.f Page 10 of 12 Attachment 1, Volume 16, Rev. 0, Page 27 of 256

Attachment 1, Volume 16, Rev. 0, Page 28 of 256 ITS 5.2 ITS M.2 INSERT 2 5.2.2.f An individual shall provide advisory technical support to unit operations shift crew in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to safe operation of the unit.

Insert Page 6-3 Page 11 of 12 Attachment 1, Volume 16, Rev. 0, Page 28 of 256

Attachment 1, Volume 16, Rev. 0, Page 29 of 256 ITS 5.2 A.1 ITS See ITS 5.3 A.4 5.2.2.f See ITS 5.3 See CTS 6.0 Page 12 of 12 Attachment 1, Volume 16, Rev. 0, Page 29 of 256

Attachment 1, Volume 16, Rev. 0, Page 30 of 256 DISCUSSION OF CHANGES ITS 5.2, ORGANIZATION 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 6.2.1.a states, in part, "These organizational charts will be documented in the UFSAR and updated in accordance with 10 CFR 50.71(e)." The ITS does not include the requirement associated with updating the UFSAR in accordance with 10 CFR 50.71(e). This changes the CTS by deleting these requirements for updating the UFSAR.

10 CFR 50.71(e) provides requirements for periodically updating the UFSAR.

This change is acceptable because the requirements deleted from the Technical Specifications are already required by 10 CFR 50.71(e). This change is designated as administrative because it does not result in technical changes to the CTS.

A.3 CTS 6.2.2.b states "At least one licensed Operator shall be in the control room when fuel is in the reactor. In addition, while the unit is in Mode 1, 2, 3, or 4, at least one licensed Senior Operator shall be in the control room." CTS 6.2.2.d requires all CORE ALTERATIONS to be directly supervised by a licensed Senior Operator trained or qualified in refueling and CORE ALTERATIONS who has no other concurrent responsibilities during this operation. The ITS does not include these requirements. This changes the CTS by deleting these requirements.

10 CFR 50.54(m)(2)(iii) states "When a nuclear power unit is in an operational mode other than cold shutdown or refueling, as defined by a units technical specifications, each licensee shall have a person holding a senior operator license for the nuclear power unit in the control room at all times. In addition to this senior operator, for each fueled nuclear power unit, a licensed operator or senior operator shall be at the controls at all times." 10 CFR 50.54(m)(2)(iv) states "Each licensee shall have present, during alteration of the core of a nuclear power unit (including fuel loading or transfer), a person holding a senior operator license or a senior operator license limited to fuel handling to directly supervise the activity and, during this time, the licensee shall not assign other duties to this person." This change is acceptable because the requirements deleted from the Technical Specifications are already required by 10 CFR 50.54(m)(2)(iii) and 10 CFR 50.54(m)(2)(iv). This change is designated as administrative because it does not result in technical changes to the CTS.

A.4 CTS 6.3.1 provides, in part, qualification requirements for the Shift Technical Advisor (STA), and requires the STA to have a bachelors degree or equivalent in a scientific or engineering discipline with specific training in plant design, and response and analysis of the plant for transients and accidents. ITS 5.2.2.f requires this individual to meet the qualification requirements of the Commission CNP Units 1 and 2 Page 1 of 4 Attachment 1, Volume 16, Rev. 0, Page 30 of 256

Attachment 1, Volume 16, Rev. 0, Page 31 of 256 DISCUSSION OF CHANGES ITS 5.2, ORGANIZATION Policy Statement on Engineering Expertise on Shift. This changes the CTS by referencing the Commission Policy Statement on Engineering Expertise on Shift for qualification requirements instead of listing the specific qualification requirements.

The purpose of the CTS 6.3.1 STA requirements is to specify the minimum qualification requirements for the STA. This change is acceptable because the qualification requirements included in the Commission Policy Statement on Engineering Expertise on Shift encompass the current STA qualification requirements. This change is designated as administrative because it does not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES M.1 CTS 6.2.1.a, regarding documentation and updating of the relationships between operating organization positions, requires the organizational charts to be documented in the UFSAR. ITS 5.2.1.a states "These requirements, including the plant-specific titles of those personnel fulfilling the responsibilities of the positions delineated in these Technical Specifications, shall be documented in the UFSAR." This changes the CTS by requiring that the specific CNP organizational titles be specified in the UFSAR.

This change is acceptable because specifying the relationship of the specific CNP organizational titles to the generic titles used in the Technical Specifications and industry standards in the UFSAR continues to ensure that organizational positions and associated responsibilities will be maintained. This change adds this requirement to the Technical Specifications. This change is designated as more restrictive because it requires additional information be maintained in the UFSAR.

M.2 CTS Table 6.2-1 requires the minimum shift crew to include one STA (shared between Units 1 and 2) when the unit is in MODE 1, 2, 3, or 4. ITS 5.2.2.f requires, in part, that an individual (shared between Units 1 and 2) provide advisory technical support to the unit operations shift crew in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit, when the unit is in MODE 1, 2, 3, or 4. This changes the CTS by detailing the specific responsibilities of the STA.

The purpose of the CTS Table 6.2-1 STA requirements is to ensure that appropriate engineering expertise is available on shift. This change is acceptable because it clarifies STA requirements consistent with Commission Policy Statement on Engineering Expertise on Shift. This change is designated as more restrictive because it provides specific details of the responsibilities of the STA.

RELOCATED SPECIFICATIONS None CNP Units 1 and 2 Page 2 of 4 Attachment 1, Volume 16, Rev. 0, Page 31 of 256

Attachment 1, Volume 16, Rev. 0, Page 32 of 256 DISCUSSION OF CHANGES ITS 5.2, ORGANIZATION REMOVED DETAIL CHANGES LA.1 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 6.2.1.b uses the title "Plant Manager," CTS 6.2.1.c uses the title "Senior Vice President - Nuclear Operations," and CTS 6.2.2.g uses the title "Operations Director." ITS 5.2.1.b uses the generic title "plant manager," ITS 5.2.1.c uses the generic title "A specified corporate officer,"

and ITS 5.2.2.e uses the generic title "operations manager." This changes the CTS by moving the specific CNP organizational titles to the UFSAR and replacing them with generic titles.

The removal of these details, which are related to meeting Technical Specification requirements, from the Technical Specifications is acceptable because this type of information is not necessary to be included in Technical Specifications to provide adequate protection of public health and safety. The allowance to relocate the specific CNP organizational titles out of the Technical Specifications is consistent with the NRC letter from C. Grimes to the Owners Groups Technical Specification Committee Chairmen, dated November 10, 1994.

The various requirements of the plant manager, the specified corporate officer, and the operations manager are still retained in the ITS. Also, this change is acceptable because the removed information will be adequately controlled in the UFSAR. Any changes to the UFSAR are made under 10 CFR 50.59 or 10 CFR 50.71(e), which ensures changes are properly evaluated. This change is designated as a less restrictive removal of detail change because information related to meeting Technical Specification requirements are being removed from the Technical Specifications.

LA.2 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 6.2.2 and Table 6.2-1, including footnote #,

provide minimum shift crew composition requirements. ITS 5.2.2 only includes the minimum shift crew composition requirements that are not already included in 10 CFR 50.54. This changes the CTS by moving the minimum shift crew composition requirements addressed by 10 CFR 50.54 to the Technical Requirements Manual (TRM).

The removal of these details, which are related to meeting Technical Specification requirements, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The minimum shift crew composition requirements for licensed operators and senior operators are also contained in 10 CFR 50.54(k), (l), and (m) and do not need to be repeated in the Technical Specifications. The minimum shift crew composition requirements for non-licensed operators are transferred from CTS Table 6.2-1 to ITS 5.2.2.a and the minimum shift crew composition requirements for the STA are transferred from CTS Table 6.2-1 to ITS 5.2.2.f. The relocation of the details of the minimum shift crew composition requirements to the TRM is acceptable considering the controls provided by regulations and the remaining requirements in the Technical Specifications. Also, this change is acceptable because these details will be adequately controlled in the TRM. 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 CNP Units 1 and 2 Page 3 of 4 Attachment 1, Volume 16, Rev. 0, Page 32 of 256

Attachment 1, Volume 16, Rev. 0, Page 33 of 256 DISCUSSION OF CHANGES ITS 5.2, ORGANIZATION change because details for meeting Technical Specification and regulatory requirements are being removed from the Technical Specifications.

LA.3 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 6.2.2.f requires the Shift Manager and Unit Supervisor to hold a Senior Operator license. ITS 5.2.2 does not contain this requirement. This changes the CTS by moving the requirement for the Shift Manager and Unit Supervisor to hold a Senior Operator license to the TRM.

The removal of these details, which are related to meeting Technical Specification requirements, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The requirement for shift supervision to hold Senior Operator licenses is contained in 10 CFR 50.54(m), and does not need to be repeated in the Technical Specifications. The relocation of the details of the shift supervision personnel that are required to hold Senior Operator licenses to the TRM is acceptable considering the controls provided by regulations. Also, this change is acceptable because these details will be adequately controlled in the TRM. 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 details for meeting Technical Specification and regulatory requirements are being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES None CNP Units 1 and 2 Page 4 of 4 Attachment 1, Volume 16, Rev. 0, Page 33 of 256

Attachment 1, Volume 16, Rev. 0, Page 34 of 256 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 16, Rev. 0, Page 34 of 256

, Volume 16, Rev. 0, Page 35 of 256 , Volume 16, Rev. 0, Page 35 of 256

, Volume 16, Rev. 0, Page 36 of 256 , Volume 16, Rev. 0, Page 36 of 256

, Volume 16, Rev. 0, Page 37 of 256 , Volume 16, Rev. 0, Page 37 of 256

Attachment 1, Volume 16, Rev. 0, Page 38 of 256 JUSTIFICATION FOR DEVIATIONS ITS 5.2, ORGANIZATION

1. ISTS 5.2.1.a is revised to reflect the CNP CTS with respect to documentation and updating of the relationships between operating organization positions. Specifically, the ISTS 5.2.1.a requirement for including these relationships in functional descriptions of departmental responsibilities and relationships, and job descriptions of key personnel positions, or in equivalent forms of documentation is not included in ITS 5.2.1.a. This change is made to achieve consistency with CTS 6.2.1.a, which was approved by the NRC in License Amendments 132 (Unit 1) and 117 (Unit 2),

dated March 9, 1990.

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

3. Grammatical/typographical error corrected.

4. The ISTS Reviewers Note has been deleted since it is not intended to be included in the ITS. The requirements for non-licensed operators for two unit sites addressed in the ISTS Reviewers Note are not adopted. This change is consistent with the CNP CTS.

5. ISTS 5.2.2.d provides requirements for working hour limitations. These requirements are revised in ITS 5.2.2.d to reflect the CNP CTS 6.2.2.e requirements, which were approved by the NRC in License Amendments 77 (Unit 1) and 58 (Unit 2), dated November 23, 1983.

6. ISTS 5.2.2.e provides a requirement for the operations manager or the assistant operations manager to hold a Senior Operator license. This requirement is revised in ITS 5.2.2.e to reflect the CNP CTS 6.2.2.g requirements. The CTS 6.2.2.g requirements were approved by the NRC in License Amendments 212 (Unit 1) and 197 (Unit 2), dated November 13, 1996.

7. ISTS 5.2.2.f provides requirements for the Shift Technical Advisor (STA). These requirements are revised in ITS 5.2.2.f to reflect the CNP CTS Table 6.2-1 requirements for the STA. The CTS Table 6.2-1 STA requirements were approved by the NRC in License Amendments 49 (Unit 1) and 34 (Unit 2), dated August 25, 1981.

8. The referenced requirements are Specifications, not Code of Federal Regulations (CFR) requirements. Therefore, the word "Specifications" has been added to clearly state that 5.5.2.a and 5.5.2.f are Specifications.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 16, Rev. 0, Page 38 of 256

Attachment 1, Volume 16, Rev. 0, Page 39 of 256 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 16, Rev. 0, Page 39 of 256

Attachment 1, Volume 16, Rev. 0, Page 40 of 256 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 5.2, ORGANIZATION There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 16, Rev. 0, Page 40 of 256

, Volume 16, Rev. 0, Page 41 of 256 ATTACHMENT 3 ITS 5.3, Unit Staff Qualifications , Volume 16, Rev. 0, Page 41 of 256

, Volume 16, Rev. 0, Page 42 of 256 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 16, Rev. 0, Page 42 of 256

Attachment 1, Volume 16, Rev. 0, Page 43 of 256 ITS 5.3 A.1 ITS 5.3 LA.1 5.3.1 See ITS 5.2 LA.1 manager Add proposed Specification 5.3.2 A.2 See CTS 6.0 Page 1 of 2 Attachment 1, Volume 16, Rev. 0, Page 43 of 256

Attachment 1, Volume 16, Rev. 0, Page 44 of 256 ITS 5.3 A.1 ITS 5.3 LA.1 5.3.1 See ITS 5.2 LA.1 manager Add proposed Specification 5.3.2 A.2 See CTS 6.0 Page 2 of 2 Attachment 1, Volume 16, Rev. 0, Page 44 of 256

Attachment 1, Volume 16, Rev. 0, Page 45 of 256 DISCUSSION OF CHANGES ITS 5.3, UNIT STAFF QUALIFICATIONS 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 ITS 5.3.2 states "For the purpose of 10 CFR 55.4, a licensed Senior Operator and a licensed Operator are those individuals who, in addition to meeting the requirements of Specification 5.3.1, perform the functions described in 10 CFR 50.54(m)." The CTS does not include such a statement. This changes the CTS by clarifying that these individuals must meet all of the qualification requirements referenced in 10 CFR 55.4, ITS 5.3.1, and 10 CFR 50.54(m).

This change is acceptable because it clarifies the existing relationship between the Technical Specifications and regulations regarding licensed Senior Operator and Operator qualification requirements. This change is designated as administrative because it does not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 6.3.1 uses the titles "Plant Radiation Protection Manager" and "Operations Director." ITS 5.3.1 uses the generic titles "radiation protection manager" and "operations manager." This changes the CTS by moving the specific CNP organizational titles to the UFSAR and replacing them with generic titles.

The removal of these details, which are related to meeting Technical Specification requirements, from the Technical Specifications is acceptable because this type of information is not necessary to be included in Technical Specifications to provide adequate protection of public health and safety. The allowance to relocate the specific CNP organizational titles out of the Technical Specifications is consistent with the NRC letter from C. Grimes to the Owners Groups Technical Specification Committee Chairmen, dated November 10, 1994.

The various requirements of the radiation protection manager and the operations CNP Units 1 and 2 Page 1 of 2 Attachment 1, Volume 16, Rev. 0, Page 45 of 256

Attachment 1, Volume 16, Rev. 0, Page 46 of 256 DISCUSSION OF CHANGES ITS 5.3, UNIT STAFF QUALIFICATIONS manager are still retained in the ITS. Also, this change is acceptable because the removed information will be adequately controlled in the UFSAR. Any changes to the UFSAR are made under 10 CFR 50.59 or 10 CFR 50.71(e),

which ensures changes are properly evaluated. This change is designated as a less restrictive removal of detail change because information related to meeting Technical Specification requirements are being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES None CNP Units 1 and 2 Page 2 of 2 Attachment 1, Volume 16, Rev. 0, Page 46 of 256

Attachment 1, Volume 16, Rev. 0, Page 47 of 256 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 16, Rev. 0, Page 47 of 256

, Volume 16, Rev. 0, Page 48 of 256 , Volume 16, Rev. 0, Page 48 of 256

, Volume 16, Rev. 0, Page 49 of 256 , Volume 16, Rev. 0, Page 49 of 256

Attachment 1, Volume 16, Rev. 0, Page 50 of 256 JUSTIFICATION FOR DEVIATIONS ITS 5.3, UNIT STAFF QUALIFICATIONS

1. The ISTS Reviewers Note has been deleted since it is not intended to be included in the ITS.

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

3. Grammatical/typographical error corrected. The terms in 10 CFR 55.4 and 10 CFR 50.54(m) are "Senior Operator" and "Operator."

4. Change made for consistency with the terminology used in other Specifications.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 16, Rev. 0, Page 50 of 256

Attachment 1, Volume 16, Rev. 0, Page 51 of 256 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 16, Rev. 0, Page 51 of 256

Attachment 1, Volume 16, Rev. 0, Page 52 of 256 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 5.3, UNIT STAFF QUALIFICATIONS There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 16, Rev. 0, Page 52 of 256

, Volume 16, Rev. 0, Page 53 of 256 ATTACHMENT 4 ITS 5.4, Procedures , Volume 16, Rev. 0, Page 53 of 256

, Volume 16, Rev. 0, Page 54 of 256 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 16, Rev. 0, Page 54 of 256

Attachment 1, Volume 16, Rev. 0, Page 55 of 256 ITS 5.4 A.1 ITS 5.4 See ITS 5.5 5.4.1 5.4.1.a Add proposed Specification 5.4.1.b M.1 LA.1 5.4.1.e A.2 5.4.1.c LA.2 5.4.1.e A.2 5.4.1.d LA.3 Add proposed Specification 5.4.1.e M.2 Page 1 of 2 Attachment 1, Volume 16, Rev. 0, Page 55 of 256

Attachment 1, Volume 16, Rev. 0, Page 56 of 256 ITS 5.4 A.1 ITS 5.4 See ITS 5.5 5.4.1 5.4.1.a Add proposed Specification 5.4.1.b M.1 LA.1 5.4.1.e A.2 5.4.1.c LA.2 5.4.1.e A.2 5.4.1.d LA.3 Add proposed Specification 5.4.1.e M.2 Page 2 of 2 Attachment 1, Volume 16, Rev. 0, Page 56 of 256

Attachment 1, Volume 16, Rev. 0, Page 57 of 256 DISCUSSION OF CHANGES ITS 5.4, PROCEDURES 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 6.8.1.e requires procedures for implementation of the OFFSITE DOSE CALCULATION MANUAL (ODCM) and CTS 6.8.1.g requires procedures for the implementation of the Component Cyclic or Transient Limits Program. ITS 5.4.1 requires procedures for various activities, but does not specifically list the ODCM and the Component Cyclic or Transient Limits Program. This changes the CTS by removing the explicit requirements for written procedures for implementation of the ODCM and the Component Cyclic or Transient Limits Program.

This change is acceptable because implementing procedures for the ODCM and the Component Cyclic or Transient Limits Program are required by ITS 5.4.1.e.

ITS 5.4.1.e (added as described in DOC M.2) requires that written procedures be established, implemented, and maintained for all programs and manuals in ITS 5.5 (including the ODCM and Component Cyclic or Transient Limits Program). Therefore, it is not necessary to specifically identify each program in ITS 5.4.1. This change is designated as administrative because it does not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES M.1 ITS 5.4.1.b requires that written procedures shall be established, implemented, and maintained for the emergency operating procedures required to implement the requirements of NUREG-0737 and NUREG-0737, Supplement 1, as stated in Generic Letter 82-33. The CTS does not include this requirement. This changes the CTS by adopting a new requirement for emergency operating procedures.

The purpose of ITS 5.4.1.b is to ensure that written procedures are established, implemented, and maintained covering the emergency operating procedures to implement the requirements of NUREG-0737 and NUREG-0737, Supplement 1, as stated in Generic Letter 82-33. This change is acceptable because it is consistent with an existing requirement to comply with NUREG-0737 and NUREG-0737, Supplement 1, as stated in Generic Letter 82-33, for emergency operating procedures. This change is designated more restrictive because it imposes a new requirement for procedures within the Technical Specifications.

