Text

ITS Conversion SE - BVPS Doc. Table M
	ML060940413
Person / Time
Site:	Beaver Valley
Issue date:	03/03/2006
From:	; Office of Nuclear Reactor Regulation
To:	;
	Clark, Robert NRR/DIRS 301-415-2297
Shared Package
ML060890360	List: ML060940410; ML060940411; ML060940413; ML060940416; ML060940422; ML060940429;
References
	TAC MC6285, TAC MC6286
	Download: ML060940413 (52)
	v • d • e

Table M More Restrictive Changes Section 1.0 - Use and Application ITS # DOC # Description of Change ITS Requirement CTS Requirement CTS #

ITS 1.0 M.1 The CTS definition for CHANNEL FUNCTIONAL TEST states the following: "A CHANNEL 1.1 Definitions 1.11 CTS 1.0 FUNCTIONAL TEST shall be the injection of a simulated signal into the channel as close to the primary sensor as practicable to verify OPERABILITY including alarm and/or trip functions". The corresponding ISTS definition for CHANNEL OPERATIONAL TEST adds the following requirements to the CTS definition: " The COT shall include adjustments, as necessary, of the required alarm, interlock, and trip setpoints required for channel OPERABILITY such that the setpoints are within the necessary range and accuracy. The COT may be performed by means of any series of sequential, overlapping, or total channel steps". The CTS definition is being revised to incorporate the additional ISTS requirements.

ITS 1.0 M.2 The CTS shutdown and refueling Mode requirements in Table 1.1 that specify the 1.1 Definitions Table 1.1 CTS 1.0 transition between shutdown and refueling Modes are revised consistent with the ISTS.

The CTS specifies Mode 6 entry when the reactor vessel head is unbolted or removed.

The corresponding ISTS Table 1.1-1 requirement for Mode 6 specifies that one or more reactor vessel head closure bolts be less than fully tensioned. Additionally, the ISTS provides a corresponding condition for the reactor vessel head bolts in Modes 4 and 5.

The ISTS specifies that in Modes 4 and 5 the reactor vessel head bolts be fully tensioned.

This changes the CTS by adding new and different Mode definition requirements for vessel head bolts that define different transition points between the shutdown Modes and Refueling Mode.

ITS 1.0 M.3 Unit 1 only. New definitions are added for MASTER RELAY TEST, ACTUATION LOGIC 1.1 Definitions 1.0 Definitions CTS 1.0 TEST, and SLAVE RELAY TEST consistent with the ISTS. The CTS is revised to conform to the ISTS. This changes the CTS by the addition of new and more specifically defined requirements for instrumentation surveillance testing.

ITS 1.0 M.4 A new definition is included for the TRIP ACTUATING DEVICE OPERATIONAL TEST 1.1 Definitions 1.0 Definitions CTS 1.0 (TADOT) consistent with the ISTS. The proposed change revises the CTS by adding a new and more specific requirement for instrumentation surveillance testing.

BVPS Units 1 and 2 Page 1 of 52 Rev. 1.5

Table M More Restrictive Changes Section 2.0 - Safety Limits ITS # DOC # Description of Change ITS Requirement CTS Requirement CTS #

NONE BVPS Units 1 and 2 Page 2 of 52 Rev. 1.5

Table M More Restrictive Changes Section 3.0 - LCO and SR Applicability ITS # DOC # Description of Change ITS Requirement CTS Requirement CTS #

ITS 3.0 M.1 CTS 4.0.2 states, Each Surveillance Requirement shall be performed within the specified SR 3.0.2 4.0.2 CTS 3/4.0 time interval with a maximum allowable extension not to exceed 25 percent of the surveillance interval. ISTS SR 3.0.2 introduces a limitation to the application of the surveillance interval extension provided by CTS 4.0.2. ISTS SR 3.0.2 states that "For Frequencies specified as "once," the above interval extension does not apply." The CTS is revised to be consistent with the ISTS. This changes the CTS by limiting the application of the surveillance interval extension permitted by CTS 4.0.2.

BVPS Units 1 and 2 Page 3 of 52 Rev. 1.5

Table M More Restrictive Changes Section 3.1 - Reactivity Control Systems ITS # DOC # Description of Change ITS Requirement CTS Requirement CTS #

ITS 3.1.1 & M.1 ITS SR 3.1.2.1 requires the core reactivity balance to be determined to be within 1% k/k SR 3.1.2.1 NA 3.1.2 of the predicted value once prior to entering MODE 1 after each refueling. The CTS does CTS 3.1.1.1 not contain a similar requirement. This changes the CTS by adding an additional performance requirement for the core reactivity balance SR.

ITS 3.1.1 & M.2 CTS 4.1.1.1.1.e requires SDM to be determined to be within its limit every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when SR 3.1.1.1 4.1.1.1.1.e 3.1.2 in MODES 3, 4, and 5. ITS SR 3.1.1.1 requires SDM to be determined to be within its limit CTS 3.1.1.1 in MODE 2 with Keff < 1.0, and MODES 3, 4, and 5. This changes the CTS by expanding the applicability of the Surveillance to include MODE 2 with Keff < 1.0.

ITS 3.1.1 NONE CTS 3.1.1.2 ITS-NA NONE CTS 3.1.1.3 ITS 3.1.3 M.1 The CTS 3.1.1.4 Applicability for MTC is Mode 1 and Mode 2 with Keff 1.0. The CTS 3.1.3 Applicability 3.1.1.4 Applicability CTS 3.1.1.4 Actions require the unit to be placed in Mode 3 when the MTC limit is not met. The ISTS and Action and Action applicability for the lower limit includes Modes 1, 2, and 3. The ISTS Action applicable when the lower MTC limit is not met requires that the plant be placed in Mode 4.

Consistent with the ISTS, the CTS applicability is expanded to include not only Mode 1 and Mode 2 with Keff 1.0 but all of Mode 2 and all of Mode 3 for the lower MTC limit. In addition, the CTS Action requirement applicable when the lower MTC limit is not met is also revised consistent with the ISTS.

ITS 3.1.3 M.2 CTS Surveillance 4.1.1.4.2.b verifies the lower MTC limit is met. The CTS surveillance SR 3.1.3.2 4.1.1.4.2.b CTS 3.1.1.4 requires that MTC be verified "At any THERMAL POWER, within 7 EFPD after reaching a RATED THERMAL POWER equilibrium boron concentration of 300 ppm". The ISTS surveillances that verify the lower MTC limit add the following requirements for verifying this limit " If the MTC is more negative than the 300 ppm Surveillance limit (not LCO limit) specified in the COLR, SR 3.1.3.2 shall be repeated once per 14 EFPD during the remainder of the fuel cycle. SR 3.1.3.2 need not be repeated if the MTC measured at the equivalent of equilibrium RTP-ARO boron concentration of 60 ppm is less negative than the 60 ppm Surveillance limit specified in the COLR". The CTS is revised by the addition of these new ISTS requirements for verification of the lower MTC limit.

BVPS Units 1 and 2 Page 4 of 52 Rev. 1.5

Table M More Restrictive Changes Section 3.1 - Reactivity Control Systems ITS # DOC # Description of Change ITS Requirement CTS Requirement CTS #

ITS 3.1.8 NONE CTS 3.1.2.9 ITS 3.1.4 M.1 CTS 3.1.3.1 Action "b" requires that with more than one rod misaligned the Unit be placed 3.1.4 Action 3.1.3.1 Action CTS 3.1.3.1 in Hot Standby within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The corresponding ISTS Action requires that additional Actions be taken in this condition to verify SDM or restore SDM to within limits within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months as well as requiring the unit to be placed in Mode 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The CTS is revised to adopt the additional ISTS Actions for SDM.

ITS 3.1.4 M.2 CTS 3.1.3.1, Action c, states that with one rod misaligned, POWER OPERATION may 3.1.4 Action 3.1.3.1 Action CTS 3.1.3.1 continue provided that certain actions are completed within one hour. If those actions are not complete, CTS 3.0.3 would be entered which allows 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to initiate action and would require entry into MODE 3 within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . Including the hour allowed in Action c, a total minimum time of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months would be allowed before having to enter Mode 3.

The proposed ISTS Condition C, states that if the Required Actions and associated Completion Times are not met, the unit must be in MODE 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The shortest Completion Time in the affected Actions is one hour. Therefore, under the ISTS, the minimum time to enter MODE 3 is 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months . This changes the CTS by reducing the time that would be allowed before Mode 3 must be entered when the Actions for a misaligned rod have not been completed within the allowed time.

ITS 3.1.7.2 M.1 CTS 3.1.3.2 does not contain an Action to follow if the Required Actions cannot be met. 3.1.7.2 Action 3.1.3.2 Action CTS 3.1.3.2 Therefore, CTS 3.0.3 would be entered which would allow 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to plan a shutdown and be in MODE 3 within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months . ISTS 3.1.7 contains Action E which states that the plant (Unit 2) must be in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months if the Required Actions and associated Completion Times are not met. The CTS is revised to incorporate the ISTS Action. This changes the CTS by eliminating the one hour in LCO 3.0.3 to plan a shutdown and, consequently, allowing one hour less for the unit to be in MODE 3.

ITS 3.1.7.1 M.1 CTS surveillance 4.1.3.2.1.a is modified by an

footnote that specifies rod position overlap SR 3.1.6.3 4.1.3.2.1 CTS 3.1.3.2 be verified as follows "During startup and shutdown, overlap must be checked for all control banks at the respective bank overlap height transition points." The corresponding (Unit 1) ISTS surveillance SR 3.1.6.3 specifies "Verify sequence and overlap limits specified in the COLR are met for control banks not fully withdrawn from the core every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ." The CTS surveillance is revised consistent with the ISTS. This changes the CTS by 1) requiring that the rod bank withdrawal sequence as well as overlap be verified, 2) that the applicable limits be specified in the COLR, and 3) that the surveillance be performed every BVPS Units 1 and 2 Page 5 of 52 Rev. 1.5

Table M More Restrictive Changes Section 3.1 - Reactivity Control Systems ITS # DOC # Description of Change ITS Requirement CTS Requirement CTS #

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months instead of only during startup and shutdown.

ITS 3.1.4 NONE CTS 3.1.3.4 ITS 3.1.5 M.1 The CTS 3.1.3.5 Actions provide the option to "Declare the rod to be inoperable and apply 3.1.5 Actions 3.1.3.5 Actions CTS 3.1.3.5 Specification 3.1.3.1" within an hour. The ISTS Actions require that SDM be verified or restored within an hour. The CTS Actions are revised to conform to the ISTS Actions.

This changes the CTS by eliminating the option to declare a rod inoperable and apply Specification 3.1.3.1.

ITS 3.1.5 M.2 CTS 3.1.3.5 is applicable in MODE 1 and MODE 2 with keff 1.0. The corresponding ISTS 3.1.5 Applicability 3.1.3.5 Applicability CTS 3.1.3.5 3.1.5 is applicable in MODES 1 and 2. The CTS is revised to conform to the ISTS. This changes the CTS by expanding the applicability from MODE 2 with the reactor critical to all of MODE 2 (which includes the approach to criticality).

ITS 3.1.6 M.1 CTS LCO 3.1.3.6 requires the control banks to be within the insertion limits specified in the 3.1.6 3.1.3.6 LCO, CTS 3.1.3.6 CORE OPERATING LIMITS REPORT. ITS LCO 3.1.6 requires the control banks to be Action, and within the insertion, sequence, and overlap limits specified in the COLR. ISTS Condition B Surveillances provides Actions for not meeting the overlap and sequence requirements, and ISTS SR 3.1.6.3 requires verification of the overlap and sequence every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The CTS is revised to conform to the ISTS. This changes the CTS by adding requirements (LCO, Action, and Surveillance) for the overlap and sequence limits to the Insertion Limits TS.

ITS 3.1.6 M.2 CTS 3.1.3.6, Action a, requires control banks inserted beyond the insertion limits to be 3.1.6 Action 3.1.3.6 Action CTS 3.1.3.6 restored within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . ISTS 3.1.6, Condition A, contains the same requirement and adds the requirements to verify the SDM is within the limits specified in the COLR or initiate boration to restore SDM to within the limit within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The CTS is revised to conform to the ISTS. This changes the CTS by adding the requirements to verify SDM or boration to restore the required SDM within one hour when control banks are below the insertion limits.

ITS - NA M.1 The CTS Test Exceptions 3.10.1, for shutdown margin, 3.10.2, for Group Height, Insertion NA 3.10.1, 3.10.2, &

CTS 3.10.1, and power distribution limits, and 3.10.3, (Unit 1 only) for pressure & temperature for 3.10.3 3.10.2, & reactor criticality are all deleted from the TS. The ISTS does not contain any similar test 3.10.3 (U1) exceptions and the test exceptions are not required for normal plant operation. The CTS is BVPS Units 1 and 2 Page 6 of 52 Rev. 1.5

Table M More Restrictive Changes Section 3.1 - Reactivity Control Systems ITS # DOC # Description of Change ITS Requirement CTS Requirement CTS #

revised to conform to the ISTS.

ITS 3.1.9 M.1 CTS 3.10.3 provides an exception to CTS 3.1.1.4, 3.1.3.1, 3.1.3.5, and 3.1.3.6 during the 3.1.9 LCO & SR 3.10.3 CTS 3.10.3 performance of PHYSICS TESTS and provides restrictions that must be followed when (Unit 2) utilizing the exception. The corresponding ISTS Test Exception (ITS 3.1.9) provides an exception to the equivalent ITS LCOs and adds a requirement to the restrictions that must CTS 3.10.4 be followed. The ISTS adds the requirement that SDM must be within the limits provided (Unit 1) in the COLR. In addition, the ISTS adds a Surveillance to verify the SDM every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and ACTIONS to follow if the SDM limit is not met. The CTS is revised to conform to the additional ISTS requirements. This changes the CTS by imposing additional requirements on the application of the test exception LCO.

ITS 3.1.9 M.2 CTS 4.10.3.1 requires THERMAL POWER to be verified to be 5% once per hour. The SR 3.1.9.3 4.10.3.1 CTS 3.10.3 corresponding ISTS Surveillance requires the verification be performed every 30 minutes.

(Unit 2) This changes the CTS by increasing the Frequency of the THERMAL POWER verification.

CTS 3.10.4 (Unit 1)

ITS 3.1.10 M.1 The CTS is revised by the addition of a new Technical Specification (3.1.10, "RCS Boron 3.1.10 NA CTS - NA Limitations < 500 0F"). The addition of this new specification is consistent with the Westinghouse Owners Group (WOG) TSTF-453. TSTF-453 was developed to address issues in Westinghouse Nuclear Safety Advisory Letter (NSAL)-00-016.

BVPS Units 1 and 2 Page 7 of 52 Rev. 1.5

Table M More Restrictive Changes Section 3.2 - Power Distribution Limits ITS # DOC # Description of Change ITS Requirement CTS Requirement CTS #

ITS 3.2.3 NONE CTS 3.2.1 ITS 3.2.1 NONE CTS 3.2.2 ITS 3.2.2 M.1 CTS 3.2.3, Action c, requires that with FNH exceeding its limit, subsequent POWER 3.2.2 Condition A 3.2.3 Action c N

CTS 3.2.3 OPERATION may proceed provided that F H is demonstrated through incore mapping to be within its limit at a nominal 50% of RATED THERMAL POWER prior to exceeding this THERMAL POWER, at a nominal 75% of RATED THERMAL POWER prior to exceeding this THERMAL POWER, and within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after attaining 95% or greater RATED THERMAL POWER. However, under the general rules of TS usage (CTS 3.0.2) these measurements do not have to be completed if at any time compliance with the LCO is reestablished. The corresponding ISTS 3.2.2 Condition A contains a Note that states, Required Actions A.2 and A.3 must be completed whenever Condition A is entered. ISTS Required Actions A.2 and A.3 require performance of a FNH measurement every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and prior to exceeding 50% RTP, 75% RTP, and within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after THERMAL POWER 95% RTP. The CTS is revised to conform to the ISTS. This changes the CTS by the addition of the ISTS Note. The ISTS Note requires the Actions that measure FNH prior to N

each specified power level and every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to be completed even if F H is restored to within its limit and compliance with the LCO is re-established.

ITS 3.2.4 M.1 CTS Action f requires that peaking factors be verified within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after reaching RTP or 3.2.4 Action A.6 3.2.4 Action f CTS 3.2.4 within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months after increasing THERMAL POWER. The corresponding ISTS action A.6 requires this verification to be performed within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after achieving equilibrium conditions at RTP not to exceed 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months after increasing THERMAL POWER. The CTS Action is revised to conform to the ISTS. This changes the CTS by requiring the verification to be performed at equilibrium conditions.

