Text

Supplement to License Amendment Request Nos. 296 and 169, Improved Standard Technical Specification Conversion
	ML061140093
Person / Time
Site:	Beaver Valley
Issue date:	04/19/2006
From:	Lash J; FirstEnergy Nuclear Operating Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	L-05-027, L-06-069, LAR 169, LAR 296, NUREG-1431
	Download: ML061140093 (873)
	v • d • e

{{#Wiki_filter:FENOC FirstEnergy Nuclear Cperating Company Jamyes H. Lash 724-682-5234 Site Vice President Fax: 724-643-8069 April 19, 2006 L-06-069 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001

Subject:

Beaver Valley Power Station, Unit Nos. 1 and 2 BV-1 Docket No. 50-334, License No. DPR-66 BV-2 Docket No. 50-412, License No. NPF-73 Supplement to License Amendment Request Nos. 296 and 169, Improved Standard Technical Specification Conversion This letter provides updated pages (Revision 2) to the FirstEnergy Nuclear Operating Company (FENOC) License Amendment Request (LAR) Nos. 296 and 169 to convert. the Beaver Valley Power Station (BVPS) Unit Nos. I and 2 Technical Specifications to the Improved Technical Specifications (ITS) for Westinghouse Plants, NUREG-1431. The BVPS ITS conversion LAR was originally submitted by FENOC letter L-05-027 dated February 25, 2005. The purpose of this supplement is to update the BVPS ITS conversion documentation contained in LAR Nos. 296 and 169 (ITS conversion) to incorporate the following:

Recently submitted BVPS LARs and supplements to LARs,
Recently approved BVPS LARs,
An approved Technical Specification Task Force (TSTF) change,
Resolution of NRC comments, and
Other changes identified during the NRC review process.

This supplement consists of two volumes. One volume (Attachment 1) of this supplement contains the revised pages organized by individual changes, such that all the affected pages for each change are grouped together by a unique change number. The purpose of Attachment 1 is to facilitate the review of each change by providing all the affected pages for that change in one place. The second volume (Attachment 2) of this supplement contains the same revised pages as in Attachment 1 but the pages are sorted by ITS section number and in numerical order. The purpose of Attachment 2 is to facilitate replacing pages in the original 10 volume BVPS ITS conversion submittal.

                                                                                                -AOo

Beaver Valley Power Station, Unit Nos. 1 and 2 Supplement to License Amendment Request Nos. 296 and 169, Improved Standard Technical Specification Conversion L-06-069 Page 2 In addition to this BVPS ITS Conversion LAR supplement, it should be noted that one or more future supplements will be required to incorporate affected pages from the following:

LARs 302 (Unit 1) and 173 (Unit 2) Extended Power Uprate (final pages when approved by the NRC)
LARs 325 (Unit 1) and 195 (Unit 2) Control Room Habitability (final pages when approved by the NRC)
Unit 2 LAR 202 Station Battery Charger Upgrades (final pages when approved by the NRC)
LARs 324 (Unit 1) and 196 (Unit 2) Steam Generator Tube Integrity TSTF-449 (draft LAR pages when available and final pages when approved by the NRC) 4 Unit 2 LAR 183 S/G Tube Inspection F* Methodology (draft LAR pages when available and final pages when approved by the NRC)

The information provided with this submittal does not change the evaluations or conclusions of the No Significant Hazards Consideration provided with the ITS conversion LAR. No new regulatory commitments are contained in this submittal. If there are any questions or if additional information is required, please contact Mr. Gregory A. Dunn, Manager, FENOC Fleet Licensing, at (330) 315-7243. I declare under penalty of perjury that the foregoing is true and correct. Executed on April 11 , 2006. Sincerely, esH. Lash Attachments:

1. BVPS ITS Conversion (LARs 296 and 169) Revision 2 pages sorted by change number.

2. Replacement pages for the original 10 volumes of the BVPS ITS Conversion (LA.Rs 296 and 169) sorted by ITS section and in numerical order.

Beaver Valley Power Station, Unit Nos. 1 and 2 Supplement to License Amendment Request Nos. 296 and 169, Improved Standard Technical Specification Conversion L-06-069 Page 3 c: Mr. T. G. Colburn, NRR Senior Project Manager (*) (2 hardcopies) Mr. P. C. Cataldo, NRC Senior Resident Inspector (*) Mr'. S. J. Collins, NRC Region I Administrator (*) Mr. D. A. Allard, Director BRP/DEP (*) Mr. L. E. Ryan (BRP/DEP) (*) (*) Electronic Copy

BEAVER VALLEY POWER STATI O N UNITS 1 & 2 IMPROVED TECHNICAL SPECIFICATION CONVERSION LICENSE AMENDMENT REQUEST REVISION 2 CHANGES Affected Pages Organized by Change Number The Revision 2 Pages In This Volume Are Organized By Individual Change Number With All Affected Pages For Each Change Grouped Together To Facilitate The Review Of The Revision 2 Changes.

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQJUEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT Z) REVISION 2 CHANGES This volume identifies each Revision 2 change by a unique alpha-numeric designation. The tabbed sections of this volume are labeled with the change numbers. Each tabbed section of this volume includes the following information:

A description of the Revision 2 change,
If applicable, the following information is also included; the name of the associated NRC Reviewer(s), the Excel Website database number(s), and the BSI number,

      . An index of the revised page number(s) organized by ITS Section(s),

a A copy of each revised page with revision bars to show the associated change, and

When a change affects multiple ITS sections a separate cover sheet and page number index is included for each ITS section.

Depending on which pages are affected by each change, the pages for each change are presented in the following order; ITS markups and associated Justifications for Deviation (JFDs), ITS Bases Markups and associated JFDs, Current Technical Specification (CTS) markups and associated Discussion of Change (DOC). Each affected page is identified as a ,V Revision 2 page. In addition, each affected page is identified with the associated change number(s) for that page. The Revision 2 changes made to each page are further identified by revision bars. The page numbers referenced in the description of each change are the ITS section specific sequential numbers added to the bottom right hand corner of each page. In order to facilitate review, the changes in this volume are further organized by the type of change. The changes are divided into four types as follows: Alpha or A Changes Changes resulting from new LARs or recently approved license amendments. Bravo or B Changes Changes resulting from the incorporation of approved Technical Specification Task Force (TSTF) changes. Charlie or C Changes Changes resulting from NRC reviewer comments including Beyond Scope Changes (BSls). Delta or D Changes Other changes resulting from additional Beaver Valley Power Station (BVPS) review. Note: This volume is organized to facilitate the review of each Revision 2 change separately from the 10 volume BVPS ITS Conversion LAR originally submitted. A separate volume is provided with the affected pages organized in numerical order by ITS section to facilitate replacing pages in the original 10 volume BVPS submittal.

BVPS UNITS I & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 CHANGE A-1 Supplement to U2 Extended Power Uprate (EPU) License Amendment Request (LAR) # 173. Submitted by FENOC letter L-05-168 dated 10/28/05. The revisions in this supplement raise the minimum accumulator nitrogen cover pressure to 611 psig, delete the percent indicated level from the accumulator volume requirements, and insert 'usable' in the LCO statement for accumulator volume (to match the existing SR text). The corresponding Unit I change was approved in the Replacement Steam Generator (RSG) Amendment # 273 issued 2/9/06. Change A-1 affects ITS 3.5.1, Accumulators. Status: These changes are in the Unit 2 EPU LAR which is scheduled to be approved in the summer of 2006. Draft Pages from this supplement are incorporated into Revision 2 of the ITS Conversion documentation. Upon approval of the EPU LAR, another revision to the ITS conversion submittal will be made to incorporate the final approved current technical specification (CTS) pages. Affected Pages: The following Table(s) list the affected pages by type (i.e., ITS markup, CTS markup, etc.). In order to facilitate review by ITS section, a separate table is provided for each ITS section affected by the change. The page numbers listed are the ITS section specific consecutive numbers found In the lower right corner of each page. Note: Because the affected page(s) for each change were extracted from a complete ITS section electronic file, the electronic hyperlinks (created In the complete ITS section filel do not work In the collection of affected pages that follow this cover page. ITS SECTION 3.5 INDEX OF AFFECTED PAGES ITS MARKUPS PAGE: 5 ITS JFDS No change ITS BASES MARKUPS PAGE: 31 ITS BASES JFDS No change CTS MARKUPS PAGE: 76 CTS DOCS No change.

I Rev. 2 Change A-1 (Unit 2)& Change A-B (Unit 1) I Accumulator; 3.5.1 2 allons 6681 nd < 76 Gls 5 (Unit 1) Values 8-98J, 60_ v I SURVEINANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.5.1.2 \Verify borated water volume in each accumulator is 4 17853 gallons ( %/and / 8171 gallons ( )%]. 12 hours 0 SR 3.5.1.3 Verify nitrogen cover pressure in each accumulator is 12 hours psig and sg I SR 3.5.1.4 Verify boron concentration in each accumulator is 31 days I-S Ve2 ppm and s RJ0 ppm. AND 23\E0 - NOTE - Only required to be performed for affected accumulators Once within 6 hours after each solution volume increase of

                                                                                       '(( ]+/-% f l 2 1%of accumulator volume I indilated evel

([ ] gallon)] thal: is not the result of addition from the I control circuit I refueling water storage tank 1 SR 3.5.1.5 au Verify power is removX from each accumulator isolation valve operator when RCS pressure is f2QOOQ]p0§i. 31 days 0 psig WOG STS 3.5.1 - 2 Rev. 2, 04/30/01 5

Rev. 2 Change A-1 (Unit 2) c and Change A-8 (Unit 1) lcm 3u5lo BASES ACTIONS (continued) D.1 If more than one accumulator is inoperable, the plant is in a condition outside the accident analyses; therefore, LCO 3.0.3 must be entered immediately. SURVEILLANCE SR 3.5.1.1 so n REQUIREMENTS Each accumulato valve should be verified to be fully open every 12 hours. This verification ensures that the accumulators are available for injection and ensures timely discovery if a valve should be less than once power is removed fully open. If an isolation valve is not fully open, the rate of injection to the from the control circuit S waill be reduced. Although a motor operated valve position should not changesith power mved, a closed valve could result in not meeting accident analyses assumptions. This Frequency is considered 2 reasonable in view of other administrative controls that ensure a mispositioned isolation valve is unlikely. TIhe required accumulator vater volumes and minimum SR 3.5.1.2 and SR 3.5.1.3 the usable 2 nitrogen pressure value are analysis values. The values Every 12 hoursborated water volume and nitrogen cover pressure are soecified for volume do not verified for each accumulator.#This Frequency is sufficient to ensure account for instrumentation uncertainty. Similarly, the adequate injection auring a LUCA. Because of the static design of the values specified for the accumulator, a 12 hour Frequency usually allows the operator to identify nitrogen cover pressure also changes before limits are reached. Operating experience has shown this do not account for Frequency to be appropriate for early detection and correction of off instrumentation uncertainty. normal trends. t L 2!1% accumulao SR 3.5.1.4 L CTS Bases CT. BaThe boron concentration should be verifie to be within required limits for each accumulator every 31 days since the static design of the The value specified accumulators limits the ways in which the oncentration can be changed. for boron The 31 day Frequency is adequate to iden fy changes that could occur concentration isan from mechanisms such as stratification or i leakage. Sampling the analysis value. affected accumulator within 6 hours after a 0 volume increase will identify whether inleakage has caused a reduction in boron concentration to below the required limit. It is not necessary to verify boron concentration if the added water inventory is from the refueling water storage tank (RWST), because the water contained in the RWST is within the accumulator boron concentration requirements. This is consistent with the recommendation of NUREG-1 366 (Ref. WOG STS B 3.5.1 - 6 Rev. 2, 04/30/01 31

I Rev. 2 Chanqe A-1I 3/4.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) l Draft Page from Unit 2 ULiJ ACCUMULATORS [iTs3.5.1 l ) LIMITING CONDITION FOR OPERATION ree ECS 3.5.1 Each REactor Coolant S e accumulator shall be OPERABLE A with. F-si 3.5.1.1 1 AC The isolation valve open, Between 6898 gallons and 8019 gallons of usable borat.ed water, I Between 2300 and 2600 ppm of boron, and B A nitrogen cover-pressure of between 611 and 685 psig. I APPLICABI LITY: MODES 1, 2 and 3.* ACTION: a-- With one accumulator inoperable due to boron concentration not within limits, restore the inoperable accumulator to OPERABLE status within 72 hours. b-- With one accumulator inoperable for reasons other than Action a, restore the inoperable accumulator to OPERABLE status within 24 hours. l E3l LCOND C ] With either Action a or b not being completed within the specified completion time, be in at least 1B* within the next 6 hours and reduce pr- -- uriz-r pressure to LCOND D S 1000 psig within 12 hours. I I _ SURVE I LLANCE REQUIREMENTS ( Each accumulator shall be demonstrated OPERABLE: ad At le sast once per 12 hours by: is 2 6898 gallons and s 8019 gallons I Verifying the sable borated water volume nd nitrogen cover-pressure in the tan-carc within limits, and A Verifying that ach accumula r isolation valve is l SR 3.5.1.1 1 open.X Bases LA accumulator is 2611 psig and s 685 psic I

     *Pressurize          Pressure above 1000 psig.