M.2 ITS 5.4.1.e requires that written procedures shall be established, implemented, and maintained for all programs specified in Specification 5.5. The CTS does not include this requirement for any program except the ODCM and the Component CNP Units 1 and 2 Page 1 of 3 Attachment 1, Volume 16, Rev. 0, Page 57 of 256

Attachment 1, Volume 16, Rev. 0, Page 58 of 256 DISCUSSION OF CHANGES ITS 5.4, PROCEDURES Cyclic or Transient Limits Program. This changes the CTS by adopting a new requirement for procedures to address all programs described in ITS 5.5.

The purpose of ITS 5.4.1.e is to ensure that written procedures are established, implemented, and maintained covering all programs specified in ITS 5.5. This change is considered acceptable because it requires written procedures, including proper procedure control to address programs required by ITS 5.5.

This change is designated more restrictive because it imposes new requirements for procedures within the Technical Specifications.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 6.8.1.d requires that written procedures for the PROCESS CONTROL PROGRAM (PCP) be established, implemented, and maintained. The ITS does not include these requirements. This changes the CTS by moving the requirements to the UFSAR.

The removal of these details, which are related to meeting Technical Specification requirements, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The PCP implements the requirements of 10 CFR 20, 10 CFR 61, and 10 CFR 71.

Compliance with these regulations is required by the CNP Units 1 and 2 Operating Licenses, and written procedures are necessary to ensure compliance with the program. Regulations provide an adequate level of control for the affected requirements, and inclusion of this requirement in the Technical Specifications is not necessary. Also, this change is acceptable because these details will be adequately controlled in the UFSAR. Any changes to the UFSAR are made under 10 CFR 50.59 or 10 CFR 50.71(e), which ensures changes are properly evaluated. This change is designated as a less restrictive removal of detail change because details for meeting Technical Specification and regulatory requirements are being removed from the Technical Specifications.

LA.2 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 6.8.1.f requires written procedures be established, implemented and maintained covering the Quality Assurance Program for effluent and environmental monitoring, "using the guidance in Regulatory Guide 1.21, Revision 1, June 1974, and Regulatory Guide 4.1, Revision 1, April 1975."

ITS 5.4.1.c does not include the Regulatory Guide references. This changes the CTS by moving the references to the Regulatory Guides to the Quality Assurance Program Description (QAPD).

The removal of these details, which are related to meeting Technical Specification requirements, from the Technical Specifications is acceptable CNP Units 1 and 2 Page 2 of 3 Attachment 1, Volume 16, Rev. 0, Page 58 of 256

Attachment 1, Volume 16, Rev. 0, Page 59 of 256 DISCUSSION OF CHANGES ITS 5.4, PROCEDURES because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement for written procedures covering quality assurance for effluent and environmental monitoring. Also, this change is acceptable because these types of procedural details will be adequately controlled in the QAPD. Any changes to the QAPD are made under 10 CFR 50.54(a), which ensures changes are properly evaluated. This change is designated as a less restrictive removal of detail change because references for meeting Technical Specification requirements are being removed from the Technical Specifications.

LA.3 (Type 3 - Removing Procedural Details for Meeting TS or Reporting Requirements) CTS 6.8.2 requires that each procedure and administrative policy of Specification 6.8.1, and changes to these documents, including temporary changes, be reviewed prior to implementation in accordance with the QAPD.

ITS 5.4 does not include this requirement. This changes the CTS by moving these details of procedure and administrative policy reviews to the QAPD.

The removal of these details, which are related to meeting Technical Specification requirements, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety.

ITS 5.4.1 still retains the requirement for written procedures required by the Technical Specifications to be established, implemented, and maintained.

Regulations provide an adequate level of control for the affected review requirement. The requirements for establishment, maintenance, and implementation of procedures related to activities affecting quality are contained in 10 CFR 50, Appendix B, Criterion II and Criterion V and ANSI N18.7-1976 (ANS 3.2-1976). In accordance with these requirements, the QAPD includes adequate detail with respect to administrative control of procedures related to activities affecting quality and nuclear safety, including the review requirements associated with maintenance of these procedures. Also, this change is acceptable because these types of procedural details will be adequately controlled in the QAPD. Any changes to the QAPD are made under 10 CFR 50.54(a), which ensures changes are properly evaluated. This change is designated as a less restrictive removal of detail change because references for meeting Technical Specification and regulatory requirements are being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES None CNP Units 1 and 2 Page 3 of 3 Attachment 1, Volume 16, Rev. 0, Page 59 of 256

Attachment 1, Volume 16, Rev. 0, Page 60 of 256 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 16, Rev. 0, Page 60 of 256

, Volume 16, Rev. 0, Page 61 of 256 , Volume 16, Rev. 0, Page 61 of 256

Attachment 1, Volume 16, Rev. 0, Page 62 of 256 JUSTIFICATION FOR DEVIATIONS ITS 5.4, PROCEDURES

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

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

3. Grammatical errors corrected.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 16, Rev. 0, Page 62 of 256

Attachment 1, Volume 16, Rev. 0, Page 63 of 256 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 16, Rev. 0, Page 63 of 256

Attachment 1, Volume 16, Rev. 0, Page 64 of 256 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 5.4, PROCEDURES There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 16, Rev. 0, Page 64 of 256

, Volume 16, Rev. 0, Page 65 of 256 ATTACHMENT 5 ITS 5.5, Programs and Manuals , Volume 16, Rev. 0, Page 65 of 256

, Volume 16, Rev. 0, Page 66 of 256 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 16, Rev. 0, Page 66 of 256

Attachment 1, Volume 16, Rev. 0, Page 67 of 256 ITS 5.5 A.1 ITS 5.5 5.5.3 5.5.3 5.5.3.a 5.5.3.b 5.5.3.c 5.5.3.d 5.5.3.e 5.5.3.f Page 1 of 69 Attachment 1, Volume 16, Rev. 0, Page 67 of 256

Attachment 1, Volume 16, Rev. 0, Page 68 of 256 ITS 5.5 A.1 ITS 5.5.3.g 5.5.3.h 5.5.3.i A.2 5.5.3.j The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Radioactive Effluent Control Program Surveillance Frequencies.

LA.1 Page 2 of 69 Attachment 1, Volume 16, Rev. 0, Page 68 of 256

Attachment 1, Volume 16, Rev. 0, Page 69 of 256 ITS 5.5 A.1 ITS 5.5.8 L.6 5.5.8.a 5.5.8.b Page 3 of 69 Attachment 1, Volume 16, Rev. 0, Page 69 of 256

Attachment 1, Volume 16, Rev. 0, Page 70 of 256 ITS 5.5 A.1 ITS 5.5.8.c 5.5.8.d 5.5.8.e 5.5.8.f M.1 Add proposed Systems list 5.5.2 Page 4 of 69 Attachment 1, Volume 16, Rev. 0, Page 70 of 256

Attachment 1, Volume 16, Rev. 0, Page 71 of 256 ITS 5.5 A.1 ITS 5.5.2 24 months L.1 The provisions of SR 3.0.2 are applicable.

LA.2 Page 5 of 69 Attachment 1, Volume 16, Rev. 0, Page 71 of 256

Attachment 1, Volume 16, Rev. 0, Page 72 of 256 ITS 5.5 A.1 ITS See CTS 6.0 5.5.1 5.5.1.a 5.5.1.b See ITS Chapter 1.0 Page 6 of 69 Attachment 1, Volume 16, Rev. 0, Page 72 of 256

Attachment 1, Volume 16, Rev. 0, Page 73 of 256 ITS 5.5 A.1 ITS See ITS Section 3.0 5.5.6 LA.3 pumps and valves LA.4 Page 7 of 69 Attachment 1, Volume 16, Rev. 0, Page 73 of 256

Attachment 1, Volume 16, Rev. 0, Page 74 of 256 ITS 5.5 A.1 ITS A.15 5.5.6.a LA.3 A.15 A.3 Biennially or every At least once per 731 days 2 years 5.5.6.b LA.3 A.4 5.5.6.d A.15 A.5 Add proposed ITS 5.5.6.c Page 8 of 69 Attachment 1, Volume 16, Rev. 0, Page 74 of 256

Attachment 1, Volume 16, Rev. 0, Page 75 of 256 ITS 5.5 A.1 ITS See ITS 3.4.13 5.5.7 Add proposed ITS 5.5.7 generic program description A.6 5.5.7 5.5.7.a 5.5.7.a.1 5.5.7.a.2 5.5.7.a.2.a)

See ITS 3.4.13 Page 9 of 69 Attachment 1, Volume 16, Rev. 0, Page 75 of 256

Attachment 1, Volume 16, Rev. 0, Page 76 of 256 ITS 5.5 A.1 ITS 5.5.7.a.2.b) 5.5.7.a.2.c) 5.5.7.a.3 5.5.7.a.3.a) 5.5.7.a.3.b) 5.5.7.b Page 10 of 69 Attachment 1, Volume 16, Rev. 0, Page 76 of 256

Attachment 1, Volume 16, Rev. 0, Page 77 of 256 ITS 5.5 A.1 ITS 5.5.7.b 5.5.7.c 5.5.7.c.1 5.5.7.c.2 5.5.7.c.3 5.5.7.c.3.a) 5.5.7.c.3.b) 5.5.7 c.3.c) 5.5.7.c.3.d)

Page 11 of 69 Attachment 1, Volume 16, Rev. 0, Page 77 of 256

Attachment 1, Volume 16, Rev. 0, Page 78 of 256 ITS 5.5 A.1 ITS 5.5.7.d 5.5.7.d.1 5.5.7.d.1.a) 5.5.7.d.1.b) 5.5.7.d.1.c) 5.5.7 d.1.d) 5.5.7.d.1.e) 5.5.7.d.1.f) 5.5.7.d.1.g) 5.5.7.d.1.h)

Add proposed ITS 5.5.7.d.1.i) A.14 Page 12 of 69 Attachment 1, Volume 16, Rev. 0, Page 78 of 256

Attachment 1, Volume 16, Rev. 0, Page 79 of 256 ITS 5.5 A.1 ITS 5.5.7.d.2 The provisions of SR 3.0.2 and SR 3.0.3 are A.6 applicable to the SG Program test Frequencies.

Page 13 of 69 Attachment 1, Volume 16, Rev. 0, Page 79 of 256

Attachment 1, Volume 16, Rev. 0, Page 80 of 256 ITS 5.5 A.1 ITS Table 5.5.7-1 Table 5.5.7-1 Footnote (a)

Table 5.5.7-1 Footnote (a)

Page 14 of 69 Attachment 1, Volume 16, Rev. 0, Page 80 of 256

Attachment 1, Volume 16, Rev. 0, Page 81 of 256 ITS 5.5 A.1 Table 5.5.7-2 ITS Page 15 of 69 Attachment 1, Volume 16, Rev. 0, Page 81 of 256

Attachment 1, Volume 16, Rev. 0, Page 82 of 256 ITS 5.5 A.1 ITS See CTS 3/4.4.10.1 5.5.5 Add proposed ITS 5.5.5 A.13 generic program statement The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Reactor Coolant Pump Flywheel Inspection Program Surveillance Frequency.

Page 16 of 69 Attachment 1, Volume 16, Rev. 0, Page 82 of 256

Attachment 1, Volume 16, Rev. 0, Page 83 of 256 ITS 5.5 A.1 ITS See ITS 3.6.1 Add proposed ITS 5.5.14 and 5.5.14.a 5.5.14.b, 5.5.14.c, A.7 5.5.14.d.1 5.5.14.d.1 L.2 See ITS 3.6.1 5.5.14.d.1 L.2 5.5.14.a See ITS 3.6.1 A.7 Add proposed ITS 5.5.14.e A.7 5.5.14.a.2 5.5.14.a.1 Page 17 of 69 Attachment 1, Volume 16, Rev. 0, Page 83 of 256

Attachment 1, Volume 16, Rev. 0, Page 84 of 256 ITS 5.5 A.1 ITS See ITS 3.6.2 5.5.14.d.2.a),

5.5.14.b See ITS 3.6.2 5.5.14.a See ITS 3.6.2 Page 18 of 69 Attachment 1, Volume 16, Rev. 0, Page 84 of 256

Attachment 1, Volume 16, Rev. 0, Page 85 of 256 ITS 5.5 A.1 ITS Add proposed ITS 5.5.9 generic program statement A.9 See ITS 3.7.10 L.3 A.8 24 5.5.9 while it is in operation that could adversely affect the filter bank or charcoal 5.5.9.b adsorber capability 5.5.9.a LA.5 5.5.9.c 5.5.9.c.1 5.5.9.c.2 5.5.9.a, 5.5.9.b Page 19 of 69 Attachment 1, Volume 16, Rev. 0, Page 85 of 256

Attachment 1, Volume 16, Rev. 0, Page 86 of 256 ITS 5.5 A.1 ITS 5.5.9 LA.5 5.5.9.c LA.5 5.5.9.c 5.5.9.c.1 5.5.9.c.2 L.4 Page 20 of 69 Attachment 1, Volume 16, Rev. 0, Page 86 of 256

Attachment 1, Volume 16, Rev. 0, Page 87 of 256 ITS 5.5 A.1 ITS L.3 24 5.5.9 5.5.9.d See ITS 3.3.7 and ITS 3.7.10 See ITS 3.7.10 5.5.9 5.5.9.a 5.5.9 5.5.9.b A.9 The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the VFTP test Frequencies.

Page 21 of 69 Attachment 1, Volume 16, Rev. 0, Page 87 of 256

Attachment 1, Volume 16, Rev. 0, Page 88 of 256 ITS 5.5 A.1 ITS See ITS 3.7.12 Add proposed ITS 5.5.9 generic program statement A.9 See ITS 3.7.12 L.3 A.8 24 months 5.5.9 while it is in operation that could adversely affect the filter bank or charcoal 5.5.9.b adsorber capability 5.5.9.a Page 22 of 69 Attachment 1, Volume 16, Rev. 0, Page 88 of 256

Attachment 1, Volume 16, Rev. 0, Page 89 of 256 ITS 5.5 A.1 ITS LA.5 5.5.9.c 5.5.9.c.1 5.5.9.c.2 L.4 5.5.9.a, 5.5.9.b 5.5.9 5.5.9.c LA.5 5.5.9.c LA.5 5.5.9.c.1 Page 23 of 69 Attachment 1, Volume 16, Rev. 0, Page 89 of 256

Attachment 1, Volume 16, Rev. 0, Page 90 of 256 ITS 5.5 A.1 ITS 5.5.9.c.2 L.4 L.3 24 5.5.9 5.5.9.d See ITS 3.7.12 5.5.9 5.5.9.a 5.5.9 5.5.9.b A.9 The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the VFTP test Frequencies.

Page 24 of 69 Attachment 1, Volume 16, Rev. 0, Page 90 of 256

Attachment 1, Volume 16, Rev. 0, Page 91 of 256 ITS 5.5 A.1 ITS See ITS 3.8.1 and ITS 3.8.3 See ITS 3.8.1 See ITS 3.8.3 See ITS 3.8.1 See ITS 3.8.1 and ITS 3.8.3 See ITS 3.8.1 See ITS 3.8.3 5.5.11.a LA.6 5.5.11.a Add proposed ITS 5.5.11 generic program statement A.10 See ITS 3.8.1 See ITS 3.8.3 Page 25 of 69 Attachment 1, Volume 16, Rev. 0, Page 91 of 256

Attachment 1, Volume 16, Rev. 0, Page 92 of 256 ITS 5.5 A.1 ITS within limits 5.5.11.a.2 LA.6 within limits 5.5.11.a.2 within limits 5.5.11.a.1 LA.6 of new fuel oil, other than those 5.5.11.a.3 addressed in Specification 5.5.11.a above, L.5 5.5.11.b LA.6 5.5.11.c See ITS 3.8.3 See ITS 3.8.1 The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Diesel Fuel Oil Testing A.10 Program test Frequencies.

See ITS 3.8.3 Page 26 of 69 Attachment 1, Volume 16, Rev. 0, Page 92 of 256

Attachment 1, Volume 16, Rev. 0, Page 93 of 256 ITS 5.5 A.1 ITS See ITS 3.7.13 Add proposed ITS 5.5.9 generic program statement A.9 See ITS 3.7.13 24 L.3 5.5.9 while it is in operation that could adversely affect the filter bank or A.8 charcoal adsorber capability 5.5.9.b See ITS 3.7.13 Page 27 of 69 Attachment 1, Volume 16, Rev. 0, Page 93 of 256

Attachment 1, Volume 16, Rev. 0, Page 94 of 256 ITS 5.5 A.1 ITS 5.5.9.a LA.5 5.5.9.c 5.5.9.c.1 5.5.9.c.2 L.4 5.5.9.a, 5.5.9.b 5.5.9 LA.5 5.5.9.c Page 28 of 69 Attachment 1, Volume 16, Rev. 0, Page 94 of 256

Attachment 1, Volume 16, Rev. 0, Page 95 of 256 ITS 5.5 A.1 ITS LA.5 5.5.9.c 5.5.9.c.1 5.5.9.c.2 L.4 24 L.3 5.5.9 5.5.9.d See ITS 3.7.13 Page 29 of 69 Attachment 1, Volume 16, Rev. 0, Page 95 of 256

Attachment 1, Volume 16, Rev. 0, Page 96 of 256 ITS 5.5 A.1 ITS 5.5.9 5.5.9.a 5.5.9 5.5.9.b The provisions of SR 3.0.2 and SR 3.0.3 are A.9 applicable to the VFTP test Frequencies.

Page 30 of 69 Attachment 1, Volume 16, Rev. 0, Page 96 of 256

Attachment 1, Volume 16, Rev. 0, Page 97 of 256 ITS 5.5 A.1 ITS A.11 Add proposed ITS 5.5.10 generic program statement 5.5.10, 5.5.10.c LA.7 LA.7 5.5.10.c LA.7 The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Storage Tank Radioactivity A.11 Monitoring Program Surveillance Frequencies.

5.5.10.c Page 31 of 69 Attachment 1, Volume 16, Rev. 0, Page 97 of 256

Attachment 1, Volume 16, Rev. 0, Page 98 of 256 ITS 5.5 A.1 ITS A.11 Add proposed ITS 5.5.10 generic program statement 5.5.10, LA.7 5.5.10.a LA.7 5.5.10.a LA.7 The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Explosive Gas Radioactivity A.11 Monitoring Program Surveillance Frequencies.

Page 32 of 69 Attachment 1, Volume 16, Rev. 0, Page 98 of 256

Attachment 1, Volume 16, Rev. 0, Page 99 of 256 ITS 5.5 A.1 ITS A.11 Add proposed ITS 5.5.10 generic program statement 5.5.10, 5.5.10.b LA.7 LA.7 5.5.10.b LA.7 The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Storage Tank Radioactivity A.11 Monitoring Program Surveillance Frequencies.