ITS 3.2.4 M.2 CTS Action e (ITS A.5) requires that QPTR be restored to within the limit. CTS Action f 3.2.4 Action e & f 3.2.4 Action A.5, CTS 3.2.4 (ITS A.6) requires a follow up verification of core status by measuring peaking factors after A.6 power has been increased. However, under the general rules of TS usage (CTS 3.0.2) the peaking factor measurements required by CTS Action f (ITS A.6) do not have to be completed if compliance with the LCO is reestablished in CTS Action e (ITS A.5).

Therefore, the ISTS 3.2.4 Action A.5 contains a Note that states, Required Action A.6 must be completed whenever Required Action A.5 is performed. The CTS is revised to BVPS Units 1 and 2 Page 8 of 52 Rev. 1.5

Table M More Restrictive Changes Section 3.2 - Power Distribution Limits ITS # DOC # Description of Change ITS Requirement CTS Requirement CTS #

conform to the ISTS. This changes the CTS by the addition of the ISTS Note to CTS Action e.

BVPS Units 1 and 2 Page 9 of 52 Rev. 1.5

Table M More Restrictive Changes Section 3.3A - 3.3.1, Reactor Trip System Instrumentation ITS # DOC # Description of Change ITS Requirement CTS Requirement CTS #

ITS 3.3.1 M.1 CTS Tables 3.3-1 and 4.3-1 list the RTS interlocks in Function 23. The CTS list of Table 3.3.1-1 Tables 3.3-1 and CTS 3.3.1.1 interlocks includes P-10 and P-13. The P-10 and P-13 interlocks function to provide the P- 4.3-1 7 interlock (low power permissive). Although the CTS references the P-7 permissive in several RTS Functions, the CTS does not specifically list the P-7 interlock in RTS Function

23. The CTS relies on specifying the components of the P-7 interlock (P-10 and P-13) to address the function of P-7. The ISTS list of interlocks includes P-10, P-13, and P-7. The CTS is revised to conform to the ISTS. This changes the CTS by adding a specific RTS line item Function for the P-7 interlock in Tables 3.3-1 and 4.3-1.

ITS 3.3.1 M.2 CTS Note 3 in Table 3.3-1 states the following; " With the reactor trip system breakers in the Table 3.3.1-1 Note Table 3.3-1 Note 3 CTS 3.3.1.1 closed position and the control rod drive system capable of rod withdrawal." This CTS Note is (a) used to modify the Applicability of RTS functions needed to mitigate the consequences of rod withdrawal events. The corresponding ISTS Note (a) states; " With Rod Control System capable of rod withdrawal or one or more rods not fully inserted." The CTS is revised to conform to the ISTS. This changes the CTS by adding the requirement to the applicability of whenever one or more rods are not fully inserted.

ITS 3.3.1 M.3 CTS Action 2.a.2, for an inoperable Power Range Neutron Flux Channel, states "place the Action D Action 2.a.2 CTS 3.3.1.1 inoperable channel in trip within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and perform SR 4.2.4." The referenced SR requires that the Quadrant Power Tilt Ratio be verified within the limit. The corresponding ISTS Action in Condition D specifies the performance of a surveillance to verify QPTR but includes a periodic frequency of "Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months " for performing this surveillance. The CTS Action 2.a.2 is revised to conform with the corresponding ISTS Action in Condition D.

This changes the CTS by specifying a periodic frequency for performing the required surveillance.

ITS 3.3.1 M.4 CTS Action 7a requires that "the inoperable channel is placed in the tripped condition within 6 Actions E, K, & L Action 7a CTS 3.3.1.1 hours". The corresponding ISTS Action Conditions E, K, and L specify the same Action but also includes the requirement that if the channel is not placed in the trip condition the affected unit must be removed from the Applicable Mode associated with the RTS Function. This additional ITS Action is to reduce power to Mode 3 in ITS Condition E, or reduce power to less than P-7 for ITS Condition K, and to reduce power to less than P-9 for ITS Condition L.

The CTS is revised to include the ISTS Action requirement to remove the unit from the Applicable Mode for the affected RTS Function. This changes the CTS by including a specific Action to remove the unit from the Applicable Mode of the affected RTS Function if the Action to place the channel in trip is not met.

ITS 3.3.1 M.5 CTS Action 8 applies to the Turbine Trip (Stop Valve Closure) RTS Function. Action 8 Action L Action 8 CTS 3.3.1.1 requires that "the inoperable channel is placed in the tripped condition within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ". The corresponding ISTS Action Condition L specifies the same Action for this RTS Function but also includes the requirement that if the channel is not placed in the trip condition the affected unit must be removed from the Applicable Mode associated with the RTS Function. The BVPS Units 1 and 2 Page 10 of 52 Rev. 1.5

Table M More Restrictive Changes Section 3.3A - 3.3.1, Reactor Trip System Instrumentation ITS # DOC # Description of Change ITS Requirement CTS Requirement CTS #

additional ITS Action requires that power be reduced to less than P-9 for ITS Condition L.

The CTS is revised to include the ITS Action requirement to remove the unit from the Applicable Mode for the affected RTS Function. This changes the CTS by including a specific Action to remove the unit from the Applicable Mode of the affected RTS Function if the Action to place the channel in trip is not met.

ITS 3.3.1 M.6 CTS Action 11 applies to the Reactor Coolant Pump (RCP) breaker position RTS Function. Action K Action 11 CTS 3.3.1.1 Action 11 requires that "the inoperable channel is placed in the tripped condition within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ". The corresponding ISTS Action Condition K specifies the same Action for this RTS Function but also includes the requirement that if the channel is not placed in the trip condition the affected unit must be removed from the Applicable Mode associated with the RTS Function. The additional ITS Action requires that power be reduced to less than P-7 for ITS Condition K. The CTS is revised to include the ITS Action requirement to remove the unit from the Applicable Mode for the affected RTS Function. This changes the CTS by including a specific Action to remove the unit from the Applicable Mode of the affected RTS Function if the Action to place the channel in trip is not met.

ITS 3.3.1 M.7 Unit 2 only (Unit 1 does not have an Action 44). Action 44 is applicable to the Unit 2 RTS Action O & P Action 44 CTS 3.3.1.1 Interlock Functions (i.e., P-6, P-8, P-9, etc.). The Unit 2 CTS Action 44 requires that action be taken "With less than the Minimum Number of Channels OPERABLE." The CTS minimum channels operable requirement for the RTS Interlock Functions is one less than the total number of Interlock channels. As such the CTS does not require any Action when a single interlock channel is inoperable. The corresponding ITS Actions Conditions O and P specify that Action be taken when "one or more channels are inoperable". The ITS Actions are based on the "Required" or total number of channels. As such, the ITS Actions for the RTS interlocks require that action be initiated as soon as a single interlock channel becomes inoperable. The CTS is revised to conform to the ISTS. This changes the CTS by specifying that action be initiated when a single interlock channel becomes inoperable.

ITS 3.3.1 M.8 Unit 2 only (Unit 1 does not have an Action 44). Action 44 is applicable to the Unit 2 RTS Action O & P Action 44 CTS 3.3.1.1 Interlock Functions (i.e., P-6, P-8, P-9, etc.). CTS Action 44 requires that the interlock be determined to be "in its required state for the existing plant condition". The default action requirement if the interlock can not be determined to be in the required state within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is to apply Specification 3.0.3. Specification 3.0.3 allows 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to prepare for a plant shutdown and then up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to be in Mode 3 or 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months total from when the channel is first declared inoperable before the shutdown must be complete. The corresponding ITS Action O and P contains different default Actions if the interlock can not be verified to be in the required state. ITS Condition O requires the plant be placed in Mode 3 in a total of 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months and is applicable to those interlock Functions that are required operable in Modes 1 and 2.

ITS Condition P requires the plant be placed in Mode 2 in a total of 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months and is applicable to those interlock Functions required operable in Mode 1. The CTS Action is revised to conform to the ISTS. This changes the CTS Action by including the specific power reduction BVPS Units 1 and 2 Page 11 of 52 Rev. 1.5

Table M More Restrictive Changes Section 3.3A - 3.3.1, Reactor Trip System Instrumentation ITS # DOC # Description of Change ITS Requirement CTS Requirement CTS #

necessary to remove the plant from the applicable Mode for the affected interlock Function and by reducing the total time allowed to complete the actions by 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

ITS 3.3.1 M.9 Unit 1 only (Unit 2 does not use Action 3 or 12 for the RTS Interlock Functions). CTS Action Actions O & P Action 3 CTS 3.3.1.1 3 is applicable to the Unit 1 RTS P-6 Interlock Function. CTS Action 12 is applicable to the other RTS interlocks (P-8, P-9, P-10). The CTS Action 3 and 12 require that action be taken "With less than the Minimum Number of Channels OPERABLE." The CTS minimum channels operable requirement for the RTS Interlock Functions is one less than the total number of Interlock channels. As such the CTS does not require any Action when a single interlock channel is inoperable. The corresponding ITS Action Conditions O and P specify that Action be taken when "one or more channels are inoperable". The ITS Actions are based on the "Required" or total number of channels. As such, the ITS Actions for the RTS interlocks require that action be initiated as soon as a single interlock channel becomes inoperable. The CTS is revised to conform to the ISTS. This changes the CTS by specifying that action be initiated when a single interlock channel becomes inoperable.

ITS 3.3.1 M.10 Unit 1 only (Unit 2 already requires the P-10 interlock in Modes 1 and 2). The CTS P-10 Applicability P-10 Applicability CTS 3.3.1.1 Applicability for the P-10 RTS Interlock Function requires the Function to be operable in Mode 1. The ISTS Applicability for the P-10 RTS Function (and the BVPS Unit 2 Applicability) require the P-10 RTS Interlock Function to be operable in Modes 1 and 2. The Unit 1 CTS is revised to conform to the ISTS (and BVPS Unit 2). This changes the CTS by requiring the P-10 RTS Interlock Function on Unit 1 CTS Tables 3.3-1 and 4.3-1 to be operable in Mode 2 as well as Mode 1.

ITS 3.3.1 M.11 The CTS daily channel calibration surveillance assigned to the power range neutron flux high SR 3.3.1.2 Note Table 4.3-1 Note 2 CTS 3.3.1.1 setpoint on Table 4.3-1 consists of adjusting the power range instrument channels to match the calorimetric heat balance calculation each day. The CTS surveillance is modified by Note 2 that states the surveillance is only required above 15% RTP. The corresponding ISTS SR 3.3.1.2 specifies that the power range channel output be adjusted if calorimetric heat balance calculation results exceed power range channel output by more than + 2% RTP.

The ITS surveillance is modified by a Note that states the surveillance is not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after Thermal Power is 15% RTP. The CTS is revised to be consistent with the ITS. This changes the CTS by adding more specific requirements for the performance of the daily adjustment of the power range channels to the results of the calorimetric heat balance calculation.

ITS 3.3.1 M.12 The CTS monthly channel calibration requirement associated with the power range neutron SR 3.3.1.3 Note Table 4.3-1 Note 3 CTS 3.3.1.1 flux high setpoint on Table 4.3-1 is modified by Note 3. CTS Note 3 specifies that the surveillance consist of an incore-excore comparison every 31 EFPD above 15% RTP and that the Nuclear Instrumentation System (NIS) be recalibrated (adjusted) if the absolute difference is > 3%. The corresponding proposed BVPS ITS surveillance SR 3.3.1.3 contains an addition Note that specifies the first performance of the surveillance must be completed BVPS Units 1 and 2 Page 12 of 52 Rev. 1.5

Table M More Restrictive Changes Section 3.3A - 3.3.1, Reactor Trip System Instrumentation ITS # DOC # Description of Change ITS Requirement CTS Requirement CTS #

within 7 days of exceeding the specified power level. The CTS is revised to conform to the proposed BVPS ITS surveillance requirement. This changes the CTS by placing a new time restriction on the first performance of the surveillance after exceeding the specified power.

ITS 3.3.1 M.13 The CTS surveillances for the Power Range Low setpoint and Intermediate Range RTS SR 3.3.1.7 Table 4.3-1 CFT CTS 3.3.1.1 Functions specified in Table 4.3-1 require a Channel Functional Test (CFT) to be performed Prior to Startup (S/U) if not performed in the previous 31 days (Note 1). The corresponding ISTS surveillance SR 3.3.1.8 (BVPS ITS SR 3.3.1.7) also requires a Channel Operational Test (COT) prior to reactor startup. However, the ISTS Surveillance Frequency is modified by a Note that states the surveillance is only required if it has not been performed in the previous 92 days. The ISTS surveillance also requires the performance of the COT 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reducing power below P-10 during shutdowns and every 92 days on a periodic basis as long as the plant is maintained in the Applicable Mode. The ISTS surveillance also requires a verification that the P-6 and P-10 interlocks are in their required state for existing plant conditions. The CTS surveillance requirements for these RTS Functions are revised to conform to the ISTS. This changes the CTS requirement to perform the surveillance prior to reactor startup by the addition of requirements to perform the surveillance during a shutdown (within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reducing power below P-10) and the addition of the requirement to repeat the surveillance every 92 days on a periodic basis after startup or during a shutdown while maintaining the plant in the Applicable Mode (Mode 2 and Mode 1 < P-7). The ISTS requirement to verify the state of the P-6 and P-10 interlocks are also included in the CTS requirement.

ITS 3.3.1 M.14 The Unit 1 and 2 CTS surveillances for the Power Range High Positive Rate, Overpower and SR 3.3.1.10 Table 4.3-1 CTS 3.3.1.1 Overtemperature T RTS Functions and the Unit 2 surveillances for the Pressurizer Pressure Channel Calibration

- Low RTS Function specified on Table 4.3-1 include the requirement to perform a channel calibration. The corresponding ISTS channel calibration surveillance requirement (ITS SR 3.3.1.10) includes an additional requirement (Note) that affects the RTS Functions listed above. The ISTS channel calibration surveillance requirement includes a Note that requires the verification that time constants are adjusted to the prescribed values. The RTS Functions listed above have time constants associated with their allowable values and trip setpoints.

The CTS surveillance requirements are revised to conform to the ISTS. This changes the CTS requirements by including a specific requirement to verify the time constants associated with the RTS Functions listed above.

ITS 3.3.1 M.15 The CTS surveillances for the Source Range RTS Function specified on Table 4.3-1 include SR 3.3.1.6 Table 4.3-1 CFT CTS 3.3.1.1 the requirement to perform a Channel Functional Test (CFT) quarterly. The CTS CFT requirement is modified by Note 8 which states that " Below P-6, not required to be performed for source range instrumentation prior to entering MODE 3 from MODE 2 until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after entry into MODE 3." The corresponding BVPS proposed ITS surveillance (SR 3.3.1.6) requires that a Channel Operational Test (COT) be performed quarterly. The ITS surveillance is modified by a note that states "Not required to be performed for source range BVPS Units 1 and 2 Page 13 of 52 Rev. 1.5

Table M More Restrictive Changes Section 3.3A - 3.3.1, Reactor Trip System Instrumentation ITS # DOC # Description of Change ITS Requirement CTS Requirement CTS #

instrumentation until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after power has been reduced below P-6." As such, the proposed change revises the CTS by changing the start of the 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months time delay allowed for performing the surveillance during shutdowns from after Mode 3 entry to after power is reduced below P-6.

ITS 3.3.1 M.16 Unit 1 only. The Unit 1 CTS surveillances specified on Table 4.3-1 for the Turbine Trip RTS SR 3.3.1.10 Table 4.3-1 CTS 3.3.1.1 Functions do not include channel calibrations every refueling cycle. The corresponding ISTS surveillance requirements (SR 3.3.1.10) (and the Unit 2 surveillance requirements) for this RTS Function include a requirement to perform channel calibrations every 18 months. The Unit 1CTS is revised to conform to the ISTS and Unit 2. This changes the Unit 1CTS by adding the requirement to perform channel calibrations on the Turbine Trip RTS Functions every 18 months.

ITS 3.3.1 M.17 Unit 1 only. The Unit 1 CTS surveillance requirements specified on Table 4.3-1 for the Table 3.3.1-1 Table 4.3-1 CTS 3.3.1.1 manual reactor trip function do not include the Applicable Modes for this RTS Function. In Applicability Applicability addition, the surveillance requirements specified on Table 4.3-1 for the power range neutron flux - low trip setpoint RTS Function do not include Mode 1 below the P-10 Interlock in the Applicable Modes for this RTS Function. The ISTS includes all the Applicable Modes for each RTS Function in the single combined ISTS Table 3.3.1-1. The CTS is revised to conform to the ISTS. This changes the CTS Table 4.3-1 by combining it with CTS Table 3.3-1 such that each RTS Function has all the associated requirements (including the Applicable Modes as modified by footnotes (a) and (b)) specified on a single Table. The proposed change results in the applicable Modes being correctly and consistently specified each affected Function in the RTS TS.