ROSG BEAVER VALLEY - UNIT 2 3/4 5-1 Amendment No. 76

BVPS UNITS I & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) NOs. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 CHANGE A-2 Unit 2 LAR # 183 Submitted by FENOC Letter L-05-061 dated 4/11/05. This LAR implements F* steam generator (SG) tube plugging criteria for Unit 2 SG tubes with degradation in the tube sheet roll expansion region (in accordance with WCAP-16385-NP, Rev. 1). Status: This change is on hold. Final draft pages were not available prior to issuing Revision 2 of the ITS Conversion LAR. Draft or approved pages from LAR number 183 will be included in a future revision of BVPS ITS conversion submittal. Affected Pages: To be determined.

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 CHANGE A-3 LAR numbers 324 (Unit 1) and 196 (Unit 2) were submitted by FENOC Letter L-05-144 dated 11/7/05. These LARs implement TSTF-449. TSTF 449 revises the definition of Leakage, introduces a new ITS LCO (3.4.20) in Section 3.4 titled Steam Generator Tube Integrity, revises. ITS 3.4.13, Operational Leakage, revises Specification 5.5.5, SG Tube Surveillance Program, and Revises 5.6.6, SG Tube Inspection Report. Note F* requirements from Unit 2 LAR No. 183 must be incorporated into the new ITS 5.5.5 for the revised SG Tube Surveillance Program. Status: This Change is on hold. Final draft pages were not available prior to issuing Revision 2 of the ITS Conversion LAR. Draft or approved pages from LAR numbers 324 and 196 will be included in a future revision of BVPS ITS conversion submittal. Affected Pages: To be determined.

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 CHANGE A-4 This Supplement to the Unit 2 EPU LAR # 173 was submitted by FENOC letter L-05-198 dated 12/16/05. Although this supplement does not revise any technical specifications it does include a technical specification Bases change for the Auxiliary Feedwater (AFW) System. The Bases addition justifies the 72 hour time allowed for one inoperable AFW pump (i.e., how the AFW system flow requirements are met with a single inoperable AFW pump). The corresponding Unit I Bases change was approved in the RSG Amendment # 273 issued by the NRC on 2/9/06. This change affects the Bases of ITS 3.7.5. Status: This change is in the extended power uprate LAR which is scheduled to be approved in the summer of 2006. This change was incorporated into Revision 2 of the ITS Conversion submittal. Affected Pages: The following Table(s) list the affected pages by type (i.e., ITS markup, CTS markup, etc.). Inorder to facilitate review by ITS section, a separate table isprovided for each ITS section affected by the change. The page numbers listed are the ITS section specific consecutive numbers found In the lower right comer of each page. Note: Because the affected page(s) for each change were extracted from a complete ITS section electronic file, the electronic hyperlinks (created Inthe complete ITS section file) do not work Inthe collection of affected pages that follow this cover page. ITS SECTION 3.7 INDEX OF AFFECTED PAGES ITS MARKUPS No change ITS JFDS No change ITS BASES MARKUPS PAGES: 106 & 113 ITS BASES JFDS No change CTS MARKUPS No change CTS DOCS No change.

AFW System B 3.7.5 W.v l Rev. 2 Change A-4 (Unit 2) & A-8 (Unit 1) I BASES ACTIONS (continued) for an inoperable turbine-driven AFW pump in MODE 3 dictated that both Completion Times apply simultaneously, and the more restrictihe must be met. ConditioX A is modified by a Note which limits the applicability of the Conditior to when the unit has not entered MODE 2 following a refueling. Condition A allows one AFW train to be inoperable for 7 days vice the 72 hour Completion Time in Condition B. This longer Completion Time is based on the reduced decay heat following refueling and prior to the reactor being critical. Required Action B.1 is modified by a Note indicating that the Required Action is only _.Id required applicable if both supply headers are OPERABLE. re. lign OPERABLE AFW pumps to separate train supply With one of the required AF rains (pump or flow path) inoperable in headers within 2 hours (if both MODE 1, 2, or 3 [for reaso other than Condition A], action must be tra n supply headers are taken t eeteHe OPERA E status within 72 hours. This Condition OPERABLE) and to restore the includes the loss of two team supply lines to the turbine driven AFW AFW train to pump The 72 hour Completion Time is reasonable, based on redundant ca ilities afforded by the AFW System, time needed for repairs, and Required Action B.1 to realign e low probability of a DBA occurring during this time period. the OPERABLE pumps to separate supply headers The second Completion Time for Required Action B. establishes a limi preserves train separation and on the maximum time allowed for any combination of Ccditions to be m en lances system reliability. The two hours allowed for this ad ion is reasonable based on inoperable during any continuous failure to meet this LC. n29 I op orating experience to The 10 day Completion Time provides a limitation time allowed in this pelform the specified task. specified Condition after discovery of failure to meet the LCO. This limit is considered reasonable for situations in which Conditions A and B are entered concurrently. The AND connector between 72 hours and 10 days dictates that both Completion Times apply simultaneously, and the more CG)Inet ENl restrictive must be met. nDAand D.2 B.2,C.1,orC.2

If two AFWtrains are inoperable in MODE 1, 2, or en Required Action A.1 not be completed within the 3 for reasons other than Condition C, or required Completion Time, or if two AF=W trains are inoperable in MOF

                                                              , 3, the unit must be placed in a MODE in which the
   . If one or two feedwater                LCO does not apply. To achieve this status, the unit must be placed in al injection headers are                least MODE 3 within 6 hours, and in MODE 4 within fI 81 hours.

inoperable in MODE 1, 2, or

t, or The allowed Completion Times are reasonable, based on operating

   . If three AFW trains are inoperable in MODE 1, 2 or experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

(

t, but the turbine-driven AFW pump is inoperable solely due to one inoperable steam supply header B 3.7.5 - 5 Rev. 2, 04/30/01 Condition D is modified by a note that limits the applicability of the condition for three inoperable AFW trains to when the turbine-driven AFW train is inoperable solely due to one inoperable steam supply. In this condition, the status of the turbine-driven AFW train is adequate to support a reduction in operating MODE.

2106

Rev. 2 Change A-4 (Unit 2) & Change A-8 (Unit 1)

8. (From TSTF-359)

-REVIEWER'S NOTE-The 3..C .4 Note pro hAkaioi o3. 4.b exception when entering MODE 1 if the plant d9 o~eido-E o r startup. If the plant does depend on APup, the Note should stateC is not applical A Note prohibits the application of LCO 3.0.4.b to an inoperable AFW trainfwhen entering MODE 11. There is an increased risk associated with entering a MODE or other specified condition in the Applicability3-entering MODE 11-with an AFW train inoperable and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

9. With one inoperable AFW pump, the remaining two AFW pumps will be aligned to separate redundant headers capable of supplying flow to each steam generator.

A realistic analyses of a loss of normal feedwater event demonstrates that one motordriven AFW pump will maintain sufficient steam generator inventory to provide a secondary heat sink and prevent the RCS from exceeding applicable pressure and temperature limits. For Unit 1, the licensing basis has changed to a requirement for two of three AFW pumps to meet the flow requirements for the limiting DBAs. This change was necessitated by the installation of cavitating venturis in the AFW injection paths. The venturis protect the AFW pumps from runout conditions and allow for flow to be directed to the intact steam generators during a FWLB. Cavitating venturis in each individual injection path to the steam generators ensure that sufficient flow will be delivered to the two intact steam generators during a FWLB. Since no single failures are assumed to occur while in an Action Condition, adequate flow can be supplied by the two operable AFW pumps. Based on this, the Completion Time of 72 hours for one inoperable AFW pump continues to remain applicable. This change to the Unit I licensing basis is consistent with the original licensing basis for Unit 2. 113

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 CHANGE A-5 Change A-5 incorporates License Amendment numbers 270 Unit 1 and 152 Unit 2. These Amendments were issued on 1/111/06. The amendments revised the Unit I and Unit 2 SG Water Level Allowable Values in ITS 3.3.1 and ITS 3.3.2. In addition, (2)footnotes were added to the Channel Functional Test and Channel Calibration surveillances for the Reactor Trip System (RTS) and Engineered Safety Feature Actuation System (ESFAS) Functions with modified setpoints. The footnotes provide more detailed instructions regarding the SR results and further actions that may be required (for setpoint drift). The addition of the footnotes required significant changes to the ITS bases. The Bases changes consisted of making the ITS Bases consistent with the CTS bases changes with regard to the footnotes added by Amendment numbers 270 and 152. In addition, the background section of the ESFAS Bases was revised to be more consistent with the RTS Bases to facilitate a common discussion of the footnotes and the affect on the trip setpoints, allowable values and Limiting Safety System settings. The addition of the footnotes was in accordance with NRC instructions. The new notes are similar to the notes proposed in a TSTF (currently under development by industry and NRC to address a setpoint issue). The following RTS and ESFAS Functions are affected by the addition of notes: Unit 1 3.3.1 RTS - SG Level Low-low, 3.3.2 ESFAS - AFW Start SG Level Low-low, Unit 2 3.3.1 RTS - SG Level Low-low, 3.3.2ESFAS - SG Level -High-High (P-14), &AFW Start on SG Level. Affected Pages: The following Table(s) list the affected pages by type (i.e., ITS markup, CTS markup, etc.). In order to facilitate review by ITS section, a separate table is provided for each ITS section affected by the change. The page numbers listed are the ITS section specific consecutive numbers found Inthe lower right comer of each page. Note: Because the affected page(s) for each change were extracted from a complete ITS section electronic file, the electronic hyperlinks (created in the complete ITS section file) do not work in the collection of affected pages that follow this cover page. ITS SECTION 3.3A (RTS) INDEX OF AFFECTED PAGES ITS MARKUPS PAGE: 17 ITS JFDS No change ITS BASES MARKUPS PAGES: 36,37,40,43,82, 84,90A, 90B, 90C, & 90D ITS BASES JFDS PAGE: 92 CTS MARKUPS PAGES: Unit 2- 103,114 & 116A. Unit 1 -127 & 129A. CTS DOCS No change. (continued)

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 169 (UNIT 2) REVISION 2 Change A-5 (continued) ITS SECTION 3.3C (ESFAS) INDEX OF AFFECTED PAGES ITS MARKUPS PAGE: 15,16,18 ITS JFDS No change ITS BASES MARKUPS PAGES: 27, 29, 30,32, 74,76,80,80A, 80B, 80C, 80D & 80E ITS BASES JFDS PAGE: 82 CTS MARKUPS PAGES: Unit 2 - 92,93,100,101 & 103. Unit 1 - 116 & 116A CTS DOCS No change.

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 CHANGE A-5 AFFECTED PAGES FOR ITS SECTION 3.3A (RTS) ITS SECTION 3.3A (RTS) INDEX OF AFFECTED PAGES ITS MARKUPS PAGE: 17 ITS JFDS No change ITS BASES MARKUPS PAGES: 36,37,40,43,82,84,90A,90B, 90C, & 90D ITS BASES JFDS PAGE: 92 CTS MARKUPS PAGES: Unit 2-103,114 & 116A. Unit 1 -127 & 129A. CTS DOCS No change.

I Rev. 2 Change A-5 I RTS Instrumentation 3.3.. Table 3.3.1-1 (page 3 of 6) \ Reactor Trip System Instrumentation

12. Undervoltage 1X+ p perbus K SR 3.3.1..

RCPS X 1 SR 3.3.1,

13. Underfrequency 14 M per bus K RCPs

14. Steam 1.2 perSG] E Generator (SG) l A-5 Water Level - 3 Low Low 3

44. Turbine Trip

a. Low Fluid Oil 3 SR 3.3.1.10 M>

. Pressure SR 3.3.1.45

b. Turbine Stop SR 3.3.1 :10)iI0 2 [I]% open Valve SR 3.3.1.45 Closure 4;. Safety 1.2 2 trains SR 3.3.1 . NA Injection (SI) i Input from Engineered Safety Feature Actuation (ItESFAS)

   'Oe)       Above the P-7 (Low Power Reactor Trips Block) interlock.               T
     ,_       Above the P-9 (Power Range Neutron Flux) interlod.
                       .           E             Ad)                       If the as-found channel setlmoint is conservative with respect to the Allowable       A-5

_U-2, Values but outside its predeirined as-found acceptance criteria band, then the diannel shalt be evaluated to verify that it is functioning as required before IUnit I1-Auto Stop _ _ retumning the channel to sei-vice. If the as-found instrument channel set oint is not conservative with respect to the Allowable Value, the channel shall be l Unit 2-Emergency Trip Header I didared inoperable.