Page 33 of 69 Attachment 1, Volume 16, Rev. 0, Page 99 of 256

Attachment 1, Volume 16, Rev. 0, Page 100 of 256 ITS 5.5 A.1 ITS See ITS 5.4 5.5.4 A.12 See ITS 5.4 Page 34 of 69 Attachment 1, Volume 16, Rev. 0, Page 100 of 256

Attachment 1, Volume 16, Rev. 0, Page 101 of 256 ITS 5.5 A.1 ITS See CTS 6.0 5.5.1.c 5.5.1.c.1 LA.8 5.5.1.c.1.a) 5.5.1.c.1.b)

LA.8 5.5.1.c.2 LA.9 5.5.1.c.3 Add proposed ITS 5.5.12, ITS 5.5.13, and ITS 5.5.15 M.2 Page 35 of 69 Attachment 1, Volume 16, Rev. 0, Page 101 of 256

Attachment 1, Volume 16, Rev. 0, Page 102 of 256 ITS 5.5 A.1 ITS 5.5 5.5.3 5.5.3 5.5.3.a 5.5.3.b 5.5.3.c 5.5.3.d 5.5.3.e 5.5.3.f Page 36 of 69 Attachment 1, Volume 16, Rev. 0, Page 102 of 256

Attachment 1, Volume 16, Rev. 0, Page 103 of 256 ITS 5.5 A.1 ITS 5.5.3.g 5.5.3.h 5.5.3.i A.2 5.5.3.j The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Radioactive Effluent Control Program Surveillance Frequencies.

LA.1 Page 37 of 69 Attachment 1, Volume 16, Rev. 0, Page 103 of 256

Attachment 1, Volume 16, Rev. 0, Page 104 of 256 ITS 5.5 A.1 ITS 5.5.8 L.6 5.5.8.a 5.5.8.b 5.5.8.c 5.5.8.d 5.5.8.e 5.5.8.f Page 38 of 69 Attachment 1, Volume 16, Rev. 0, Page 104 of 256

Attachment 1, Volume 16, Rev. 0, Page 105 of 256 ITS 5.5 A.1 ITS M.1 Add proposed Systems list 5.5.2 24 months L.1 The provisions of SR 3.0.2 are applicable.

LA.2 Page 39 of 69 Attachment 1, Volume 16, Rev. 0, Page 105 of 256

Attachment 1, Volume 16, Rev. 0, Page 106 of 256 ITS 5.5 A.1 ITS 5.5.1 5.5.1.a 5.5.1.b See ITS Chapter 1.0 Page 40 of 69 Attachment 1, Volume 16, Rev. 0, Page 106 of 256

Attachment 1, Volume 16, Rev. 0, Page 107 of 256 ITS 5.5 A.1 ITS See ITS Section 3.0 5.5.6 LA.3 pumps and valves LA.4 Page 41 of 69 Attachment 1, Volume 16, Rev. 0, Page 107 of 256

Attachment 1, Volume 16, Rev. 0, Page 108 of 256 ITS 5.5 A.1 ITS A.15 5.5.6.a LA.3 A.15 A.3 Biennially or every At least once per 731 days 2 years 5.5.6.b LA.3 A.4 5.5.6.d A.15 Add proposed ITS 5.5.6.c A.5 Page 42 of 69 Attachment 1, Volume 16, Rev. 0, Page 108 of 256

Attachment 1, Volume 16, Rev. 0, Page 109 of 256 ITS 5.5 A.1 ITS See ITS 3.4.13 5.5.7 Add proposed ITS 5.5.7 generic program description A.6 5.5.7 5.5.7.a 5.5.7.a.1 5.5.7.a.2 See ITS 3.4.13 Page 43 of 69 Attachment 1, Volume 16, Rev. 0, Page 109 of 256

Attachment 1, Volume 16, Rev. 0, Page 110 of 256 ITS 5.5 A.1 ITS 5.5.7.a.2.a) 5.5.7.a.2.b) 5.5.7.a.2.c) 5.5.7.a.3 5.5.7.a.3.a) 5.5.7.a.3.b) 5.5.7.b Page 44 of 69 Attachment 1, Volume 16, Rev. 0, Page 110 of 256

Attachment 1, Volume 16, Rev. 0, Page 111 of 256 ITS 5.5 A.1 ITS 5.5.7.c 5.5.7.c.1 5.5.7.c.2 5.5.7.c.3 5.5.7.c.3.a) 5.5.7.c.3.b) 5.5.7.c.3.c) 5.5.7.c.3.d)

Page 45 of 69 Attachment 1, Volume 16, Rev. 0, Page 111 of 256

Attachment 1, Volume 16, Rev. 0, Page 112 of 256 ITS 5.5 A.1 ITS 5.5.7.d 5.5.7.d.1 5.5.7.d.1.a) 5.5.7.d.1.b) 5.5.7.d.1.c) 5.5.7 d.1.d) 5.5.7.d.1.e) 5.5.7.d.1.f) 5.5.7.d.1.g) 5.5.7.d.1.h)

Page 46 of 69 Attachment 1, Volume 16, Rev. 0, Page 112 of 256

Attachment 1, Volume 16, Rev. 0, Page 113 of 256 ITS 5.5 A.1 ITS 5.5.7.d.1.i) 5.5.7.d.2 The provisions of SR 3.0.2 and SR 3.0.3 are A.6 applicable to the SG Program test Frequencies.

See ITS 5.6 Page 47 of 69 Attachment 1, Volume 16, Rev. 0, Page 113 of 256

Attachment 1, Volume 16, Rev. 0, Page 114 of 256 ITS 5.5 A.1 Table 5.5.7-1 Table 5.5.7-1 Table 5.5.7-1 ITS Footnote (a) Footnote (a)

Page 48 of 69 Attachment 1, Volume 16, Rev. 0, Page 114 of 256

Attachment 1, Volume 16, Rev. 0, Page 115 of 256 ITS 5.5 A.1 Table 5.5.7-2 ITS Page 49 of 69 Attachment 1, Volume 16, Rev. 0, Page 115 of 256

Attachment 1, Volume 16, Rev. 0, Page 116 of 256 ITS 5.5 A.1 ITS See ITS 3/4.4.10.1 5.5.5 A.13 Add proposed ITS 5.5.5 generic program statement The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Reactor Coolant Pump Flywheel Inspection Program Surveillance Frequency.

Page 50 of 69 Attachment 1, Volume 16, Rev. 0, Page 116 of 256

Attachment 1, Volume 16, Rev. 0, Page 117 of 256 ITS 5.5 A.1 ITS See ITS 3.6.1 Add proposed ITS 5.5.14 and 5.5.14.a 5.5.14.b, 5.5.14.c, A.7 5.5.14.d.1 5.5.14.d.1 L.2 See ITS 3.6.1 5.5.14.d.1 L.2 5.5.14.a See ITS 3.6.1 A.7 Add proposed ITS 5.5.14.e A.7 5.5.14.a.1 Page 51 of 69 Attachment 1, Volume 16, Rev. 0, Page 117 of 256

Attachment 1, Volume 16, Rev. 0, Page 118 of 256 ITS 5.5 A.1 ITS See ITS 3.6.2 5.5.14.d.2.a),

5.5.14.b See ITS 3.6.2 5.5.14.a See ITS 3.6.2 Page 52 of 69 Attachment 1, Volume 16, Rev. 0, Page 118 of 256

Attachment 1, Volume 16, Rev. 0, Page 119 of 256 ITS 5.5 A.1 ITS Add proposed ITS 5.5.9 generic program statement A.9 See ITS 3.7.10 L.3 A.8 24 5.5.9 while it is in operation that could adversely affect the filter bank or charcoal adsorber capability 5.5.9.b 5.5.9.a LA.5 5.5.9.c 5.5.9.c.1 5.5.9.c.2 5.5.9.a, 5.5.9.b Page 53 of 69 Attachment 1, Volume 16, Rev. 0, Page 119 of 256

Attachment 1, Volume 16, Rev. 0, Page 120 of 256 ITS 5.5 A.1 ITS LA.5 5.5.9 5.5.9.c LA.5 5.5.9.c 5.5.9.c.1 5.5.9.c.2 L.4 Page 54 of 69 Attachment 1, Volume 16, Rev. 0, Page 120 of 256

Attachment 1, Volume 16, Rev. 0, Page 121 of 256 ITS 5.5 A.1 ITS L.3 24 5.5.9 5.5.9.d See ITS 3.3.7 and ITS 3.7.10 See ITS 3.7.10 5.5.9 5.5.9.a 5.5.9 5.5.9.b A.9 The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the VFTP test Frequencies.

Page 55 of 69 Attachment 1, Volume 16, Rev. 0, Page 121 of 256

Attachment 1, Volume 16, Rev. 0, Page 122 of 256 ITS 5.5 A.1 ITS See ITS 3.7.12 Add proposed ITS 5.5.9 generic program statement A.9 See ITS 3.7.12 L.3 A.8 24 months 5.5.9 while it is in operation that could adversely affect the filter bank or charcoal adsorber capability 5.5.9.b 5.5.9.a Page 56 of 69 Attachment 1, Volume 16, Rev. 0, Page 122 of 256

Attachment 1, Volume 16, Rev. 0, Page 123 of 256 ITS 5.5 A.1 ITS LA.5 5.5.9.c 5.5.9.c.1 5.5.9.c.2 L.4 5.5.9.a, 5.5.9.b 5.5.9 LA.5 5.5.9.c LA.5 5.5.9.c 5.5.9.c.1 Page 57 of 69 Attachment 1, Volume 16, Rev. 0, Page 123 of 256

Attachment 1, Volume 16, Rev. 0, Page 124 of 256 ITS 5.5 A.1 ITS 5.5.9.c.2 L.4 L.3 24 5.5.9 5.5.9.d See ITS 3.7.12 5.5.9 5.5.9.a 5.5.9 5.5.9.b A.9 The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the VFTP test Frequencies.

See ITS LA.6 3.7.12 Page 58 of 69 Attachment 1, Volume 16, Rev. 0, Page 124 of 256

Attachment 1, Volume 16, Rev. 0, Page 125 of 256 ITS 5.5 A.1 ITS See ITS 3.8.1 and ITS 3.8.3 See ITS 3.8.1 See ITS 3.8.3 See ITS 3.8.1 See ITS 3.8.1 and ITS 3.8.3 See ITS 3.8.1 See ITS 3.8.3 5.5.11.a 5.5.11.a LA.6 Add proposed ITS 5.5.11 generic program statement A.10 See ITS 3.8.1 See ITS 3.8.3 Page 59 of 69 Attachment 1, Volume 16, Rev. 0, Page 125 of 256

Attachment 1, Volume 16, Rev. 0, Page 126 of 256 ITS 5.5 A.1 ITS within limits 5.5.11.a.2 LA.6 within limits 5.5.11.a.2 within limits 5.5.11.a.1 LA.6 of new fuel oil, other than those addressed in 5.5.11.a.3 Specification 5.5.11.a above, L.5 5.5.11.b 5.5.11c LA.6 See ITS 3.8.3 See ITS 3.8.1 The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Diesel Fuel Oil Testing A.10 Program test Frequencies.

See ITS 3.8.3 Page 60 of 69 Attachment 1, Volume 16, Rev. 0, Page 126 of 256

Attachment 1, Volume 16, Rev. 0, Page 127 of 256 ITS 5.5 A.1 ITS See ITS 3.7.13 Add proposed ITS 5.5.9 generic program statement A.9 See ITS 3.7.13 24 L.3 5.5.9 while it is in operation that could A.8 adversely affect the filter bank or charcoal adsorber capability 5.5.9.b See ITS 3.7.13 Page 61 of 69 Attachment 1, Volume 16, Rev. 0, Page 127 of 256

Attachment 1, Volume 16, Rev. 0, Page 128 of 256 ITS 5.5 A.1 ITS 5.5.9.a LA.5 5.5.9.c 5.5.9.c.1 5.5.9.c.2 L.4 5.5.9.a, 5.5.9.b 5.5.9 LA.5 5.5.9.c Page 62 of 69 Attachment 1, Volume 16, Rev. 0, Page 128 of 256

Attachment 1, Volume 16, Rev. 0, Page 129 of 256 ITS 5.5 A.1 ITS LA.5 5.5.9.c 5.5.9.c.1 5.5.9.c.2 L.4 24 L.3 5.5.9 5.5.9.d See ITS 3.7.13 Page 63 of 69 Attachment 1, Volume 16, Rev. 0, Page 129 of 256

Attachment 1, Volume 16, Rev. 0, Page 130 of 256 ITS 5.5 A.1 ITS 5.5.9 5.5.9.a 5.5.9 5.5.9.b The provisions of SR 3.0.2 and SR 3.0.3 are A.9 applicable to the VFTP test Frequencies.

Page 64 of 69 Attachment 1, Volume 16, Rev. 0, Page 130 of 256

Attachment 1, Volume 16, Rev. 0, Page 131 of 256 ITS 5.5 A.1 ITS A.11 Add proposed ITS 5.5.10 generic program statement 5.5.10, 5.5.10.c LA.7 LA.7 5.5.10.c LA.7 The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Storage Tank Radioactivity A.11 Monitoring Program Surveillance Frequencies.

5.5.10.c Page 65 of 69 Attachment 1, Volume 16, Rev. 0, Page 131 of 256

Attachment 1, Volume 16, Rev. 0, Page 132 of 256 ITS 5.5 A.1 ITS A.11 Add proposed ITS 5.5.10 generic program statement 5.5.10, LA.7 5.5.10.a LA.7 5.5.10.a LA.7 The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Explosive Gas Radioactivity A.11 Monitoring Program Surveillance Frequencies.

Page 66 of 69 Attachment 1, Volume 16, Rev. 0, Page 132 of 256

Attachment 1, Volume 16, Rev. 0, Page 133 of 256 ITS 5.5 A.1 ITS A.11 Add proposed ITS 5.5.10 generic program statement 5.5.10, 5.5.10.b LA.7 LA.7 5.5.10.b LA.7 The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Storage Tank Radioactivity A.11 Monitoring Program Surveillance Frequencies.

Page 67 of 69 Attachment 1, Volume 16, Rev. 0, Page 133 of 256

Attachment 1, Volume 16, Rev. 0, Page 134 of 256 ITS 5.5 A.1 ITS See ITS 5.4 5.5.4 A.12 See ITS 5.4 Page 68 of 69 Attachment 1, Volume 16, Rev. 0, Page 134 of 256

Attachment 1, Volume 16, Rev. 0, Page 135 of 256 ITS 5.5 A.1 ITS See CTS 6.0 5.5.1.c 5.5.1.c.1 LA.8 5.5.1.c.1.a) 5.5.1.c.1.b)

LA.8 5.5.1.c.2 LA.9 5.5.1.c.3 Add proposed ITS 5.5.12, ITS 5.5.13, and ITS 5.5.15 M.2 Page 69 of 69 Attachment 1, Volume 16, Rev. 0, Page 135 of 256

Attachment 1, Volume 16, Rev. 0, Page 136 of 256 DISCUSSION OF CHANGES ITS 5.5, PROGRAMS AND MANUALS 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 6.8.4.a specifies the requirements for the Radioactive Effluent Controls Program, however there is no statement as to whether or not the provisions of CTS 4.0.2 and CTS 4.0.3 are applicable. ITS 5.5.3 states that the provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Radioactive Effluent Controls Program Surveillance Frequencies. This changes the CTS by adding the allowances of ITS SR 3.0.2 and SR 3.0.3 to the Radioactive Effluent Controls Program.

This statement is needed to maintain allowances for Surveillance Frequency extensions contained in the ITS since ITS SR 3.0.2 and SR 3.0.3 are not normally applied to Frequencies identified in the Administrative Controls Chapter of the ITS. In addition, prior to Amendments 189 (Unit 1) and 175 (Unit 2), dated February 10, 1995, these requirements were located in the LCO sections of the Technical Specifications. Amendments 189 (Unit 1) and 175 (Unit 2) relocated the Radiological Effluents Technical Specification from the Technical Specifications to other plant controlled documents, and added CTS 6.8.4.a to the CTS. Since this change is a clarification required to maintain provisions that would be allowed in the LCO sections of the Technical Specifications, it is considered administrative in nature. This change is designated as administrative because it does not result in technical changes to the CTS.

A.3 CTS 4.0.5.b does not include all of the required Surveillance Frequencies for performing inservice testing activities. ITS 5.5.6.a adds a new required Frequency of "Biennially or every 2 years." This changes the CTS by adding a new Frequency to the required Frequencies for performing inservice testing activities.

This change is acceptable because the change does not include any new requirements, but only provides clarification of required Frequencies for performing inservice testing activities. Therefore, this change is considered administrative. This change is designated as administrative because it does not result in technical changes to the CTS.

A.4 CTS 4.0.5.d states that the performance of the above testing activities shall be in addition to other specified Surveillance Requirements. ITS 5.5.6 does not include a similar statement. This changes the CTS by deleting the statement.

CTS 4.0.5.d restates that all applicable requirements must be met. Repeating this overall requirement as a specific detail is redundant and unnecessary.

Therefore, this detail can be omitted without any technical change in the CNP Units 1 and 2 Page 1 of 16 Attachment 1, Volume 16, Rev. 0, Page 136 of 256

Attachment 1, Volume 16, Rev. 0, Page 137 of 256 DISCUSSION OF CHANGES ITS 5.5, PROGRAMS AND MANUALS requirements and is considered administrative in nature. This change is designated as administrative because it does not result in technical changes to the CTS.

A.5 CTS 4.0.5 specifies the requirements for the Inservice Testing Program, however there is no statement whether the provisions of CTS 4.0.3 are applicable.

ITS 5.5.6.c states that the provisions of SR 3.0.3 are applicable to the inservice testing activities. This changes the CTS by adding the allowances of ITS SR 3.0.3 to the Technical Specification Inservice Testing Program requirements.

This statement is needed to maintain allowances for Surveillance Frequency extensions contained in the ITS since ITS SR 3.0.3 is not normally applied to Frequencies identified in the Administrative Controls Chapter of the ITS. Since this change is a clarification required to maintain provisions that would be allowed in the LCO sections of the Technical Specifications, it is considered administrative in nature. This change is designated as administrative because it does not result in a technical change to the CTS.

A.6 CTS 4.4.5.1, 4.4.5.2, 4.4.5.3, and 4.4.5.4, including Table 4.4-1 and 4.4-2, specify the requirements for the steam generator tube surveillance testing activities. In the ITS, these requirements are included as ITS 5.5.7, "Steam Generator (SG) Program," and a generic statement describing the program has been included. In addition, a statement has been added which states that the provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Steam Generator Program test Frequencies. This changes the CTS by adding a generic description of the program and specifically stating that the allowances of ITS SR 3.0.2 and SR 3.0.3 are applicable to the Steam Generator Program.

The ITS SR 3.0.2 and SR 3.0.3 statement is needed to maintain allowances for Surveillance Frequency extensions contained in the ITS since ITS SR 3.0.2 and SR 3.0.3 are not normally applied to Frequencies identified in the Administrative Controls Chapter of the ITS. Since this change is a clarification required to maintain provisions that are allowed in the CTS (since CTS 4.0.2 and CTS 4.0.3 apply to the Surveillances of CTS 3/4.4.5), it is considered acceptable. In addition, the generic statement describing the program is also acceptable. This change is designated as administrative because it does not result in technical changes to the CTS.

A.7 CTS 4.6.1.2 requires the performance of containment leakage rate testing in accordance with 10 CFR 50 Appendix J Option B, except as modified by NRC-approved exemptions, and Regulatory Guide 1.1.63, dated September 1995.