ITS 3.3.1 M.18 CTS Table 3.3-1 contains a line item that addresses the requirements for the reactor Trip Table 3.3.1-1 Table 3.3-1 CTS 3.3.1.1 Breakers (RTBs). CTS Table 3.3-1 does not contain any reference to the RTB bypass breakers. The corresponding ISTS Table 3.3.1-1 contains a footnote (g) that modifies the requirements for the RTBs such that the RTB requirements are applicable to an RTB bypass breaker when the bypass breaker is racked in and closed to bypass an RTB. The CTS is revised to conform to the ISTS. This changes the CTS by providing specific requirements that are applicable to the bypass breakers when they are used in place of the RTBs.

ITS 3.3.1 M.19 A new ITS surveillance BVPS ITS SR 3.3.1.9 (ISTS 3.3.1.6) is added to the CTS SR 3.3.1.9 Table 4.3-1 CTS 3.3.1.1 surveillances for the power range neutron flux high trip setpoint on CTS Table 4.3-1. The new surveillance requires that the excore nuclear instrumentation channels be calibrated to agree with incore detector measurements once per refueling cycle. The new surveillance is modified by a note that establishes the criteria for the initial performance following a refueling outage. The note requires that the surveillance be performed within 7 days after thermal power exceeds 50% RTP. The CTS is revised to incorporate this new surveillance requirement.

BVPS Units 1 and 2 Page 14 of 52 Rev. 1.5

Table M More Restrictive Changes Section 3.3A - 3.3.1, Reactor Trip System Instrumentation ITS # DOC # Description of Change ITS Requirement CTS Requirement CTS #

ITS 3.3.1 M.20 CTS Action 40a, applicable to the RTB undervoltage and shunt trip mechanisms, includes Action N Action 40a CTS 3.3.1.1 the allowance to bypass the RTB in order to perform maintenance on the trip mechanisms.

The CTS Action states "Neither breaker shall be bypassed while one of the diverse trip features is inoperable except for the time required for performing maintenance to restore the breaker to OPERABLE status." The ISTS contains a corresponding note (#2) in the Action Condition (ITS Condition N) for an inoperable RTB that states "One RTB may be bypassed for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for maintenance on undervoltage or shunt trip mechanisms, provided the other train is OPERABLE." The CTS allowance is revised to conform to the ISTS note.

This changes the CTS allowance by limiting the time the RTB can be bypassed to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months and requiring the other RTB train to be operable.

ITS 3.3.1 M.21 The CTS is revised by the addition of new Applicable Modes and Actions for the Power Table 3.3.1-1 Tables 3.3-1 & 4.3-CTS 3.3.1.1 Range Neutron Flux Low Trip Function. The addition of the new Modes and Actions is 1 consistent with the Westinghouse Owners Group TSTF-453. TSTF-453 was developed to address issues identified in Westinghouse Nuclear Safety Advisory Letter (NSAL)-00-016.

BVPS Units 1 and 2 Page 15 of 52 Rev. 1.5

Table M More Restrictive Changes Section 3.3B - Instrumentation (Other than RTS & ESFAS)

ITS # DOC # Description of Change ITS Requirement CTS Requirement CTS #

ITS 3.3.3 M.1 The CTS PAM instrumentation listed on Table 3.3-11 is revised by the addition of new LCO LCO CTS 3.3.3.8 instrumentation consistent with the proposed list of PAM Functions on ITS Table 3.3.3-1.

3.3.3.1 The proposed change enhances the existing CTS requirements by providing a more complete set of PAM indications in the TS. The proposed provides additional assurance that instrumentation necessary to perform PAM functions is maintained operable.

ITS 3.3.3 M.2 The S/U frequency for the Channel Check on the Auxiliary Feedwater Flow Rate (i.e., the Channel Check Channel Check CTS 3.3.3.8 ITS Secondary Heat Sink Indication) PAM Function is revised to an M frequency. Frequency Frequency 3.3.3.1 Additionally, the footnote in Table 4.3-7 that specifies the Auxiliary Feedwater Flow Rate PAM Function Channel Check is to be performed in conjunction with Surveillance Requirement 4.7.1.2.7 following an extended plant outage is deleted. These changes result in a Channel Check being performed on this PAM Function monthly consistent with the Frequency of all other PAM functions.

ITS 3.3.3 M.3 The N/A frequency for the Channel Check on the Containment Wide-Range Pressure PAM Channel Check Channel Check CTS 3.3.3.8 Function is deleted, and a Channel Check will be required to be performed on the Frequency Frequency 3.3.3.1 Containment Wide-Range Pressure PAM Function consistent with the Channel Check Frequency of the other PAM functions (i.e., monthly).

ITS 3.3.3 M.4 CTS 3.3.3.1 Action "c" provides an exception to the requirements of Specification 3.0.3. Actions Actions CTS 3.3.3.8 Specification 3.0.3 contains requirements that would become applicable if the CTS did not 3.3.3.1 provide an appropriate Action or the CTS Actions were not met for some reason.

Specification 3.0.3 would require that the plant be placed in a Mode where the requirements of CTS 3.3.3.1 were no longer applicable. The PAM ITS does not include an exception to ITS LCO 3.0.3. As such, the proposed change would result in ITS LCO 3.0.3 being applicable if the PAM ITS did not contain an appropriate Action for an inoperable condition or if the ITS Actions were not met.

ITS 3.3.3 M.5 CTS Action 35 part "b" contains a requirement that becomes applicable if the Containment Actions Actions CTS 3.3.3.8 Area Radiation Monitor channel(s) are not restored to operable status within the allowed 3.3.3.1 time. The CTS Action requires that an explanation of why the inoperable instrument was not corrected in a timely manner be included in the next Annual Radioactive Effluent Release Report. The corresponding ITS Action if the Containment Area Radiation Monitor channel(s) are not restored to operable status within the specified Completion Time requires immediate compliance with ITS Specification 5.6.5. ITS Specification 5.6.5 states that "a report shall be submitted within the following 14 days. The report shall outline the preplanned alternate method of monitoring, the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels of the Function to OPERABLE status." The CTS is revised to conform to the ITS. This changes the CTS by requiring a more timely and complete NRC report be submitted when the Containment Area Radiation Monitor channel(s) are not restored to operable status within the specified Completion Time.

BVPS Units 1 and 2 Page 16 of 52 Rev. 1.5

Table M More Restrictive Changes Section 3.3B - Instrumentation (Other than RTS & ESFAS)

ITS # DOC # Description of Change ITS Requirement CTS Requirement CTS #

ITS 3.3.3 M.6 (Unit 1 only) The CTS PAM requirement for Reactor Vessel Level Indicating System LCO LCO CTS 3.3.3.8 requires one channel operable. The corresponding ITS PAM specifies 2 Reactor Vessel 3.3.3.1 Water Level channels operable. The CTS is revised to conform to the ITS. This changes the CTS to require redundant channels of this PAM Function operable.

ITS 3.3.4 M.1 CTS LCO 3.3.3.5 Actions specify required actions to be conducted within specific times. If Action B Actions CTS 3.3.3.5 the actions cannot be completed within the allowed time, the unit is required to be in at least HOT SHUTDOWN (i.e., Mode 4) within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The corresponding Actions of ITS LCO 3.3.4 Condition B state: Required Action and associated Completion Time not met, be in Mode 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and Mode 4 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The CTS is revised to conform to the ISTS. This changes the CTS Action by specifying the intermediate requirement that the plant be placed in Mode 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months as well as requiring the plant to be in Mode 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

ITS 3.3.4 M.2 Not used.

CTS 3.3.3.5 ITS 3.3.4 M.3 CTS Surveillance Requirement 4.3.3.5 states Each remote shutdown monitoring SR 3.3.4.1 4.3.3.5, Table 4.3-6 CTS 3.3.3.5 instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK and CHANNEL CALIBRATION operations at the frequencies shown in Table 4.3-6. The CTS Table specifies that a Channel Check for AFW Flow Rate be performed only upon a unit startup (S/U). The S/U frequency for this surveillance is modified by a note that states Channel check to be performed in conjunction with Surveillance Requirement 4.7.1.2.7 following an extended plant outage. CTS 4.7.1.2.7 verifies AFW flow to the SGs after the Unit has been in Mode 5 or 6 for more than 30 days.

The corresponding ITS SR 3.3.4.1 requires the performance of a CHANNEL CHECK every month for each required instrumentation channel that is normally energized. The CTS is revised to conform to the ISTS surveillance requirement. This changes the CTS by replacing the requirement to perform an AFW flow channel check once per unit startup following an extended outage with the requirement for a channel check to be performed every month.

ITS 3.3.4 M.4 CTS 3.3.3.5 only contains requirements for monitoring instrumentation. CTS surveillance SR 3.3.4.2 4.3.3.5 CTS 3.3.3.5 requirement 4.3.3.5 states Each remote shutdown monitoring instrumentation channel shall be demonstrated OPERABLE by performance of the Channel Check and Channel Calibration operations at the frequencies shown in Table 4.3-6. The CTS requirements only specify a Channel Check and Channel Calibration for the specified monitoring channels. The corresponding ISTS 3.3.4 includes requirements for control and transfer switches as well as monitoring instrumentation. ITS SR 3.3.4.2 provides requirements to verify the operability of the control and transfer switches. ITS SR 3.3.4.2 requires that BVPS Units 1 and 2 Page 17 of 52 Rev. 1.5

Table M More Restrictive Changes Section 3.3B - Instrumentation (Other than RTS & ESFAS)

ITS # DOC # Description of Change ITS Requirement CTS Requirement CTS #

each specified control circuit and transfer switch be verified capable of performing the intended function. The ITS SR must be performed every 36 months. The CTS is revised to conform to the ITS. This changes the CTS by adding specific control and transfer Functions to the Remote Shutdown System specification along with a surveillance requirement to verify the transfer and control switches can perform their intended function.

ITS 3.3.5 M.1 The CTS requires the loss of power instrumentation operable in Modes 1-4. ISTS 3.3.5 Applicability Applicability CTS 3.3.2.1 requires this instrumentation operable in Modes 1-4 and when the associated DG is required to be operable by LCO 3.8.2, "AC Sources - Shutdown. ITS LCO 3.8.2, AC Sources Shutdown, requires one DG to be operable in Modes 5 and 6 (both units) and when moving irradiated fuel (Unit 1) or recently irradiated fuel (Unit 2). The CTS Applicability for the loss of power instrumentation is revised to conform to the ISTS Applicability. This changes the CTS by requiring the loss of power instrumentation to be operable when the associated DG is required operable by ITS LCO 3.8.2.

ITS 3.3.6 M.1 Unit 2 only. CTS LCO 3.9.9 Action states close each of the purge and exhaust Action B.1 Action (Unit 2 only) penetrations providing direct access from the containment atmosphere to the outside CTS 3.9.9 & atmosphere. ITS Required Action B.1 states Place and maintain containment purge and CTS 3.3.3.1 exhaust valves in closed position." The Completion Time for ITS Required Action B.1 is immediate. The CTS is revised to conform to the ITS. This changes the CTS Action by specifying an immediate Completion Time.

ITS 3.3.6 M.2 Unit 2 only. CTS 3.3.3.1 Action b states, "With one or more radiation monitoring channels Action B Action b (Unit 2 only) inoperable, take the ACTION shown in Table 3.3-6. CTS Table 3.3-6 specifies Action 22 CTS 3.9.9 & be taken. CTS Table 3.3-6 Action 22 requires the action specified in CTS 3.9.9 to be CTS 3.3.3.1 applied. The Action in CTS 3.9.9 requires the containment purge and exhaust penetrations to be isolated. The corresponding ITS Action Condition B requires that the containment purge and exhaust penetrations be isolated immediately. The CTS is revised to conform to the ITS. This changes the CTS Action by specifying an immediate Completion Time.

ITS 3.3.7 M.1 CTS 3.3.3.1 Action "a" states, "With a radiation monitoring channel alarm/trip setpoint NA Action a CTS 3.3.3.1 exceeding the value shown in Table 3.3-6, adjust the setpoint to within the limit within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months or declare the channel inoperable." The CTS Action provides a 4-hour delay before a radiation monitoring channel must be declared inoperable and CTS Action "b" applied.

ITS 3.3.7 does not have a corresponding Action that allows a delay before the required channel must be declared inoperable. The CTS Actions are revised to conform to the ISTS BVPS Units 1 and 2 Page 18 of 52 Rev. 1.5

Table M More Restrictive Changes Section 3.3B - Instrumentation (Other than RTS & ESFAS)

ITS # DOC # Description of Change ITS Requirement CTS Requirement CTS #

Actions. This changes the CTS by eliminating CTS Action "a" which results in radiation monitoring channels being declared inoperable upon discovery instead of 4-hours after discovery.

ITS 3.3.7 M.2 Unit 2 only. Unit 2 CTS Action 46 applicable when one control room area monitor is Action A Action 46 CTS 3.3.3.1 inoperable states, "With the number of OPERABLE channels one less than required by the Minimum Channels OPERABLE requirement, either restore the inoperable channel to OPERABLE status within 7 days or close the control room series normal air intake and exhaust isolation dampers." The corresponding ITS 3.3.7 Action Condition A states "One or more Functions with one channel or train inoperable. Place one CREVS train in emergency pressurization mode in 7 days." The CTS is revised to conform to the ITS.

This changes the CTS Action by revising the Action to address more actuation instrument functions than just the radiation monitors. In addition, the CTS is revised to not only isolate the control room but place a CREVS train in operation to pressurize the control room with filtered air.

ITS 3.3.7 M.3 Unit 2 only. Unit 2 CTS Action 47 applicable when two radiation monitor channels are Action B Action 47 CTS 3.3.3.1 inoperable states "With no OPERABLE channels either restore one inoperable channel to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or close the control room series normal air intake and exhaust isolation dampers. The corresponding ITS Action Condition B states "One or more Functions with two channels or two trains inoperable. Place one CREVS train in the emergency pressurization mode immediately. AND Enter applicable Conditions and required Actions of LCO 3.7.10, "CREVS" for one CREVS train made inoperable by inoperable CREVS actuation instrumentation immediately." The CTS is revised to conform to the ITS. This changes the CTS Action by revising the Action to address more actuation instrument functions than just the radiation monitors. The CTS is also revised to not only isolate the control room but place a CREVS train in operation to pressurize the control room with filtered air immediately instead of within one hour. In addition, the CTS is revised to include an Action to enter the applicable plant systems specification (3.7.10) for an inoperable train of CREVS. The Action for an inoperable CREVS train in 3.7.10 allows 7 days of operation in this condition before the CREVS train must be restored to operable status (initiation instrument channel or train restored to operable status) or the plant must be placed in a condition where the affected CREVS train is no longer required operable.

ITS 3.3.7 M.4 Unit 2 only. Unit 2 Actions 46 and 47 provide the requirements to be implemented when Actions C & D NA CTS 3.3.3.1 one or two required instrument channels are inoperable. The CTS Actions do not contain default requirements to follow if the specified Actions are not accomplished within the required time. The corresponding ITS 3.3.7 Actions include default Actions (Conditions C and D) that must be implemented if the Actions in ITS Conditions A and B are not met.

The two ITS default Conditions address the different Applicabilities of ITS 3.3.7 (i.e.,

Modes 1-4 and fuel movement involving recently irradiated fuel). The ITS default Actions require the plant to be removed from the associated Applicability (i.e., be in Mode 5 or BVPS Units 1 and 2 Page 19 of 52 Rev. 1.5

Table M More Restrictive Changes Section 3.3B - Instrumentation (Other than RTS & ESFAS)

ITS # DOC # Description of Change ITS Requirement CTS Requirement CTS #

suspend fuel movement involving recently irradiated fuel). The CTS is revised to incorporate the ITS default Action Conditions C and D. This changes the CTS by providing clear Action requirements to implement if the primary Actions that address the inoperable condition are not met within the required completion time.

ITS 3.3.7 M.5 CTS 3.3.3.1 contains the requirements for radiation monitors, including the monitors used LCO, Actions, & NA CTS 3.3.3.1 to actuate the Control Room Emergency Ventilation System (CREVS). CTS 3.3.3.1 does SRs not contain requirements for manual initiation of the CREVS. ITS 3.3.7 CREVS Actuation Instrumentation, contains all the instrumentation requirements for the CREVS including the radiation monitors. ITS 3.3.7 also includes the requirements for the manual switches associated with each CREVS train. The CREVS manual initiation Function is applicable in MODES 1, 2, 3, and 4, and During the movement of recently irradiated fuel assemblies, or during movement of fuel assemblies over recently irradiated fuel assemblies. Two trains of manual initiation are required operable and a TADOT surveillance is assigned to the manual function. The CTS is revised to conform to the ITS. This changes the CTS by adding the requirements for the manual CREVS initiation Function to the TS.