        , WOG STS                                                       3.3.1    -15                                            Rev. 2. 04/30/0'1 (I)  The instrument channel selpoint shall be reset to a value that is within the as-left tolerance of the Nominal Trip          A-5 Setpoint, or a value that is more conservative than the Nominal Trip Setpoint; othetwise, the channel shall         pn 18            deSared inoperable. The Nominal Trip Setpoint andt                              oterie       the chaNominal Trip Satpoint, the predefined as-found acceptance criteria band, and the as-left selpoint tolerance band are specified in a document incorporated by reference into the Updated Final Safety Analysis Report.                                                   7

RTS Instrumentation B 3.3.1 KiJ'Q I Rev. 2 Change A-5 I BASES BACKGROUND (continued) defined in Technical Specifications as "...being capable of performing its safety functions(s)." Fer automatic protective devicoG, the required safet: 2n functo is to enuroEthAt ZS4i not exceeded and therefore the LSSS a; X-ItA1.%

                                                         - . n-  -    -   nI !n   . _             .1 -  -  -  1-- -  D-DI.   -   -I      TV I .1  - - -.or+a 10O8ROU By iU WISK OV.Jl ivw         m        amue av MO UrPKEM\M        llLlI Tl-Y-mit     iur    MIUE-dpyine-       However, usE of       the  trip   6etpointttodepfinA-OPE RABILITY               in Text ieleted because the Thnical Specifications and its corresponding designation as the LS, BVPS CTS Bases                        requi by 10 CFR 50.36 would be an overly restrictive require                                         if it discussions that identify            were app edas an OPERABILITY limit for the "as found" val of a and describe the BVPS         4       protective dev setting during a surveillance. This wou result in specific LSSS are used in            Technical Specific           n compliance problems, as wes reports and place of this generic text Thenrfore, this text is                corrective actions requ ed by the rule which are, t necessary to ensure unneessary detail that                safety. For example, an a                  tatic protecti        evice with a setting that explains something which               has been found to be different                   the p setpoint due to some drift of is nol applicable to BVPS.            the setting may still be OPERABL                    ce drift is to be expected. This expected drift would have bee pecific                      accounted for in the setpoint methodology for calculati               e trip setpoint           thus the automatic protective action wou still have ensured that the                         would not be exceeded with th         as found" setting of the protective                     vice. Therefore, the device wad still be OPERABLE since it would have ormed its safety fu ion and the only corrective action required would b o reset the       ice to the trip setpoint to account for further drift during the 2                   rveillance interval.

I designation as the point to define "as found" OF etciumstances described above wonsreuoh rand the rule Technical Iil _ ins ~~~~~thatere clearivntwrraned.U __me point beyond which the device would have not been able to rforr its function due, for example, to greater than expected drift. TW~valuef of this needs to be specified in the Technical Specifications in order to define setting is OPERABILITY of the devices and is designated as the Allowable Value,= [OPERABILITY limit which, as stated above, is the same as the LSSS. I The Allowable Value specified in Table 3.3.1-1 serves as thestSz such - that a channel is OPERABLE if the trip setpoint is found not to exceed the Te):t deleted because it is Allowable Value duroina-he HAINIEL OPIERATIONlAL TEST ({OT). As eitt er redundant to sucE able Value differs from the trip setpoint by an sut sequent discussions in primarily equal to s ed instrument tes, such as Trip SetpointlAllowable Value section of Bases or drift, during the surveillance int manner, the actual setting of is Lnnecessary detail that the device willsi e SSS definition ani atna Safety (20 does not significantly add Lthe e xce eded at any given point of time as long as the a to tie understanding of the not drifted beyond that expected during the su-eillance intorval. Note RTM TS that, although the channel is "OPERABLE" under these circumstances, WOG STS B 3.3.1 - 2 Rev. 2, 04130/01 36

I Rev. 2 Change A-5 I RTS Instrumentation B 3.3.,,. BASES the BVPS Unit 1 and Unit 2 setpoint l methodology for protection systems (Ref. 1). BACKGROUND (coni inued) the trip setpoint should be lIft adjusted to a value within the established -i7 trip setpoint calibration toleIance band, in accordance with w~nnnAiA&- H assumptions stated in the *eforoned eetpoint methodology (a lef l Aoi_ r -Airrtlt4 r k-hi ro-tn *ho cb~ibi-l I1s---r At the uncertainty terms assigned. If the actual setting of the device is found to have exceeded the Allowable Value the device would be considered inoperable from a Technical Specification perspective. This requires corrective action including those actions required by 10 CFR 50.36 when automatic protective devices do not function as required. natiely a S frmat incorporating an Allowable Valus columnmad poed bya licensee. In this case tht on vaueo Tbe .39slsted in the TS Bsi a icensee-controlled document outsid C oteri setpoint value would be controlled by 10 CF p ministratively as appropriate, and adjusted per the sepitehdlg appicable surveillance requirements. ir option, the licensee may inc trip setpoint in Table 3. - as shown, or as suggested by the licensees' se oxntroidology or license. I During AOOs, which are those events expected to occur one or more times during the unit life, the acceptable limits are:

1. The Departure from Nucleate Boiling Ratio (DNBR) shall be maintained above the Safety Limit (SL) value to prevent departu4 from. nucleate boiling Pg),

2. Fuel centerline melt shall not occur, an

3. The RCS pressure SL of psia shall not be exceeded.

Operation within the SLs of Specification 2.0, "Safety Limits (SLs)," also maintains the above values and assures that offsite dose will be within the 10 CFR 50, and1CFR100 limits Accidents are events that are analyzed eœv Tuugh they are not expected to occur during the unit life. The acceptable limit during accidents is that offsite dose shall be maintained within an arreptahbl f 0aGtien-e 10 CFR 0limits. Different accident categories are allowed a dite-re-nTTFacTion ot these limits, based on probability of occurrence. Meeting the acceptable dose limit for an accident category is considered having acceptable consequences for that event. WOG STS B 3.3.1 - 3 Rev. 2, 04/30101 37

RTS Instrumentation B 3.3.1 Rev. 2 Change A-5 BASES BACKGROUND (cc Allowable Values RS Setoint trio devices Th rip setpoints used in are based on the analytical limits stated in Reference 1. The selection of these ip setpoints is such that nominal K INSERT I Insert pages follow the adequate protection is provided when all sensor and processing time delays are taken into account. To allow for calibration tolerances,

                                       - instrumentatein uncertainties, instrument drilf, and severe environment errors for thote RTSC channels that nnmust fiunction in harsh environments
    .      Bases pages                    as defined by 10 CFR 50.19 (Ref. 5), the Allowable Values spccified in Table 3.3.1 1 in the accompanying LCO are conservative with respect to tho analtical limits. A detailed description of the methodology used to 20              calculate the Allowable Values ancrrip setpoints, including their explicit                  nominal uncertainties, is provided in the "RTS/ESFAS Sctpoint Methodology Study (Ref. ) which incorporates all of the known uncertainties applicable to each channel. The magnitudes of these uncertainties are l   Reference I   /         factored into the determination of each¶rip setpoint and correspnd                     r devIc Allowable Value. The trip setpoint entered into the biis                  more conservative than that specified by the Allowable Value (LSSS) to                                  l nominal         account or measurement errors detectable by the COT. The Allowable Value serves as the Technical Specification OPERABILITY limit forlthe

(' INSERT 6 purpoe of the GOT. One example of such a change in measurement ror is drift during the surveillance interval. If the measured setpoiIt doe xceed the Allowable Value, the co char nomna OPERABLE devise l L o HI tnp evice Thtrip setpoint is the value at which the and is the l i expected value to be achieved during calibration. Thejr tpointvalue trip device with a ensures the LSSS and the safety analysis limits are met for surveillance to be within nominal trip setpoint interval selected why a channel is adjusted on state the tahed uRneltainties. Any bisftle is considered to be properly adjusted when calibration the "as left" setpoint value is within the band for CHANNItr CAI BRRATION UnRortainft allowanen (i A e rack calibrtionL _Cibration comparator cltting uncoeraiatiAe). Tho trip sotpoint value is thereforoterane. I INSERT bEffiiuuureu :i riurrnr;:ii :Juu uI.u.. uu[eLiuU i u '.auuo 'xnrloui ieu s o COT.and.CHANNEL CALIBRATION' inequilalitieQ feir the prprv ioseof GOT-rr a 1d GHANLr I rAL BR~ATION. _I v~ r .rT~wrsrs T-Ap sctpoints consristont with the roquiremnents of the Allowable Val-u Operable RTS Functions ensure that SLs are not violated during AOOs (and that the wilh setpoints maintained consequences of DBAs will be acceptable, providing the unit is operated wilhin the Allowable Values frmwtithLCsathoneofteAOrDBadteeqpet specified in the Technical from within the LCOs at the onset of the AOO or DBA and the equipment Specifications functions as designed). I INSERT 8 [j I WOG STS B 3.3.1 - 6 Rev. 2, 04/30/01 40

RTS Instrumentation Rev. 2 Change A-5 . . BASES CT Basesl APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued) provided that the +/- calibration tolerance band nominal trip setpoint. A trip setpoint may be set more conservative than remair s the same and 2 the nominal trip setpoint as necessary in response to plant conditions 7 the All zwable Value is Failure of any instrumen -enders the affected channel(s) inoperable and admin stratively controlled reduces the reliability ffected Functions. accorcingly inthe I meettiveassumptions o The LCO generally requi t PERABILITY of four or three channels in the selpoint methodology. each instrumentation Function, two channels of Manual Reactor Trip in The conservative each logic Function, and two trains in each Automatic Trip Logic Function. direction isestablished by Four OPERABLE instrumentation channels in a two-out-of-four the dirctiylon of the configurati required when one RTS channel is also used as a Allowable Value. c system input. This configuration accounts for the possibility of the may be ~shared channel failing in such a manner that it creates a transient that requires RTS action. In this case, the RTS will still provide protection, However, exceptions to even with random failure of one of the other three protection channels. these requirements are Three OPERABLE instrumentation channels in a two-out-of-three Fart of the current configuration are generally required when there is no potential for control tasis (e.g., inthe steam system and protection system interaction that could simultaneously create Generator level a need for RTS trip and disable one RTS channel. The two-out-of-three instrumentation a median and two-out-of-four configurations allow one channel to Pe tripped during selector switch isutilized maintenance or testing without causing a reactor trip.,,pecific exception; separa tion between the to the above general philosophy emst-and are discussed below. Frotedion and control systems instead of a Reactor Trip System Functions fourth level instrument channel). The The safety analyses and OPERABILITY requirements applicable to each RTS Function are discussed below: The Manual Reactor Trip feature is not The Manual Reactor Trip fetr5i o

1. Manual Reactor Trip Ia W eD-"credited by any safety analyses.

The Manual Reactor Trip ensures that the control room perator can initiate a reactor trip at any time by using either of two re tor trip switches in the control room. A Manual Reactor Trip acco plishes the same results as any one of the automatic trip Functions. It is manually used by the reactor operator toishut down the reactor wheonever any parameter iWrapidly trending toward its Trip Setpoint. The LCO requires two Manual Reactor Trip channels to be OPERABLE. Each channel is controlled by a manual reactor trip switch. Each channel activates the reactor trip breaker in both trains. Two independent channels are required to be OPERABLE so that no single random failure will disable the Manual Reactor Trip Function. WOG STS B 3.3.1 - 9 Rev. 2, 04/30/01 43

RTS Instrumentation B 3.3.1 Rev. 2 Change A-5 BASES SURVEILLANCE REQUIREMENTS (continued) L 7 N1-OH~ relay are verified by other Technical Specifications and non Technical Specifkiations tests at least ORne per refueling interval with appralicbe eX9r46ien6. Setpoints must be within the Allowable Values specified in Table 3.3.1-11 The difference between the current "as found" values and the previous NSER test "as left" values must be consistent with the drift allowance used in the IT10 setpoint methodology. The setpoint shall be left set consistent with the assumptions of the current unit specific setpoint methodology. I The "as found" and "as left" v'.alues must also be recorded and reviowed

                   ~frconistn        w-ith the ~rassumptioens of Rhfoueren 7 F6                       ,....x.                  o....v P                        ___.

12 hour SR 3.3.1.7- is modified by a Note that provides a delay in the M requirement to perform this Surveillance for source range instrumentation 0-~ when entering MODE 3 fromMAQOE 2. This Note allows a normal shutdown to proceed without a delay for testing in MODE 2 and short time in MODE 3 until the RTBs are open and SF .3.1isno be performed. If the unit is to be Wn4MODE3vitNh-t a 12I RTBs closed fo this Surveillance must be performed prior to hours after entry-intoMODE3. decreasing power below the P-6 setpoint. The Frequency of f92] days is justified in Reference 7. SR 3.3. 8 1 SR 3.3.1. s the performance of a COT as described in SR 3.3.1.;, except it is modified by a Note that this test shall include verification that the P-6 and P-1 0 interlocks are in their required state for the existing unit condition. l ssful test of the required contact(s) of a chani may be performed by t d

                                                    -vat-  tion of the change Si               gle contact of the relay. This clarifis faiesa b eCToa relay.

93This is acceptable because all om Et cts of the relay aeverified by other cfiains and non . Specificat Q S leas;-t once per refileling interIa with appli ems. The Frequency is modified by a Note that allows this surveillance to be satisfied if it has been performed within 1921 days of theJ Frequencies prior to reactor startup and Y ours after reducing power [ below P-1 0 and-P 6. The Frequency of "prior to startup" ensures this surveillance is performed prior to critical operations and applies to the 6GuF#eintermediate and power range low instrument channels. The Frequency of {121-hours after reducing power WOG STS B 3.3.1 - 48 Rev. 2, 04/30/01 82

RTS Instrumentation B 3.3.1 Rev. 2 Change A-5 BASES SURVEILLANCE REQUIREMENTS (continued) verifies that the channel responds to a measured parameter within the

 \       \                       necessary range and accuracy.

Insert description of CHANNEL CALIBRATIONS must be performed consistent with the RTD calibration assumptions of the unit specific setpoint methodology. The difference from next page. between the current "as found" values and the previous test "as left" values must be consistent with the drift allowance used in the setpoint

                             , \nethodology.