CTS 4.6.1.2 is also modified by two exceptions. CTS 4.6.1.2.b states that the requirements of Specification 4.0.2 are not applicable. CTS 4.6.1.3.a contains a requirement to perform air lock testing in accordance with 10 CFR 50 Appendix J Option B and Regulatory Guide 1.163, dated September 1995. ITS 5.5.14.a requires a program to establish the leakage rate testing of the containment as required by 10 CFR 50.54(o) and 10 CFR 50, Appendix J, Option B, as modified by approved exemptions. This program shall be in accordance with the guidelines contained in Regulatory Guide 1.163, "Performance-Based Containment Leak-Test Program," dated September, 1995, as modified by the listed exceptions. ITS 5.5.14.e states that the provision of SR 3.0.3 are CNP Units 1 and 2 Page 2 of 16 Attachment 1, Volume 16, Rev. 0, Page 137 of 256

Attachment 1, Volume 16, Rev. 0, Page 138 of 256 DISCUSSION OF CHANGES ITS 5.5, PROGRAMS AND MANUALS applicable to the Containment Leakage Rate Testing Program. This changes the CTS by including the requirements of CTS 4.6.1.2 and 4.6.1.3 in a program, adding the statement that the provisions of SR 3.0.3 are applicable to the Containment Leakage Rate Testing Program, and deleting the statement that the provisions of Specification 4.0.2 are not applicable.

This change is acceptable because no changes have been made to the existing requirements. The CTS and proposed ITS 5.5.14 continue to require the same testing to be performed. The statement associated with CTS 4.0.2 is not needed since the Frequency extensions of ITS SR 3.0.2 are not applied to Frequencies identified in the Administrative Controls Section of the ITS, unless specifically identified. The statement associated with ITS SR 3.0.3 is needed to maintain allowances for Surveillance Frequency extensions contained in the ITS since ITS SR 3.0.2 and SR 3.0.3 are not applied to Frequencies identified in the Administrative Controls Chapter of the ITS, unless specifically identified. Since these changes are clarifications required to maintain provisions that would be allowed in the LCO sections of the Technical Specifications, it is considered administrative in nature. This change is designated as administrative because it does not result in technical changes to the CTS.

A.8 CTS 4.7.5.1.c, 4.7.6.1.b, and 4.9.12.b require the performance of ventilation filter testing "following painting, fire, or chemical release in any ventilation zone communicating with the system." ITS 5.5.9 requires the performance of the same ventilation filter testing "following painting, fire, or chemical release in any ventilation zone communicating with the system while it is in operation that could adversely affect the filter bank or charcoal adsorber capability." This changes the CTS by requiring the filter testing to be performed only if the associated system was in operation and the painting, fire, or chemical release is considered significant enough to adversely affect the filter bank or charcoal adsorber capability.

The purpose of ITS 5.5.9 is to ensure that ventilation filter testing is only performed when there is a potential adverse impact on the affected filter. Current CNP practice is that not all painting, fire, or chemical release results in the need to perform certain ventilation filter tests. Only painting, fire, or chemical release that could affect the functional capability of the ventilation filter trains (i.e., that are significant) would require performance of the tests. The words "that could adversely affect the filter bank or charcoal adsorber capability" were added for clarity and consistency with current practice to avoid a misinterpretation that any painting, fire, or chemical release (such as using a small can of paint to do touch-up work) would result in the need to perform the tests. Similarly, the wording "while it is in operation" was added to clarify that this is the time when the painting, fire, or chemical release could be communicating with the system. This clarification is administrative, and is consistent with other ITS submittals. In addition, the NRC in a letter to Entergy Operations, Inc., dated September 11, 1997, supported the clarification that not all painting, fires, or chemical releases required the filter trains to be tested. Furthermore, this clarification is also consistent with Regulatory Guide 1.52, Revision 3. This change is designated as administrative because it does not result in technical changes to the CTS.

CNP Units 1 and 2 Page 3 of 16 Attachment 1, Volume 16, Rev. 0, Page 138 of 256

Attachment 1, Volume 16, Rev. 0, Page 139 of 256 DISCUSSION OF CHANGES ITS 5.5, PROGRAMS AND MANUALS A.9 The Surveillances (CTS 4.7.5.1.c, 4.7.5.1.d, 4.7.5.1.e.1, 4.7.5.1.f, and 4.7.5.1.g) associated with the ventilation filter testing for the Control Room Emergency Ventilation (CREV) System, the Surveillances (CTS 4.7.6.1.b, 4.7.6.1.c, 4.7.6.1.d.1, 4.7.6.1.e, and 4.7.6.1.f) associated with the ventilation filter testing for the Engineered Safety Features (ESF) Ventilation System, and the Surveillances (CTS 4.9.12.b, 4.9.12.c, 4.9.12.d.1, 4.9.12.e, and 4.9.12.f) associated with the filter testing for the Fuel Handling Area Exhaust Ventilation (FHAEV) System have been placed in a program in the proposed Administrative Controls Chapter 5.0 (ITS 5.5.9). As such, a general program statement has been added as ITS 5.5.9. Also, a statement of the applicability of ITS SR 3.0.2 and SR 3.0.3 is needed to clarify that the allowances for Surveillance Frequency extension do apply. This changes the CTS by moving the ventilation filter testing Surveillances associated with the CREV, ESF Ventilation, and FHAEV Systems to a program in ITS 5.5 and specifically stating the applicability of ITS SR 3.0.2 and SR 3.0.3 in the program.

The addition of the program statement is acceptable because it is describing the intent of the CTS Surveillances. The addition of the ITS SR 3.0.2 and SR 3.0.3 statement is a clarification needed to maintain provisions that are currently allowed in the LCO and SR sections of the CTS, therefore it is considered acceptable. This change is designated as administrative because it does not result in technical changes to the CTS.

A.10 The Surveillances associated with diesel fuel oil testing (CTS 4.8.1.1.2.c and d) have been placed in a program in the proposed Administrative Controls Chapter 5.0 (ITS 5.5.11). As such, a general program statement has been added as ITS 5.5.11. Also, a statement of the applicability of ITS SR 3.0.2 and SR 3.0.3 is needed to clarify that the allowances for Surveillance Frequency extension do apply. This changes the CTS by moving the diesel fuel oil testing Surveillances to a program in ITS 5.5 and specifically stating the applicability of ITS SR 3.0.2 and SR 3.0.3 in the program.

The addition of the program statement is acceptable because it is describing the intent of the CTS Surveillances. The addition of the ITS SR 3.0.2 and SR 3.0.3 statement is a clarification needed to maintain provisions that are currently allowed in the LCO and SR sections of the CTS, therefore it is considered acceptable. This change is designated as administrative because it does not result in technical changes to the CTS.

A.11 The liquid holdup tank requirements in CTS 3/4.11.1, the explosive gas mixture requirements in CTS 3/4.11.2.1, and the gas storage tank requirements in CTS 3/4.11.2.2 have been placed in a program in the proposed Administrative Controls Chapter 5.0 (ITS 5.5.10). As such, a general program statement has been added. Also, a statement of applicability of ITS SR 3.0.2 and SR 3.0.3 is needed to clarify that the allowances for Surveillance Frequency extensions do apply. This changes the CTS by moving the liquid holdup tank, explosive gas mixture, and gas storage tank requirements to a program in ITS 5.5.10 and specifically stating the applicability of ITS SR 3.0.2 and SR 3.0.3 in the program.

The addition of the program statement is acceptable because it is describing the intent of the CTS Specifications. The addition of the ITS SR 3.0.2 and SR 3.0.3 CNP Units 1 and 2 Page 4 of 16 Attachment 1, Volume 16, Rev. 0, Page 139 of 256

Attachment 1, Volume 16, Rev. 0, Page 140 of 256 DISCUSSION OF CHANGES ITS 5.5, PROGRAMS AND MANUALS statement is a clarification needed to maintain provisions that are currently allowed in the LCO and SR sections of the CTS, therefore it is considered acceptable. This change is designated as administrative because it does not result in technical changes to the CTS.

A.12 CTS 6.8.1.g requires written procedures to be established, implemented and maintained covering the activities of the component cyclic or transient limits program, which provides controls to track the UFSAR Section 4.1, cyclic and transient occurrences to ensure that components are maintained within the limits.

ITS 5.5.4 requires a program to track the UFSAR, Section 4.1 cyclic and transient occurrences to ensure that components are maintained within the design limits. This changes the CTS by placing the requirements of the Component Cyclic or Transient Limits Program currently located in the procedure section of the CTS Administration Controls Chapter into the Program section of the ITS Administrative Controls Chapter.

One purpose of CTS 6.8.1.g is to ensure that there is a program to track the UFSAR, Section 4.1 cyclic and transient occurrences to ensure that components are maintained within the design limits. Since this change is a clarification that CTS 6.8.1.g also requires a program to be established, it is considered acceptable. This change is designated as administrative because it does not result in technical changes to the CTS.

A.13 CTS 4.4.10.1 requires the inspection of each reactor coolant pump flywheel.

ITS 5.5.5 requires a program to provide for the inspection of each reactor coolant pump flywheel. In addition, a statement has been added which states the provisions of ITS SR 3.0.2 and SR 3.0.3 are applicable to the Reactor Coolant Pump Flywheel Inspection Program Surveillance Frequency. This changes the CTS by including the requirements of CTS 4.4.10.1 in a program in the Administrative Controls Chapter of the Technical Specifications instead of as a Surveillance and specifically stating that the allowances of ITS SR 3.0.2 and SR 3.0.3 are applicable to the Reactor Coolant Pump Flywheel Inspection Program Surveillance Frequency. Other changes to 3/4.4.10.1 is discussed in the Discussion of Changes for CTS 3/4.4.10.1.

This change is acceptable because no changes have been made to the existing requirements. The CTS and proposed ITS 5.5.5 continue to require the same reactor coolant pump flywheel inspections to be performed. The ITS SR 3.0.2 and SR 3.0.3 statement is needed to maintain allowances for Surveillance Frequency extensions contained in the CTS because ITS SR 3.0.2 and SR 3.0.3 are not normally applied to Frequencies identified in the Administrative Controls Chapter of the ITS. Since this change is a clarification required to maintain provisions that are allowed in the CTS (since CTS 4.0.2 and CTS 4.0.3 apply to the Surveillances of CTS 3/4.4.10), it is considered acceptable. This change is designated as administrative because it does not result in technical changes to the CTS.

A.14 (Unit 1 only) CTS 4.4.5.4.a does not contain a definition for Preservice Inspection. ITS 5.5.7.d.1.i) includes the definition. This changes the Unit 1 CTS by adding a definition for Preservice Inspection.

CNP Units 1 and 2 Page 5 of 16 Attachment 1, Volume 16, Rev. 0, Page 140 of 256

Attachment 1, Volume 16, Rev. 0, Page 141 of 256 DISCUSSION OF CHANGES ITS 5.5, PROGRAMS AND MANUALS CTS 4.4.5.2.b, 4.4.5.3.a, and Table 4.4-1 (ITS 5.5.7.a.2, ITS 5.5.7.e.1, and ITS Table 5.5.7-1) refer to a preservice inspection. This proposed change is acceptable because the definition is consistent with the definition for preservice inspection in CTS 4.4.5.4.a.9 for Unit 2, and because ITS 5.5.7.a.2, 5.5.7.e.1, and Table 5.5.7-1 continue to refer to the preservice inspections. This change is designated as administrative because it does not result in technical changes to the CTS.

A.15 CTS 4.0.5 requires pump and valve testing per the requirements of Section XI of the ASME Boiler and Pressure Vessel Code. ITS 5.5.6 requires pump and valve testing per the requirements of the ASME Operation and Maintenance Standards and Guides (OM Codes). This changes the CTS by referring to the ASME OM Codes instead of ASME Boiler and Pressure Code,Section XI.

In the 1987 Addenda to the 1986 edition of ASME Boiler and Pressure Vessel Code,Section XI, the requirements for Inservice Testing were removed and relocated to the ASME/ANSI OM Codes. This change was endorsed in 10CFR50.55a. 10CFR50.55a(f) now addresses the requirements for inservice testing using the ASME/ANSI OM Codes and 10CFR50.55a(g) addresses the requirements for inservice inspection using ASME Boiler and Pressure Vessel Code,Section XI. The ITS has been revised to incorporate the current Code requirements. In addition, the terms weekly, monthly, and semiannually are not used in the applicable ASME/ANSI OM Codes. Therefore, these Frequencies have been deleted. This change is designated as administrative because it does not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES M.1 License Conditions 2.H (Unit 1) and 2.G (Unit 2) provide the requirements for a System Integrity program. The program is not explicit as to which systems outside containment must be monitored. ITS 5.5.2 includes the requirements for the Leakage Monitoring Program and provides a list of systems that should be monitored because they could contain highly radioactive fluids during a serious transient or accident.

The purpose of the Leakage Monitoring Program is to minimize leakage from those portions of systems outside containment that could contain highly radioactive fluids during a serious transient or accident to levels as low as practicable. The systems added to the Specification include the Safety Injection System, Chemical and Volume Control System, Residual Heat Removal System, Containment Spray System, post accident sampling, and the boron injection tank injection flowpath of the Centrifugal Charging System. The change is acceptable because these systems are currently monitored to satisfy the current License Conditions and is a complete list of those systems that could contain highly radioactive fluids during a serious transient or accident. This change is designated as more restrictive because it adds an explicit list of systems to the Technical Specifications.

M.2 The CTS does not include program requirements for a Technical Specification Bases Control Program, Safety Function Determination Program, or Battery CNP Units 1 and 2 Page 6 of 16 Attachment 1, Volume 16, Rev. 0, Page 141 of 256

Attachment 1, Volume 16, Rev. 0, Page 142 of 256 DISCUSSION OF CHANGES ITS 5.5, PROGRAMS AND MANUALS Monitoring and Maintenance Program. The ITS includes programs for these activities. This changes the CTS be adding the following programs:

ITS 5.5.12, "Technical Specifications (TS) Bases Control Program";

ITS 5.5.13, "Safety Function Determination Program (SFDP)"; and ITS 5.5.15, "Battery Monitoring and Maintenance Program."

The TS Bases Control Program is provided to specifically delineate the appropriate methods and reviews necessary for a change to the Technical Specification Bases. The Safety Function Determination Program is included to support implementation of the support system OPERABILITY characteristics of the Technical Specifications. The Battery Monitoring and Maintenance Program is included to provide for battery restoration and maintenance. The specific wording associated with these three programs may be found in ITS 5.5.12, ITS 5.5.13, and ITS 5.5.15. The changes are acceptable because they support implementation of the requirements of the ITS and the UFSAR. This change is designated as more restrictive because it imposes additional programmatic requirements in the Technical Specifications.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 6 - Removal of LCO, SR, or other TS requirement to the TRM, UFSAR, ODCM, QAPD, or IIP) CTS 6.8.4.b, "Radiological Environmental Monitoring Program," describes a program to monitor the radiation and radionuclides in the environs of the plant. ITS Chapter 5.0 does not require such a program. This changes the CTS by moving the requirements for the Radiological Environmental Monitoring Program to the Offsite Dose Calculation Manual (ODCM).

The purpose of CTS 6.8.4.b is to provide representative measurements of radioactivity in the highest potential exposure pathways, and verification of the accuracy of the effluent monitoring program and modeling of environmental exposure pathways. The removal of the requirement for this program from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. ITS 5.6.2 still requires an annual report of the results of the "Radiological Environmental Monitoring Program." Also, this change is acceptable because these types of procedural details will be adequately controlled in the ODCM. Changes to the ODCM are controlled by the ODCM change control process in ITS 5.5.1, which ensures changes are properly evaluated. This change is designated as a less restrictive removal of requirement change because the requirements for a program are being removed from the Technical Specifications.

CNP Units 1 and 2 Page 7 of 16 Attachment 1, Volume 16, Rev. 0, Page 142 of 256

Attachment 1, Volume 16, Rev. 0, Page 143 of 256 DISCUSSION OF CHANGES ITS 5.5, PROGRAMS AND MANUALS LA.2 (Type 6 - Removal of LCO, SR, or other TS requirement to the TRM, UFSAR, ODCM, QAPD, or IIP) Operating License Conditions 2.I (Unit 1) and 2.H (Unit 2) specify that the Iodine Monitoring Program shall be implemented and provides a description of what the program shall include. ITS 5.5 does not include this program. This changes the CTS by moving the details of the Iodine Monitoring Program to the Technical Requirements Manual (TRM).

The removal of this requirement from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. This program is required by the CNP Units 1 and 2 commitment to NUREG-0578, Item 2.1.8.c, as stated in a letter from R.S. Hunter (AEP) to Harold R. Denton (NRC) dated December 10, 1980. The program is designed to minimize radiation exposure to plant personnel in vital areas of the plant after an accident, and has no impact on nuclear safety or the health and safety of the public. The training aspect of the program is accomplished as part of the continual training program for personnel in the cognizant organizations, as well as during training for those individuals responsible for implementing the radiological emergency planning procedures. Provisions for monitoring and performing maintenance of the sampling and analysis equipment are addressed in chemistry and radiation protection procedures. This change is acceptable because the program requirements will be adequately controlled in the TRM. 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 requirement change because requirements are being removed from the Technical Specifications.

LA.3 (Type 6 - Removal of LCO, SR, or other TS requirement to the TRM, UFSAR, ODCM, QAPD, or IIP) CTS 4.0.5 provides requirements for the Inservice Inspection Program. The ITS does not include Inservice Inspection Program requirements. In addition, since the Inservice Testing Program is the only requirement remaining, the reference to ASME Code Class 1, 2, and 3 "components" has been changed to "pumps and valves" for clarity. Pumps and valves are the only components related to the Inservice Testing Program (as described in CTS 4.0.5.a). This changes the CTS by moving these requirements from the Technical Specifications to the Inservice Inspection Program (IIP).

The removal of these requirements 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 Technical Specifications still retain requirements for the affected components to be OPERABLE. Also, this change is acceptable because these requirements will be adequately controlled by the IIP, which is required by 10 CFR 50.55a.

Compliance with 10 CFR 50.55a is required by the CNP Units 1 and 2 Operating Licenses. This change is designated as a less restrictive removal of requirement change because requirements are being removed from the Technical Specifications.

LA.4 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 4.0.5.a specifies that the Inservice Testing of ASME Code Class 1, 2, and 3 pumps and valves shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and CNP Units 1 and 2 Page 8 of 16 Attachment 1, Volume 16, Rev. 0, Page 143 of 256

Attachment 1, Volume 16, Rev. 0, Page 144 of 256 DISCUSSION OF CHANGES ITS 5.5, PROGRAMS AND MANUALS applicable Addenda as required by 10 CFR 50, Section 50.55a. ITS 5.5.6 states that the Inservice Testing Program provides controls for inservice testing of ASME Code Class 1, 2, and 3 pumps and valves. This changes the CTS by moving these procedural details from the Technical Specifications to the Inservice Testing Program.

The removal of these details for meeting Technical Specification requirements from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains requirements for the control for inservice testing of ASME Code Class 1, 2, and 3 pumps and valves. Also, this change is acceptable because these types of details will be adequately controlled in the plant controlled Inservice Testing Program. Changes to the Inservice Testing Program will be controlled by the provisions of 10 CFR 50.55a. This change is designated as a less restrictive removal of detail change because the details for meeting Technical Specification requirements are being removed from the Technical Specifications.