ITS 3.3.7 M.6 CTS LCO 3.3.3.1 states The radiation monitoring instrumentation channels shown in Table 3.3.7-1 Table 3.3-6 CTS 3.3.3.1 Table 3.3-6 shall be OPERABLE. Table 3.3-6 lists the radiation monitors required for the Control Room Area. ITS LCO 3.3.7 states The Control Room Emergency Ventilation System (CREVS) actuation instrumentation for each Function in Table 3.3.7-1 shall be OPERABLE. ITS Table 3.3.7-1 lists all the required CREVS instrument functions which includes the containment isolation Phase B (CIB) signal. The ITS Table 3.3.7-1 specification of the CIB actuation includes a reference to the requirements for the CIB being specified in ITS 3.3.2, ESFAS Instrumentation. The CTS is revised to conform to the ISTS. This changes the CTS by specifying an additional instrumentation actuation function for the CREVS.

ITS 3.3.7 M.7 CTS LCO 3.3.3.1 Surveillance Requirement 4.3.3.1 states Each radiation monitoring SR 3.3.7.3 NA CTS 3.3.3.1 instrumentation channel shall be demonstrated OPERABLE by the performance of the CHANNEL CHECK, CHANNEL CALIBRATION and CHANNEL FUNCTIONAL TEST operations during the modes and at the frequencies shown in Table 4.3-3. The CTS does not include any requirements for the CREVS manual initiation function. ITS LCO 3.3.7 Control Room Emergency Ventilation System (CREVS) Actuation Instrumentation, specifies the manual initiation Function and requires SR 3.3.7.3 to be performed on the manual function. The ITS SR requires a TADOT to be performed every 18 months. SR 3.3.7.3 is modified by a Note that states Verification of setpoint is not required. This changes the CTS by adding a surveillance requirement that is not currently specified.

ITS 3.3.7 M.8 Unit 1 only. CTS 3.3.3.1 contains the requirements for the control room radiation monitors. NA Action 41 CTS 3.3.3.1 The Unit 1 CTS 3.3.3.1 Action 41 allows Unit 1 to take credit for the Unit 2 control room area radiation monitors when the corresponding Unit 1 control room area radiation BVPS Units 1 and 2 Page 20 of 52 Rev. 1.5

Table M More Restrictive Changes Section 3.3B - Instrumentation (Other than RTS & ESFAS)

ITS # DOC # Description of Change ITS Requirement CTS Requirement CTS #

monitors are inoperable. The corresponding Actions in proposed ITS 3.3.7 are simplified and treat each Unit equally and do not contain provisions for Unit 1 to credit the Unit 2 radiation monitors. The CTS is revised to conform to the ITS. The proposed change results in a more simplified set of Actions for Unit 1 that are consistent with the proposed Unit 2 Actions and the corresponding ISTS Actions.

ITS 3.3.7 M.9 Unit 1 only. CTS 3.3.3.1 contains the Actions applicable when one or more control room Actions A & B Action 41 CTS 3.3.3.1 area radiation monitors are inoperable. CTS Actions 41a) 2, 41b) 2, and 41b) 3 require that the control room be isolated from the outside atmosphere by closing the series air intake and exhaust isolation dampers. The corresponding ITS 3.3.7 Action Conditions A and B require that a CREVS train be placed in the emergency pressurization mode of operation. The emergency pressurization mode of operation includes isolation of the control room ventilation intake and exhaust ducts as well as the start of a CREVS fan aligned to provide filtered makeup air to pressurize the control room. The CTS Actions are revised to conform to the ITS Actions. This changes the CTS Actions by requiring the control room to be placed in the emergency pressurization mode of operation instead of simply being isolated.

ITS 3.3.8 M.1 CTS Action 5, applicable to the Source Range instrumentation, requires that positive Action A.1 Action 5 CTS 3.3.1.1 reactivity additions be suspended. The corresponding ITS Action A.1 also requires positive reactivity additions to be suspended. However, the ITS Action also requires that actions be suspended immediately. The CTS is revised to conform to the ITS. This changes the CTS by specifying that the Action is required immediately.

BVPS Units 1 and 2 Page 21 of 52 Rev. 1.5

Table M More Restrictive Changes Section 3.3C - 3.3.2, Engineered Safety Feature Actuation System (ESFAS) Instrumentation ITS # DOC # Description of Change ITS Requirement CTS Requirement CTS #

ITS 3.3.2 M.1 Unit 2 only. The Unit 2 Turbine Trip and Feedwater Isolation consists of three ESFAS Table 3.2-1 Table 3.3-3 Turbine CTS 3.3.2.1 Functions. The requirements for the Safety Injection input are addressed separately under Turbine Trip and Trip and Feedwater Function 1 in the CTS. However, the operability requirements for the SG Water Level Feedwater Isolation Function High-High Function and the Automatic Actuation Logic and Relays Function are addressed Isolation Function under the Turbine Trip and Feedwater Isolation Function. The CTS SG Water Level High-High Function is required operable in Modes 1-3 and the CTS Automatic Actuation Logic and Relays Function is only required operable in Modes 1-2. The corresponding ISTS Functions indicate that Mode 3 is optional (bracketed). The CTS is revised to make both these Functions required operable in Mode 3. This changes the CTS by requiring the Automatic Actuation Logic and Relays Function operable in Mode 3 as well as Modes 1-2.

ITS 3.3.2 M.2 CTS Action statement 13 applies the trains of Automatic Actuation Logic and requires that with Action C Action 13 CTS 3.3.2.1 an inoperable channel the plant be placed in Hot Standby (Mode 3) in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in Cold Shutdown (Mode 5) within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . The corresponding ISTS Action (Condition C) adds an additional requirement to restore the train to operable status in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months prior to the requirement to be in Mode 3 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and Mode 5 in the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . The CTS is revised to conform to the ISTS. This changes the CTS by adding a specific Action requirement to restore the affected train to operable status in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

ITS 3.3.2 M.3 The CTS Actions require that "the inoperable channel is placed in trip [or in bypass]". The Actions Actions CTS 3.3.2.1 corresponding ISTS Action Conditions specify the same Action but also include the requirement that if the channel is not placed in the trip condition or bypassed the affected unit must be removed from the Applicable Mode associated with the ESFAS Function. The additional ISTS Action requires power and Mode reductions to place the affected unit in a Mode where the ESFAS Function is no longer required operable. The CTS is revised to include the ISTS Action requirement to remove the unit from the Applicable Mode for the affected ESFAS Function. This changes the CTS by including specific Action(s) to remove the unit from the Applicable Mode of the affected ESFAS Function if the Action is not met.

ITS 3.3.2 M.4 The CTS Action #16 requires that the inoperable channel be placed in the bypassed condition. Actions E & J Action 16 CTS 3.3.2.1 The CTS Action does not specify a time in which the channel must be placed in the bypassed condition. The corresponding ITS Action Conditions E and J require that the affected channel be placed in the bypassed condition within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The CTS Action is revised to conform to the ITS. This changes the CTS Action by limiting the time operation may continue before the affected channel must be bypassed.

ITS 3.3.2 M.5 CTS Action #38 applies to the ESFAS Interlock Functions and addresses with less than the Action K Action 38 CTS 3.3.2.1 minimum number of channels operable. In the case of the ESFAS Interlocks, the minimum channels required operable is one less than the total number of channels. Therefore, CTS Action #38 is not applicable until two interlock channels become inoperable. The corresponding ITS Action Condition K is applicable when one or more interlock channels are inoperable. The CTS Action is revised to conform to the ISTS Action. This changes the CTS BVPS Units 1 and 2 Page 22 of 52 Rev. 1.5

Table M More Restrictive Changes Section 3.3C - 3.3.2, Engineered Safety Feature Actuation System (ESFAS) Instrumentation ITS # DOC # Description of Change ITS Requirement CTS Requirement CTS #

by making the Required Actions applicable when the first interlock channel becomes inoperable instead of waiting until two interlock channels are inoperable.

ITS 3.3.2 M.6 CTS Action 38 is applicable to the ESFAS Functions (i.e., P-11, and P-12). CTS Action 38 Action K Action 38 CTS 3.3.2.1 requires that the interlock be determined to be "in its required state for the existing plant condition". The default action requirement if the interlock can not be determined to be in the required state within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is to apply Specification 3.0.3. Specification 3.0.3 allows 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to prepare for a plant shutdown and then up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to be in Mode 3 and another 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to be in Mode 4 or 14 hours1.62037e-4 days 0.00389 hours 2.314815e-5 weeks 5.327e-6 months total from when the channel is first declared inoperable and the Action is first applicable. The corresponding ITS Action K contains a different default Action if the interlock can not be verified to be in the required state. The ITS Condition requires the plant be placed in Mode 3 in a total of 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months and Mode 4 in a total of 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months . The CTS Action is revised to conform to the ISTS. This changes the CTS Action by including the specific power reduction necessary to remove the plant from the applicable Mode for the affected interlock Function and by reducing the total time allowed to complete the actions by 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

ITS 3.3.2 M.7 Not used.

CTS 3.3.2.1 ITS 3.3.2 M.8 Unit 1 only. The Unit 1 general ESFAS surveillance requirement 4.3.2.1.1 specifies the Table 3.2.1.1 SRs 4.3.2.1.1 CTS 3.3.2.1 instrumentation to be tested and the surveillances that must be performed in a similar manner as the corresponding Unit 2 general surveillance requirement. However, unlike Unit 2, the Unit 1 requirement does not specify that interlock, automatic actuation logic, and master and slave relay instrument functions are included in the ESFAS surveillance requirements. The corresponding ISTS ESFAS requirements do not include a general surveillance requirement similar to CTS 4.3.2.1.1. Instead, the ISTS surveillance requirements are specified in detail on Table 3.3.2-1. However, the ISTS ESFAS surveillance requirements, similar to the Unit 2 ESFAS TS, specify that testing be performed on interlock, automatic actuation logic, and master and slave relay instrument functions. The Unit 1 CTS surveillance 4.3.2.1.1 is revised to conform more closely to the corresponding Unit 2 and ISTS ESFAS surveillance requirements. This changes the Unit 1 CTS by adding a more specific surveillance requirement for the interlock, automatic actuation logic, and master and slave relay instrument functions.

ITS 3.3.2 M.9 Unit 1 only. The Unit 1 ESFAS Automatic Actuation Logic Functions specified on Table 3.3-3 Table 3.3.2-1 Table 3.3-3 & 4.3-2 CTS 3.3.2.1 are revised to include the associated "Actuation Relays". In addition, the Unit 1 surveillance requirements specified on Table 4.3-2 are revised to include the Actuation Relays. This changes the Unit 1 ESFAS requirements by adding specific requirements for SSPS Actuation Relay operability to the ESFAS requirements specified on CTS Table 3.3-3 and 4.3-2.

ITS 3.3.2 M.10 Unit 1 only. The CTS requirements for the automatic actuation logic and RWST level Table 3.3.2-1 Table 3.3-3 & 4.3-2 BVPS Units 1 and 2 Page 23 of 52 Rev. 1.5

Table M More Restrictive Changes Section 3.3C - 3.3.2, Engineered Safety Feature Actuation System (ESFAS) Instrumentation ITS # DOC # Description of Change ITS Requirement CTS Requirement CTS #

CTS 3.3.2.1 instrumentation for the SI transfer from injection to re-circulation mode Function require this Applicability Applicability instrumentation to be operable in Modes 1-3. These requirements are specified in both Unit 1 CTS Table 3.3-3 and CTS Table 4.3-2. The corresponding Unit 2 and ISTS instrumentation is required operable in Modes 1-4. The Unit 1 CTS requirements for this instrumentation on both Tables are revised to conform to the ISTS and corresponding Unit 2 TS. This changes the Unit 1 CTS by adding Mode 4 to the Applicability requirements specified on CTS Tables 3.3-3 and 4.3-2 for this instrumentation.

ITS 3.3.2 M.11 Unit 1 only. The CTS Turbine Trip and Feedwater Isolation ESFAS Function specified on Table 3.3.2-1 Table 3.3-3 & 4.3-2 CTS 3.3.2.1 Tables 3.3-3 and 4.3-2 is revised to include requirements for the Automatic Actuation Logic and Actuation Relays and SI Functions. The proposed addition of Automatic Actuation Logic and Actuation Relays and the associated surveillances to the existing requirements for the Turbine Trip and Feedwater Isolation Function make this Unit 1 Function more consistent with the corresponding Unit 2 and ISTS Functions. This changes the Unit 1 ESFAS requirements by adding specific requirements for SSPS Automatic Actuation Logic and Actuation Relays and SI Functions to the ESFAS requirements specified on CTS Table 3.3-3 and 4.3-2 for the Turbine Trip and Feedwater Isolation ESFAS Function.

ITS 3.3.2 M.12 Unit 1 only. The CTS AFW ESFAS Function specified on Tables 3.3-3 and 4.3-2 is revised to Table 3.3.2-1 Table 3.3-3 & 4.3-2 CTS 3.3.2.1 include requirements for the Automatic Actuation Logic and Actuation Relays. The proposed addition of Automatic Actuation Logic and Actuation Relays and the associated surveillances to the existing requirements for the AFW Function make this Unit 1 Function more consistent with the corresponding ISTS Functions. This changes the Unit 1 ESFAS requirements by adding specific requirements for SSPS Automatic Actuation Logic and Actuation Relays to the ESFAS requirements specified on CTS Table 3.3-3 and 4.3-2 for the AFW ESFAS Function.

ITS 3.3.2 M.13 Unit 1 only. The CTS requirements for the AFW pump start on RCP bus undervoltage Table 3.3.2-1 Table 3.3-3 & 4.3-2 CTS 3.3.2.1 Function require this instrumentation to be operable in Mode 1. The corresponding Unit 2 and ISTS instrumentation is required operable in Modes 1-2. The Unit 1 CTS requirements for this instrumentation are revised to conform to the ISTS and corresponding Unit 2 TS.

This changes the Unit 1 CTS by adding Mode 2 to the Applicability requirements for this instrumentation.

ITS 3.3.2 M.14 Unit 1 only. The Unit 1 CTS specifies Action 38 for the P-4 interlock. Action 38 requires that Action F Action 38 CTS 3.3.2.1 the interlock be verified in its required state within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or Specification 3.0.3 must be applied. Note that Unit 1 Action 38 is the same as Unit 2 Action 38. The corresponding ISTS Action requirement (Condition F) specifies that the inoperable channel or train be restored to operable status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or that the plant be placed in Mode 4 in 60 hours6.944444e-4 days 0.0167 hours 9.920635e-5 weeks 2.283e-5 months . In Mode 4, the P-4 interlock Function is no longer required operable. The Unit 1 Action for the P-4 interlock Function is revised to conform to the corresponding ISTS Action requirements.

This changes the Unit 1 Action by requiring the inoperable channel be restored to operable BVPS Units 1 and 2 Page 24 of 52 Rev. 1.5

Table M More Restrictive Changes Section 3.3C - 3.3.2, Engineered Safety Feature Actuation System (ESFAS) Instrumentation ITS # DOC # Description of Change ITS Requirement CTS Requirement CTS #

status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months instead of simply verifying the interlock status.

ITS 3.3.2 M.15 The CTS surveillance requirements for the P-11 and P-12 ESFAS interlock Functions do not SR 3.3.2.1 Table 4.3-2, P-11 &

CTS 3.3.2.1 include a channel check of the associated instrumentation. The corresponding ISTS P-12 SRs surveillance requirements for these ESFAS Functions include a channel check (SR 3.3.2.1).

The CTS requirements are revised to conform to the ISTS. This changes the CTS by adding a channel check (SR 3.3.2.1) for the instrumentation associated with the P-11 and P-12 Interlock Functions.

BVPS Units 1 and 2 Page 25 of 52 Rev. 1.5

Table M More Restrictive Changes Section 3.4 - Reactor Coolant System ITS # DOC # Description of Change ITS Requirement CTS Requirement CTS #

ITS 3.1.4 M.1 The CTS footnote 2 to the applicability states that "The provisions of Specification 4.0.4 are SR 3.4.1.4 Note Applicability CTS 3.2.5 not applicable for Reactor Coolant System total flow rate to allow a calorimetric flow footnote 2 measurement and the calibration of the Reactor Coolant System total flow rate indicators."

The CTS exception allows entry into Mode 1 without performing the required RCS flow verification surveillance. The ISTS does not contain a note that modifies the applicability of the TS. Instead, the ISTS contains a note that modifies the performance of the surveillance. The ISTS surveillance 3.4.1.4 note states that the surveillance is "Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after [90%] RTP." The CTS is revised to more closely conform to the ISTS method of providing the required exception. The CTS footnote to the applicability is revised to state that the heat balance surveillance is "not required to be performed until 30 days after 90% RTP" and is moved into the ITS surveillance 3.4.1.4. This changes the CTS by requiring the surveillance to be performed at a specific time after entering the applicable Mode.