Ca)-/~The 111 T F fINSERT Frequency of 18 months is based on the assumption of an 18 mor ith calibration interval in the determination of the magnitude of equipment I drift in the setpoint methodology. cc) SR 3.3.1.10 is modified by a Not tating that this test shall include verification that the time constants are adjusted to the prescribed values where applicable. SR 3.3.1.11 l ndition, thisp SR: 3 2 I II is the peff n rAlrI IIr Qas

                                                                                  ..3.v[SR msis modified by a 2    Notetating that neutron detectors are excluded from the CHANNEL CALIBRATION. The CHANNEL CALIBRATION for the power range calibration data      neutron detectors consists of a normalization of the detectors based on a and establishing      power calorimetric and flux map performed above 15% RTP. The detector              CHANNEL CALIBRATION for the source range and intermediate range operating             neutron detectors consists of obtaining the detector plateau or preamp conditions in                                ,  aluating those curves, and comparing the curGec approved plant        to the manufacturer's datae This Surveillance is not required for the NIS procedures.           power range detectors for entry into MODE 2 or 1, and is not required for the NIS intermediate ranae detectors for entrv into MODE 2. because the unit must be in at least MODE 2 to perform the test for the intermediate range detectors and MODE 1 for the power range detectors. The based on the need to perform this Su            bn apply during a plant outap           e tential fot l         eillan         erformed with the Lng       ienc       hown these components WOG STS                                            B 3.3.1 - 50                             Rev. 2, 04/30/01 84

I Rev. 2 Change A-5 l 3.3.1 Bases Inserts

5. In addition to the channel OPERABILITY guidance discussed above, the CHANNEL OPERATIONAL TEST (COT) and CHANNEL CALIBRATION Surveillance Requirements (SRs) specified on Table 3.3.1-1 for certain RTS Functions are modified by Notes (k) and (I) that specify additional Technical Specification requirements. The applicable Notes are specifiec directly on Table 3.3.1-1 next to the numerical SR designations for the affected RTS Functions.

The additional Technical Specification requirements for these RTS Functions include OPERABILITY evaluations for setpoints found outside the as-found acceptance criteria band and the requirement to reset the setpoint to within the as-left tolerance of the nominal trip setpoint or a value that is more conservative than the nominal trip setpoint or declare the affected channel inoperable. These additional Technical Specification requirements are on y applicable to the RTS Functions with the Notes modifying their COT and CHANNEL CALIBRATION SR numbers on Table 3.3.1-1.

6. As discussed earlier, for certain RTS Functions, the COT and CHANNEL CALIBRATION SR numbers specified on Table 3.3.1-1 are modified by Notes that impose additional Technical Specification requirements for channel OPERABILITY.

7. The nominal trip setpoint is based on the calculated total loop uncertainty per the plant specific methodology documented in the Licensing Requirements Manual. The setpoint methodology, used to derive the nominal trip setpoints, is based upon combining all of the uncertainties in the channels. Inherent in the determination of the nominal trip setpoints are the magnitudes of these channel uncertainties. Sensors and other instrumentation utilized in these channels should be capable of operating within the allowances of these uncertainty magnitudes.

Occasional drift in excess of the allowance may be determined to be acceptable based on the other device performance characteristics. Device drift in excess of the allowance that is more than occasional, may be indicative of more serious problems and would warrant further investigation.

8. For most RTS Functions the Allowable Value specified on Table 3.3.1-1 is the LSSS required by 10 CFR 50.36. However, for certain RTS Functions, the COT and CHANNEL CALIBRATION SR numbers specified on Table 3.3.1-1 are modified by Notes (k) and (I) that impose additional Technical Specification Requirements for channel OPERABILITY and change the LSSS for the affected Functions. For each RTS Function in Table 3.3.1-1 with Notes modifying the required COT and CHANNEL CALIBRATION SR numbers, the nominal trip setpoint specified in the Licensing Requirements Manual is the LSSS.

This definition of the LSSS is consistent with the guidance issued to the industry through correspondence with Nuclear Energy Institute (NEI) (Reference NRC-NEI Letter dated September 7, 2005). The definition of LSSS values continues to be discussed between the industry and the NRC, and further modifications to these Bases will be implemented as guidance is provided. Table 3.3.1-1 Notes (k) and (I) are applicable to the COT and CHANNEL CALIBRATION SRs for specific instrument functions since changes to Allowable Values associated with these instrument functions were already under review by the NRC at the time the revised NRC setpoint criteria were documented and made available to the industry in an NRC letter to NIEl. Changes to the remaining instrument functions may be pursued after guidance endorsed by both the NRC and NEI is issued. 90A

I Rev. 2 Change A-5 l 3.3.1 Bases Inserts

9. In addition to the channel OPERABILITY guidance discussed above, the CHANNEL OPERATIONAL TEST (COT) and CHANNEL CALIBRATION Surveillance Requirements (SRs) specified on Table 3.3.3-1 for certain RTS Functions are modified by Notes (k) and (I) that specify additional Technical Specification requirements. The applicable Notes are specified directly on Table 3.3.1-1 next to the numerical SR designations for the affected RTS Functions.

The additional Technical Specification requirements for these RTS Functions include OPERABILITY evaluations for setpoints found outside the as-found acceptance criteria band and the requirement to reset the setpoint to within the as-left tolerance of the nominal trip setpoint or a value that is more conservative than the nominal trip setpoint or declare the affected channel inoperable. These additional Technical Specification requirements are only applicable to the RTS Functions with the Notes modifying their COT and CHANNEL CALIBRATION SR numbers on Table 3.3.1-1.

10. For certain RTS Functions the required COT (SR 3.3.1.6 specified in Table 3.3.1-1) is modified by Notes (k) and (I). These Notes specify additional requirements for the affected instrument channels.

Note (k) specifies the following:

If the as-found channel setpoint is conservative with respect to the Allowable Value but outside its predefined as-found acceptance criteria band, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service, and
If the "as-found" instrument channel setpoint is not conservative with respect to the Allowable Value, the channel shall be declared inoperable.

The evaluation of channel performance required by Note (k) involves an assessment to verify the channel will continue to behave in accordance with design basis assumptions, and to ensure confidence in the channel performance prior to returning the channel to service. In addition, if the 'as found' trip setpoint value is non-conservative with respect to the Allowab!e Value, or is found to be outside of the two sided predefined acceptance criteria band on either side of the nominal trip setpoint, the affected channel will be evaluated under the corrective action program. Note (I) specifies the following:

The instrument channel setpoint shall be reset to a value that is within the as-left tolerance of the nominal trip setpoint, or a value that is more conservative than the nominal trip setpoint; otherwise, the channel shall be declared inoperable, and
The nominal trip setpoint and the methodology used to determine the nominal trip setpoint, the predefined as-found acceptance criteria band, and the as-left setpoint tolerance band are specified in a document incorporated by reference into the Updated Final Safety Analysis Report.

For BVPS, the document containing the nominal trip setpoint, the methodology used to determine the nominal trip setpoint, the predefined as-found acceptance criteria band, and the as-left setpoint tolerance band is the LRM. 90B

I Rev. 2 Change A-5 3.3.1 Bases Inserts (Insert 10 continued) For the RTS Functions with a COT modified by Note (I), the Note requires that the instrument channel setpoint be reset to a value within the "as left" setpoint tolerance band on either side of the nominal trip setpoint or to a value that is more conservative than the nominal trip setpoint. The conservative direction is established by the direction of the inequality sign applied to the associated Allowable Value. Setpoint restoration and post-test verification assure that the assumptions in the plant setpoint methodology are satisfied in order to protect the safety analysis limits. If the channel can not be reset to a value within the required "as left" setpoint tolerance band on either side of the nominal trip setpoint, or to a value that is more conservative than the nominal trip setpoint (if required based on plant conditions) the channel is declared inoperable and the applicable ACTION is entered. For the RTS Functions with a COT modified by Notes (k) and (I), the "as found" and "as left' setpoint data obtained during COTs or CHANNEL CALIBRATIONS are programmatically trended to demonstrate that the rack drift assumptions used in the plant setpoint methodology are valid. If the trending evaluation determines that a channel is performing inconsistent with the uncertainty allowances applicable to the periodic surveillance test being performed, the channel is evaluated under the corrective action program. If the channel is not capable of performing its specified safety function, it is declared inoperable.

11. For certain RTS Functions the required CHANNEL CALIBRATION (SR 3.3.1.1 0 specified in Table 3.3.1-1) is modified by Notes (k) and (I). These Notes specify additional requirements for the affected instrument channels.

Note (k) specifies the following:

If the as-found channel setpoint is conservative with respect to the Allowable Value but outside its predefined as-found acceptance criteria band, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service, and
If the "as-found" instrument channel setpoint is not conservative with respect to the Allowable Value, the channel shall be declared inoperable.

The evaluation of channel performance required by Note (k) involves an assessment to verify the channel will continue to behave in accordance with design basis assumptions, and to ensure confidence in the channel performance prior to returning the channel to service. In addition, if the 'as found" trip setpoint value is non-conservative with respect to the Allowable Value, or is found to be outside of the two sided predefined acceptance criteria band on either side of the nominal trip setpoint, the affected channel will be evaluated under the corrective action program. Note (I) specifies the following:

The instrument channel setpoint shall be reset to a value that is within the as-left tolerance of the nominal trip setpoint, or a value that is more conservative than the nominal trip setpoint; otherwise, the channel shall be declared inoperable, and
The nominal trip setpoint and the methodology used to determine the nominal trip 90C

Rev. 2 Change A-5 3.3.1 Bases Inserts (Insert 11 continued) setpoint, the predefined as-found acceptance criteria band, and the as-left setpoint tolerance band are specified in a document incorporated by reference into the Updated Final Safety Analysis Report. For BVPS, the document containing the nominal trip setpoint, the methodology used to determine the nominal trip setpoint, the predefined as-found acceptance criteria band, and the as-left setpoint tolerance band is the LRM. For the RTS Functions with a CHANNEL CALIBRATION modified by Note (I), the Note requires that the instrument channel setpoint be reset to a value within the 'as left" setpoint tolerance band on either side of the nominal trip setpoint or to a value that is more conservative than the nominal trip setpoint. The conservative direction is established by the direction of the inequality sign applied to the associated Allowable Value. Setpoint restoration and post-test verification assure that the assumptions in the plant setpoint methodology are satisfied in order to protect the safety analysis limits. If the channel can not be reset to a value within the required 'as left" setpoint tolerance band on either side of the nominal trip setpoint, or to a value that is more conservative than the nominal trip setpoint (if required based on plant conditions) the channel is declared inoperable and the applicable ACTION is entered. For the RTS Functions with a CHANNEL CALIBRATION modified by Notes (k) and (I), the 'as found" and 'as left" setpoint data obtained during COTs or CHANNEL CALIBRATIONS are programmatically trended to demonstrate that the rack drift assumptions used in the plant setpoint methodology are valid. If the trending evaluation determines that a channel is performing inconsistent with the uncertainty allowances applicable to the periodic surveillance test being performed, the channel is evaluated under the corrective action program. If the channel is not capable of performing its specified safety function, it is declared inoperable. 90D

Rev. 2 Change A-5 BVPS ISTS Conversion 3.3A RTS Instrumentation Enclosure 2 Changes to The ISTS Bases ITS 3.3.1 Reactor Trip System InstrumentationBases JUSTIFICATION FOR DEVIATION (JFD)

1. This JFD addresses all changes made to the Bases that are editorial in nature and that do not affect the technical content of the Bases. The changes addressed by this JFD are made to correct spelling, grammar, and capitalization errors as well as incorporate wording preferences. In some cases, these changes are necessary to make the descriptions of reference content correct (e.g., the content of the BVPS UFSARs may not be exactly the same as described in the ISTS Bases) or to make the actual location of information discussed correct for BVPS (e.g., the location of trip setpoints outside of the TS or the location of the list of the number of required channels for each RTS Function). The reasons for the changes addressed by this JFD are considered self-explanatory and a separate more detailed explanation unnecessary. These changes do not significantly impact the technical discussions contained in the Bases and in general improve the clarity or correctness of the affected text or make the text more specific to BVPS. As such, the proposed changes ale acceptable.

2. Changes are made to the ISTS Bases to reflect the BVPS specific setpoint methodology and changes introduced by Amendment numbers 270 Unit I and 152 (Unit 2). These Amendments introduced Notes to the COT and Channel Calibration SRs that affect the definition of the LSSS for certain RTS Functions. The BVPS trip setpoints associated with the RTS Functions are typically nominal values with a calibration tolerance. The nominal trip setpoints are specified in the Licensing Requirements Manual not the TS. The BVPS Allowable Value is determined by the nominal trip setpoint calibration tolerance. The BVPS RTS Function operability is determined by verifying the Function is within the specified Allowable Value (setpoint calibration tolerance). The changes associated with this JFD are required to maintain consistency with the current BVPS setpoint methodology and the current BVPS licensing basis as modified by Amendment numbers 270 and 152.

3. Consistent with the BVPS safety analyses performed by Westinghouse, maintaining the minimum DNBR above the safety limit does not prevent DNB from occurring. By definition, maintaining the DNBR above the safety limit demonstrates that there is a 95% probability at a 95% confidence level that the lead rod will not experience DNB. As such, the generic ISTS bases text is revised to delete the reference to preventing DNB. In addition, the more conservative BVPS specific analytical acceptance criteria for RCS pressure (2748.5 psia) is referenced in the Bases instead of the Safety Limit (SL) value used in the standard Bases.