LA.5 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 4.7.5.1.c.3, 4.7.5.1.d.1, 4.7.5.1.d.2, 4.7.6.1.b.4, 4.7.6.1.c.1, 4.7.6.1.c.2, 4.9.12.b.4, 4.9.12.c.1, and 4.9.12.c.2 require that within 31 days after removal of a carbon sample the laboratory analysis results are shown to be within limit. ITS 5.5.9.c requires the same analysis to be performed however the detail of "within 31 days after removal of a carbon sample" is not included. This changes the CTS by moving these procedural details from the Technical Specifications to the Technical Requirements Manual (TRM).

The removal of these details for performing Surveillance Requirements from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement to perform the testing at the appropriate Frequencies. Also, this change is acceptable because these types of procedural details will be adequately controlled in the TRM. 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 procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications.

LA.6 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 4.8.1.1.2.c, 4.8.1.1.2.c.1), 4.8.1.1.2.c.1)a),

4.8.1.1.2.c.1)b), 4.8.1.1.2.c.2), 4.8.1.1.2.c.3), 4.8.1.1.2.c.4), and 4.8.1.1.2.d specify test and sampling requirements for new diesel fuel oil and diesel fuel oil in the storage tanks in accordance with certain ASTM standards (i.e., D4057-81, D975-81, D1298-80, D4176-82, D2622-82, and D2276-83) and provide limits for kinematic viscosity, flash point, API gravity, absolute specific gravity, and specific gravity. ITS 5.5.11 does not include either the explicit reference to the ASTM standards or the specific limits, but continues to require the verification that the new and stored diesel fuel oil is tested in accordance with the applicable standards and that the parameters are within limits. This changes the CTS by CNP Units 1 and 2 Page 9 of 16 Attachment 1, Volume 16, Rev. 0, Page 144 of 256

Attachment 1, Volume 16, Rev. 0, Page 145 of 256 DISCUSSION OF CHANGES ITS 5.5, PROGRAMS AND MANUALS moving the procedural details on the testing requirements and the specific limits to the Bases of ITS 3.8.3.

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

LA.7 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 3/4.11.1 includes the details for implementing the requirements for the liquid holdup tank. CTS 3/4.11.2.1 includes the details for implementing the requirements for the explosive gas mixture. CTS 3/4.11.2.2 includes the details for implementing the requirements for the gas storage tank.

The details for implementing these requirements, including the specific limits, are not included in the ITS. The ITS only includes a requirement to maintain a program for these requirements. This changes the CTS by moving these procedural details for implementing the requirements, including the specific limits, from the Technical Specifications to the Technical Requirements Manual (TRM).

The removal of these details for the specific limits, Applicability, Actions, and Surveillance Requirements from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety.

ITS 5.5.10 still retains the requirement to include a program, which provides controls for potentially explosive gas mixtures contained in the Waste Gas Holdup System, the quantity of radioactivity contained in gas storage tanks, and the quantity of radioactivity contained in unprotected outdoor temporary liquid storage tanks. Also, this change is acceptable because these types of procedural details will be adequately controlled in the TRM. 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 procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications.

LA.8 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 6.14.1.a requires changes to the ODCM to be documented and records of reviews performed to be retained as required by the Quality Assurance Program Description, Appendix C, Section 6.10.2.n.

CTS 6.14.1.b requires changes to the ODCM to be effective after review and acceptance by the PORC and the approval of the plant manager. ITS 5.5.1.c.1 requires changes to the ODCM to be documented and records of reviews performed to be retained. ITS 5.5.1.c.2 requires changes to the ODCM to become effective after the approval of the plant manager. This changes the CTS CNP Units 1 and 2 Page 10 of 16 Attachment 1, Volume 16, Rev. 0, Page 145 of 256

Attachment 1, Volume 16, Rev. 0, Page 146 of 256 DISCUSSION OF CHANGES ITS 5.5, PROGRAMS AND MANUALS by moving the record retention requirement reference and the PORC review and approval requirement to the Quality Assurance Program Description (QAPD).

The removal of these details, which are related to meeting Technical Specification requirements, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety.

ITS 5.5.1 still retains the requirement for changes to the ODCM. Also, this change is acceptable because these types of procedural details will be adequately controlled in the QAPD. Any changes to the QAPD are made under 10 CFR 50.54(a), which ensures changes are properly evaluated. This change is designated as a less restrictive removal of detail change because procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications.

LA.9 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 6.14.1.b uses the title "Plant Manager."

ITS 5.5.1.c.2 uses the generic title "plant manager." This changes the CTS by moving the specific CNP organizational title to the UFSAR and replacing it with a generic title.

The removal of these details, which are related to meeting Technical Specification requirements, from the Technical Specifications is acceptable because this type of information is not necessary to be included in Technical Specifications to provide adequate protection of public health and safety. The allowance to relocate the specific CNP organizational title out of the Technical Specifications is consistent with the NRC letter from C. Grimes to the Owners Groups Technical Specification Committee Chairmen, dated November 10, 1994.

The various requirements of the plant manager are still retained in the ITS. Also, this change is acceptable because the removed information will be adequately controlled in the UFSAR. Any changes to the UFSAR are made under 10 CFR 50.59 or 10 CFR 50.71(e), which ensures changes are properly evaluated. This change is designated as a less restrictive removal of detail change because information related to meeting Technical Specification requirements are being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L.1 (Category 10 - 18 to 24 Month Surveillance Frequency Change, Non-Channel Calibration Type) License Conditions 2.H (Unit 1) and 2.G (Unit 2) specify that the integrated leak test requirements for each system outside containment that would or could contain highly radioactive fluids during a serious transient or accident must be performed at a frequency not to exceed refueling cycle intervals. ITS 5.5.2 specifies that the same test must be performed at least once per 24 months and an allowance has been added which states that the provisions of ITS SR 3.0.2 are applicable. This changes the CTS by extending the Frequency of the Surveillance from 18 months (i.e., the current CNP normal refueling cycle interval) to 24 months (i.e., a maximum of 30 months accounting for the allowable grace period specified in ITS SR 3.0.2).

CNP Units 1 and 2 Page 11 of 16 Attachment 1, Volume 16, Rev. 0, Page 146 of 256

Attachment 1, Volume 16, Rev. 0, Page 147 of 256 DISCUSSION OF CHANGES ITS 5.5, PROGRAMS AND MANUALS The purpose of License Conditions 2.H (Unit 1) and 2.G (Unit 2) is to ensure the leakage from systems outside containment that would or could contain highly radioactive fluids during a serious transient or accident is reduced to as low as practicable levels. This change was evaluated in accordance with the guidance provided in NRC Generic Letter No. 91-04, "Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel Cycle," dated April 2, 1991. Reviews of historical surveillance data and maintenance data sufficient to determine failure modes have shown that these tests normally pass their Surveillances at the current Frequency. An evaluation has been performed using this data, and it has been determined that the effect on safety due to the extended Surveillance Frequency will be minimal. Extending the Surveillance test interval for the System Integrity integrated leak test verification SR is acceptable because most portions of the subject systems included in this program are visually walked down, while the plant is operating, during plant testing, and/or operator/system engineer walkdowns. In addition, housekeeping/safety walkdowns also serve to detect any gross leakage. If leakage is observed from these systems, corrective actions will be taken to repair the leakage. Finally, the plant radiological surveys will also identify any potential sources of leakage. These visual walkdowns and surveys provide monitoring of the systems at a greater frequency than once per refueling cycle, and support the conclusion that the impact, if any, on safety is minimal as a result of the proposed changes. Based on the inherent system and component reliability and the testing performed during the operating cycle, the impact, if any, from this change on system availability is minimal. The review of historical surveillance data also demonstrated that there are no failures that would invalidate this conclusion. In addition, the proposed 24 month Surveillance Frequency, if performed at the maximum interval allowed by ITS SR 3.0.2 (30 months) does not invalidate any assumptions in the plant licensing basis. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

L.2 (Category 1 - Relaxation of LCO Requirements) CTS 3.6.1.2.a specifies that the overall integrated leakage rate shall be limited to < La. CTS 3.6.1.2.b specifies that combined leakage rate shall be limited to < 0.60 La for all penetrations and valves subject to Types B and C tests. However, the CTS 3.6.1.2 Action does not allow the unit to increase Reactor Coolant System temperature above 200°F if either the measured overall integrated leakage rate exceeds 0.75 La or if the measured combined leakage rate for all penetrations and valves subject to Type B and C tests exceeds 0.60 La. ITS 5.5.14 specifies that the containment leakage rate acceptance criterion is 1.0 La and that during the first unit startup following testing in accordance with this program, the leakage rate acceptance criteria are < 0.60 La for the Type B and C tests and < 0.75 La for Type A tests.

This changes the CTS by only requiring the 0.60 La and 0.75 La limits to be met during the first unit startup following testing in accordance with the Containment Leakage Rate Testing Program.

The purpose of ITS 5.5.14 is to ensure the appropriate limits are specified for the Containment Leakage Rate Testing Program. This change is acceptable because the acceptance limits continue to ensure the containment leakage is within the value assumed in the accident analysis. Currently, the overall integrated leakage rate of < La and the combined leakage rate of < 0.6 La applies CNP Units 1 and 2 Page 12 of 16 Attachment 1, Volume 16, Rev. 0, Page 147 of 256

Attachment 1, Volume 16, Rev. 0, Page 148 of 256 DISCUSSION OF CHANGES ITS 5.5, PROGRAMS AND MANUALS in MODES 1, 2, 3, and 4. The CTS 3.6.1.2 Action will not allow the unit to enter MODE 4 from MODE 5 unless the integrated leakage rate is < 0.75 La and the combined leakage rate for all penetrations and valves subject to Types B and C tests is < 0.60 La. In the ITS, the containment leakage rate acceptance criterion is < 1.0 La and is applicable in MODES 1, 2, 3, and 4. The other limits (i.e.,

< 0.60 La and < 0.75 La) are only applicable during the first unit startup following testing in accordance with this program. This will allow subsequent unit startups (after the first unit startup following testing in accordance with the program) to proceed as long as the containment leakage rate acceptance criterion of < 1.0 La is met. This is acceptable because the leakage limit of La is assumed in the accident analysis. This change is designated as less restrictive because less stringent LCO requirements are being applied in the ITS than were applied in the CTS.

L.3 (Category 10 - 18 to 24 Month Surveillance Frequency Change, Non-Channel Calibration Type) CTS 4.7.5.1.c, 4.7.5.1.e.1, 4.7.6.1.b, 4.7.6.1.d.1, 4.9.12.b, and 4.9.12.d.1 require the performance of ventilation filter testing once per 18 months. ITS 5.5.9 requires these same Surveillances to be performed once per 24 months. This changes the CTS by extending the Frequency of the Surveillance from 18 months (i.e., a maximum of 22.5 months accounting for the allowable grace period specified in CTS 4.0.2 and ITS SR 3.0.2) to 24 months (i.e., a maximum of 30 months accounting for the allowable grace period specified in CTS 4.0.2 and ITS SR 3.0.2).

The purpose of CTS 4.7.5.1.c, 4.7.5.1.e.1, 4.7.6.1.b, 4.7.6.1.d.1, 4.9.12.b, and 4.9.12.d.1 is to ensure that the Control Room Emergency Ventilation (CREV)

System, the Engineered Safety Features (ESF) Ventilation System, and the Fuel Handling Area Exhaust Ventilation (FHAEV) System charcoal adsorbers and HEPA filters can perform their safety function. This change was evaluated in accordance with the guidance provided in NRC Generic Letter No. 91-04, "Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel Cycle," dated April 2, 1991. Reviews of historical surveillance data and maintenance data sufficient to determine failure modes have shown that these tests normally pass their Surveillances at the current Frequency. An evaluation has been performed using this data, and it has been determined that the effect on safety due to the extended Surveillance Frequency will be minimal.

Extending the Surveillance test interval for the HEPA filter dioctyl phthalate (DOP) tests, the charcoal adsorber halogenated hydrocarbon refrigerant tests, the laboratory analysis test, and the flow test is acceptable since other tests may be required to be performed during the operating cycle. Tests described in ITS 5.5.9.a (the HEPA filter test) and 5.5.9.b (the charcoal adsorber halogenated hydrocarbon), shall be performed once per 24 months; after each complete or partial replacement of the HEPA filter bank or charcoal adsorber bank; subsequent to reinstalling the adsorber tray used for obtaining the carbon sample, after any structural maintenance on the HEPA filter bank or charcoal adsorber bank housing; and, following painting, fire, or chemical release in any ventilation zone communicating with the subsystem while it is in operation that could adversely affect the filter bank or charcoal adsorber capability. Tests described in ITS 5.5.9.c (laboratory test of the charcoal sample) shall be performed once per 24 months; after 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of adsorber operation, after any structural maintenance on the HEPA filter or charcoal adsorber bank housing; CNP Units 1 and 2 Page 13 of 16 Attachment 1, Volume 16, Rev. 0, Page 148 of 256

Attachment 1, Volume 16, Rev. 0, Page 149 of 256 DISCUSSION OF CHANGES ITS 5.5, PROGRAMS AND MANUALS and, following painting, fire, or chemical release in any ventilation zone communicating with the subsystem while it is in operation that could adversely affect the filter bank or charcoal adsorber capability. The additional Surveillance Frequencies are adequate to ensure the filters remain OPERABLE during the cycle. Tests described in ITS 5.5.9.d (combined pressure drop across the combined HEPA filter and charcoal adsorbers) shall be performed once per 24 months. The CREV, ESF Ventilation, and FHAEV Systems are required to be tested every 184 days for > 15 minutes. This testing ensures that a significant portion of the associated ventilation system is operating properly and will detect significant failures. Based on the inherent system and component reliability and the testing performed during the operating cycle, the impact, if any, from this change on system availability is minimal. The review of historical surveillance data also demonstrated that there are no failures that would invalidate this conclusion. In addition, the proposed 24 month Surveillance Frequency, if performed at the maximum interval allowed by ITS SR 3.0.2 (30 months) does not invalidate any assumptions in the plant licensing basis. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

L.4 (Category 5 - Deletion of Surveillance Requirement) CTS 4.7.5.1.d.2 requires the performance of a halogenated hydrocarbon refrigerant gas test on the CREV System charcoal adsorber and a DOP test on the CREV System HEPA filter banks after the reinstallation of the adsorber tray used for obtaining a carbon sample. CTS 4.7.6.1.b.4 and 4.7.6.1.c.2 require the performance of a halogenated hydrocarbon refrigerant gas test on the ESF Ventilation System charcoal adsorber after the reinstallation of the adsorber tray used for obtaining a carbon sample. CTS 4.9.12.b.4 and 4.9.12.c.2 require the performance of a halogenated hydrocarbon refrigerant gas test on the FHAEV System charcoal adsorber after the reinstallation of the adsorber tray used for obtaining a carbon sample. ITS 5.5.9 does not contain these explicit post maintenance testing requirements. This changes the CTS by deleting these explicit post maintenance requirements.

The purpose of CTS 4.7.5.1.d.2, 4.7.6.1.b.4, 4.7.6.1.c.2, 4.9.12.b.4, and 4.9.12.c.2 is to verify the OPERABILITY of the ventilation filter trains after the reinstallation of the adsorber tray used for taking a carbon sample. This change is acceptable because the deleted Surveillance Requirements are not necessary to verify the equipment used to meet the LCO can perform its required function.

Thus, appropriate equipment continues to be tested in a manner and at a Frequency necessary to give confidence that the equipment can perform its assumed safety function. Any time the OPERABILITY of a system or component has been affected by repair, maintenance, modification, or replacement of a component, post maintenance testing is required to demonstrate the OPERABILITY of the system or component. This is described in the Bases for ITS SR 3.0.1 and required under ITS SR 3.0.1. The OPERABILITY requirements for the affected ventilation filter trains are described in the Bases for ITS 3.7.10, 3.7.12, and 3.7.13. In addition, the requirements of 10 CFR 50, Appendix B, Section XI (Test Control) provide adequate controls for test programs to ensure that testing incorporates applicable acceptance criteria. Compliance with 10 CFR 50, Appendix B is required under the Units 1 and 2 Operating Licenses.

As a result, post maintenance testing will continue to be performed and an CNP Units 1 and 2 Page 14 of 16 Attachment 1, Volume 16, Rev. 0, Page 149 of 256

Attachment 1, Volume 16, Rev. 0, Page 150 of 256 DISCUSSION OF CHANGES ITS 5.5, PROGRAMS AND MANUALS explicit requirement in the Technical Specifications is not necessary. In addition, ITS 5.5.9 requires the performance of ITS 5.5.9.a (a halogenated hydrocarbon refrigerant gas test on the charcoal adsorber) and ITS 5.5.9.b (a DOP test on the HEPA filter banks) after any structural maintenance on the HEPA filter bank or charcoal adsorber bank housing. Therefore, if after the reinstallation of the adsorber tray used for obtaining a carbon sample it is determined that ITS 5.5.9.a or 5.5.9.b are not met, the applicable ITS SRs must be declared not met and the appropriate Required Actions must be entered. Therefore, although the explicit Surveillance Frequency has been deleted, both ITS SR 3.0.1 and ITS 5.5.9 will require the performance of these tests if it is determined that the Surveillances may not be satisfied after reinstallation of the adsorber trays. This change is designated as less restrictive because Surveillances which are required in the CTS will not be required in the ITS.

L.5 (Category 7 - Relaxation Of Surveillance Frequency, Non-24 Month Type Change) CTS 4.8.1.1.2.c.4 requires the evaluation that certain diesel fuel oil properties are within the appropriate limits within 31 days of obtaining the sample. ITS 5.5.11.b requires this same evaluation to be performed within 31 days following addition of the new fuel oil to the storage tanks. This changes the CTS by changing the time by which the evaluation for these properties must be completed.

The purpose of ITS 5.5.11.b is to ensure that the properties of the new diesel fuel oil added to the storage tanks are acceptable. This change is acceptable because the new Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability. CTS 4.8.1.1.2.c.4 requires the evaluation that certain diesel fuel oil properties are within the appropriate limits within 31 days of obtaining the sample, while the ITS time limit begins after the fuel oil is added to the storage tanks. The new fuel oil can affect the stored fuel oil only when it is added to the storage tanks. Failure to meet the limit for these other fuel oil properties would not have an immediate effect on diesel generator operation because the oil added is normally only a small portion of the entire fuel oil storage volume. The 31 day period is also acceptable because the fuel oil properties of interest, even if they were not within stated limits, would not have an immediate effect on diesel generator operation. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

L.6 (Category 1 - Relaxation of LCO Requirements) Operating License Conditions 2.C.(7) (Unit 1) and 2.C.(3)(v) (Unit 2) specify that the Secondary Water Chemistry Monitoring Program shall be described in the station chemistry manual and provides a description of what the manual should contain. ITS 5.5.8 does not specify that the program must be described in the station chemistry manual. It only states what shall be included in the Secondary Water Chemistry Program. This changes the CTS by deleting the details of where the description of the Secondary Water Chemistry Program shall reside from the Technical Specifications.