ITS 3.4.2 NONE CTS 3.1.1.5 ITS 3.4.4 M.1 CTS 3.4.1.1 requires that all the RCS loops be in operation. The corresponding ISTS LCO 3.4.4 LCO 3.4.1.1 LCO CTS 3.4.1.1 3.4.4 requires that all the RCS loops be operable and in operation. The CTS LCO is revised to conform to the ISTS LCO. This changes the CTS by requiring the RCS loops to be operable as well as in operation.

ITS 3.4.5 M.1 The CTS 3.4.1.2 LCO item a specifies that two RCS loops be in operation when the rod LCO LCO CTS 3.4.1.2 control system is capable of control bank rod withdrawal. The corresponding ISTS (3.4.5) requires that two RCS loops be operable and that two RCS loops be in operation when the Rod Control System is capable of rod withdrawal. The CTS is revised to conform to the ISTS. This changes the CTS LCO by adding the explicit requirement for two RCS loops to be operable in Mode 3 in addition to the CTS requirement for two loops to be in operation.

ITS 3.4.5 M.2 CTS 3.4.1.2 Action statement a provides Actions for less than the required RCS loops Actions Action a, c CTS 3.4.1.2 operable and allows up to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to restore the loop(s) to operable status. CTS Action statement c addresses no RCS loops in operation and specifies immediate Actions to remedy this condition. However, CTS Action statement c does not address inoperable RCS loops. The corresponding ISTS Actions Conditions specify that the Action that allows for a 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months restoration time is applicable to the condition of only one required RCS loop inoperable. In addition, the ISTS Action Condition for no RCS loops in operation also provides the Actions for two inoperable RCS loops. The ISTS Condition for two loops not BVPS Units 1 and 2 Page 26 of 52 Rev. 1.5

Table M More Restrictive Changes Section 3.4 - Reactor Coolant System ITS # DOC # Description of Change ITS Requirement CTS Requirement CTS #

in operation or inoperable specifies immediate Actions. The CTS Actions are revised to conform to the ISTS Actions. This changes the CTS by limiting the application of the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months restoration Action time to the condition of a single inoperable RCS loop and assigning more immediate Actions to the Condition of 2 inoperable RCS loops.

ITS 3.4.5 M.3 Not used.

CTS 3.4.1.2 ITS 3.4.5 M.4 CTS 3.4.1.2.b requires two reactor coolant loops to be OPERABLE with each loop SR 3.4.5.2 NA CTS 3.4.1.2 consisting its associated steam generator, and the reactor coolant pump. CTS 3.4.1.2 does not contain any OPERABILITY requirements for the associated steam generator.

ISTS SR 3.4.5.2 requires verification that each required steam generator has the required secondary side water level every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The CTS is revised to conform to the ISTS.

This changes the CTS by adding a surveillance requirement to verify adequate steam generator secondary side level so the steam generator can perform its safety function (heat removal).

ITS 3.4.6 M.1 CTS 3.4.1.3, Action a, states that when less than the two required coolant loops are Action A, B Action a, b CTS 3.4.1.3 OPERABLE, immediate action must be taken to return the required loops to OPERABLE status as soon as possible and the unit must be in cold shutdown within 20 hours2.314815e-4 days 0.00556 hours 3.306878e-5 weeks 7.61e-6 months . CTS 3.4.1.3, Action b, states that when no coolant loops are in operation, all operations involving a reduction in boron concentration of the RCS must be suspended and action must be initiated to return the required coolant loop to operation. The corresponding ISTS 3.4.6, Condition A applies when one of the required coolant loops is inoperable and continues to require a transition to Mode 5. ISTS 3.4.6, Condition B, applies when two of the required coolant loops are inoperable or the required loop is not in operation. ISTS Condition B specifies additional immediate Actions for two inoperable loops to prevent boron dilution as well as the CTS Action a requirement to initiate action immediately to restore one coolant loop to operable status. This changes the CTS by revising the actions to be taken if both required coolant loops are inoperable. The ISTS requires additional Actions to prevent a dilution of the RCS boron concentration.

ITS 3.4.7 M.1 CTS 3.4.1.3 requires that two coolant loops must be OPERABLE in MODES 4 and 5 and LCO LCO CTS 3.4.1.3 one loop must be in operation. The CTS allows any combination of operable RCS loops and RHR loops and allows for either type of loop to be in operation. The corresponding ISTS 3.4.7 (applicable in Mode 5 only) also requires two operable loops but specifies that one RHR loop must be OPERABLE and in operation. In addition, the remaining required loop must be either the non-operating RHR loop or an RCS loop with the steam generator level within the required limit. The CTS is revised to conform to the ISTS. This changes BVPS Units 1 and 2 Page 27 of 52 Rev. 1.5

Table M More Restrictive Changes Section 3.4 - Reactor Coolant System ITS # DOC # Description of Change ITS Requirement CTS Requirement CTS #

the CTS LCO by requiring one RHR loop to be OPERABLE and in operation in MODE 5 when an RCS or RHR loop is allowed by the CTS. In addition, the proposed change further restricts the options for the second required loop. The CTS Action and surveillance are also revised to incorporate the requirements for one RHR loop to be operable and in operation.

ITS 3.4.8 M.1 CTS 3.4.1.3 Action a specifies the Action for inoperable loops. CTS Action a requires Actions Action a, b CTS 3.4.1.3 immediate Action to restore the loop(s) to operable status. CTS 3.4.1.3 Action b only addresses no loop in operation. The CTS Action requires immediate Action to restore as well as an Action to preclude dilution of the required boron concentration. The ISTS 3.4.8 Action that corresponds to CTS Action b also applies to the condition of "no required RHR loops operable". The CTS is revised to conform to the ISTS. This changes the CTS LCO by requiring the additional Action to preclude a boron dilution for the condition of "no required RHR loops operable.

ITS 3.4.8 M.2 CTS 3.4.1.3 footnote (4) provides an allowance for all reactor coolant pumps or RHR Note 1 footnote 4 CTS 3.4.1.3 pumps to be de-energized for up to one hour per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period. The corresponding ISTS 3.4.8 Note 1 allows all RHR pumps to be not in operation for 15 minutes only when switching from one RHR loop to the other. In addition, the ISTS 3.4.8 Note 1 contains an additional provision (c) that prohibits operations that would reduce the RCS water volume during the time that the RHR pumps are not in operation. The CTS is revised to conform to the ISTS.

ITS 3.4.17 M.1 CTS 3.4.1.4.1 Action a is applicable when an RCS isolation valve is closed. This action Action B Action a CTS requires that the valves be maintained closed and that the plant be placed in Mode 5 to 3.4.1.4.1 recover the isolated loop. The corresponding ISTS 3.4.17 Action Condition B contains the same requirement to place the plant in Mode 5. However, the ISTS Action is modified by a note that requires the Action to be completed whenever the Condition is entered. The CTS does not contain a similar note that requires that the action be completed whenever it is started. The CTS is revised to conform to the ISTS. This changes the CTS by requiring the Action to be in Mode 5 to be completed whenever it is started.

ITS 3.4.18 M.1 CTS 3.4.1.5 LCO requires that the hot and cold leg isolation valves be closed until the LCO, Action, & SR NA CTS 3.4.1.5 isolated portion of the loop has been drained and refilled from the RWST or RCS. In addition, the CTS LCO requires that the hot and cold leg isolation valves be closed if the boron concentration in the isolated loop is less than the minimum required to satisfy the requirements of Specification 3.1.1.2 (Mode 5 SDM) and Specification 3.9.1 (Mode 6 boron BVPS Units 1 and 2 Page 28 of 52 Rev. 1.5

Table M More Restrictive Changes Section 3.4 - Reactor Coolant System ITS # DOC # Description of Change ITS Requirement CTS Requirement CTS #

concentration). The corresponding ISTS 3.4.18 LCO requirements specify that the hot and cold leg isolation valves be closed if the boron concentration of the isolated loop is less than the boron concentration required to meet the SDM of LCO 3.1.1 (Mode 5) or boron concentration of LCO 3.9.1 (Mode 6). In addition, the ISTS LCO requires that the cold leg isolation valve be closed if the cold leg temperature of the isolated loop is > [20]°F below the highest cold leg temperature of the operating loops. The CTS is revised to be more consistent with the ISTS LCO requirements. However, the proposed change includes BVPS specific temperature requirements that differ from the ISTS temperature requirement described above. This changes the CTS by adding additional requirements (LCO, Action, and Surveillance) to verify an upper and lower temperature limit is met for the isolated loop being returned to service.

ITS 3.4.18 M.2 The CTS applicability for isolated loop startup states: "Whenever an RCS loop has been Applicability Applicability CTS 3.4.1.5 isolated greater than 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months or drained(1)." The footnote (1) identifies that fuel must be in the vessel. The corresponding ISTS Applicability simply states "MODES 5 and 6." The CTS Applicability is revised to conform to the ISTS Applicability. This changes the CTS by eliminating the 4-hour isolation or loop drained allowance in the CTS Applicability and requiring the LCO to be applicable at all times in Modes 5 and 6.

ITS 3.4.10 M.1 CTS 3.4.3 Action, requires that when one pressurizer safety valve is inoperable, it must be Actions Actions CTS 3.4.3 restored to OPERABLE status within 15 minutes or the plant must be placed in hot shutdown within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . In addition to requiring the plant to be placed in Mode 4 for the same condition, the corresponding ISTS 3.4.10 also requires that the plant must be placed in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The CTS is revised to incorporate this additional Action. This changes the CTS by requiring the unit to be in MODE 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

ITS 3.4.9 M.1 The CTS 3.4.4 Actions when the required pressurizer heater capacity is not met require Action C Actions CTS 3.4.4 that the plant be placed in Mode 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and Mode 4 in the following 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . As such, the CTS allows up to 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months to reach Mode 4. The corresponding ISTS Actions (Condition C) allows 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to be in Mode 3 and 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to be in Mode 4 from the start of the shutdown. The CTS Action time to Mode 4 is revised to conform to the ISTS Action time to Mode 4. This changes the CTS by reducing the total time allowed to reach Mode 4 from 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

ITS 3.4.9 M.2 CTS 3.4.4 requires that a bubble be maintained in the pressurizer but does not include any SR 3.4.9.1 NA CTS 3.4.4 surveillance to verify the LCO requirement is being met. The corresponding ISTS requirement is more specific in that it specifies a maximum pressurizer level (discussed in another DOC). The ISTS also contains a surveillance requirement to verify the pressurizer level requirement is met every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The CTS is revised to conform to the ISTS. This BVPS Units 1 and 2 Page 29 of 52 Rev. 1.5

Table M More Restrictive Changes Section 3.4 - Reactor Coolant System ITS # DOC # Description of Change ITS Requirement CTS Requirement CTS #

changes the CTS by adding a surveillance requirement to verify the pressurizer level requirement is met every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

ITS 3.4.13 NONE CTS 3.4.5 ITS 3.4.15 M.1 CTS Table 4.4-3 contains the surveillance requirements for the RCS leakage detection NA Table 4.3-3, #

CTS 3.4.6.1 radiation monitors. The CTS Table contains a # footnote that modifies the channel footnote calibration requirement for the radiation monitors. The CTS footnote states "# Surveillance interval may be extended to the upcoming refueling outage if the interval between refueling outages is greater than 18 months." The corresponding ISTS 3.4.15 does not contain a similar allowance. The CTS is revised to conform to the ISTS. This changes the CTS by deleting the # footnote.

ITS 3.4.13 NONE CTS 3.4.6.2 ITS 3.4.14 M.1 ISTS 3.4.14 Required Action A.1 is modified by a note that requires the following: "Each Action A.1, Note Action CTS 3.4.6.3 valve used to satisfy Required Action A.1 must have been verified to meet SR 3.4.14.1."

The corresponding CTS Action does not contain this requirement. The CTS is revised to conform to the ISTS. This changes the CTS by requiring that valves used to meet the Required Action must have been previously verified to meet the leakage limits specified in SR 3.4.14.1.

ITS 3.4.16 M.1 SR 3.4.16.3 Table 4.4-12 item 3 CTS Table 4.4-12 item 3 requires that E be determined once every 6 months. The CTS 3.4.8 corresponding ISTS surveillance SR 3.4.16.3 specifies that E be determined once per 184 days within 31 days after a minimum of 2 effective full power days and 20 days of Mode 1 operation have elapsed since the reactor was last subcritical for 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . The CTS is revised to be consistent with the ISTS. This changes the CTS by adding the ISTS restrictions to the requirement to determine E.

BVPS Units 1 and 2 Page 30 of 52 Rev. 1.5

Table M More Restrictive Changes Section 3.4 - Reactor Coolant System ITS # DOC # Description of Change ITS Requirement CTS Requirement CTS #

ITS 3.4.3 M.1 CTS 3.4.9.1 requires that the RCS temperature and pressure shall be limited in Applicability Applicability CTS 3.4.9.1 accordance with the PTLR during heatup, cooldown, criticality, and inservice leak and hydrostatic testing. CTS 3.4.9.1 is applicable in Modes 1, 2, 3, 4, and 5. The corresponding ISTS 3.4.3 states that the RCS pressure, temperature, and RCS heatup and cooldown rates shall be maintained within the limits specified in the PTLR. ISTS 3.4.3 is applicable "at all times". The CTS is revised to conform to the ISTS. This changes the CTS by eliminating the LCO requirement that the limits must be met during heatup, cooldown, and inservice leak and hydrostatic testing and revising the applicability from Modes 1-5 to "at all times."

ITS 3.4.3 M.2 CTS 3.4.9.1 Action requires that with any of the pressure or temperature limits exceeded, Action C Actions CTS 3.4.9.1 the temperature and/or pressure must be restored to within the limit within 30 minutes and an engineering evaluation must be performed to determine the effects of the out-of limit condition on the structural integrity of the RCS within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in at least hot standby within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and reduce the RCS Tavg and pressure to less than 200°F and 500 psig, respectively, within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . This CTS Action is applicable in Modes 1-

5. The corresponding ISTS Actions are divided into Actions applicable in Modes 1-4 and Actions applicable any time in other than Mode 1-4. The ISTS 3.4.3 Action Condition A and B applicable in Modes 1-4 are similar to the CTS Actions described above. However, the ISTS 3.4.3 Action Condition C, states that with the requirements of the LCO not met any time in other than MODE 1, 2, 3, or 4, initiate immediate action to restore the parameter(s) to within limits and determine the RCS is acceptable for continued operation prior to entering MODE 4. The CTS is revised to conform to the ISTS. This changes the CTS by adopting the new ISTS Action C that requires an immediate action to restore the parameters to within limits when the LCO is not met any time in other than MODE 1, 2, 3, or 4.

ITS 3.4.12 M.1 CTS surveillance 4.4.9.3.3 verifies an RCS vent of the specified size is available when SR 3.4.12.5 4.4.9.3.3 CTS 3.4.9.3 required. The surveillance requires that an open valve with remote position indication be verified open every 31 days. The corresponding ISTS surveillance SR 3.4.12.5 only U1 CTS provides the 31-day surveillance interval for valves that are locked or secured in the open 3.5.4.1.2 position. In the ISTS surveillance, unlocked open vent valves must be verified every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The CTS is revised to conform to the ISTS. This changes the CTS by requiring valves with remote position indication that are not locked or secured in the open position to be verified open every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months instead of every 31 days.

ITS 3.4.11 NONE CTS 3.4.11 BVPS Units 1 and 2 Page 31 of 52 Rev. 1.5

Table M More Restrictive Changes Section 3.4 - Reactor Coolant System ITS # DOC # Description of Change ITS Requirement CTS Requirement CTS #

ITS 3.4.19 M.1 Applies to Unit 1 only. CTS surveillance 4.10.5.2 specifies in part that a Channel SR 3.4.19.2 and 4.10.5.2 U1 CTS Functional Test be performed on the P-7 interlock function. The corresponding ITS SR 3.4.19.3 3.10.5 surveillance requirements (SR 3.4.19.2 and SR 3.4.19.3) specify a Channel Operational Test be performed on the P-10 and P-13 interlock functions and an Actuation Logic Test U2 CTS be performed on the P-7 interlock function. This changes the CTS by specifying more 3.10.4 specific (defined) surveillance requirements for each function.