4. The ISTS discussion of offsite dose limits is revised to include the limits of 10 CFR 50.67.

The BVPS design basis accident analysis utilize the Alternate Source Term and offsite dose limits associated with 10 CFR 50.67 instead of 10 CFR 100 for the dose calculations. This change makes the ISTS Bases more consistent with the current BVPS licensing Basis.

5. The standard bases text is deleted or revised to make the generic bases discussion more BVPS Units 1 & 2 Page 1 Revision 2, 4/06 92

N t r .E Rev. 2 Change A-5 FUNCTION A A - ontinuedl U OR OTHER SPECIFIED CONDITION REQUIRED REAC E INSTRUMENTATION T CONDITIONS

                                           \             X                                 >    \~MINIMUM                                                       //

TGTAL NG. CHANNELS CHANNELS ALLOWABLE APPLIC LE _____________IT 4F CHANNELS TO TRIP PERABLE VALUE MODES ACTION H:. Overtemperature AT 3 2 See Table 1, 2 _ K 7 \/Notation W3

4. Overpower-AT.- 3 2 2\ I See Table 1, 2 /

0 R treC atow Low lp2 o 1941 psig**op 1 SePramGnrator Waer- 3 2 2/ Ž 2379 psig narrow 1, Taiao. Press - I 2 arer secnd f l and High eAnbsueta 4 tiSe these cnstants sar a t t I _lSingle Loopd 2/loop in 2/ f p hoparating opCratin SR N Ba D DIlil loop lp\ _-(A21 WA1) . W20Loo l3/lop2/loop in 2 100p > 89.6klo 0 I r, (Above P-7leYd

10. Reactor Coolant Flow Low N two operating loops qach peratin oop \

indicated loop flwBSES A YL l/ _-_ lK N 1

Al

14. Steam Generator Water 3/loop 2/loop 2lo \2 0ofnarrow 1 <-l 7 Level-Low-Low range instrumn

                                                     ,__>s                                     >                     ~span-each       staI

( LA BASS Jr( L2<

                                                                                                                      ,generator

~8 (h)Above the P-7 (Low Power Reactor Trips Block) Interlock. utilized in the lead-lag controller for Prsuier Pressure-Low are 2- 2 seconds for lead and

         **  Time     constants for    lag. Channel   calibration      shall      ensure      that      these     time    constants        are  adjusted to     those
             !5  1  second Ivalues.
                                                                      ,Channel             Calibration SR 3/4    3-3                                                         Amendment   No. 152    l   A-6 BEAVER       VALLEY      -   UNIT 2 C:

rC C-> _CHANNEL OPERATIONAL TEST (COT) OR Rev. 2 Change A-S ACTUATING DEVICE. ITS SR 3.3.1.14 Verify RTS OPERATIONAL TEST TADOTlI A28 Response Time Is within limits. LGC ETChanges to Modes are F _toFunctions REACTOR TR-RUMMENTA TION SUKVE;L REME ____ATATO S lladdressed In markup of Changes to Functions ITable 3.3-1 are addressed In markup Mezde in Which. of Table 3.3.1ne Channel Channel Func nal l urveillinz1-Functional Unit Check Calibration est l -c--e

12. Loss of Flow-Singe O 1

3. Loss of Flow - Two Loop /1 (Above P-7 P ca3nd l r o w .1 R 1

14. team/Generator Water L el- S (161 (173 1 2 A-6 L -Low

15. DE ED. Table 3.3.1.1 Notes (k)& I 1 1

16. Unde ltage-Reac r Coolant N.A. 1 - 1 Pumps ove P-7) 1 S

17. Underfre ency eactor N.A. R 1 Coolant Pu s (Above P-7)

18. Turbine Tr (Above P-9) _

A. Emerg ncy ip Header N.A. Low ~ressure l 1\ SR 3.3.1.135 L1 B. Tu me Stop alve N.A. C oue

19. Saf ty Injection Inp t from N.A. N.A. R ES

20. eactor Coolant Pump Br aker N.A. N.A. P N.A.

Position Trip (Above P-7 lSR3.3.1.4 a

1. Reactor Trip Breaker N.A. N.A. 11) , 3 I N BEAVER VALLEY - UNIT 2 3/4

Rev. 2 Change A-5 f -s a . T TV I - - / §- t - a-

                                                                           @-   I I i1,'AxP NOTATION (Continued)

(16) If the as-found channel setpoint is conservative with respect to the Allowable Value but outside its predefirted as-found acceptance criteria band, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service. If the as-found instrument channel setpoint is not conservative with respect to the Allowable Value, the channel shall be declared inoperable. (17) - The instrument channel setpoint shall be reset to a value A-5 that is within the as-left tolerance of the Nominal Trip Setpoint, or a value that is more conservative than the Nominal Trip Setpoint; otherwise, the channel shall be declared inoperable. The Nominal Trip Setpoint and the methodology used to determine the Nominal Trip Setpoint, the predefined as-found acceptance criteria band, and t:he as-left setpoint tolerance band are specified in a document incorporated by reference into the Updated Final Safety Analysis Report. l ITS Table 3.3.1-1 Notes (k) & (I) BEAVER VALLEY - UNIT 2 3/4 3-13a Amendment No. 152 116A

L v ¶t f, I Chanqes to this Unit I material are addressed in the I I Rev. 2 Chanae A-5 Unit 2 markup. 1 4.3-1 (Continued) I I I It REACTOR TRIP SYSTEM INSTRUMENTATION SURVEILLANCE REQUIREMENTS Channel Modes in Channel Channel Functional Sur nce Functiot Unit Check Calibration Test Reauired

12. Loss of Flow - S S R l

13. Loss of Flow - Two Loops R/

14. Steam/Generator Water S 1 l, (16) 17) 2 A-s Level-Low-Low

15. DELETED

16. Undervoltage olant N.A. R Q Pums

17. erfrequency-Reactor N.A. R Q Coolant Pumps

__x

-4

Rev. 2 Change A-5] TABLE 4.3-1 (Continued) NOTATT>qChanges to this Unit I material are addressed in the Unit 2 markup. (16) - If t as-found channel setpoint is onservative with respect the Allowable Value but o side its predefined as-found ac tance criteria band, en the channel shall be evaluated t verify that it functioning as required before returning e channel service. If the as-found instrument channel etpo is not conservative with respect to the Allow Value, the channel shall be declared inoperable. A-5 (17) - The instrument nnel setpoin shall be reset to a value that is with' the as-left toler ce of the Nominal Trip Setpoint, a value that is more onservative than the Nominal rip Setpoint; otherwise, th channel shall be decla d inoperable. The Nominal Trip tpoint and the me odology used to determine the Nominal ip Setpoirnt, e predefined as-found acceptance criteria ba , and the as-left setpoint tolerance band are specified in a!ocument incorporated by reference into the Updated Final fety Analysis Report. X BEAVER VALLEY - UNIT I 3/4 3-13a Amendment No. 27() 129A

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 CHANGE A-5 AFFECTEDPAGES FOR ITS SECTION 3.3C (ESFAS) ITS SECTION 3.3C (ESFAS) INDEX OF AFFECTED PAGES ITS MARKUPS PAGE: 15,16,18 ITS JFDS No change ITS BASES MARKUPS PAGES: 27, 29,30,32, 74,76,80, 80A, 80B, 80C, 80D & 80E ITS BASES JFDS PAGE: 82 CTS MARKUPS PAGES: Unit 2 - 92, 93,100,101 & 103. Unit 1 - 116 & 116A CTS DOCS No change.

I Rev.n2 Ch ESFAS Instrumentation 3.3.2

c. Safety Injection Refer to Function I (Safety Injection) for all initiation functions and requirements.

                                                                                                                                     =r.r

6. Auxiliary W - ~.

                                                                                                                                               .-    I Feedwater                                                                                                     I 8: '

a. Automatic 1,2,3 2 trains G SR 3.3.2.y NA Actuation Logic SR 3.3.2.. I, 3 and Actuation SR 3.3.2.6 Relays o lSe . W r d [d .

I.': , 11

     .Automatic                    1,2,3                2 trains            G             SR 3.3.2.3                       N Actuation Logic 31 and Actuation.._

Relays 8_l (Balance of - _ ( h) WOG STS Noe e)& Excopt whon all MSIVcs aro dor~ed and [de WWAWtv3ed 332 1Re. 2, 04300 O <xcp when all WMFe, MF-RVc, [and accodalod bypacc valvnc] aro docod and Ids artivatedi [eF icoblotd by a cWocod mranual vatlq.

      \       l_cept when all Main Feedwater Lines are isolated by either closed and dleactivatiedI_

MFIVs, or MFRVs and associated bypass valves, or closed manual valves. l z IA-5 WOG STS n oe e ') l 3.3.2 - 13 Rev. 2, 04/30/01 15

I Rev. 2 Change A-5 & A-6 ESFAS instrumentation 3.3.2

b. Refueling 1,2,3,4 4 Water Storage Tank (RWST)

Level-4Low Coincident with Refer to Function 1 (Safety Inj Safety Injection Lowt(Unit1) A-5 [to w ~~ nil2 4Notes It(e)&8(f l A-6 WOG STS 3.3.2- 14 Rev. 2, 04/30/01 16

Rev. 2 Changes A-5, A-6, & A-8 The Notes were added by Change A-5. Changes A-6 & A-Z reference the Notes added by A-5 INSERTS FOR ITS 3.3.2, ESFAS INSERT I - SR 3.3.2.6 Frequencv Note 92 days OR Note J provided a satisfactory contact loading analysis has been completed, and a satisfactory slave relay service life has been established, for the slave relay being tested. 12 Months AND

                          .   =~     '. ...... t  ....

Note Only applicable to Unit 1 18 Months INSERT 2 - Table 3.3.2-1 Notes (e) & if) (e) If the as-found channel setpoint is conservative with respect to the Allowable Value but outside its predefined as-found acceptance criteria band, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service. If the as-found instrument channel setpoint is not conservative with respect to the Allowable Value, the channel shall be declared A-5 inoperable. A-X A-8 (f) The instrument channel selpoint shall be reset to a value that is within the as-left tolerance of the Nominal Trip Setpoint, or a value that is more conservative than the Nominal Trip Setpoint; otherwise, the channel shall be declared inoperable. The Nominal Trip Setpoint and the methodology used to determine the Nominal Trip Setpoint, the predefined as-found acceptance criteria band, and the as-left setpoint tolerance band are specified ina document incorporated by reference into the Updated Final Safety Analysis Report. 18 .

I Rev. 2 Change A-5:l ESFAS Instrumentation B 3.3.2 B 3.3 INSTRUMENTATION B 3.3.2 Engineered Safety Feature Actuation System (ESFAS) Instrumentation BASES 0 BACKGROUND The ESFAS initiates necessary safety systems, based on the values of selected unit parameters, to protect against violating core design limits and the Reactor Coolant System (RCS) pressure boundary, and to mitigate accidents. I INSERT 2 .11

       -           The ESFAS instrumentation is segmented into three distinct but interconnected modules as identified below.

Field transmitters or process sensors and instrumentation: provide a UR measurable electronic signal based on the physical characteristics of the parameter being measured,
Signal processing equipment including analog protection system, field contacts, and protection channel sets: provide signal conditioning, bistable setpoint comparison, process algorithm actuation, compatible electrical signal output to protection system devices, and control board/control room/miscellaneous indications, and
Solid State Protection System (SSPS) including input, logic, and output bays: initiates the proper unit shutdown or engineered safety 2 feature (ESF) actuation in accordance with the defined logic and based on the bistable outputs from the signal process control and protection system.

lowable Value in conjunction with the trip setpoint and LCO establcc e threshold for ESFAS action to prevent excee ed acceptable lIs uch that the consequences of DeinHs Accidents (DBAs) will beacc e The Allowable Value Cosdred a limiting value such tht a channes OPRABLE if e point is found not to exceed the Allowable Valu dh tAN OPERATIONAL TEST (COT). Note that, although a ch .. PRABLE" under these circumstances, the ESFAfpont must Edadjusted to within the established calibrat erance band of the ESP setpoint in accordance wee uncertainty assumptions stated ins efrene setpoin odology, (as-left criteria) and confirmed to be o ting he statistical allowances of the uncertainty terms assigned. WOG STS B 3.3.2 - I Rev. 2, 04/30/01 27