The purpose of the Secondary Water Chemistry Program is to ensure proper controls are placed on monitoring secondary water chemistry in order to inhibit steam generator tube degradation. The change is acceptable because the CNP Units 1 and 2 Page 15 of 16 Attachment 1, Volume 16, Rev. 0, Page 150 of 256

Attachment 1, Volume 16, Rev. 0, Page 151 of 256 DISCUSSION OF CHANGES ITS 5.5, PROGRAMS AND MANUALS Technical Specifications still retain the requirement to have a Secondary Water Chemistry Program and the Technical Specifications continue to describe the contents of the program. Thus, the Technical Specifications continue to control the general content of the program and any changes will still require NRC approval. In addition, removal of this detail for meeting Technical Specification requirements (i.e., the actual location of the program) from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. This change is designated as less restrictive because less stringent Technical Specifications requirements are being applied in the ITS than were applied in the CTS.

CNP Units 1 and 2 Page 16 of 16 Attachment 1, Volume 16, Rev. 0, Page 151 of 256

Attachment 1, Volume 16, Rev. 0, Page 152 of 256 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

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Attachment 1, Volume 16, Rev. 0, Page 155 of 256 5.5 1

INSERT 1 Residual Heat Removal System, Containment Spray System, post accident sampling, and the boron injection tank injection flowpath of the Centrifugal Charging System Insert Page 5.5-2 Attachment 1, Volume 16, Rev. 0, Page 155 of 256

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Attachment 1, Volume 16, Rev. 0, Page 158 of 256 5.5 21 INSERT 1A The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Reactor Coolant Pump Flywheel Inspection Program Surveillance Frequency.

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Attachment 1, Volume 16, Rev. 0, Page 161 of 256 5.5 12 INSERT 2 This program provides requirements for steam generator tube sample selection and inspection. Each steam generator shall be determined OPERABLE during shutdown by selecting and inspecting at least the minimum number of steam generators specified in Table 5.5.7-1. The steam generator tube minimum sample size, inspection result classification, and the corresponding action required shall be as specified in Table 5.5.7-2. The inservice inspection of steam generator tubes shall be performed at the Frequencies specified in Specification 5.5.7.c and the inspected tubes shall be verified acceptable per the acceptance criteria of Specification 5.5.7.d.

a. The tubes selected for each inservice inspection shall include at least 3% of the total number of tubes in all steam generators. The tubes selected for these inspections shall be selected on a random basis except:

1. Where experience in similar plants with similar water chemistry indicates critical areas to be inspected, then at least 50% of the tubes inspected shall be from these critical areas;

2. The first sample of tubes selected for each inservice inspection (subsequent to the preservice inspection) of each steam generator shall include:

a) All nonplugged tubes that previously had detectable wall penetrations greater than or equal to 20%;

b) Tubes in those areas where experience has indicated potential problems; and c) A tube inspection pursuant to Specification 5.5.7.d.1.h) shall be performed on each selected tube. If any selected tube does not permit the passage of the eddy current probe for a tube inspection, this shall be recorded and an adjacent tube shall be selected and subjected to a tube inspection;

3. The tubes selected as the second and third samples (if required by Table 5.5.7-2) during each inservice inspection may be subjected to a partial tube inspection provided:

a) The tubes selected for these samples include the tubes from those areas of the tube sheet array where tubes with imperfections were previously found; and b) The inspections include those portions of the tubes where imperfections were previously found.

b. The results of each sample inspection shall be classified into one of the following three categories:

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Attachment 1, Volume 16, Rev. 0, Page 164 of 256 5.5 12 INSERT 2 (continued)

2. The steam generator shall be determined OPERABLE after completing the corresponding actions (plugging all tubes exceeding the plugging limit and all tubes containing through-wall cracks) required by Table 5.5.7-2.

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Attachment 1, Volume 16, Rev. 0, Page 165 of 256 5.5 12 INSERT 2A Table 5.5.7-1 (page 1 of 1)

Minimum Number of Steam Generators to be Inspected During Inservice Inspection Preservice Inspection Yes Number of Steam Generators per Unit 4 First Inservice Inspection 2 Second and Subsequent Inservice Inspections 1(a)

(a) The third and fourth steam generators not inspected during the first inservice inspection shall be inspected during the second and third inspections, respectively.

The fourth and subsequent inspections may be limited to one steam generator on a rotating schedule encompassing 3 N% of the tubes (where N is the number of steam generators in the plant) if the results of the first or previous inspections indicate that all steam generators are performing in a like manner. Note that under some circumstances, the operating conditions in one or more steam generators may be found to be more severe than those in other steam generators. Under such circumstances the sample sequence shall be modified to inspect the most severe conditions.

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Attachment 1, Volume 16, Rev. 0, Page 166 of 256 5.5 12 INSERT 2A (continued)

Table 5.5.7-2 (page 1 of 1)

Steam Generator (SG) Tube Inspection First Sample Inspection Second Sample Inspection Third Sample Inspection Sample Size Result Action Result Action Result Action Required Required Required A minimum of C-1 None NA NA NA NA S tubes per C-2 Plug defective C-1 None NA NA SG tubes and C-2 Plug defective C-1 None inspect tubes and C-2 Plug additional 2S inspect defective tubes in this additional 4S tubes SG tubes in this C-3 Perform SG action for C-3 result of first sample C-3 Perform action NA NA for C-3 result of first sample C-3 Inspect all All other None NA NA tubes in this SGs are C-SG, plug 1 defective Some SGs Perform action NA NA tubes, inspect are C-2, for C-2 result 2S tubes in but no for second each other additional sample SG, and notify SGs are NRC pursuant C-3 to Additional Inspect all NA NA Specification SG is C-3 tubes in each 5.6.7 SG, plug or repair defective tubes, and notify NRC pursuant to Specification

5.6.7 Where

S = 3 (N/n)%;

N is the number of SGs in the unit; and n is the number of SGs inspected during an inspection.

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Attachment 1, Volume 16, Rev. 0, Page 171 of 256 5.5 15 INSERT 6 ESF Ventilation Face Velocity Penetration (%) RH (%)

System (fpm)

CREV System NA 1 95 ESF Ventilation 45.5 5 95 System FHAEV System 46.8 5 95 In addition, the carbon samples not obtained from test canisters shall be prepared by either:

1. Emptying one entire bed from a removed adsorber tray, mixing the adsorbent thoroughly, and obtaining samples at least two inches in diameter and with a length equal to the thickness of the bed; or

2. Emptying a longitudinal sample from an adsorber tray, mixing the adsorbent thoroughly, and obtaining samples at least two inches in diameter and with a length equal to the thickness of the bed.

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Attachment 1, Volume 16, Rev. 0, Page 180 of 256 5.5 17 CTS INSERT 10 Unit 1 4.6.1.2 Note 2, Unit 2 4.6.1.2 Note 1 1. The Type A testing Frequency specified in NEI 94-01, Revision 0, Paragraph 9.2.3, as at least once per 10 years based on acceptable performance history is modified to be at least once per 15 years based on acceptable performance history. This change applies only to the interval following the Type A test performed in October 1992 (Unit 1) and May 1992 (Unit 2).

Unit 1 4.6.1.2 Note 1 2. (Unit 1 only) A one-time exception to the requirement to perform post-modification Type A testing is allowed for the steam generators and associated piping, as components of the containment barrier. For this case, ASME Section XI leak testing will be used to verify the leak tightness of the repaired or modified portions of the containment barrier. Entry into MODES 3 and 4 following the extended outage that commenced in 1997 may be made to perform this testing.

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Attachment 1, Volume 16, Rev. 0, Page 183 of 256 JUSTIFICATION FOR DEVIATIONS ITS 5.5, PROGRAMS AND MANUALS

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

2. This Specification has been renumbered to be consistent with the ITS format and for clarity.

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

4. The bracketed ISTS 5.5.3, Post Accident Sampling, is not included in the CNP Units 1 and 2 ITS. The requirements for Post Accident Sampling have been deleted from the CTS in License Amendments 261 (Unit 1) and 244 (Unit 2) dated January 16, 2002. Subsequent programs have been renumbered, as necessary.

5. Editorial changes made for enhanced clarity or to be consistent with the Writers Guide.

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

7. ISTS 5.5.6 provides requirements for the Pre-Stressed Concrete Containment Tendon Surveillance Program. There is no requirement for this program in the CTS.

Not including this ISTS program in the CNP Units 1 and 2 ITS is consistent with the CNP Units 1 and 2 licensing bases.

8. ISTS 5.5.7 (ITS 5.5.5) provides requirements for the Reactor Coolant Pump Flywheel Inspection Program. The allowance to perform the inspection per the recommendations of Regulatory Position C.4.b of Regulatory Guide 1.14, Revision 1, August 1975 has been deleted. This change is consistent with the CNP Units 1 and 2 licensing bases. The Surveillance Frequency has also been modified to be consistent with the CNP Units 1 and 2 licensing bases.

9. The Reviewers Note has been deleted since it is not intended to be included in the ITS.

10. The Inservice Testing (IST) Program (ISTS 5.5.8) has been modified to state that the IST Program provides control for ASME Code Class 1, 2, and 3 "pumps and valves" in place of the current "components." 10 CFR 50.55a(f) provides the regulatory requirements for an IST Program. It specifies that ASME Code Class 1, 2, and 3 pumps and valves are the only components covered by an IST Program.

10 CFR 50.55a(g) provides regulatory requirements for an Inservice Inspection (ISI)

Program. It specifies that ASME Code Class 1, 2, and 3 components are covered by the ISI Program, and that pumps and valves are covered by the IST Program in 10 CFR 50.55a(f). The ISTS does not include ISI Program requirements as these requirements have been relocated to a plant specific document. Therefore, the components to which the IST Program applies (i.e., pumps and valves) have been added for clarity. In addition, the statement "The program shall include the following:" has been deleted because not all of the statements that follow are really part of the program requirements. Also, in the 1987 Addenda to the 1986 edition of ASME Boiler and Pressure Vessel Code,Section XI, the requirements for Inservice CNP Units 1 and 2 Page 1 of 3 Attachment 1, Volume 16, Rev. 0, Page 183 of 256

Attachment 1, Volume 16, Rev. 0, Page 184 of 256 JUSTIFICATION FOR DEVIATIONS ITS 5.5, PROGRAMS AND MANUALS Testing were removed and relocated to the ASME/ANSI OM Code. This change was endorsed in 10 CFR 50.55a. 10 CFR 50.55a(f) now addresses the requirements for inservice testing using the ASME/ANSI OM Code and 10 CFR 50.55a(g) addresses the requirements for inservice inspection using ASME Boiler and Pressure Vessel Code,Section XI. The ITS has been revised to incorporate the current ASME/ANSI OM Code requirements. In addition, the terms weekly, monthly, semiannually, and every 9 months are not used in the ASME/ANSI OM Code and have been deleted.

11. Typographical/grammatical error corrected.

12. ISTS 5.5.9 (ITS 5.5.7) provides the requirements for the Steam Generator (SG)

Program. Consistent with the associated Reviewers Note, the CNP Units 1 and 2 current licensing basis, reflected in CTS 4.4.5.1, 4.4.5.2, 4.4.5.3, and 4.4.5.4, for SG tube inspections are included in this program. The corresponding ISTS Reviewers Note is deleted. The Reviewers Note provides information for the NRC to identify acceptable methods to meet the requirements. The Reviewers Note is not meant to be retained in the final version of the plant-specific submittal.

13. ISTS 5.5.10 (ITS 5.5.8) provides the requirements for the Secondary Water Chemistry Program. The program in the ISTS includes requirements to provide controls for monitoring secondary water chemistry to inhibit SG tube degradation and low pressure turbine disc stress corrosion. ITS 5.5.8 provides controls for monitoring secondary water chemistry only to inhibit SG tube degradation. This modification is consistent with the current requirements in License Condition 2.C.(7) (Unit 1) and 2.C.(3)(v) (Unit 2).

14. ISTS 5.5.10.c includes a requirement that the Secondary Water Chemistry Program identify process sampling points, "which shall include monitoring the discharge of the condensate pumps for evidence of condenser in leakage." ITS 5.5.8.c only includes the requirement that the Secondary Chemistry Program identify process sampling points and does not provide any explicit monitoring points. This change is consistent with current Operating Licensing Conditions 2.C.(7).3 (Unit 1) and 2.C.(3)(v)3 (Unit 2).

15. ISTS 5.5.11 (ITS 5.5.9) provides requirements for the Ventilation Filter Testing Program. ITS 5.5.9 is revised to reflect the CNP Units 1 and 2 licensing bases. The 18 month Frequencies in the CTS have been changed to 24 months in the ITS.

16. The following changes have been made to ISTS 5.5.13 (ITS 5.5.11):

a. Specific gravity has been added as an option to API gravity or absolute specific gravity consistent with the current licensing basis;

b. Saybolt viscosity has been added as an option to kinematic viscosity and the viscosity check is only required if the gravity was not determined by comparison with the supplier's certification, consistent with current licensing basis;

c. The type of fuel oil, Type 2D, has been deleted consistent with current licensing basis; and CNP Units 1 and 2 Page 2 of 3 Attachment 1, Volume 16, Rev. 0, Page 184 of 256

Attachment 1, Volume 16, Rev. 0, Page 185 of 256 JUSTIFICATION FOR DEVIATIONS ITS 5.5, PROGRAMS AND MANUALS

d. The words "ASTM D-2276 Method A-2 or A-3" in ISTS 5.5.13.c (ITS 5.5.11.c) have been changed to "ASTM D-2276 Method A" in ITS 5.5.11.c to be consistent with current licensing basis.

17. ISTS 5.5.16 (ITS 5.5.14) provides requirements for the Containment Leakage Rate Testing Program. The requirements of the ISTS are revised to reflect the Containment Leakage Rate Testing Program requirements of CTS 3/4.6.1.2 and 3/4.6.1.3. The containment design pressure limit specified in ISTS 5.5.16.b was not included because it currently does not exist in the CTS, and because this limit does not provide any useful input to the Containment Leakage Rate Testing Program.

The air lock door leakage test of ISTS 5.5.16.d.2.b) is not included because it is not required by the CTS. In addition, the statement in ISTS 5.5.16.f that "Nothing in these Technical Specifications shall be construed to modify the testing Frequencies required by 10 CFR 50, Appendix J" has been deleted because the phrase is not consistent with the allowances in ISTS 5.5.16.a (ITS 5.5.14.a), which states that the 10 CFR 50, Appendix J, Option B requirements may be modified by approved exemptions and exceptions.

18. The program details of the Explosive Gas and Storage Tank Radioactivity Monitoring Program are described in ISTS 5.5.12 (ITS 5.5.10) parts a, b, and c. Therefore, the sentence in the introductory paragraph that specifies a method to determine the explosive gas and storage tank radioactivity is not necessary .

19. Changes are made to ISTS 5.5.12.c (ITS 5.5.10.c) to be consistent with the first paragraph in ISTS 5.5.12 (ITS 5.5.10).

20. ISTS 5.5.11.d demonstrates that the pressure drop across the combined HEPA filters, prefilters, and charcoal adsorbers is less than the specified pressure drop when tested at the specified system flow rate. The referenced methods for performing the test, Regulatory Guide 1.52, Revision 2 and ASME N510-1989, do not provide the methods for performing this test. As a result, these test method references have been deleted in ITS 5.5.9.d.

21. The requirement of ISTS 5.5.7 (ITS 5.5.5) is currently located in an individual Specification in the CTS (CTS 4.4.10.1). Thus, CTS 4.0.2 (ITS SR 3.0.2) and CTS 4.0.3 (ITS SR 3.0.3) apply to the CTS Surveillance Frequency. To maintain consistency with the current licensing basis requirements, an allowance that ITS SR 3.0.2 and SR 3.0.3 are applicable to the Reactor Coolant Pump Flywheel Inspection Program Surveillance Frequency has been included in ITS 5.5.5. In addition, approved TSTF-421, which extends the Frequency to 20 years has not been adopted.

CNP Units 1 and 2 Page 3 of 3 Attachment 1, Volume 16, Rev. 0, Page 185 of 256

Attachment 1, Volume 16, Rev. 0, Page 186 of 256 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 16, Rev. 0, Page 186 of 256

Attachment 1, Volume 16, Rev. 0, Page 187 of 256 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 5.5, PROGRAMS AND MANUALS There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 16, Rev. 0, Page 187 of 256

, Volume 16, Rev. 0, Page 188 of 256 ATTACHMENT 6 ITS 5.6, Reporting Requirements , Volume 16, Rev. 0, Page 188 of 256

, Volume 16, Rev. 0, Page 189 of 256 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 16, Rev. 0, Page 189 of 256

Attachment 1, Volume 16, Rev. 0, Page 190 of 256 ITS 5.6 A.1 ITS 5.6 5.6 in accordance with 10 CFR 50.4 A.2 L.1 Page 1 of 16 Attachment 1, Volume 16, Rev. 0, Page 190 of 256

Attachment 1, Volume 16, Rev. 0, Page 191 of 256 ITS 5.6 A.1 ITS L.1 by April 30 (for Occupational Radiation Exposure Report) L.2 5.6.1, 5.6.7 5.6.1 A.3 5.6.7 L.3 L.4 5.6.1 Note 5.6.1 Page 2 of 16 Attachment 1, Volume 16, Rev. 0, Page 191 of 256

Attachment 1, Volume 16, Rev. 0, Page 192 of 256 ITS 5.6 A.1 ITS by May 15 L.2 5.6.2 INSERT 1 M.1 A.1 5.6.3 5.6.2 Note, 5.6.3 Note A.9 Page 3 of 16 Attachment 1, Volume 16, Rev. 0, Page 192 of 256

Attachment 1, Volume 16, Rev. 0, Page 193 of 256 ITS 5.6 ITS M.1 INSERT 1 5.6.2 The Annual Radiological Environmental Operating Report shall include the results of analyses of all radiological environmental samples and of all environmental radiation measurements taken during the period pursuant to the locations specified in the table and figures in the ODCM, as well as summarized and tabulated results of these analyses and measurements in the format of the table in the Radiological Assessment Branch Technical Position, Revision 1, November 1979. In the event that some individual results are not available for inclusion with the report, the report shall be submitted noting and explaining the reasons for the missing results. The missing data shall be submitted in a supplementary report as soon as possible.

Insert Page 6-11 Page 4 of 16 Attachment 1, Volume 16, Rev. 0, Page 193 of 256

Attachment 1, Volume 16, Rev. 0, Page 194 of 256 ITS 5.6 A.1 ITS 5.6.4 L.3 A.4 5.6.5 5.6.5.a A.5 Reactor Core Safety Limits; SHUTDOWN MARGIN; RTS Instrumentation A.6 Overpressure T and Overpower T Allowable Value parameter values; RCS Pressure, Temperature, and Flow DNB Limits; and Boron Concentration.