BVPS Units 1 and 2 Page 32 of 52 Rev. 1.5

Table M More Restrictive Changes Section 3.5 - Emergency Core Cooling Systems ITS # DOC # Description of Change ITS Requirement CTS Requirement CTS #

ITS 3.5.1 NONE CTS 3.5.1 ITS 3.5.2 M.1 CTS 3.5.2 Action a requires, when one ECCS subsystem is inoperable, the ECCS Action B Action a CTS 3.5.2 subsystem be restored to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or the unit must be placed in HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . In this condition, ITS 3.5.2 Action A requires the ECCS train to be restored to OPERABLE status in 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . ITS 3.5.2 Action B requires the unit to be placed in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months if the Required Action and associated Completion Time for ITS 3.5.2 Action A are not met. This changes the CTS by requiring entry into MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

ITS 3.5.2 M.2 Unit 1 only. A new surveillance is added to the Unit 1 TS. The new ITS surveillance (SR SR 3.5.2.2 NA CTS 3.5.2 3.5.2.2) requires that the charging pump (i.e., HHSI pump) minimum flow valve (MOV-1CH-373) be verified open with power removed from the valve every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The ISTS does not contain a corresponding surveillance requirement. The inclusion of this new Unit 1 requirement is based on the existing Unit 2 CTS requirement for the corresponding Unit 2 valve.

ITS 3.5.3 NONE CTS 3.5.3 ITS 3.5.5 M.1 CTS 3.5.4 Action a requires when the seal injection flow is not within limit that the manual Action B Action a seal injection throttle valves are adjusted to restore the limits within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , or the unit U2 CTS must be placed in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within 3.5.4 the following 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . In this condition, ITS 3.5.5 Action A requires the manual seal U1 CTS throttle valves to be adjusted within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . ITS 3.5.5 Action B requires the unit to be 3.5.5 placed in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months if the Required Action and associated Completion Time for ITS 3.5.5 Action A are not met. This changes the CTS by requiring entry into MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months rather than 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months .

ITS 3.5.4 NONE CTS 3.1.2.8 BVPS Units 1 and 2 Page 33 of 52 Rev. 1.5

Table M More Restrictive Changes Section 3.6 - Containment Systems ITS # DOC # Description of Change ITS Requirement CTS Requirement CTS #

ITS 3.6.1 NONE CTS 3.6.1.1 ITS 3.6.1 NONE CTS 3.6.1.2 ITS 3.6.2 NONE CTS 3.6.1.3 ITS 3.6.4 NONE CTS 3.6.1.4 ITS 3.6.5 NONE CTS 3.6.1.5 ITS 3.6.1 NONE CTS 3.6.1.6 ITS 3.6.6 NONE CTS 3.6.2.1 ITS 3.6.7 M.1 Unit 2 only. CTS 3.6.2.2 Action statement a addresses a single inoperable Recirculation Actions Actions CTS 3.6.2.2 Spray System (RSS) subsystem (containing the A or B pump) and allows 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to restore the inoperable subsystem to operable status. CTS Action c addresses the inoperability of a single train of RSS subsystems (pumps A & C or pumps B & D). CTS Action c refers to CTS Action statement a for subsystems containing pumps A and B and refers to the appropriate ECCS Actions of CTS 3.5.2 or 3.5.3 for inoperable subsystems containing pumps C & D. The ECCS Actions that would be applicable to the RSS subsystems containing pumps C and D allow 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to restore an inoperable ECCS train in Modes 1-3 (CTS 3.5.2) similar to CTS 3.6.2.2 Action statement a for RSS subsystems BVPS Units 1 and 2 Page 34 of 52 Rev. 1.5

Table M More Restrictive Changes Section 3.6 - Containment Systems ITS # DOC # Description of Change ITS Requirement CTS Requirement CTS #

containing pumps A or B. The ECCS Actions applicable in Mode 4 (CTS 3.5.3) require that an inoperable ECCS train be restored to operable status within one hour. The ISTS does not address the BVPS Unit 2 specific RSS design which shares RSS components between the ECCS system and the RSS. As the BVPS Unit 2 RSS C and D pumps are shared between the RSS and ECCS, the proposed change includes specific RSS Actions that would be applied to inoperable subsystems containing the C and D pumps as well as the ECCS Actions that are currently referenced in the CTS for subsystems containing the C or D pumps. The proposed ITS 3.6.7 Action Condition C (applicable only to Unit 2) addresses any one subsystem inoperable or two subsystems inoperable in the same train.

The proposed Condition allows 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to restore the affected subsystem(s) to operable status. This changes the CTS by specifying new inclusive Actions for all the Unit 2 subsystems in the RSS TS instead of relying solely on the ECCS TS Actions for subsystems containing the C and D pumps.

ITS 3.6.7 M.2 The CTS 3.6.2.2 RSS Actions are revised by the addition of a new Action Condition Action E NA CTS 3.6.2.2 consistent with the ISTS. The addition of ITS Action Condition E provides an Action for the Condition of three inoperable subsystems and requires immediate entry into LCO 3.0.3.

The CTS is revised to conform to the ISTS Action Conditions. This changes the CTS by adding a specific requirement to enter LCO 3.0.3 when three RSS subsystems are inoperable.

ITS 3.6.8 M.1 The CTS 3.6.2.3 Action contains the default requirement if a chemical addition subsystem Action B Actions CTS 3.6.2.3 is not restored to operable status. The CTS default Action requires that the plant be in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ; restore the inoperable spray subsystem to OPERABLE status within the next 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or be in COLD SHUTDOWN within the next 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The CTS default Action allows a total time of 90 hours0.00104 days 0.025 hours 1.488095e-4 weeks 3.4245e-5 months to reach Mode 5 (6 + 48 +

36 = 90). The corresponding ISTS Action (ITS 3.6.8 Condition B) simply specifies be in Mode 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and be in Mode 5 in 84 hours9.722222e-4 days 0.0233 hours 1.388889e-4 weeks 3.1962e-5 months . The ITS Action provides a total of 84 hours9.722222e-4 days 0.0233 hours 1.388889e-4 weeks 3.1962e-5 months to reach Mode 5. The CTS is revised to conform to the ISTS. This changes the CTS Action by simplifying the required Actions and reducing the total time to reach Mode 5 from 90 hours0.00104 days 0.025 hours 1.488095e-4 weeks 3.4245e-5 months to 84 hours9.722222e-4 days 0.0233 hours 1.388889e-4 weeks 3.1962e-5 months .

ITS 3.6.3 NONE CTS 3.6.3.1 BVPS Units 1 and 2 Page 35 of 52 Rev. 1.5

Table M More Restrictive Changes Section 3.7 - Plant Systems ITS # DOC # Description of Change ITS Requirement CTS Requirement CTS #

ITS 3.7.1 NONE CTS 3.7.1.1 ITS 3.7.5 M.1 CTS 3.7.1.2 Action d currently applies to two inoperable AFW trains and requires that the Action D Action d CTS 3.7.1.2 affected unit be placed in a Mode where the two inoperable AFW trains are no longer required operable. The mode reductions required by the CTS Action are acceptable because of the availability of the remaining operable AFW train. If three AFW trains are inoperable, the CTS Action e precludes any Mode transitions that may place the plant in a condition that could increase the likelihood that the AFW would be required to support decay heat removal and requires that one AFW train be restored to operable status prior to initiating a plant transient. The corresponding ISTS Action Condition D for two inoperable AFW trains also contains a provision for three inoperable AFW trains and requires a plant shutdown to Mode 4 be made. The provision of the ISTS Action D for three inoperable AFW trains in MODE 1, 2 or 3 applies only to a turbine-driven AFW pump that is inoperable solely due to one required steam supply line being inoperable. Conversely, the ISTS Action E for three inoperable AFW trains (applicable when the turbine-driven AFW pump is inoperable for reasons other than a single inoperable steam supply line) continues to require the restoration of one AFW train prior to placing the plant in Mode 4. The corresponding CTS Actions are revised to incorporate this provision of the ISTS Actions.

This changes the CTS by requiring a plant shutdown to Mode 4 when three AFW trains are inoperable if the turbine-driven pump is inoperable solely due to a single required steam supply being inoperable.

ITS 3.7.5 M.2 CTS surveillance 4.7.1.2.7 is revised by CTS Note 7 that states: "This surveillance is SR 3.7.5.5 4.7.1.2.7, Note 7 CTS 3.7.1.2 required to be performed prior to entry into MODE 2 whenever the plant has been in MODES 5 or 6 for greater than 30 continuous days." The corresponding ISTS surveillance contains a similar frequency for performance with the exception that the ISTS specifies that the surveillance is applicable after the plant has been in a "defueled" condition as well as in Modes 5 and 6. The CTS is revised to conform to the ISTS. This changes the CTS by expanding the operating conditions for which the cumulative time is tracked by CTS surveillance 4.7.1.2.7. As such, the proposed change requires the time spent in a defueled condition be accounted for as well as the time spent in Modes 5 and 6 for determining when surveillance 4.7.1.2.7 must be performed.

ITS 3.7.6 M.1 CTS 3.7.1.3 specifies requirements for the PPDWST that are applicable in MODES 1, 2, Applicability Applicability CTS 3.7.1.3 and 3. ITS 3.7.6 specifies requirements are applicable in MODES 1, 2, 3, and MODE 4 when a steam generator is relied upon for heat removal. The CTS has been revised to incorporate the additional Mode of Applicability for MODE 4 when a steam generator is BVPS Units 1 and 2 Page 36 of 52 Rev. 1.5

Table M More Restrictive Changes Section 3.7 - Plant Systems ITS # DOC # Description of Change ITS Requirement CTS Requirement CTS #

relied upon for heat removal. Consistent with this change in the Mode of Applicability, the phrase Be in MODE 4, without reliance on steam generator for heat removal is added as specified in ITS 3.7.6 Required Action B.2. This changes the CTS requirements by requiring the PPDWST to be Operable in MODE 4 when a steam generator is relied upon for heat removal.

ITS 3.7.6 M.2 CTS 3.7.1.3 Action b allows 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to demonstrate Operability of the reactor plant river Action A.1 Action b CTS 3.7.1.3 water system (Unit 1) or the service water system (Unit 2) as a backup water supply to the auxiliary feedwater pumps whenever the PPDWST is inoperable. ITS 3.7.6 Required Action A.1 allows 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to verify by administrative means the Operability of the backup water supply and requires a verification of the backup water supply be performed every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter whenever the PPDWST is inoperable. This changes the CTS by requiring the plant to perform verifications every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months of the backup water supply Operability.

The verifications follow the initial 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months verification and continues through the 7 days the PPDWST is allowed to be inoperable. The CTS has been revised to incorporate the additional Completion Time for the backup water supply Operability verification.

ITS 3.7.6 M.3 CTS 3.7.1.3 Action b states that if demonstration of the Operability of the backup water Action B Action b CTS 3.7.1.3 supply is not satisfied and if the PPDWST is not restored to Operable status within 7 days, the plant must be in HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . ITS 3.7.6 Condition B states that if verification of the Operability of the backup water supply is not satisfied or an inoperable PPDWST is not restored to OPERABLE status within 7 days, the plant must be in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 4 without reliance on the steam generators for heat removal within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . This changes the CTS to require the plant to be in MODE 3 within six hours prior to satisfying the MODE 4 requirement. The CTS has been revised to incorporate the additional MODE step requirement.

ITS 3.7.13 M.1 CTS Table 4.7-2 Item #2 allows the sampling frequency for the DOSE EQUIVALENT I-131 NA Table 4.7-2, Item #

CTS 3.7.1.4 to be extended to once per 6 months whenever the gross activity determination indicates 2 the iodine concentrations are below 10% of the allowable limits. ISTS SR 3.7.18.1 (ITS SR 3.7.13.1) does not provide for this extended time frame for determining the DOSE EQUIVALENT I-131 and requires verification of specific activity of the secondary coolant every 31 days whenever the unit is in MODES 1, 2, 3, and 4. The CTS surveillance is revised to conform to the ISTS fixed surveillance frequency of 31 days for determining DOSE EQUIVALENT I-131. This changes the CTS by revising the specified frequency for determining DOSE EQUIVALENT I-131 to 31 days instead of referencing the program specified on CTS Table 4.7-2. The proposed change also eliminates the need for CTS Table 4.7-2.

BVPS Units 1 and 2 Page 37 of 52 Rev. 1.5

Table M More Restrictive Changes Section 3.7 - Plant Systems ITS # DOC # Description of Change ITS Requirement CTS Requirement CTS #

ITS 3.7.2 M.1 CTS 3.7.1.5 Action for MODE 1 requires that when one MSIV is inoperable, the valve is to Actions Actions CTS 3.7.1.5 be restored to OPERABLE status within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months or the unit is to be in HOT SHUTDOWN (MODE 4) within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . ITS Action A allows 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to restore an inoperable MSIV to OPERABLE status when in MODE 1, and an additional 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to be in MODE 2.

The total CTS Completion Time from MSIV inoperability to exiting MODE 1 is 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months .

The total ITS Completion Time from MSIV inoperability to exiting MODE 1 is 14 hours1.62037e-4 days 0.00389 hours 2.314815e-5 weeks 5.327e-6 months .

This reduces the CTS Completion Time to restore an inoperable MSIV by 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months (16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months versus 14 hours1.62037e-4 days 0.00389 hours 2.314815e-5 weeks 5.327e-6 months ).

ITS 3.7.2 M.2 CTS 3.7.1.5 Actions for MODES 2, and 3 states subsequent operation in MODES 2 or 3 Actions Actions CTS 3.7.1.5 may proceed provided the inoperable MSIV is maintained closed. The CTS does not require further verification of the MSIV position after it is closed. If the valve is not maintained closed, the unit must be in HOT SHUTDOWN (MODE 4) within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The CTS does not include a specific time in which the unit must be placed in Mode

3. Thus, the CTS would allow continued operation in Modes 2 and 3 with an open and inoperable MSIV for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months before Mode 4 must be entered. The CTS Action does not require the inoperable MSIV be closed prior to the 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowed to transition into Mode 4. Since in Mode 4 the MSIV is not required operable, the CTS does not require the MSIV to be closed. The corresponding ITS 3.7.2 Required Actions C.1 requires an inoperable MSIV to be closed within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and Required Action C.2 requires the valve to be verified closed once per 7 days. Thus, the ITS limits operation with an open inoperable MSIV to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . Additionally, the ISTS requires a continuous check of the valve position to verify that it is closed while operating in Modes 2 or 3 (which is not required by the CTS).

As long as the requirements of C.1 and C.2 are met, the ISTS permits continued operation in Modes 2 and 3. Otherwise, ISTS Condition D requires the unit to be placed in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The CTS is revised to conform to the ISTS.

This changes the CTS by specifying a time within which an inoperable MSIV must be closed (8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ) and requiring periodic verification that the inoperable MSIV is closed. In addition, the CTS has been changed to add a specific time the unit is required to be in MODE 3 (within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ).

ITS 3.7.2 M.3 The CTS does not require testing to verify that the MSIVs close on an actuation signal. SR 3.7.2.2 NA CTS 3.7.1.5 ITS SR 3.7.2.2 requires verification that each MSIV actuates to the isolation position on an actual or simulated actuation signal. This changes the CTS by requiring verification that each MSIV actuates to the isolation position on an actual or simulated actuation signal.

ITS 3.7.3 M.1 CTS does not have any requirement for main feedwater isolation valves (MFIVs), main 3.7.3 NA CTS NA feedwater regulating valves (MFRVs), and associated bypass valves to be OPERABLE, other than a requirement for an actuation signal to be supplied to the valves in CTS 3.3.2.1. ITS 3.7.3 requires the MFIVs, MFRVs, and associated bypass valves be BVPS Units 1 and 2 Page 38 of 52 Rev. 1.5

Table M More Restrictive Changes Section 3.7 - Plant Systems ITS # DOC # Description of Change ITS Requirement CTS Requirement CTS #

OPERABLE in MODES 1, 2, and 3. This changes the CTS by incorporating the requirements of ITS 3.7.3.

ITS 3.7.7 M.1 CTS 3.7.3.1 Action currently contains no requirement to enter applicable Actions of CTS Action Note Actions CTS 3.7.3.1 3.4.1.3, RCS Loops and Coolant Circulation - Shutdown for RHR loops made inoperable by CCW. ITS 3.7.7 Required Action A.1 Note provides this requirement. The CTS is revised to conform to the ITS. This changes the CTS by adding a note to the CTS Actions requiring entry into the applicable Conditions and Required Actions of LCO 3.4.6, RCS Loops - Mode 4 for RHR loops made inoperable by CCW.

ITS 3.7.8 M.1 CTS 3.7.4.1 Action currently contains no requirement to enter applicable Actions of CTS Action A.1 Note NA CTS 3.7.4.1 3.4.1.3, RCS Loops and Coolant Circulation - Shutdown for RHR loops made inoperable by SWS or CTS 3.8.1.1, A. C. Sources for emergency diesel generator made inoperable by SWS. ITS 3.7.8 Required Action A.1 Note provides this requirement. The CTS is revised to conform to the ISTS. This changes the CTS by adding a note to the CTS Actions requiring entry into the applicable Conditions and Required Actions of LCO 3.4.6, RCS Loops - Mode 4 for RHR loops made inoperable by SWS and LCO 3.8.1, A. C.

Sources - Operating for an emergency diesel generator made inoperable by SWS.