ESFAS Instrumentation I Rev. 2 Change A-5 B 3.3.2 BASES BACKGROUND (coritinued) provide the required reliability and redundancy. The circuit must be able to withstand both an input failure to the control system, which may then "r..-A e +A_ ; f rr.__; __.Je P; r eI r _ flso ;r&A l_ However, exceptions to the require Oe pIULUotIII WIunAIU1 datudtlIuI, dIIU aibilII I lu nIiUIC III LIM 01Me requirement for four channels channels providing the protection function actuation. Again, a single fire part of the design and failure will neither cause nor prevent the protection function actuation. I censing basis of the ESFAS\ (e.g. steam generator level These requirements are described in IEEE-279-1971 (Ref. 4The a~tUial listrumentation). number of c nn ir for each unit parameter is specifi re nominal ,and LSSS Technical Specification ._ / / LTable 3.3.2-1 -Allowab alue ESFAS Seo ms A and other trip devices the BVPS Unit 1 and Unit 2 Therip setpoints used in the bistables~b.tased on the analytical limits selpoint methodology for stated in e . The selection of thesttrip setpoints is such that Frotection systems (Ref. 3). adequate protection is provided when all sensor and processing time delays are taken into account. To allow for calibration tolerances, instfumentation UnCerta^ is, instrument drt, ana severe environment I INSERT 1 Insert pages follow the en.ironments as defined by 10 cFR 50.10 (Ref. 5), the Allowablo .u-_ Bases pages.speified 1 in Table LC 3.3.2 in the accompanying onr_;tive4 O are respect to the analytical its A detailed description of iethodology used to calculate the Allowable Values and ESFA9etpoints including Renc i their explicit uncertainties, is provided in the plant specific setpoinint - methodology study (Ref,6) which incorporates all of the known I_._._ uncertainties applicable to each channel. The magnitudes of thes inal tiPI uncertainties are factored into the determination of each point and corresponding Allowable Value. The et oint trip device entered into the hist:9is more conservative than that specified by the IV Allowable Value to account for measurement errors detectable by the COT. The Allowable Value serves as the Technical Specification OPERABILITY limit foF-the purpose of the COT. One example of such a change in measurement error is drift during the surveillance interval. If INSERT the measured setpoint cIs not exceed the Allowable Value, the bye I isconsidered OP E l d I iE ll channel no;nl r SFSFAS setpoinae the values at which the he expected valu to be achieved during calibration. The ESIAS lobe within the Et are set trip device with a setpoint value ensures the safety analysis limits are met for the / caliation tolerance. nominal trip sefpoint giiryvpillanrn intpryni splted when a channel is adjusted bargertatesl n h ait Any a is considered to be properly adjusted when the "as-left" setpoint value is within the band FGHANNEL CALIBRATION uncertainty allowance (i.e., calibration tolerance c untr~ni6 Th ECL.AC r otIon v.1l ;f. thrfr cosde I _

                                        -1 I-                 - I-      -     I                I-,--     -   11             ---            -- -

I INSERT 4 I WOG STS B 3.3.2 - 3 Rev. 2, 04/30/01 29

ESFAS Instrumentation Rev. 2 Change A-5 B 3.3.2 BASES BACKGROUND (continued)

'1nr-inAw~--e (~e. epresised as a value without Inequalitiels) foF the purposes of the COT and CHANNEL CALIBRATION. except for mpanual Operable ESFAS Setpoints adjusted consirtent with the requirements of the Allowable initiation Functions with Val!q9ensure that the consequences of Design Basis Accidents (DBAs) channels setpoints maintained will be acceptable, providing the unit is operated from within the LCOs at and the trip within the Allowable ... of all main Values specified inthe the onset of the DBA and the equipment functions as designed. feedwater Technical pump Specifications Each channel can be tested on lineto verify that the signal processing channels, e uipment and setpoint accuracy is within the specified allowance requirements of Reference . Once a designated channel is taken out of 3 LS service for testing, a simulated signal is injected in place of the field instrument signal. The process equipment for the channel in test is then 3 tested, verified, and calibrated. SRs for the channels are specified in the R SR section. inputs from field contacts, control board
]l Solid State Protection System I and The SSPS equipment is used for the decision logic processing o 2 Gm the signal processing equipment bistables. To meet the redundancy requirements, two trains of SSPS, each performing the same functions, are provided. If one train is taken out of service for maintenance or test purposes, the second train will provide ESF actuation for the unit. If both trains are taken out of service or placed in test, a reactor trip will result.

Each train is packaged in its own cabinet for physical and electrical separation to satisfy separation and independence requirements. The SSPS performs the decision logic for most ESF equipment actuation; generates the electrical output signals that initiate the required actuation; input signals from field and provides the status, permissive, and annunciator output signals to the contacts, control board ma control room of the unit. switches and Th bistable outputs from the signal processing equipment are sensed by the SSPS equipment and combined into logic matrices that represent combinations indicative of various transients. If a required logic matrix combination is completed, the system will send actuation signals via master and slave relays to those components whose aggregate Function best serves to alleviate the condition and restore the unit to a safe condition. Examples are given in the Applicable Safety Analyses, LCO, and Applicability sections of this Bases. Each SSPS train has a built in testing device that can automatically test the ecision logic matrix functions an the actuation le6 while the WlTS B 3 3-rtially test re3a0 R 2 WOG STS B 3.3.2 - 4 Rev. 2, 04/30101 30

ESFAS Instrumentation Rev. 2 Change A-5 B 3.3.2 BASES I L_~ o LICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued) b provided that the +/- The LCO requires all instrumentation performing an ESFAS Function to cE libration tolerance band be OPERABLE. A channel is OPERABLE with a tip setpoint valued remains the same and the Allowable Value is outside its calibration toleraAe-band provided the trip setpoint "as-found" administratively controlled value does not exceed its associated Allowable Value and provided the accordingly in the trip setpoint "as-left" value is adjusted to a value within the calibration ma conservative direction to tolerance band of the nominal trip setpoint. A trip setpoint may et * .I m Bet the assumptions of the more conservative than the nominal trip setpoint as neces n setpoint methodology. The conservative direction is response to plant conditionsy4ailure of any instrument nders the es tablished by the direction affected channel(s) inoperable and reduces the reliability of the affected of the inequality applied to Functions. I ineAlliowable Value. I in___Allowable__I ,/rhe LCO generally requires OPERABILITY of four or three channels in each instrumentation function and two channels in each logic and manual ( INSERT 8 initiation function. The two-out-of-three and the two-out-of-four configurations allow one channel to be tripped during maintenance or testing without causing an ESFAS initiation. Two logic or manual initiation channels are required to ensure no single random failure disables the ESFAS. The required channels of ESFAS instrumentation provide unit protection in the event of any of the analyzed accidents. ESFAS protection functions are as follows:

1. Safety Iniection Safety Injection (SI) provides two primary functions:

1. Primary side water addition to ensure maintenance or recovery of reactor vessel water level (coverage of the active fuel for heat removal, clad integrity, and for limiting peak clad temperature to s 2200 0F), and

2. Boration to ensure recovery and maintenance of SDM (kf

                                            < 1.0).

These functions are necessary to mitigate the effects of high energy line breaks (HELBs) both inside and outside of containment. The SI signal is also used to initiate other Functions such as:

Phase A Isolation, 3 Containmont Purge Isolation, WOG STS B 3.3.2 - 6 Rev. 2, 04/30/01 32

ESFAS Instrumentation I Rev. 2 Change A-5 B 3.3.2 BASES SURVEILLANCE REQUIREMENTS (continued) performeson a STAGGERED he 3 Frequency is adequat-rating experience, nt reliability and operating is SR 3.3.2. SR 3.3.2. the performance of a MASTER RELAY TEST. The MASTER RELAY TEST is the energizing of the master relay, verifying contact operation and a low voltage continuity check of the slave relay coil. Upon master relay contact operation, a low voltage is injected to the slave relay coil. This voltage is insufficient to pick up the slave relay, but large enough to demonstrate signal path continuity. This test is performed every 31 days on a STAGGERED TEST BASIS. The time allowed for the testing (4 hours) and the surveillance interval are justified in Reference _ (excluding time constants which are verified SR 3.3.2.7Fj-] during CHANNEL CALIBRATIONS). SR 3.3.2.'is the performance of a COT. \ A COT is performed on each required channel to ns e entire [ channel will perform the intended Function. Setp s must be found LJNthin the Allowable Values specified in Table .2- A successful test 0 required contact(s) of a channel re may be performed by the verification of the change of state of ngle contact of the relay. This clarifies what is an acceptable C of a relay. This is acceptable because all of the other requi contacts of the relay are verified by other Technical Specifications_ once per refueling inter al with applicable extensions. The difference between the current "as found" values and the previous test "as left" values must be consistent with the drift allowance used in the setpoint methodology. The setpoint shall be left set consistent with the assumptions of the current unit specific setpoint methodology. The -as foun-da- "_ues must a a re for consistency wrval extension The Frequency of 92 days is justified in Reference I WOG STS B 3.3.2 - 48 Rev. 2, 04/30/01 74

ESFAS Instrumentation B 3.3.2 KJfy BASES Rev. 2 Change A-5 SURVEILLANCE REQUIREMENTS (continued) I Surveillance Requirements. 6 the relay. This clarifies what is an acceptab TADOT of a relay. This is acceptable because all of the other require contacts of the relay are verified by other Technical Specifications nd-RTeGhni~al Specifications tests at least once per refueling interval with applicable exteni6iets. In some instances, the test includes actuation of the end device (i.e., pump starts, valve cycles, etc.). The Frequency is adequate, based on industry operating experience and is consistent with the typical refueling cycle. The SR is modified by a Note that excludes verification of setpoints during the TADOT for-manual-initia tie F-c-tio&-G The manual initiation Functions have no associated setpoints.ni\, SR 3 3.2 8 SR 3.3.2. is the perfomance of a CHANNEL CALIBRATION. A CHANNEL CALIBRATION is performed every-18] months, or approximately at every refueling. CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to measured parameter within the necessary range and accuracy. CHANNEL CALIBRATIONS must be performed consistent with the 2 assumptions of the unit specific setpoint methodology. The difference between the current "as found" values and the previous test "as left" values must be consistent with the drift allowance used in the setpoint methodology. Frequency of f181months is based on the assumption of an J181 month calibration interval in the determination of the magnitude of equipment drift in the setpoint methodology. This SR is modified by a Note stating that this test should include I verification that the time constants are adjusted to the prescribed values where applicable. SR 3.3.2.4*-2 1l Licensing Requirements Manual This SR ensures the individual channel ESF RESPONSE TIME/are less. than or equal to the maximum values assumed in the accident Analysis. Response Time testing acceptance criteria are included in the Requiromonts Manual, Section 15 (Ref. 9). Individual component response times are not modeled in the analyses. The analyses model the overall or total elapsed time, from the point at which the parameter WOG STS B 3.3.2 - 50 Rev. 2.. 04/30/01 76

Rev. 2 Change A-5 3.3.2 BASES INSERTS

1. The nominal trip setpoints account for calibration tolerances, instrument uncertainties, instrument drift, and severe environment errors for those ESFAS channels that must function in harsh environments as defined by 10 CFR 50.49 (Ref. 4). The nominal trip setpoints are specified in the Licensing Requirements Manual (LRM). The Allowable Values specified in the Technical Specifications are determined by adding (or subtracting) the calibration accuracy of the trip device to the nominal trip setpoint in the non-conservative direction (i.e., toward or closer to the safety analysis limit) for the application. The Allowable Values remain conservative with respect to the analytical limits. For those channels that provide trip actuation via a bistable in the process racks, the calibration accuracy is defined by the rack calibration accuracy term. For a limited number of channels that provide trip actuation without being processed via the process racks (e.g., undervoltage relay channels) the Allowable Value is defined by device drift or repeatability (Ref. 3). The application of the calibration accuracy term (or device drift as applicable) to each ESFAS setpoint results i 1 a "calibration tolerance band" for each setpoint. Thus, the trip setpoint value is considered a

   "'nominal" value (i.e., expressed as a value with a calibration tolerance) for the purposes of the COT and CHANNEL CALIBRATION. The calibration tolerance band for each ESFAS setpoint is specified in plant procedures.

2. This is achieved by specifying limiting safety system settings (LSSS) in terms of parameters directly monitored by the ESFAS as well as specifying LCOs on other system parameters and equipment performance.

Technical Specifications are required by 10 CFR 50.36 to contain LSSS defined by the regulation as "...settings for automatic protective devices ...so chosen that automatic protective action will correct the abnormal situation before a Safety Limit (SL) is exceeded." The Analytical Limit is the limit of the process variable at which a safety action is initiated, as established by the safety analysis, to ensure that a SL is not exceeded. Any automatic protection action that occurs when reaching the Analytical Limit therefore ensures that the SL is not exceeded. However, in practice, the actual settings for automatic protective devices must be chosen to be more conservative than the Analytical Limit to account for instrument loop uncertainties related to the setting at which the automatic protective action may actually occur. The nominal trip setpoint is a predetermined setting for a protective device chosen to ensure automatic actuation prior to the process variable reaching the Analytical Limit and thus ensuring that the SL would not be exceeded. Technical Specifications contain values related to the OPERABILITY of equipment required for safe operation of the facility. OPERABLE is defined in Technical Specifications as

  "...being capable of performing its safety functions(s)." For each automatic protective device there is a setting beyond which the device would not be able to perform its function due, for example, to greater than expected drift. The value of this setting is specified in the Technical Specifications in order to define OPERABILITY of the devices and is designated 80

Rev. 2 Change A-5 3.3.2 BASES INSERTS (Insert 2 continued) as the Allowable Value. The Allowable Value specified in Table 3.3.2-1 serves as the OPERABILITY limit such that a channel is OPERABLE if the trip setpoint is found not to exceed the Allowable Value. Note that, although the channel is "OPERABLE" under these circumstances, the trip setpoint should be left adjusted to a value within the established trip setpoint calibration tolerance band, in accordance with the assumptions stated in the BVPS Unit I and Unit 2 setpoint methodology for protection systems (Ref. 3). If the actual setting of the device is found to have exceeded the Allowable Value the device would be considered inoperable from a Technical Specification perspective. This requires corrective action including those actions required by 10 CFR 50.36 when automatic protective devices do not function as required. In addition to the channel OPERABILITY guidance discussed above, the CHANNEL OPERATIONAL TEST (COT) and CHANNEL CALIBRATION Surveillance Requirements (SRs) specified on Table 3.3.2-1 for certain ESFAS Functions are modified by Notes (e) and () that specify additional Technical Specification requirements. The applicable Notes are specified directly on Table 3.3.2-1 next to the numerical SR designations for the affected ESFAS Functions. The additional Technical Specification requirements for these ESFAS Functions include OPERABILITY evaluations for setpoints found outside the as-found acceptance criteria band and the requirement to reset the setpoint to within the as-left tolerance of the nominal trip setpoint or a value that is more conservative than the nominal trip setpoint or declare the affected channel inoperable. These additional Technical Specification requirements are only applicable to the ESFAS Functions with the Notes modifying their COT and CHANNEL CALIBRATION SR numbers on Table 3.3.2-1.