5.6.5.b LA.1 Page 5 of 16 Attachment 1, Volume 16, Rev. 0, Page 194 of 256

Attachment 1, Volume 16, Rev. 0, Page 195 of 256 ITS 5.6 A.1 ITS 5.6.5.c 5.6.5.d A.4 A.7 Page 6 of 16 Attachment 1, Volume 16, Rev. 0, Page 195 of 256

Attachment 1, Volume 16, Rev. 0, Page 196 of 256 ITS 5.6 A.1 ITS See ITS 3.4.15 See CTS 3/4.3.3.1 See ITS 3.3.6 See ITS 3.3.3 5.6.6 See ITS 3.3.3 See CTS 3/4.3.3.1 Page 7 of 16 Attachment 1, Volume 16, Rev. 0, Page 196 of 256

Attachment 1, Volume 16, Rev. 0, Page 197 of 256 ITS 5.6 A.1 ITS 5.6.7 A.8 A.10 Page 8 of 16 Attachment 1, Volume 16, Rev. 0, Page 197 of 256

Attachment 1, Volume 16, Rev. 0, Page 198 of 256 ITS 5.6 A.1 ITS 5.6 5.6 in accordance with 10 CFR 50.4 A.2 L.1 Page 9 of 16 Attachment 1, Volume 16, Rev. 0, Page 198 of 256

Attachment 1, Volume 16, Rev. 0, Page 199 of 256 ITS 5.6 A.1 ITS L.1 by April 30 (for Occupational Radiation Exposure Report) L.2 5.6.1, 5.6.7 A.3 5.6.1 5.6.7 L.3 L.4 5.6.1 Note 5.6.1 Page 10 of 16 Attachment 1, Volume 16, Rev. 0, Page 199 of 256

Attachment 1, Volume 16, Rev. 0, Page 200 of 256 ITS 5.6 A.1 ITS by May 15 L.2 5.6.2 INSERT 1 M.1 A.1 5.6.3 5.6.2 Note, 5.6.3 Note A.9 Page 11 of 16 Attachment 1, Volume 16, Rev. 0, Page 200 of 256

Attachment 1, Volume 16, Rev. 0, Page 201 of 256 ITS 5.6 ITS M.1 INSERT 1 5.6.2 The Annual Radiological Environmental Operating Report shall include the results of analyses of all radiological environmental samples and of all environmental radiation measurements taken during the period pursuant to the locations specified in the table and figures in the ODCM, as well as summarized and tabulated results of these analyses and measurements in the format of the table in the Radiological Assessment Branch Technical Position, Revision 1, November 1979. In the event that some individual results are not available for inclusion with the report, the report shall be submitted noting and explaining the reasons for the missing results. The missing data shall be submitted in a supplementary report as soon as possible.

Insert Page 6-11 Page 12 of 16 Attachment 1, Volume 16, Rev. 0, Page 201 of 256

Attachment 1, Volume 16, Rev. 0, Page 202 of 256 ITS 5.6 A.1 ITS 5.6.4 L.3 A.4 5.6.5 5.6.5.a A.5 Reactor Core Safety Limits; SHUTDOWN MARGIN; RTS Instrumentation A.6 Overpressure T and Overpower T Allowable Value parameter values; RCS Pressure, Temperature, and Flow DNB Limits; and Boron Concentration.

5.6.5.b LA.1 Page 13 of 16 Attachment 1, Volume 16, Rev. 0, Page 202 of 256

Attachment 1, Volume 16, Rev. 0, Page 203 of 256 ITS 5.6 A.1 ITS 5.6.5.c 5.6.5.d A.4 A.7 Page 14 of 16 Attachment 1, Volume 16, Rev. 0, Page 203 of 256

Attachment 1, Volume 16, Rev. 0, Page 204 of 256 ITS 5.6 A.1 ITS See ITS 3.4.15 See CTS 3/4.3.3.1 See ITS 3.3.6 See ITS 3.3.3 5.6.6 See ITS 3.3.3 See CTS 3/4.3.3.1 Page 15 of 16 Attachment 1, Volume 16, Rev. 0, Page 204 of 256

Attachment 1, Volume 16, Rev. 0, Page 205 of 256 ITS 5.6 A.1 ITS See ITS 5.5 5.6.7 A.8 A.10 Page 16 of 16 Attachment 1, Volume 16, Rev. 0, Page 205 of 256

Attachment 1, Volume 16, Rev. 0, Page 206 of 256 DISCUSSION OF CHANGES ITS 5.6, REPORTING REQUIREMENTS 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 6.9.1 requires, in addition to the requirements of 10 CFR, reports be submitted to the Regional Administrator. ITS 5.6 requires that the reports be submitted in accordance with 10 CFR 50.4. This changes the CTS by removing the explicit requirement to send reports to the Regional Administrator.

10 CFR 50.4 provides distribution requirements for written communications to the NRC. This change is acceptable because the requirements deleted from the Technical Specifications are already required by 10 CFR 50.4. This change is designated as administrative because it does not result in technical changes to the CTS.

A.3 CTS 6.9.1.4 regarding annual reports requires the initial report to be submitted prior to March 1 of the year following initial criticality. The ITS does not include such a statement. This changes the CTS by deleting a requirement for report submissions that have already occurred and will not be repeated.

This change is acceptable because the one time reporting requirement has already been met and no longer needs to be specified. This change is designated as administrative because it does not result in technical changes to the CTS.

A.4 CTS 6.9.1.8 requires the Monthly Reactor Operating Report be submitted to the U.S. Nuclear Regulatory Commission with a copy to the Regional Office.

CTS 6.9.1.9.4 requires the CORE OPERATING LIMITS REPORT (COLR) to be provided to the NRC document control desk with copies to the Regional Administrator and Resident Inspector. ITS 5.6.4 requires the Monthly Operating Report to be submitted and ITS 5.6.5.d requires the COLR to be provided to the NRC. This changes the CTS by removing the specifics regarding distribution of the reports to the NRC.

10 CFR 50.4 provides distribution requirements for written communications to the NRC. This change is acceptable because the requirements deleted from the Technical Specifications are already required by 10 CFR 50.4. This change is designated as administrative because it does not result in technical changes to the CTS.

A.5 CTS 6.9.1.9.1 requires, in part, that core operating limits be established and documented in the COLR for the rod drop time limits in CTS 3/4.1.3.3.

ITS 5.6.5.a does not include a reference to rod drop time limits. This changes CNP Units 1 and 2 Page 1 of 6 Attachment 1, Volume 16, Rev. 0, Page 206 of 256

Attachment 1, Volume 16, Rev. 0, Page 207 of 256 DISCUSSION OF CHANGES ITS 5.6, REPORTING REQUIREMENTS the CTS eliminating the reference to rod drop time limits being core operating limits that are included in the COLR.

Rod drop time limits are included in the CTS and the ITS, not the COLR. The information that CTS 3/4.1.3.3 is referring to in the COLR is the definition of what constitutes the full withdrawn position for the purposes of performing the rod drop time Surveillance. This information is not a core operating limit and is therefore not included in the list of individual Specifications that address core operating limits in ITS 5.6.5. This change is acceptable because the information that was moved to the COLR and is referenced in CTS 3/4.1.3.3 (i.e., what constitutes the full withdrawn position) remains in the COLR. This change is designated as administrative because it does not result in technical changes to the CTS.

A.6 CTS 6.9.1.9.1 contains a list of the core operating limits established and documented in the COLR. ITS 5.6.5.a includes additional core operating limits established and documented in the COLR. These are Reactor Core Safety Limits; SHUTDOWN MARGIN; Reactor Trip System Instrumentation Functions 6 and 7 (Overtemperature T and Overpressure T; respectively) Allowable Value parameter values; RCS Pressure, Temperature, and Flow Departure from Nucleate Boiling Limits; and Boron Concentration. These limits had previously been addressed in other parts of the CTS, but are being moved to the COLR in the ITS, and because of this are listed in ITS 5.6.5.a. This changes the CTS by adding core operating limits established and documented in the COLR because they are being moved there as part of changes to other parts of the CTS.

Technical aspects of the changes are addressed in the Discussion of Changes for the respective individual ITS Specifications.

This change is acceptable because it administratively documents changes made to other parts of the CTS and the COLR. This change is designated as administrative because it does not result in technical changes to the CTS.

A.7 CTS 6.9.2 requires special reports be submitted to the NRC and lists the CTS Specifications that require special reports to be submitted. The ITS does not require these special reports to be prepared and submitted. This changes the CTS by deleting the references to the CTS Specifications requiring special reports.

Justification for disposition of each of the special report requirements is addressed by the Discussion of Changes for the respective ITS or CTS Specification.

The purpose of CTS 6.9.2 is to identify the Specifications that require special reports to be submitted. This change is acceptable because the special reports are no longer required by the respective Specifications. Justification for disposition of each of the special report requirements is addressed by the Discussion of Changes for the respective ITS or CTS Specification. This change is designated as administrative because it does not result in technical changes to the CTS.

A.8 CTS 4.4.5.5.b requires the complete results of the steam generator tube inservice inspection to be included in the Annual Operating Report. ITS 5.6.7 requires these same results to be submitted on an annual basis (i.e., prior to March 1 for the inspection that was completed in the previous calendar year).

CNP Units 1 and 2 Page 2 of 6 Attachment 1, Volume 16, Rev. 0, Page 207 of 256

Attachment 1, Volume 16, Rev. 0, Page 208 of 256 DISCUSSION OF CHANGES ITS 5.6, REPORTING REQUIREMENTS This changes the CTS by eliminating the requirement to include the steam generator tube inservice inspection results in the Annual Operating Report.

The purpose of CTS 4.4.5.5.b is to ensure the results of the steam generator tube inservice inspection are provided to the NRC. It is not necessary to specify the report that will include the results. This change is acceptable because the steam generator tube inservice inspection results will still be required to be provided to the NRC at the same Frequency as in the CTS. This change is designated as administrative because it does not result in technical changes to the CTS.

A.9 CTS 6.9.1.6 and 6.9.1.7 Footnote 3 states that, for these reports, the submittal should combine those sections that are common to all units at the station; however, for units with separate radwaste systems, the submittal shall specify the releases of radioactive material for each unit. ITS 5.6.2 and 5.6.3 does not include the portion of the statement concerning units with separate radwaste systems. This changes the CTS by deleting the reference to units with separate radwaste systems.

This change is acceptable because CNP Units 1 and 2 share a radwaste system; they do not have separate radwaste systems. This change is designated as administrative because it does not result in technical changes to the CTS.

A.10 CTS 4.4.5.5.c requires a prompt notification to the NRC pursuant to CTS 6.9.1 prior to resumption of plant operation and a followup written report if the results of the steam generator tube inspection fall into the Category C-3. ITS 5.6.7.c requires Category C-3 results to be reported to the NRC in accordance with 10 CFR 50.72 and a Licensee Event Report to be submitted in accordance with 10 CFR 50.73. This changes the CTS by explicitly referencing the applicable Regulations that require the report.

The purpose of CTS 4.4.5.5.c is to ensure NRC prompt notification and followup written reporting if an inspection result falls into Category C-3. 10 CFR 50.72 governs prompt phone notifications and 10 CFR 50.73 governs written reports.

These changes are acceptable because they are consistent with the current manner in which the CTS 4.4.5.5.c notification and reporting are performed. This change is designated as administrative because it does not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES M.1 The second paragraph of ITS 5.6.2 includes details required to be included in the Annual Radiological Environmental Operating Report. CTS 6.9.1.6 does not contain this level of detail. This changes the CTS by requiring additional detail to be included in the Annual Radiological Environmental Operating Report.

The purpose of the second paragraph of ITS 5.6.2 is to specify details to be included in the Annual Radiological Environmental Operating Report. This change is acceptable because the content requirements are consistent with the objectives outlined in the Offsite Dose Calculation Manual. This change is CNP Units 1 and 2 Page 3 of 6 Attachment 1, Volume 16, Rev. 0, Page 208 of 256

Attachment 1, Volume 16, Rev. 0, Page 209 of 256 DISCUSSION OF CHANGES ITS 5.6, REPORTING REQUIREMENTS designated more restrictive because it adds new reporting requirements to the Technical Specifications.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 6.9.1.9.2 specifies the revision numbers and dates of the referenced methodologies used for the development of the COLR. ITS 5.6.5.b does not contain this level of detail. This changes the CTS by moving the specific methodology references for revisions and dates to the COLR.

The removal of these details, which are related to meeting Technical Specifications requirements, from the Technical Specifications is acceptable because this type of information is not necessary to be included in Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the references for the COLR and only NRC-approved methodologies may be used. The methodologies used to develop the parameters in the COLR have obtained prior approval by the NRC in accordance with Generic Letter 88-16. Also, this change is acceptable because the removed information will be adequately controlled in the COLR under the requirements provided in ITS 5.6.5, "CORE OPERATING LIMITS REPORT". ITS 5.6.5 ensures that the applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems limits, and nuclear limits such as SDM, transient analysis limits, and accident analysis limits) of the safety analyses are met and that only NRC-approved methodologies are used.

This change is designated as a less restrictive removal of detail change because information relating to the methodology used to develop cycle-specific parameter limits is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L.1 (Category 8 - Deletion of Reporting Requirements) CTS 6.9.1.1, CTS 6.9.1.2, and CTS 6.9.1.3 contain requirements for submitting a report of plant startup and power escalation testing following receipt of an operating license; amendments to the license involving planned increase in power level; installation of fuel that has a different design or has been manufactured by a different fuel supplier; and modifications that may have significantly altered the nuclear, thermal, or hydraulic performance of the unit. The ITS does not contain such reporting requirements.

This changes the CTS by deleting the requirements of CTS 6.9.1.1, CTS 6.9.1.2, and CTS 6.9.1.3.

The purpose of CTS 6.9.1.1, CTS 6.9.1.2 and CTS 6.9.1.3, is to provide a summary of plant startup and power escalation testing following the four specified conditions as verification that the unit operated as expected. This change is acceptable because the regulations provide adequate reporting requirements. If CNP Units 1 and 2 Page 4 of 6 Attachment 1, Volume 16, Rev. 0, Page 209 of 256

Attachment 1, Volume 16, Rev. 0, Page 210 of 256 DISCUSSION OF CHANGES ITS 5.6, REPORTING REQUIREMENTS there were any unit conditions outside the expected parameters during unit startup, they would be reported to the NRC if they met the reporting requirements in the regulations. Otherwise, the reports would document that the unit operated as expected and already approved by the NRC, as required by regulations. This change is designated as less restrictive because reports that would be submitted under the CTS will not be required under the ITS.

L.2 (Category 1 - Relaxation of LCO Requirements) CTS 6.9.1.4 requires annual reports described in CTS 6.9.1.5, which include the Occupational Radiation Exposure Report, to be submitted prior to March 1 of each year. CTS 6.9.1.6 requires the Annual Radiological Environmental Operating Report to be submitted before May 1 of each year. ITS 5.6.1 requires the Occupational Radiation Exposure Report to be submitted by April 30 of each year. ITS 5.6.2 requires the Annual Radiological Environmental Operating Report to be submitted by May 15 of each year. This changes the CTS by allowing an additional time to submit these reports each year.

The purpose of the due date for submitting the Occupational Radiation Exposure Report and Annual Radiological Environmental Operating Report is to ensure that the reports are provided in a reasonable period of time to the NRC for review. This change is acceptable because the reports are still required to be submitted in a reasonable time frame. Given that the reports are still required to be provided to the NRC on or before April 30 or May 15, respectively, and cover the previous calendar year, report completion and submittal is clearly not necessary to assure operation in a safe manner for the interval between March 1 and April 30, and May 1 and May 15, respectively. Additionally, there is no requirement for the NRC to approve the reports. This change is designated as less restrictive because it allows more time to prepare and submit the reports to the NRC.

L.3 (Category 8 - Deletion of Reporting Requirements) CTS 6.9.1.5.c and 6.9.1.8 require annual and monthly reporting of all challenges to the Reactor Coolant System pressurizer operated relief valves (PORVs) or safety valves. ITS 5.6 does not include these reporting requirements. This changes the CTS by deleting the requirement to include documentation of all challenges to the Reactor Coolant System PORVs or safety valves in the annual and monthly reports.

The purpose of the annual and monthly reporting requirements is to ensure the NRC receives appropriate routine reports of operating statistics and shutdown experience. This change is acceptable because the regulations provide adequate details of reporting requirements, and the reporting of these challenges does not affect continued plant operation. The change deletes the requirement to include documentation of all challenges to the Reactor Coolant System PORVs or safety valves in the annual and monthly reports. This change is designated as less restrictive because reports that would be submitted under the CTS will not be required under the ITS.

L.4 (Category 8 - Deletion of Reporting Requirements) CTS 6.9.1.5.d requires annual reporting of information regarding any instances when the I-131 specific activity limit for the primary coolant is exceeded. ITS 5.6 does not contain any CNP Units 1 and 2 Page 5 of 6 Attachment 1, Volume 16, Rev. 0, Page 210 of 256

Attachment 1, Volume 16, Rev. 0, Page 211 of 256 DISCUSSION OF CHANGES ITS 5.6, REPORTING REQUIREMENTS requirements for such a report. This changes the CTS by not including the requirements for the annual reporting of instances when the Technical Specification I-131 specific activity limit for the primary coolant is exceeded.

The purpose of CTS 6.9.1.5.d is to specify the requirements for submitting information regarding any instances when the Technical Specification I-131 specific activity limit for the primary coolant is exceeded in an annual report. This change is acceptable because the regulations provide adequate details of reporting requirements, and the reporting of exceeding the I-131 limit does not affect continued plant operation. Operations or conditions prohibited by the plants Technical Specifications are required to be reported in accordance with 10 CFR 50.73. Subsequent reports would be provided if necessary, without requiring a specific annual report. This change is designated as less restrictive because reports that would be submitted under the CTS will not be required under the ITS.

CNP Units 1 and 2 Page 6 of 6 Attachment 1, Volume 16, Rev. 0, Page 211 of 256

Attachment 1, Volume 16, Rev. 0, Page 212 of 256 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 16, Rev. 0, Page 212 of 256

, Volume 16, Rev. 0, Page 213 of 256 , Volume 16, Rev. 0, Page 213 of 256

, Volume 16, Rev. 0, Page 214 of 256 , Volume 16, Rev. 0, Page 214 of 256

Attachment 1, Volume 16, Rev. 0, Page 215 of 256 5.6 CTS 3 INSERT 1 6.9.1.7 within 90 days of January 1 of each year 2

INSERT 2 6.9.1.9.1 1. SL 2.1.1, "Reactor Core Safety Limits;"

2. LCO 3.1.1, "SHUTDOWN MARGIN (SDM);"

3. LCO 3.1.3, "Moderator Temperature Coefficient (MTC);"

4. LCO 3.1.5, "Shutdown Bank Insertion Limits;"

5. LCO 3.1.6, "Control Bank Insertion Limits;"

6. LCO 3.2.1, "Heat Flux Hot Channel Factor (FQ(Z));"

7. LCO 3.2.2, "Nuclear Enthalpy Rise Hot Channel Factor (FNH);"

8. LCO 3.2.3, "AXIAL FLUX DIFFERENCE (AFD);"

9. LCO 3.3.1, "Reactor Trip System (RTS) Instrumentation," Functions 6 and 7 (Overtemperature T and Overpower T, respectively) Allowable Value parameter values;

10. LCO 3.4.1, "RCS Pressure, Temperature, and Flow Departure from Nucleate Boiling (DNB) Limits;" and

11. LCO 3.9.1, "Boron Concentration."

Insert Page 5.6-2 Attachment 1, Volume 16, Rev. 0, Page 215 of 256

, Volume 16, Rev. 0, Page 216 of 256 , Volume 16, Rev. 0, Page 216 of 256

Attachment 1, Volume 16, Rev. 0, Page 217 of 256 5.6 CTS 2 INSERT 3 6.9.1.9.2

1. WCAP-9272-P-A, "Westinghouse Reload Safety Evaluation Methodology,"

(Westinghouse Proprietary);

2. WCAP-8385, "Power Distribution Control and Load Following Procedures - Topical Report," (Westinghouse Proprietary);

3. WCAP-10216-P-A, "Relaxation of Constant Axial Offset Control/FQ Surveillance Technical Specification," (Westinghouse Proprietary);

4. WCAP-10266-P-A, "The 1981 Version of Westinghouse Evaluation Mode Using BASH Code," (Westinghouse Proprietary); and

5. WCAP-12610-P-A, "VANTAGE+ Fuel Assembly Reference Core Report,"

(Westinghouse Proprietary).