ITS 3.7.8 M.2 CTS 4.7.4.1.c requires the cycling of power operated valves in the SWS flow path servicing SR 3.7.8.2 & SR 4.7.4.1.c CTS 3.7.4.1 safety related equipment that is not testable during plant operation once per 18 months 3.7.8.3 during shutdown. ITS SR 3.7.8.2 requires every 18 months the verification that each SWS automatic valve in the flow path that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal. ITS SR 3.7.8.3 requires every 18 months the verification that each SWS pump starts automatically on an actual or simulated actuation signal. The CTS has been revised to incorporate the new ISTS surveillance requirements.

ITS 3.7.9 NONE CTS 3.7.5.1 ITS 3.7.4 M.1 The BVPS CTS does not contain any requirements for the steam generator (SG) 3.7.4 NA CTS NA atmospheric dump valve (ADV) lines. Currently BVPS controls the operability of the ADV lines outside of the Technical Specifications. ISTS 3.7.4 specifies requirements for the ADV lines. The CTS is revised by adopting a BVPS specific version of ISTS 3.7.4. This changes the CTS by incorporating new Technical Specification requirements for the SG BVPS Units 1 and 2 Page 39 of 52 Rev. 1.5

Table M More Restrictive Changes Section 3.7 - Plant Systems ITS # DOC # Description of Change ITS Requirement CTS Requirement CTS #

ADV lines based on ISTS 3.7.4.

ITS 3.7.11 NONE CTS 3.7.6 ITS 3.7.10 NONE CTS 3.7.7.1 (U1) &

CTS 3.7.7 (U2)

ITS NA NONE CTS 3.7.8.1 ITS 3.7.12 M.1 Unit 2 only. The Unit 2 CTS requirements for SLCRS do not include a requirement to SR 3.7.12.3 NA CTS 3.9.12 verify the fuel building integrity by verifying that the required SLCRS can maintain a negative pressure in the fuel building. The proposed ITS 3.7.12 includes a surveillance requirement (SR 3.7.12.3) to verify a SLCRS train can maintain the Unit 2 fuel building at a negative pressure. The proposed new surveillance contains a note that clarifies the surveillance is only applicable for fuel movement involving recently irradiated fuel in the fuel storage pool. The Note is necessary as the Unit 1 SLCRS is also required operable for fuel movement involving recently irradiated fuel inside containment. The new surveillance is only for the fuel building integrity and would not be appropriate if the Unit 1 SLCRS was only required for fuel movement inside containment. The containment penetration refueling requirements are addresses in ITS 3.9.3 of the technical specifications. The note does not affect the Unit 2 surveillance as the Unit 2 SLCRS is only required for fuel movement in the fuel building. Thus, the Unit 2 CTS is revised by the addition of a new surveillance requirement.

ITS 3.7.15 M.1 CTS 3.9.11 specifies the minimum spent fuel storage pool water level. If the required Action Action CTS 3.9.11 water level is not met the CTS 3.9.11 Action specifies that the movement of irradiated fuel assemblies and fuel assemblies over irradiated fuel assemblies be suspended. The corresponding ITS 3.7.15 Required Action is the same except that the ITS Action requires BVPS Units 1 and 2 Page 40 of 52 Rev. 1.5

Table M More Restrictive Changes Section 3.7 - Plant Systems ITS # DOC # Description of Change ITS Requirement CTS Requirement CTS #

an "immediate" suspension of the specified fuel movement. The CTS Action is revised to be consistent with the ITS Action. This changes the CTS by adding the requirement that movement be suspended immediately.

ITS 3.7.14 NONE CTS 3.9.14 ITS 3.7.16 M.1 Action b of CTS 3.9.14 (Unit 1 only) does not require the initiation of action to restore fuel Actions Action b CTS 3.9.14 storage pool boron concentration to within limit whenever the limit is not met. ITS 3.7.16 (U1) requires the immediate initiation of action to restore fuel storage pool boron concentration to within limit whenever the limit is not met. This changes the CTS by adding a specific CTS 3.9.15 requirement to restore the boron concentration parameter.

(U2)

ITS 3.7.16 M.2 Unit 1 only. CTS 3.9.14 LCO requires that the specified boron concentration be LCO & LCO & Applicability CTS 3.9.14 maintained in the spent fuel pool when moving fuel in the spent fuel pool. The CTS 3.9.14 Applicability (U1) Applicability states during storage of fuel in the spent fuel pool. The Applicability of the corresponding ITS 3.7.16 requires the specified boron concentration be maintained in the CTS 3.9.15 fuel storage pool when fuel assemblies are stored in the fuel storage pool and a fuel (U2) storage pool verification has not been performed since the last movement of fuel assemblies in the fuel storage pool. ITS 3.7.16 also includes a new Action to perform a fuel storage pool verification in addition to the CTS requirement to stop moving fuel. The Unit 1 CTS is revised to conform to the ISTS requirements.

BVPS Units 1 and 2 Page 41 of 52 Rev. 1.5

Table M More Restrictive Changes Section 3.8 - Electrical Power Systems ITS # DOC # Description of Change ITS Requirement CTS Requirement CTS #

ITS 3.8.1 ITS M.1 Unit 1 CTS LCO 3.8.1.1 and surveillances do not contain any requirements for DG LCO 3.8.3, SR NA 3.8.3 lubricating oil. ITS LCO 3.8.3 states the stored diesel lube subsystem shall be within limits 3.8.3.2 CTS 3.8.1.1 for each required DG. ITS Condition B allows less than the 7-day supply of lube oil for 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . ITS SR 3.8.3.2 requires verification that the lubricating oil inventory is the specified volume every 31 days. This changes the Unit 1 CTS by adding requirements to maintain a DG lube oil inventory (ITS 3.8.3 LCO, Action and Surveillance).

ITS 3.8.1 ITS M.2 Unit 1 CTS surveillance requirement 4.8.1.1.2.a.6 states that the generator is capable of SR 3.8.1.3 4.8.1.1.2.a.6 3.8.3 being synchronized to the bus, loaded to 1425 kW, and operated for 60 minutes. ITS CTS 3.8.1.1 SR 3.8.1.3 states that the DG is capable of being synchronized to the bus, operated for 60 minutes at a load of 2340 kW and 2600 kW. This changes the CTS loading requirement for the DG to a greater value.

ITS 3.8.1 ITS M.3 Not used.

3.8.3 CTS 3.8.1.1 ITS 3.8.1 ITS M.4 CTS surveillance requirement 4.8.1.1.2.b.5 requires each diesel to be tested every 18 SR 3.8.1.10 4.8.1.1.2.b.5 3.8.3 months during shutdown to a specific kW load for 60 minutes. The loading for Unit 1 is CTS 3.8.1.1 2750 kW and Unit 2 load is 4238 kW. ITS SR 3.8.1.10 states that each DG is loaded. Unit 1 is required to run for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months at a load of 2750 kW and 2850 kW. Unit 2 is required to run for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months at a load of 4238 kW and 4535 kW. Three notes modify the SR. Notes 1 and 2 are addressed by a less restrictive discussion of change. Note 3 states if the SR is performed with the DG synchronized with offsite power, it shall be performed at a power factor of 0.9. Additionally, the note states that if grid conditions do not permit, the power factor limit is not required to be met. The note goes on to state that under this condition, the power factor shall be maintained as close to the limit as possible. This changes the CTS by specifying a loading band, and specifying a power factor limit for each DG for this test.

ITS 3.8.1 ITS M.5 Not used.

3.8.3 CTS 3.8.1.1 ITS 3.8.1 ITS M.6 Not used.

3.8.3 CTS 3.8.1.1 ITS 3.8.1 ITS M.7 Not used.

3.8.3 CTS 3.8.1.1 BVPS Units 1 and 2 Page 42 of 52 Rev. 1.5

Table M More Restrictive Changes Section 3.8 - Electrical Power Systems ITS # DOC # Description of Change ITS Requirement CTS Requirement CTS #

ITS 3.8.1 ITS M.8 Not used.

3.8.3 CTS 3.8.1.1 ITS 3.8.1 ITS M.9 CTS surveillance requirements for LCO 3.8.1.1 do not require a test of the diesel generator SR 3.8.1.11 NA 3.8.3 capability to carry emergency loads, transfer those loads to offsite source upon a simulated CTS 3.8.1.1 restoration of the offsite power, transfer loads to offsite power source, and return to the specified position. ITS SR 3.8.1.11 requires verification for each DG that it is capable of synchronizing with the offsite power source while carrying emergency loads. Upon a simulated restoration of offsite power, the emergency loads would be transferred to the offsite source and the DG would return to a specified condition. The Unit 2 DGs would return to a ready-to-load position and the Unit 1 DGs would be required to proceed through the shutdown sequence. The surveillance is required to be performed every 18 months. A note modifies the SR. The note states this surveillance shall not normally be performed in MODE 1, 2, 3, and 4. The note allows the performance of the SR in MODES 1, 2, 3, and 4 to reestablish OPERABILITY for the DG provides an assessment can determine that the safety of the plant can be maintained or enhanced. This changes the CTS by requiring each DG demonstrate the described requirements every 18 months.

ITS 3.8.1 ITS M.10 Unit 2 CTS surveillance requirements for LCO 3.8.1.1 do not require a diesel generator, SR 3.8.1.12 NA 3.8.3 while operating in a test mode and connected to its emergency bus, to override the test CTS 3.8.1.1 mode, return the DG to a ready-to-load. ITS SR 3.8.1.12 requires verification that with a DG operating in a test mode and connected to its bus, an actual or simulated ESF actuation signal overrides the test mode. The actual or simulated signal would cause the DG to return to the ready-to-load condition. The surveillance is required to be performed every 18 months. Two notes modify the SR. Note 1 states that the SR is only applicable to Unit 2 only. The second note states this surveillance shall not normally be performed in MODE 1, 2, 3, and 4. The note allows portions of the SR to be performed in MODES 1, 2, 3, and 4 to reestablish OPERABILITY for the DG provides an assessment can determine that the safety of the plant can be maintained or enhanced. This changes the CTS by requiring each Unit 2 DG to demonstrate the described requirements every 18 months.

ITS 3.8.1 ITS M.11 CTS SR 4.8.1.1.2.b.2 requires the verification of the diesel generator capability to reject a SR 3.8.1.8 4.8.1.1.2.b.2 3.8.3 load. This surveillance is required to be performed every 18 months during shutdown. ITS CTS 3.8.1.1 SR 3.8.1.8 contains the requirement to verify that a DG has the capability to reject its associated single largest post-accident load. Two notes modify the SR. Note 1 is addressed in a less restrictive change. Note 2 requires the performance of the SR with the DG synchronized with offsite power with a power factor of 0.9. The note allows, if grid conditions do not permit, the power factor limit to not be met, be maintained as close as possible to the limit. This changes the CTS by requiring the performance of the SR with a power factor limit.

BVPS Units 1 and 2 Page 43 of 52 Rev. 1.5

Table M More Restrictive Changes Section 3.8 - Electrical Power Systems ITS # DOC # Description of Change ITS Requirement CTS Requirement CTS #

ITS 3.8.1 ITS M.12 CTS surveillance requirement 4.8.1.1.2.a.6 requires the verification that the generator is SR 3.8.1.3 4.8.1.1.2.a.6 3.8.3 synchronized, loaded to the bus at a specific kW rating, and operated for 60 minutes or CTS 3.8.1.1 longer. ITS SR 3.8.1.3 requires the verification that each DG is synchronized and load and operates for 60 minutes within a given load band. Four notes modify the SR. Note 1 is addressed by an administrative change and note 2 is addressed by a less restrictive change. Note 3 states that the surveillance shall be conducted on only one DG at a time.

Note 4 requires the SR shall be preceded by and immediately follow without shutdown a successful performance of SR 3.8.1.2. This changes the CTS by allowing only one DG at a time to be tested and the loading of the DG shall only be conducted after specific start requirements.

ITS 3.8.1 ITS M.13 CTS surveillance 4.8.1.1.2.c.1 requires the diesel generator day tank to be checked for SR 3.8.1.5.1 4.8.1.1.2.c.1 3.8.3 water and the accumulated water removed. The corresponding ITS SR 3.8.1.5.1 requires CTS 3.8.1.1 both the day and engine mounted tanks to be checked for water and accumulated water removed. This changes the CTS by adding the requirement to check for and remove accumulated water from the engine mounted tank.

ITS 3.8.1 ITS M.14 CTS 3.8.1.1 does not require specific limits or requirements for starting air system for DG LCO 3.8.3, Action NA 3.8.3 OPERABILITY. ITS LCO 3.8.3 adds a requirement for starting air system to be E, SR 3.8.3.4 CTS 3.8.1.1 OPERABLE when an associated DG is required to be OPERABLE. ITS 3.8.3 Condition E is added and specifies the appropriate Action for the air start system when the air pressure is not within the limit. ITS SR 3.8.3.4 is added and requires the verification of each DG air start receiver pressure is the required limit every 31 days. This changes the CTS by adding the appropriate requirements for starting air system to ensure DG OPERABILITY.

ITS 3.8.1 ITS M.15 CTS surveillance requirement 4.8.1.1.2.b.2 requires a verification that the generator (DG) SR 3.8.1.8 4.8.1.1.2.b.2 3.8.3 is capable of rejecting a load 825 kw without tripping and without exceeding 64.4 Hz for CTS 3.8.1.1 Unit 2. Unit 1 surveillance requirement states; verify the generator capability to reject a load of 615 kw without tripping and without exceeding 66.2 Hz. ITS SR 3.8.1.8 states Verify each DG rejects a load greater than or equal to its associated single largest post-accident load, and following load rejection, the frequency is 66.2 Hz (Unit 1) or 64.4 Hz (Unit 2). The SR additionally requires that within 3 seconds following load rejection, the voltage is 4106 V and 4368 V for (Unit 1), or 3994 V and 4368 V for (Unit 2), and within 4 seconds following load rejection, the frequency is 58.8 Hz and 61.2 Hz (Unit 1) or 59.9 Hz and 60.3 Hz (Unit 2). This changes the CTS by adding additional requirements to the surveillance requirement.

ITS 3.8.1 ITS M.16 CTS Action a requires with one offsite circuit inoperable, it must be restored to OPERABLE Action A & B Action a & b 3.8.3 status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . CTS Action b states with one diesel generator inoperable, it must CTS 3.8.1.1 be restored to OPERABLE status within 14 days. The corresponding ITS Action A requires with one offsite circuit inoperable, the circuit must be restored to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months and within 17 days from discovery of failure to meet the LCO. Corresponding ITS BVPS Units 1 and 2 Page 44 of 52 Rev. 1.5

Table M More Restrictive Changes Section 3.8 - Electrical Power Systems ITS # DOC # Description of Change ITS Requirement CTS Requirement CTS #

Action B states with one DG inoperable, the DG must be restored to OPERABLE status within 14 days and within 17 days from discovery of failure to meet the LCO. The CTS is revised to conform to the ITS. This changes the CTS by adding an additional restriction for an inoperable offsite circuit or DG that limits the total time for not meeting the LCO.

ITS 3.8.2 None CTS 3.8.1.2 ITS 3.8.7 M.1 CTS LCO 3.8.2.1 provides the requirements for the AC 4160 volt and AC 120 volts buses. Action A & B Action a ITS 3.8.9 CTS LCO 3.8.2.1 Actions a requires for the AC 4160 volt buses, With one of the required trains of A.C. emergency busses not fully energized, re-energize the train within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

CTS 3.8.2.1 CTS LCO 3.8.2.1 Action b states for the AC 120 volts buses, With one A.C. Vital Bus not energized, re-energize the A.C. Vital Bus within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . ITS LCO 3.8.9 provides the requirements for the distributions subsystems for the AC 4160 volts and AC 120 volts buses. ITS 3.8.9 Action A states with one or more AC electrical power distributions subsystems inoperable, restore AC electrical power distribution subsystem(s) to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of failure to meet LCO. ITS 3.8.9 Action B requires with one or more AC vital buses inoperable, restore AC vital bus subsystem(s) to OPERABLE status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months and 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of failure to meet LCO. This changes the CTS by adding the requirement, and 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of failure to meet LCO.

ITS 3.8.7 M.2 CTS surveillance requirement 4.8.2.1 states The specified busses shall be determined SR 3.8.7.1 4.8.2.1 ITS 3.8.9 energized in the required manner at least once per 7 days by verifying correct breaker alignment and indicated voltage on the busses. ITS SR 3.8.7.1 requires verification of the CTS 3.8.2.1 correct inverter voltage and alignment to required AC vital buses. This changes the CTS by specifying each inverter is supplying the correct voltage instead of simply indicating voltage.