3. As discussed earlier, for certain ESFAS Functions, the COT and CHANNEL CALIBRATION SR numbers specified on Table 3.3.2-1 are modified by Notes that impose additional Technical Specification requirements for channel OPERABILITY.

4. The Nominal Trip Setpoint is based on the calculated total loop uncertainty per the plant specific methodology documented in the Licensing Requirements Manual. The setpoint methodology, used to derive the Nominal Trip Setpoints, is based upon combining all of the uncertainties in the channels. Inherent in the determination of the Nominal Trip Setpoints are the magnitudes of these channel uncertainties. Sensors and other instrumentation utilized in these channels should be capable of operating within the allowances of these uncertainty magnitudes. Occasional drift in excess of the allowance may be determined to be acceptable based on the other device performance characteristics. Device drift in excess of the allowance that is more than occasional, may be indicative of more serious problems and would warrant further investigation.

80A

I Rev. 2 Change A-5 3.3.2 BASES INSERTS

5. For most ESFAS Functions the Allowable Value specified on Table 3.3.2-1 is the LSSS required by 10 CFR 50.36. However, for certain ESFAS Functions, the COT and CHANNEL CALIBRATION SR numbers specified on Table 3.3.2-1 are modified by Notes (e) and (e that impose additional Technical Specification Requirements for channel OPERABILITY and change the LSSS for the affected Functions. For each ESFAS Function in Table 3.3.2-1 with Notes modifying the required COT and CHANNEL CALIBRATION SR numbers, the nominal trip setpoint specified in the Licensing Requirements Manual is the LSSS.

This definition of the LSSS is consistent with the guidance issued to the industry through correspondence with NEI (Reference NRC-NEI Letter dated September 7, 2005). The definition of LSSS values continues to be discussed between the industry and the NRC, and further modifications to these TS Bases will be implemented as guidance is provided. Table 3.3.2-1 Notes (e) and (f) are applicable to the COT and CHANNEL CALIBRATION SRs for specific instrument functions since changes to Allowable Values associated with these instrument functions were already under review by the NRC at the time the revised NRC setpoint criteria were documented and made available to the industry in an NRC letter to the Nuclear Energy Institute. Changes to the remaining instrument functions may be pursued after guidance endorsed by both the NRC and NEI is issued.

6. For certain ESFAS Functions the required COT (SR 3.3.2.4 specified in Table 3.3.2-1) is modified by Notes (e) and (f). These Notes specify additional requirements for the affect ed instrument channels.

Note (e) specifies the following:

If the as-found channel setpoint is conservative with respect to the Allowable Value but outside its predefined as-found acceptance criteria band, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service, and
If the 'as-found" instrument channel setpoint is not conservative with respect to the Allowable Value, the channel shall be declared inoperable.

The evaluation of channel performance required by Note (e) involves an assessment to verify the channel will continue to behave in accordance with design basis assumptions, and to ensure confidence in the channel performance prior to returning the channel to service). In addition, if the 'as found' trip setpoint value is non-conservative with respect to the Allowable Value, or is found to be outside of the two sided predefined acceptance criteria band on either side of the nominal trip setpoint, the affected channel will be evaluated under the corrective action program. Note (I) specifies the following: 80B

I Rev. 2 Change A-5 3.3.2 BASES INSERTS (Insert 6 continued)

The instrument channel setpoint shall be reset to a value that is within the as-left tolerance of the nominal trip setpoint, or a value that is more conservative than the nominal trip setpoint; otherwise, the channel shall be declared inoperable, and
The nominal trip setpoint and the methodology used to determine the nominal trip setpoint, the predefined as-found acceptance criteria band, and the as-left setpoint tolerance band are specified in a document incorporated by reference into the Updated Final Safety Analysis Report.

For BVPS, the document containing the nominal trip setpoint, the methodology used to determine the nominal trip setpoint, the predefined as-found acceptance criteria band, and the as-left setpoint tolerance band is the LRM. For the ESFAS Functions with a COT modified by Note (1), the Note requires that the instrument channel setpoint be reset to a value within the 'as left" setpoint tolerance band on either side of the nominal trip setpoint or to a value that is more conservative than the nominal trip setpoint. The conservative direction is established by the direction of the inequality sign applied to the associated Allowable Value. Setpoint restoration and post-test verification assure that the assumptions in the plant setpoint methodology are satisfied in order to protect the safety analysis limits. If the channel can not be reset to a value within the required 'as left" setpoint tolerance band on either side of the nominal trip setpoint, or to a value that is more conservative than the nominal trip setpoint (if required based on plant conditions) the channel is declared inoperable and the applicable ACTION is entered. For the ESFAS Functions with a COT modified by Notes (e) and (e, the 'as found" and "as left" setpoint data obtained during COTs or CHANNEL CALIBRATIONS are programmatically trended to demonstrate that the rack drift assumptions used in the plant setpoint methodology are valid. If the trending evaluation determines that a channel is performing inconsistent with the uncertainty allowances applicable to the periodic surveillance test being performed, the channel is evaluated under the corrective action program. If the channel is not capable of performing its specified safety function, it is declared inoperable.

7. For certain ESFAS Functions the required CHANNEL CALIBRATION (SR 3.3.2.8 specified in Table 3.3.2-1) is modified by Notes (e) and (f). These Notes specify additional requirements for the affected instrument channels.

Note (e) specifies the following: If the as-found channel setpoint is conservative with respect to the Allowable Value but outside its predefined as-found acceptance criteria band, then the channel shall be evaluated to verify that it is functioning as required before retuming the channel to service, and 80C

I Rev. 2 Change A-5 3.3.2 BASES INSERTS (Insert 7 continued) If the "as-found" instrument channel setpoint is not conservative with respect to the Allowable Value, the channel shall be declared inoperable. The evaluation of channel performance required by Note (e) involves an assessment to verify the channel will continue to behave in accordance with design basis assumptions, and to ensure confidence in the channel performance prior to returning the channel to service. In addition, if the 'as found" trip setpoint value is non-conservative with respect to the Allowable Value, or is found to be outside of the two sided predefined acceptance criteria band on either side of the nominal trip setpoint, the affected channel will be evaluated under the corrective action program. Note (I) specifies the following: The instrument channel setpoint shall be reset to a value that is within the as-left tolerance of the nominal trip setpoint, or a value that is more conservative than the nominal trip setpoint; otherwise, the channel shall be declared inoperable, and The nominal trip setpoint and the methodology used to determine the nominal trip setpoint, the predefined as-found acceptance criteria band, and the as-left setpDint tolerance band are specified in a document incorporated by reference into the Updated Final Safety Analysis Report. For BVPS, the document containing the nominal trip setpoint, the methodology used to determine the nominal trip setpoint, the predefined as-found acceptance criteria band, and the as-left setpoint tolerance band is the LRM. For the ESFAS Functions with a CHANNEL CALIBRATION modified by Note (0, the Note requires that the instrument channel setpoint be reset to a value within the "as left" setpoint tolerance band on either side of the nominal trip setpoint or to a value that is more conservative than the nominal trip setpoint. The conservative direction is established by the direction of the inequality sign applied to the associated Allowable Value. Setpoint restoration and post-test verification assure that the assumptions in the plant setpoint methodology are satisfied in order to protect the safety analysis limits. If the channel car not be reset to a value within the required 'as left" setpoint tolerance band on either side of the nominal trip setpoint, or to a value that is more conservative than the nominal trip setpoint (if required based on plant conditions) the channel is declared inoperable and the applicable ACTION is entered. For the ESFAS Functions with a CHANNEL CALIBRATION modified by Notes (e) and (f), the "as found" and "as left" setpoint data obtained during COTs or CHANNEL CALIBRATIONS are programmatically trended to demonstrate that the rack drift assumptions used in the plant setpoint methodology are valid. If the trending evaluation determines that a channel is performing inconsistent with the uncertainty allowances applicable to the periodic surveillance test being performed, the channel is evaluated uncer 80D

Rev. 2 Change A-5 3.3.2 BASES INSERTS (Insert 7 continued) the corrective action program. If the channel is not capable of performing its specified safety function, it is declared inoperable.

8. In addition to the channel OPERABILITY guidance discussed above, the CHANNEL OPERATIONAL TEST (COT) and CHANNEL CALIBRATION Surveillance Requirements (SRs) specified on Table 3.3.2-1 for certain ESFAS Functions are modified by Notes (e) and (f that specify additional Technical Specification requirements. The applicable Notes are specified directly on Table 3.3.2-1 next to the numerical SR designations for the affected RTS Functions. The additional Technical Specification requirements for these ESFAS Functions include OPERABILITY evaluations for setpoints found outside the as-found acceptance criteria band and the requirement to reset the setpoint to within the as-left tolerance of the nominal trip setpoint or a value that is more conservative than the nomirnal trip setpoint or declare the affected channel inoperable. These additional Technical Specification requirements are only applicable to the ESFAS Functions with the Notes modifying their COT and CHANNEL CALIBRATION SR numbers on Table 3.3.2-1.

80E

I Rev. 2 Change A-5 & D-9 BVPS ISTS Conversion 3.3C ESFAS Instrumentation Enclosure 2 Changes to The ISTS Bases ITS 3.3.2 Engineered Safety Feature Actuation System Instrumentation Bases JUSTIFICATION FOR DEVIATION (JFD)

1. This JFD addresses all changes made to the Bases that are editorial in nature or to correct I D-9 minor typographical errors that do not affect the technical content of the Bases. The changes addressed by this JFD are made to correct spelling, grammar, and capitalization errors as well as incorporate wording preferences. In some cases, these changes are necessary to make the descriptions of reference content correct (e.g., the content of the BVPS UFSARs may not be exactly the same as described in the ISTS Bases) or to make the actual location of information discussed correct for BVPS (e.g., the location of trip setpoints outside of the TS or the location of the list of the number of required channels for each ESFAS Function). The reasons for the changes addressed by this JFD are considered self-explanatory and a separate more detailed explanation unnecessary. These changes do not significantly impact the technical discussions contained in the Bases and in general improve the clarity or correctness of the affected text or make the text more specific to BVPS. As such, the proposed changes are acceptable.

2. Changes are made to the ISTS Bases to reflect the BVPS specific setpoint methodology and changes introduced by Amendment numbers 270 Unit 1 and 152 (Unit 2). These Amendments introduced Notes to the COT and Channel Calibration SRs that affect the definition of the LSSS for certain ESFAS Functions. The BVPS trip setpoints associated with the ESFAS Functions are nominal values with a calibration tolerance. The nominal trip setpoints are specified inthe Licensing Requirements A-5 Manual not the TS. The BVPS Allowable Value is determined by the nominal trip setpoint calibration tolerance. The BVPS ESFAS Function operability is determined by verifying the Function is with n the specified Allowable Value (setpoint calibration tolerance). The changes associated with this .JFD are required to maintain consistency with the current BVPS setpoint methodology and the current BVPS licensing basis as modified by Amendment numbers 270 and 152.

3. The standard bases text is deleted or revised to make the generic bases discussion mole accurate or complete for BVPS. The proposed revisions include changes resulting from revisions to the corresponding TS requirements that are justified in the associated JFDs for the TS. The proposed changes also include additional or revised references, additional or revised design or safety analysis descriptions that make the standard bases discussion more specific to the corresponding BVPS documentation, design, safety analyses, or licensing basis. In some cases, additional information is added that was moved from the CTS or that is consistent with the existing CTS Bases. The proposed changes enhance the ISTS Bases discussion and help to make the generic bases text more specific to each BVPS Unit.

4. The ISTS Bases text is revised to remove the details of specific instrument locations in tle plant. This level of detail is not necessary in the TS bases to understand the purpose of the ESFAS Function or to determine the ESFAS Function operability. As this information was not included in the RTS Bases, the proposed change makes the level of detail in the RTS and ESFAS Bases more consistent. In addition, the TS are not intended to control the details of the plant design and this type of design information is contained in other more BVPS Units 1 & 2 Page 1 Revision 2, 4/06 82

Fe L 17-E4C t 5.

b. Steam Generator Water 3/loeo 2/loop2//100P i 9 f narrow 1, 2, 3 Level--High-High, P-14 in any each range instrument operating eratin span Bases loop

c. Safety Injection See Item 1 a}b,ove for all Safety Injection initiating functions and requirements.