Insert Page 5.6-3 Attachment 1, Volume 16, Rev. 0, Page 217 of 256

, Volume 16, Rev. 0, Page 218 of 256 , Volume 16, Rev. 0, Page 218 of 256

, Volume 16, Rev. 0, Page 219 of 256 , Volume 16, Rev. 0, Page 219 of 256

Attachment 1, Volume 16, Rev. 0, Page 220 of 256 5.6 CTS 5 INSERT 4 6.9.1.5.b, 4.4.5.5

a. Within 15 days following the completion of each inservice inspection of steam generator tubes, the number of tubes plugged in each steam generator shall be reported to the NRC.

b. The complete results of the steam generator tube inservice inspection shall be submitted to the NRC prior to March 1 for the inspection that was completed in the previous calendar year. This report shall include:

1. Number and extent of tubes inspected;

2. Location and percent of wall-thickness penetration for each indication of an imperfection; and

3. Identification of tubes plugged.

c. Results of steam generator tube inspections which fall into Category C-3 shall be reported to the NRC in accordance with 10 CFR 50.72. A Licensee Event Report shall be submitted in accordance with 10 CFR 50.73 and shall provide a description of investigations conducted to determine the cause of the tube degradation and corrective measures taken to prevent recurrence.

Insert Page 5.6-5 Attachment 1, Volume 16, Rev. 0, Page 220 of 256

Attachment 1, Volume 16, Rev. 0, Page 221 of 256 JUSTIFICATION FOR DEVIATIONS ITS 5.6, REPORTING REQUIREMENTS

1. Grammatical/typographical error corrected.

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

3. ISTS 5.6.3 requires submittal of the Radioactive Effluent Release Report prior to May 1 of each year in accordance with 10 CFR 50.36a. The phrase "in accordance with 10 CFR 50.36a" is duplicative of the requirements in 10 CFR 50.36a, and is therefore not required to be in the Technical Specifications. 10 CFR 50.36a states that the report must be submitted within one year of the previous report. The existing CNP CTS submittal date for this report is not May 1 of each year. Since Technical Specifications cannot supersede the requirements of 10 CFR 50, implementation of this change would require NRC approval of an exemption request in accordance with 10 CFR 50.12. This is considered to be outside the scope of the ITS conversion.

Therefore, the submittal date for this report is revised in ITS 5.6.3 to reflect the CNP CTS (i.e., within 90 days of January 1 of each year).

4. ISTS 5.6.6, "Reactor Coolant System (RCS) PRESSURE AND TEMPERATURE LIMITS REPORT (PTLR)," is not adopted in the ITS. CTS Figures 3.4-2 and 3.4-3, which provide Reactor Coolant System heatup and cooldown limitations, respectively, were adopted in ITS 3.4.3, "RCS Pressure and Temperature (P/T)

Limits." Subsequent Specifications are renumbered accordingly. In addition, since the PTLR is not included in the ITS, approved TSTF-419, which modifies ISTS 5.6.6, is not incorporated.

5. The ISTS Reviewers Notes have been deleted since they were not intended to be included in the ITS. The requirements for the Steam Generator Tube Inspection Report have been included consistent with these ISTS Reviewers Notes and the CNP CTS requirements.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 16, Rev. 0, Page 221 of 256

Attachment 1, Volume 16, Rev. 0, Page 222 of 256 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 16, Rev. 0, Page 222 of 256

Attachment 1, Volume 16, Rev. 0, Page 223 of 256 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 5.6, REPORTING REQUIREMENTS There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 16, Rev. 0, Page 223 of 256

, Volume 16, Rev. 0, Page 224 of 256 ATTACHMENT 7 ITS 5.7, High Radiation Area , Volume 16, Rev. 0, Page 224 of 256

, Volume 16, Rev. 0, Page 225 of 256 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 16, Rev. 0, Page 225 of 256

Attachment 1, Volume 16, Rev. 0, Page 226 of 256 ITS 5.7 A.1 ITS See CTS 6.0 5.7 5.7.1 LA.1 5.7.2 LA.1 5.7.1 Page 1 of 2 Attachment 1, Volume 16, Rev. 0, Page 226 of 256

Attachment 1, Volume 16, Rev. 0, Page 227 of 256 ITS 5.7 A.1 ITS See CTS 6.0 5.7 5.7.1 LA.1 5.7.2 LA.1 5.7.1 Page 2 of 2 Attachment 1, Volume 16, Rev. 0, Page 227 of 256

Attachment 1, Volume 16, Rev. 0, Page 228 of 256 DISCUSSION OF CHANGES ITS 5.7, HIGH RADIATION AREA ADMINISTRATIVE CHANGES A.1 In the conversion of the CNP Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 2, "Standard Technical Specifications-Westinghouse Plants" (ISTS).

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

MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 6.12.1.c uses the title "Plant Radiation Protection Manager" and CTS 6.12.2 uses the titles "Shift Manager" and "Plant Radiation Protection Manager." ITS 5.7.1.c uses the generic title "radiation protection manager" and ITS 5.7.2 uses the generic titles "shift manager" and "radiation protection manager." This changes the CTS by moving the specific CNP organizational titles to the UFSAR and replacing them with generic titles.

The removal of these details, which are related to meeting Technical Specification requirements, from the Technical Specifications is acceptable because this type of information is not necessary to be included in Technical Specifications to provide adequate protection of public health and safety. The allowance to relocate the specific CNP organizational titles out of the Technical Specifications is consistent with the NRC letter from C. Grimes to the Owners Groups Technical Specification Committee Chairmen, dated November 10, 1994.

The various requirements of the radiation protection manager and the shift manager are still retained in the ITS. Also, this change is acceptable because the removed information will be adequately controlled in the UFSAR. Any changes to the UFSAR are made under 10 CFR 50.59 or 10 CFR 50.71(e),

which ensures changes are properly evaluated. This change is designated as a less restrictive removal of detail change because information related to meeting Technical Specification requirements are being removed from the Technical Specifications.

CNP Units 1 and 2 Page 1 of 2 Attachment 1, Volume 16, Rev. 0, Page 228 of 256

Attachment 1, Volume 16, Rev. 0, Page 229 of 256 DISCUSSION OF CHANGES ITS 5.7, HIGH RADIATION AREA LESS RESTRICTIVE CHANGES None CNP Units 1 and 2 Page 2 of 2 Attachment 1, Volume 16, Rev. 0, Page 229 of 256

Attachment 1, Volume 16, Rev. 0, Page 230 of 256 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 16, Rev. 0, Page 230 of 256

, Volume 16, Rev. 0, Page 231 of 256 , Volume 16, Rev. 0, Page 231 of 256

Attachment 1, Volume 16, Rev. 0, Page 232 of 256 CTS 5.7 1 INSERT 1 6.12.1 5.7.1 Each high radiation area in which radiation levels from radiation sources external including Footnote

• to the body could result in an individual receiving a dose equivalent in excess of 100 mrem but less than or equal to 1000 mrem in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 30 cm from the radiation source or 30 cm from any surface that the radiation penetrates, shall be barricaded and conspicuously posted as a high radiation area and entrance thereto shall be controlled by requiring issuance of a Radiological Work Permit (RWP). Radiation protection personnel shall be exempt from the RWP issuance requirement during the performance of their assigned radiation protection duties, provided they comply with approved radiation protection procedures for entry into high radiation areas. Any individual or group of individuals permitted to enter such areas shall be provided with or accompanied by at least one of the following:

a. A radiation monitoring device that continuously indicates the radiation dose rate in the area;

b. A radiation monitoring device that continuously integrates the radiation dose rate in the area and alarms when a preset integrated dose is received. Entry into such areas with this monitoring device may be made after the dose rate level in the area has been established and personnel have been made knowledgeable of it; or

c. An individual qualified in radiation protection procedures who is equipped with a radiation dose rate monitoring device. This individual shall be responsible for providing positive control over the activities within the area and shall perform periodic radiation surveillance at the frequency specified by a radiation protection manager in the RWP.

6.12.2 5.7.2 In addition to the requirements of Specification 5.7.1 above, for each high radiation area in which the radiation level at 30 cm from the radiation source or 30 cm from any surface that the radiation penetrates is greater than 1000 mrem in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, locked doors shall be provided, when possible, to prevent unauthorized entry into such areas and the keys shall be maintained under administrative control of the shift manager on duty or a radiation protection manager. Doors shall remain locked except during periods of access by personnel under an approved RWP that shall specify the dose rate levels in the immediate work areas. In the event that it is not possible or practicable to provide locked doors due to area size or configuration, the area shall be roped off, conspicuously posted and a flashing light shall be activated as a warning device.

Insert Page 5.7-1 Attachment 1, Volume 16, Rev. 0, Page 232 of 256

, Volume 16, Rev. 0, Page 233 of 256 , Volume 16, Rev. 0, Page 233 of 256

, Volume 16, Rev. 0, Page 234 of 256 , Volume 16, Rev. 0, Page 234 of 256

, Volume 16, Rev. 0, Page 235 of 256 , Volume 16, Rev. 0, Page 235 of 256

Attachment 1, Volume 16, Rev. 0, Page 236 of 256 JUSTIFICATION FOR DEVIATIONS ITS 5.7, HIGH RADIATION AREA

1. ISTS 5.7 provides requirements for High Radiation Areas. The brackets are removed and the proper plant specific information/value is provided. ITS 5.5.7 is revised to reflect the CNP current licensing basis and high radiation area controls The change is consistent with the requirements in CTS 6.12.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 16, Rev. 0, Page 236 of 256

Attachment 1, Volume 16, Rev. 0, Page 237 of 256 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 16, Rev. 0, Page 237 of 256

Attachment 1, Volume 16, Rev. 0, Page 238 of 256 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 5.7, HIGH RADIATION AREA There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 16, Rev. 0, Page 238 of 256

Attachment 1, Volume 16, Rev. 0, Page 239 of 256 ATTACHMENT 8 Relocated/Deleted Current Technical Specifications (CTS)

Attachment 1, Volume 16, Rev. 0, Page 239 of 256

, Volume 16, Rev. 0, Page 240 of 256 CTS 6.0, Administrative Controls , Volume 16, Rev. 0, Page 240 of 256

, Volume 16, Rev. 0, Page 241 of 256 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 16, Rev. 0, Page 241 of 256

, Volume 16, Rev. 0, Page 242 of 256 CTS 6.0 See ITS 5.2 and ITS 5.3 LA.1 Page 1 of 10 , Volume 16, Rev. 0, Page 242 of 256

, Volume 16, Rev. 0, Page 243 of 256 CTS 6.0 A.1 LA.2 See ITS Chapter 2.0 Page 2 of 10 , Volume 16, Rev. 0, Page 243 of 256

, Volume 16, Rev. 0, Page 244 of 256 CTS 6.0 LA.3 See ITS 5.7 Page 3 of 10 , Volume 16, Rev. 0, Page 244 of 256

, Volume 16, Rev. 0, Page 245 of 256 CTS 6.0 LA.4 See ITS 5.5 Page 4 of 10 , Volume 16, Rev. 0, Page 245 of 256

, Volume 16, Rev. 0, Page 246 of 256 CTS 6.0 LA.4 See ITS 5.5 See ITS Chapter 1.0 Page 5 of 10 , Volume 16, Rev. 0, Page 246 of 256

, Volume 16, Rev. 0, Page 247 of 256 CTS 6.0 See ITS 5.2 and ITS 5.3 LA.1 Page 6 of 10 , Volume 16, Rev. 0, Page 247 of 256

, Volume 16, Rev. 0, Page 248 of 256 CTS 6.0 A.1 LA.2 See ITS Chapter 2.0 Page 7 of 10 , Volume 16, Rev. 0, Page 248 of 256

, Volume 16, Rev. 0, Page 249 of 256 CTS 6.0 LA.3 See ITS 5.7 Page 8 of 10 , Volume 16, Rev. 0, Page 249 of 256

, Volume 16, Rev. 0, Page 250 of 256 CTS 6.0 LA.4 See ITS 5.5 Page 9 of 10 , Volume 16, Rev. 0, Page 250 of 256

, Volume 16, Rev. 0, Page 251 of 256 CTS 6.0 See ITS Chapter 1.0 LA.4 Page 10 of 10 , Volume 16, Rev. 0, Page 251 of 256

Attachment 1, Volume 16, Rev. 0, Page 252 of 256 DISCUSSION OF CHANGES CTS 6.0, ADMINISTRATIVE CONTROLS ADMINISTRATIVE CHANGES A.1 CTS 6.6.1, Reportable Event Action, including CTS 6.6.1.a, specifies, in the case of a Reportable Event, that the Commission be notified and a report be submitted pursuant to the requirements of 10 CFR 50.73. The requirements of CTS 6.6.1 and 6.6.1.a are not included in the ITS. This changes the CTS by removing the requirements for Reportable Event Action.

This change is acceptable because the requirements of CTS 6.6.1 and 6.6.1.a are contained in 10 CFR 50.72 and 10 CFR 50.73. Therefore, there is no need to repeat these requirements in the Technical Specifications. Since the CNP Units 1 and 2 Operating Licenses require compliance with 10 CFR 50, the change is designated as administrative because it does not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 6 - Removal of LCO, SR, or other TS requirements to the TRM, UFSAR, ODCM, QAPD, or IIP) CTS 6.4 states that a retraining and replacement training program for the facility staff shall be maintained under the direction of the Training Manager and shall meet or exceed the requirements and recommendations of Section 5.5 of ANSI N18.1-1971 and 10 CFR Part 55. ITS Chapter 5.0 does not require such a program. This changes the CTS by moving the requirements for the retraining and replacement training program to the UFSAR.

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. These training provisions are adequately addressed by other proposed ITS Chapter 5.0 provisions and by regulations. ITS 5.3, "Unit Staff Qualifications," provides requirements to ensure adequate, competent staff in accordance with ANSI N 18.1-1971 and Regulatory Guide 1.8, 1975. ITS 5.2 details organization requirements. ITS 5.2.2.a, 5.2.2.b, and 10 CFR 50.54 state minimum shift crew requirements. Training and requalification of NRC licensed positions is contained in 10 CFR 50.55. Placement of training requirements in the UFSAR will ensure that training programs are properly maintained in accordance with CNP Unit 1 and 2 commitments and applicable regulations.

Also, this change is acceptable because the removed information will be adequately controlled in the UFSAR. Any changes to the UFSAR are made under 10 CFR 50.59 or 10 CFR 50.71(e), which ensures changes are properly CNP Units 1 and 2 Page 1 of 3 Attachment 1, Volume 16, Rev. 0, Page 252 of 256

Attachment 1, Volume 16, Rev. 0, Page 253 of 256 DISCUSSION OF CHANGES CTS 6.0, ADMINISTRATIVE CONTROLS evaluated. This change is designated as a less restrictive removal of detail change because a requirement is being removed from the Technical Specifications.

LA.2 (Type 6 - Removal of LCO, SR, or other TS requirements to the TRM, UFSAR, ODCM, QAPD, or IIP) CTS 6.6.1.b states that each reportable event shall be reviewed by the PORC, and the results of this review shall be submitted to the NSRB and the Site Vice President. The ITS does not include this requirement.

This changes the CTS by moving these details of Reportable Event Action to the Quality Assurance Program Description (QAPD).

The removal of these 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. Given that these reviews and submittal of results are required following the event without a specified completion time, the proposed relocated requirements are not necessary to assure operation of the facility in a safe manner. As such, the relocated requirements are not required to be in the ITS to provide adequate protection of the public health and safety. Also, this change is acceptable because these types of procedural details will be adequately controlled in the QAPD. Any changes to the QAPD are made under 10 CFR 50.54(a), which ensures changes are properly evaluated. This change is designated as a less restrictive removal of detail change because requirements are being removed from the Technical Specifications.

LA.3 (Type 6 - Removal of LCO, SR, or other TS requirements to the TRM, UFSAR, ODCM, QAPD, or IIP) CTS 6.11 provides requirements for the Radiation Protection Program. The ITS does not include these requirements. This changes the CTS by moving the requirements for the Radiation Protection Program to the UFSAR.

The removal of these 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 Radiation Protection Program requires procedures to be prepared for personnel radiation protection consistent with 10 CFR 20. These procedures are for nuclear plant personnel and have no impact on nuclear safety or the health and safety of the public. Requirements to have procedures to implement 10 CFR 20 are contained in 10 CFR 20.1101(b). Periodic review of these procedures is addressed in 10 CFR 20.1101(c). Since the CNP Units 1 and 2 Operating Licenses require compliance with 10 CFR 20, there is no need to repeat the requirements in the ITS. As such, the relocated details are not required to be in the ITS to provide adequate protection of the public health and safety. Also, this change is acceptable because these details will be adequately controlled in the UFSAR. Any changes to the UFSAR are made under 10 CFR 50.59 or 10 CFR 50.71(e), which ensures changes are properly evaluated. This change is designated as a less restrictive removal of detail change because details for meeting Technical Specification and regulatory requirements are being removed from the Technical Specifications.

CNP Units 1 and 2 Page 2 of 3 Attachment 1, Volume 16, Rev. 0, Page 253 of 256

Attachment 1, Volume 16, Rev. 0, Page 254 of 256 DISCUSSION OF CHANGES CTS 6.0, ADMINISTRATIVE CONTROLS LA.4 (Type 6 - Removal of LCO, SR, or other TS requirements to the TRM, UFSAR, ODCM, QAPD, or IIP) CTS Definition 1.28 contains the definition for the Process Control Program (PCP). CTS 6.13.1 describe the process for control of changes to the PCP. The ITS does not include these requirements. This changes the CTS by moving the requirements of the PCP to the UFSAR.

The removal of these 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 PCP implements the requirements of 10 CFR 20, 10 CFR 61, and 10 CFR 71. Compliance with these regulations is required by the CNP Units 1 and 2 Operating Licenses, and procedures are the method to ensure compliance with the program. Regulations provide an adequate level of control for the affected requirements and inclusion of this requirement in the Technical Specifications is not necessary. Also, this change is acceptable because these details will be adequately controlled in the UFSAR. Any changes to the UFSAR are made under 10 CFR 50.59 or 10 CFR 50.71(e), which ensures changes are properly evaluated. This change is designated as a less restrictive removal of requirements because details for meeting Technical Specification and regulatory requirements are being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES None CNP Units 1 and 2 Page 3 of 3 Attachment 1, Volume 16, Rev. 0, Page 254 of 256

Attachment 1, Volume 16, Rev. 0, Page 255 of 256 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 16, Rev. 0, Page 255 of 256

Attachment 1, Volume 16, Rev. 0, Page 256 of 256 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS CTS 6.0, ADMINISTRATIVE CONTROLS There are no specific NSHC discussions for this Specification.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 16, Rev. 0, Page 256 of 256