ITS 3.8.7 M.3 CTS surveillance requirement 4.8.2.1 states The specified busses shall be determined SR 3.8.9.1 4.8.2.1 ITS 3.8.9 energized in the required manner at least once per 7 days by verifying correct breaker alignment and indicated voltage on the busses. ITS SR 3.8.9.1 requires the verification of CTS 3.8.2.1 correct breaker alignments and voltage to AC and AC vital bus electrical power distribution subsystems. This changes the CTS by specifying each inverter is supplying the correct voltage instead of simply indicating voltage.

ITS 3.8.8 M.1 CTS surveillance requirement 4.8.2.2 states The specified busses shall be determined SR 3.8.8.1 4.8.2.2 energized in the required manner by verifying correct breaker alignment and indicated BVPS Units 1 and 2 Page 45 of 52 Rev. 1.5

Table M More Restrictive Changes Section 3.8 - Electrical Power Systems ITS # DOC # Description of Change ITS Requirement CTS Requirement CTS #

ITS 3.8.10 voltage on the busses. ITS SR 3.8.8.1 requires verification of correct inverter voltage and CTS 3.8.2.2 alignments to required AC vital buses. This changes the CTS by specifying each inverter supplies the correct voltage.

ITS 3.8.8 M.2 CTS surveillance requirement 4.8.2.2 states The specified busses shall be determined SR 3.8.10.1 4.8.2.2 ITS 3.8.10 energized in the required manner by verifying correct breaker alignment and indicated voltage on the busses. ITS SR 3.8.10.1 requires the verification of correct breaker CTS 3.8.2.2 alignments and voltage to required AC and AC vital bus electrical power distribution subsystems. This changes the CTS by specifying each inverter supplies the correct voltage.

ITS 3.8.4 M.1 CTS LCO 3.8.2.3 Action a specifies with one of the required battery banks inoperable, 3.8.9 Condition C Action a ITS 3.8.6 restore the inoperable battery bank to OPERABLE status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . ITS LCO 3.8.9 Condition C requires with one or more DC electrical power subsystems inoperable, restore ITS 3.8.9 the DC electrical power subsystem to OPERABLE status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . ITS LCO 3.8.9 CTS 3.8.2.3 Condition C provides an additional limitation on the Completion Time. This specifies the two-hour requirement and 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of failure to meet the LCO. This changes the CTS by requiring an additional limitation that is not currently required.

ITS 3.8.4 M.2 Unit 2 CTS LCO 3.8.2.3 Action b in part states with one of the required full capacity 3.8.4 Action A Action b ITS 3.8.6 chargers inoperable, demonstrate the OPERABILITY of its associated battery bank by performing Surveillance Requirement 4.8.2.3.2.a.1 within one hour. The action allows with ITS 3.8.9 an inoperable charger in Unit 2, the spare 2 - 7 charger to be substituted for an inoperable CTS 3.8.2.3 charger within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months with no additional requirements specified. ITS LCO 3.8.4 Condition A states with one or two battery chargers on one train inoperable, restore battery terminal voltage to greater than or equal to the minimum established float voltage within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months is specified by Required Action A.1. Required Action A.2 states a verification of float current of 2 amps is required once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . Required Action A.3 specifies that the inoperable charger(s) must be restored to OPERABLE status within 7 days. This changes the Unit 2 CTS by deleting the allowance to substitute the 2-7 charger within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for a required charger.

ITS 3.8.4 M.3 CTS surveillance requirement 4.8.2.3.2.a.1 requires once per 7 days that the battery bank SR 3.8.6.1 4.8.2.3.2.a.1 ITS 3.8.6 be demonstrated OPERABLE by verifying all Category A parameters, listed in Table 3.8-1, are within specified limits for each pilot cell. The Category A parameters are electrolyte ITS 3.8.9 level, float voltage, and specific gravity. Two notes modify specific gravity requirements in CTS 3.8.2.3 CTS Table. Note (a) modifies the general requirement for specific gravity and states Corrected for electrolyte temperature and level. Note (b) modifies the Category A and the allowable values of the Category B limits and states Or battery charging current is less than (2) amps when on charge. The Category B limits apply to each connected cell. ITS SR 3.8.6.1 requires that the float current for each battery is verified 2 amps every 7 days.

BVPS Units 1 and 2 Page 46 of 52 Rev. 1.5

Table M More Restrictive Changes Section 3.8 - Electrical Power Systems ITS # DOC # Description of Change ITS Requirement CTS Requirement CTS #

A Note modifies the SR. The Note states Not required to be met when battery terminal voltage is less than the minimum established float voltage of SR 3.8.4.1 This changes the CTS by eliminating a method for determining specific gravity requirements.

ITS 3.8.4 M.4 CTS 4.8.2.3.2.b.1 states the parameters in Table 3.8-1 meet the Category B limits every 92 SR 3.8.6.3 4.8.2.3.2.b.1 ITS 3.8.6 days and within 7 days after a battery discharge or overcharge condition. Category B parameters applies to each connected cell. ITS SR 3.8.6.3 states Verify each battery ITS 3.8.9 connected cell electrolyte level is greater than or equal to minimum established design CTS 3.8.2.3 limits, every 31 days. This changes the CTS by requiring each connected cell electrolyte level be verified every 31 days instead of 92 days.

ITS 3.8.4 M.5 CTS surveillance requirement 4.8.2.3.1 requires the specified busses to be determined SR 3.8.9.1 4.8.2.3.1 ITS 3.8.6 operable and energized by verifying correct breaker alignment and indicated power availability. ITS SR 3.8.9.1 requires verification of correct voltage and breaker alignments ITS 3.8.9 for the required buses. This changes the CTS by specifying the indicated bus voltage is the CTS 3.8.2.3 correct voltage.

ITS 3.8.5 CTS surveillance requirement 4.8.2.4.1 requires the specified busses to be determined SR 3.8.10.1 4.8.2.4.1 ITS 3.8.10 operable and energized by verifying correct breaker alignment and indicated power availability. ITS SR 3.8.10.1 requires verification of correct voltage and breaker alignments CTS 3.8.2.4 for the required buses. This changes the CTS by specifying the indicated bus voltage is the correct voltage.

BVPS Units 1 and 2 Page 47 of 52 Rev. 1.5

Table M More Restrictive Changes Section 3.9 - Refueling Operations ITS # DOC # Description of Change ITS Requirement CTS Requirement CTS #

ITS 3.9.1 NONE CTS 3.9.1 ITS 3.9.2 M.1 The CTS 3.9.2 LCO exception that allows only one source range monitor to be operable LCO LCO CTS 3.9.2 during installation of the upper internals is eliminated. This exception does not exist in the ISTS. This changes the CTS by eliminating an exception to the LCO requirements.

ITS 3.9.2 M.2 CTS Action b for two inoperable source range monitors is revised by the addition of a new Action Action CTS 3.9.2 Action requirement consistent with the corresponding Required Actions of the ISTS. The ISTS Action to " initiate action to restore one source range neutron flux monitor to OPERABLE status immediately" is added to the existing CTS Action to verify the RCS boron concentration every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

ITS 3.9.2 M.3 CTS 4.9.2 requires a CHANNEL CHECK to be performed once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months during CORE SR 3.9.2.1 4.9.2 CTS 3.9.2 ALTERATIONS. The corresponding ISTS SR requires a CHANNEL CHECK to be performed every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This changes the CTS by requiring the CHANNEL CHECK to be performed every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months in Mode 6 even if CORE ALTERATIONS are not in progress.

ITS 3.9.2 M.4 CTS Surveillance Requirement 4.9.2 specifies testing for the source range instrumentation SR 3.9.2.2 NA CTS 3.9.2 channels in Mode 6. The corresponding ISTS surveillances require the performance of a CHANNEL CALIBRATION on the source range monitors every 18 months. This 18-month surveillance is not specified in CTS 4.9.2. The CTS is revised to incorporate the ISTS 18-month channel Calibration requirement for the source range monitors. This addition changes the CTS by requiring a CHANNEL CALIBRATION every 18 months on each source range monitor.

ITS NA NONE CTS 3.9.3 ITS 3.9.3 M.1 Unit 2 only. The sections of CTS 3.9.4 marked-up for deletion and identified by the "M1" LCO LCO CTS 3.9.4 change designation are only contained in the Unit 2 CTS 3.9.4 and do not appear in the Unit 1 CTS 3.9.4. The Unit 2 provisions that allow open PAL doors and other containment penetrations added by Amendment 116 to Unit 2 CTS 3.9.4 are eliminated from the TS.

This changes the Unit 2 LCO by eliminating the allowance for penetrations to be open.

ITS 3.9.4 M.1 The CTS 3.9.8.1 actions applicable with less than one RHR loop in operation are revised Actions Actions BVPS Units 1 and 2 Page 48 of 52 Rev. 1.5

Table M More Restrictive Changes Section 3.9 - Refueling Operations ITS # DOC # Description of Change ITS Requirement CTS Requirement CTS #

CTS 3.9.8.1 consistent with the corresponding ISTS Actions by the addition of a new requirement to initiate action to satisfy the RHR loop requirements. In addition, the nonspecific completion time for the CTS Actions to "suspend operations involving" is revised by the addition of an immediate completion time for these CTS Actions, also consistent with the ISTS.

ITS 3.9.4 M.2 CTS 3.9.8.1 Actions b and c specify, in part, that "the residual heat removal loop may be LCO Notes Actions b & c CTS 3.9.8.1 removed from operation for up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period" and that " the residual heat removal loop may be removed from operation for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period during the performance of Ultrasonic In-service Inspection inside the reactor vessel nozzles." The corresponding ISTS requirement (LCO Note) contains a provision that limits the applicability of the CTS allowances. The ISTS limitation states "provided no operations are permitted that would cause introduction into the Reactor Coolant System, coolant with boron concentration less than required to meet the minimum required boron concentration of LCO 3.9.1." The CTS is revised to incorporate the ISTS limitation. This changes the CTS allowance by prohibiting operations that will cause introduction into the RCS, coolant with a boron concentration less than required to meet the boron concentration of LCO 3.9.1.

ITS 3.9.4 M.3 CTS 4.9.8.1 requires that an RHR loop be verified in operation and circulating a specified SR 3.9.4.1 4.9.8.1 CTS 3.9.8.1 flow only in certain circumstances (i.e., during dilution and reduced inventory operations).

The corresponding ITS surveillance (SR 3.9.4.1) specifies that the required RHR loop be verified in operation every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This changes the CTS by requiring verification of the required RHR loop in operation every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months regardless of the RCS water level or dilution operations.

ITS 3.9.4 M.4 Unit 1 only. Unit 1 CTS 3.9.8.1 LCO only specifies that an RHR loop be in operation. The LCO LCO CTS 3.9.8.1 corresponding ITS 3.9.4 also requires that the RHR loop be operable. The CTS LCO is revised to conform to the ITS LCO. This changes the CTS LCO by adding the requirement for the RHR loop to be operable as well as in operation.

ITS 3.9.5 M.1 CTS 3.9.8.2 requires two independent RHR loops to be OPERABLE and at least one loop SR 3.9.5.2 NA CTS 3.9.8.2 to be in operation. The corresponding ISTS specifies a surveillance that requires verification every seven days of correct breaker alignment and indicated power available to the RHR pump not in operation. The CTS does not have a corresponding surveillance.

The CTS is revised to adopt the ITS SR 3.9.5.2 for the standby RHR pump. This changes the CTS by adding a new Surveillance Requirement.

ITS 3.9.3 NONE ITS 3.3.6 BVPS Units 1 and 2 Page 49 of 52 Rev. 1.5

Table M More Restrictive Changes Section 3.9 - Refueling Operations ITS # DOC # Description of Change ITS Requirement CTS Requirement CTS #

CTS 3.9.9 ITS 3.9.6 M.1 The Action requirement for CTS 3.9.10 specifies that "With the requirements of the above Action Action CTS 3.9.10 specification not satisfied, suspend all operations involving movement of irradiated fuel assemblies within the containment and movement of fuel assemblies over irradiated fuel assemblies within the containment". No specific time is associated with the CTS Action.

The corresponding Action in the ISTS requires that the Action be performed "immediately".

The CTS is revised consistent with the ISTS to require that the Action be performed immediately.

BVPS Units 1 and 2 Page 50 of 52 Rev. 1.5

Table M More Restrictive Changes Section 4.0 - Design Features ITS # DOC # Description of Change ITS Requirement CTS Requirement CTS #

ITS 4.0 NONE CTS 5.0 BVPS Units 1 and 2 Page 51 of 52 Rev. 1.5

Table M More Restrictive Changes Section 5.0 - Administrative Controls ITS # DOC # Description of Change ITS Requirement CTS Requirement CTS #

ITS 5.0 M.1 CTS 6.8.1 specifies that written procedures be established, implemented, and maintained 5.4.1.b 6.8.1 CTS 6.0 covering the activities referenced in CTS 6.8.1.a through 6.8.1.h. ITS 5.4.1.b is added to the list of CTS activities to cover emergency operating procedures (EOPs). This changes the CTS by requiring written procedures be established, implemented, and maintained covering emergency operating procedures.

ITS 5.0 M.2 CTS 6.8.1 specifies that written procedures be established, implemented, and maintained 5.4.1.e 6.8.1 CTS 6.0 covering the activities referenced in CTS 6.8.1.a through 6.8.1.h. ITS 5.4.1.e is added to the list of CTS activities to cover all programs and manuals specified in ITS 5.5. This changes the CTS by requiring written procedures be established, implemented, and maintained covering all programs and manuals specified in ITS 5.5.

ITS 5.0 M.3 CTS do not include program requirements for component cyclic or transient limits, safety 5.5.3, 5.5.11, NA CTS 6.0 function determination, or battery monitoring and maintenance. ISTS includes programs 5.5.13 for these activities. The CTS are revised to conform to the ISTS. This changes the CTS by adding the following programs. ITS 5.5.3 Component Cyclic or Transient Limit, ITS 5.5.11 Safety Function Determination Program (SFDP), ITS 5.5.13 Battery Monitoring and Maintenance Program.

ITS 5.0 M.4 CTS 6.8.1 specifies that written procedures be established, implemented, and maintained 5.4.1.c 6.8.1 CTS 6.0 covering the activities referenced in CTS 6.8.1.a through 6.8.1.h. ITS 5.4.1.c is added to the list of CTS activities to cover the quality assurance for effluent and environmental monitoring. This changes the CTS by requiring written procedures be established, implemented, and maintained covering the quality assurance for effluent and environmental monitoring.

ITS 5.0 M.5 (Unit 2 only) CTS 3/4.7.8.1, Supplemental Leak Collection and Release System (SLCRS) 5.5.7.e NA CTS 6.0 requires the heater controls to be operational. This requirement is reflected in ITS 3.7.12.

The CTS, however, does not specify heater test parameters that would typically be included in ITS Section 5.0 for the Ventilation Filter Testing Program (VFTP) to support the operational requirements of the SLCRS heaters. The Unit 2 CTS has been revised to require the demonstration that the SLCRS heaters dissipate 160.9 kW and 264.5 kW when tested in accordance with ANSI N510-1980 (ITS 5.5.7.e).

BVPS Units 1 and 2 Page 52 of 52 Rev. 1.5

v t e Letter Sequence Other
TAC:MC6285, Increase Flexibility in Mode Restraints, Steam Generator Tube Integrity, Addition of New Tech Spec on RCS Boron Limits and Revisions to Tech Spec 3.3.1 to Address Rwfs, Implement 10 CFR 50, Appendix J, Option B, Provide Actions for One Steam Supply to Turbine Driven Afw/Efw Pump Inoperable, Changes to Reflect Revision of 10 CFR 50.55A, Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors, TSTF-1, Allow Time for Stabilization After Reducing Power Due to Qptr Out of Limit, Correct Bases Change Made by TSTF-283, TSTF-21, TSTF-38 (Approved, Closed) TAC:MC6286, Increase Flexibility in Mode Restraints, Steam Generator Tube Integrity, Addition of New Tech Spec on RCS Boron Limits and Revisions to Tech Spec 3.3.1 to Address Rwfs, Implement 10 CFR 50, Appendix J, Option B, Provide Actions for One Steam Supply to Turbine Driven Afw/Efw Pump Inoperable, Changes to Reflect Revision of 10 CFR 50.55A, Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors, TSTF-1, Allow Time for Stabilization After Reducing Power Due to Qptr Out of Limit, Correct Bases Change Made by TSTF-283, TSTF-21, TSTF-38 (Approved, Closed)
Initiation Request Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance Supplement, Supplement, Supplement, Supplement Administration Questions Answers Results Approval, Approval, Approval Other: L-07-086, Implementation of Beaver Valley, Units 1 & 2, Improved Technical Specification Amendment Nos. 278 (Unit 1) and 161 (Unit 2), ML060940413, ML060940429, ML061220200, ML070240291, ML070390057, ML070390061, ML070390530
MONTHYEAR2006-05-09 [Table View]

ML060940413

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