6 SSOF POWER/

a. 4.16v ecy Bus

1. Undervoltage 2/4.16kv 2/4.16kv 2 71.2% of ra 1, 2, 3, 4 33 (Trip Feed) Bus Bus Bus Vol with a . 1scond ime delay

2. Undervoltage 1/4.16kv 1/4.1 4kv Bus 2 71.2t of rated 1, 2, 3, 4 33 (Start Diesel) Bus B

b. 4.16kv Emergenc 2/4.16kv 2/Bus 2/Bus 2 93.1% of ra , 2, 3, 4 34 (Degraded ge) Bus Bus Voltage w 90 i 5 second time delay\

Moved to ITS LCO 3.3.5. Changes to this material (d) Except when all Main Feedwater Lines are Isolated by are addressed in the markups and DOCs A7 either closed and deactivated MFiVs, MFRVs and associated with ITS LCO 3.3.5. L6 associated bypass valves, or closed manual valves. BEAVER VALLEY - UNIT 2 3/4 3-19 Amendment No.152 j A-6 CD

A12.... BEAVER VALLEY - UNIT 2 3/4 3-20 Amendment No.152 I A-5 CO (A)

w it 0 O

r Ec r%V-r BEAVER VALLEY - UNIT 2 3/4 3-36 Amendment No. 152 I A-5 0.

Rev. 2 Change A-5 l Frequency of SR 3.3.2.2, Actuation Logic _ Test and SR 3.3.2.3 Master Relay Test -4+ Each train or logic channel shall be tested 4- days. (2) If the as-found channel setpoint is conservative with respect to the Allowable Value but outside its predefined as-found acceptance criteria band, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service. If the as-found instrument channel setpoint is not conservative with respect to the Allowable Value, the channel shall be declared inoperable. A-5 The instrument channel setpoint shall be reset to a value that is within the as-left tolerance of the Nominal TripSetpoint, or a value that is more conservative than the Nominal Trip Setpoint; otherwise, the channel shall be declared inoperable. The Nominal Trip Setpoint and the methodology used to determine the Nominal Trip Setpoint, the predefined as-found acceptance criteria band, and the as-left setpoint tolerance band are specified in a document incorporated by reference into the Updated Final Safety Analysis Report. ITS Table 3.3.2-1 Notes (e) & (f) BEAVER VALLEY - UNIT 2 3/4 3-38 Amendment No. 152 I A-5 103

l i Changes to this Unit I material are addressed in the Unit 2 markup.[ I Rev. 2 Change A-5 TABLE 4.3-2 (Continued) ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION Automatic Actuation Logic and Actuation Relays SURVEILLANCE REQUIREMENTS CHANNEL MODES I CHANNEL CHANNEL FUNCTIONAL S ILLANCE FUNCTIONAL UNIT CHECK CALIBRATION TEST REQUIRED

7. AUXILIARY FEEDWATER Mi2 Steam Generator 0Q Water S R(2)(3 / l2(3) 1, 2, 3 I A-6

                 ~~<evel-Low-Low

b. u -RCP S Q 1, 2

c. S.I. S bove (all SI surveillance requirements)

d. (Deleted)

e. Trip of Main R 1, 2, 3 Feedwater Pumps

8. ESF INTERLOCKS

a. N.A. N.A. R1, 2, 3 P-11 N.A. R Q 1 3 P-12 N.A. R O 1. 2.3 Changes to this Unit I material are addressed in the Unit 2 markup.

BEAVER VALLEY - UNIT 1 3/4 3-31a Amendment No.270 l A-5 -A

I Rev. 2 Change A-5 l TABLE 4.3-2 (Continued) TABLE NOTATION (:1) Each train o logic channel shall be tested a east every other 31 days.\/ (2) If the as-found cha 1 setpoint is c ervative with respect to the Allowable Value but utside its edefined as-found acceptance criteria band, then the c el s 1 be evaluated to verify that it is functioning as requi efore returning the channel to service. If the as-found n rument channel setpoint is not A-5 conservative with respect the A owable Value, the channel shall be declared inoperable. (3) The instrument ch eX setpoint shall be et to a value that is within the as- t tolerance of the Nominal rip Setpoint, o:c a value that more conservative than the Nomi 1 Trip Setpoint; otherwise, he channel shall be declared inoperab . The Nominal Trip S oint and the methodology used to determin the Nominal Trip etpoint, the predefined as-found acceptance crit ia band, a the as-left setpoint tolerance band are specified in a curent ncorporated by reference into the Updated Final Safety Ana sis

     / Report.\
                 \                                               /

IChanges to this Unit I material are addressed in the Unit 2 markup. Ct BEAVER VALLEY - UNIT 1 3/4 3-32 Amendment No. 270 l A-4 116A

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) NoS. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 CHANGE A-6 This change incorporates amendment numbers 271 (Unit 1) and 153 (Unit 2) issued by the NRC, on 2/6106. The BVPS Unit 1 and Unit 2 Containment Conversion changes proposed in LARs numbers 317 and190 and approved in Amendments 271 and 153 respectively resulted in the revision of several technical specifications. The changes were needed to support plant operation at a containment pressure that is only slightly below atmospheric instead of the significantly more negative pressure previously required. In addition to the changes related to the containment pressure requirements, this Amendment includes the addition of footnotes to the Channel Functional Test and Channel Calibration surveillances for those Unit 1 and Unit 2 ESFAS Functions that had setpoints revised in these amendments. The new footnotes provide more detailed instructions regarding the SR results and further actions that may be required (for drift). The footnotes are the same as were added in Change A-5 at the request of the NRC. Change A-6 affects technical specification requirements in Section 3.3C (ESFAS Instrumentation), Section 3.6 ( Containment), and Section 5.0 (Administrative Controls). The following ESFAS (ITS 3.3.2) setpoints were changed and had Notes added. Unit 1 Si Containment Pressure-High, RWST Level -Low, Containment Pressure High-High, Containment Pressure Intermediate High-High, Unit 2 Containment Pressure -High, RWST Level Extreme Low, Containment Pressure High-High, Containment Pressure Intermediate-High-High. Affected Paqes: The following Table(s) list the affected pages by type (i.e., ITS markup, CTS markup, etc.). In order to facilitate review by ITS section, a separate table is provided for each ITS section affected by the change. The page numbers listed are the ITS section specific consecutive numbers found in the lower right corner of each page. Note: Because the affected page(s) for each change were extracted from a complete ITS section electronic file, the electronic hyperlinks (created in the complete ITS section file) do not work in the collection of affected pages that follow this coveir page. (continued)

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) NOs. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 Change A-6 (continued) ITS SECTION 3.3C (ESFAS) INDEX OF AFFECTED PAGES ITS MARKUPS PAGES: 10,11,12,13,16 & 18 ITS JFDS No change ITS BASES MARKUPS No change ITS BASES JFDS No change CTS MARKUPS PAGES: Unit 2 - 89, 90, 91, 98 & 99. Unit 1 - 108 & 115. CTS DOCS No change. ITS SECTION 3.6 (CONTAINMENT) INDEX OF AFFECTED PAGES ITS MARKUPS No change ITS JFDS No change ITS BASES MARKUPS No change ITS BASES JFDS No change CTS MARKUPS PAGES: Unit 2- 162,164,165,179, & 180. Unit 1 - 177. CTS DOCS No change. ITS SECTION 5.0 (ADMINISTRATIVE CONTROLS) INDEX OF AFFECTED PAGES ITS MARKUPS No change ITS JFDS No change ITS BASES MARKUPS No change ITS BASES JFDS No change CTS MARKUPS PAGES: Unit 2-110 & 86. Unit 1-85 & 111. CTS DOCS No change.

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQDUEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT Z) REVISION 2 CHANGE A-6 AFFECTED PAGES FOR ITS SECTION 3.3C (ESFAS) ITS SECTION 3.3C (ESFAS) INDEX OF AFFECTED PAGES ITS MARKUPS PAGES: 10,11,12,13,16& 18 ITS JFDS No change ITS BASES MARKUPS No change ITS BASES JFDS No change CTS MARKUPS PAGES: Unit 2 - 89,90, 91, 98 & 99. Unit 1 -108 & 115. CTS DOCS No change.

ESFAS Instrumentation l Rev. 2 Change A-6 I 3.3.2 K).t Table 3.3.2-1 (page 1 of 8) UNIT 2 Engineered Safety Feature Actuation System Instrumentation ALLOWABLE ziz/ VALUE

1. Safety lnrection

a. Manual 1,2,3,4 2 B Initiation

b. Automatic 1,2,3,4 2 trains C Actuation Logic and Actuation Relays IA-6

c. Containment 1,2,3 3 D Pressure -

High 4

d. Pressurizer 1 .2 3(a)) D SR Pressure - Low SR SR SR

e. Steam Line E Pressuref, t (4) Low 112,31( ) l 3 per steam t D tSR line SR SR SR Pressure Between Steam (a) Above the P-1I (Pressurizer Pressure) interlock.

(b) s d in the lead/lag controller are t, 2 [501 seconds and t2 5[5] seconds. ein (c) Above the P-12 (T. Lwl

^,-

(d) Less than or equal to a function defined as core o [44 % ow belw [201% load, and AP increasing linearly from [441% full steam flow at [201% load to (1141% full stem a P corresponding to [1141% full steam flow abovti 100% load. (e) Less than or e nctioined as coPrresponding to [40]% full steam fow between an and then a tP arly from [401% steam flow at [20]% load to [1101% full steam flow at [1001% load. INSERT 2 IA-6

                                                ~[ Notes (e)& (f)

WOG STS 3.3.2 - 8 Rev. 2, 04/30/01 10

I Rev. 2 Change A-6 ESFAS Instrumentation 3.3.2 Table 3.3.2-1 (page 2 of 8) Engineered Safety Feature Actuation System (d) Less than or equal to a function defined as tAP coroew below 1201%load, and AP increasing linearti from [44]% full steam flow at (201% load to [11411 full stea and corresponding to 1 141% fullsteamflow abou 100% load. (e) Less than or uction defined as AP corresponding to 1401% full steam flow between [01%nnd then a tiP ng linearly from [401% steam flow at 1201%load to [1101% full steam flowwat[1001%load. INSERT 2 A Notes (e) & (f) WOG STS 3.3.2 - 9 Rev. 2, 04/30/01 11

I Rev. 2 Change A-6 I ESFAS Instrumentation t 44 - 3.3.2 Table 3.3.2-1 (page 3 of 8) Engineered Safety Feature Actuation System Instrumentation (7) UN4

3. Containment Isolation

a. Phase A Isolation (1) Manual 1.2,3,4 2 B SR 3.3.2.8 NA Initiation (2) Automatic 1.2.3,4 2 trai ns C SR 3.31.2.2 Ul ,i NA; Actuation SR 3.3.2.4 Logic and SR 3.3.2.6 Actuation Relays (3) Safety Refer to Function 1 (I3afety Injection) for all initiation functions and requirements.

Injection

b. Phase B B 5 .32 R NA Isolation (1) Manual 1,2,3.4 2pertrain,2 ! B SR 3.3.2.8 il <,-,i NA Initiation trains (2) Automatic 1,2,3,4 2 trains C SR 3.3.2.2.. , NA Actuation SR 3.3.2.4 Logic and SR 3.3.2.6 - l Actuation Relays (3) Contain- 1,2,3 141 E SR ment SR Pressure SR High 3 SR (High-High)

F INSERT 2 Notes (e)& (fl A-6 WOG STS 3.3.2- 10 Rev. 2, 04/30/01 12

I I D-IVD.

                           -3f-h~ --

5 'IjIaguw A r-rYu ESFAS Instrumentation 3.3.2 6& UNIT2 Table 3.3.2-1 (page 4 of 8) ALLOWABLE Engineered Safet C Ire Actuation Instrume VALUE UI m 1 WOG STS 3.3.2 -11 Rev. 2, 04/30/01 13

I Rev. 2 Change A-5 & A-6 I ESFAS Instrumentation 3.3.2

b. Refueling 1,2,3,4 4 Water Storage Tank (RWST)

_ Level-Low Coincident with Refer to Function 1 (Safety In Safety Injection { ~Low (Unit 1) ' le 2 A-S 'it Notes (e)&(I) l A-6 WOG STS 3.3.2- 14 Rev. 2, 04/30/01 16

Rev. 2 Chanaes A-5. A-6, & A-8 The Notes were added by Change A-5. Changes A-6 & A-8 reference the Notes added by A-5 INSERTS FOR ITS 3.3.2. ESFAS INSERT I - SR 3.3.2.6 Frequency Note 92 days OR Note Jntj5~p e ti ~ provided a satisfactory contact loading analysis has been completed, and a satisfactory slave relay service life has been established, for the slave relay being tested. 12 Months AND Note Only applicable to UnitI1 18 Months INSERT 2 - Table 3.3.2-1 Notes (e) & (f) (e) Ifthe as-found channel setpoint is conservative with respect to the Allowable Value but outside its predefined as-found acceptance criteria band, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service. If the as-found instrument channel setpoint is not conservative with respect to the Allowable Value, the channel shall be declared A-5 inoperable. A-6 A-8 (1) The instrument channel setpoint shall be reset to a value that is within the as-left tolerance of the Nominal Trip Setpoint, or a value that is more conservative than the Nominal Trip Setpoint; otherwise, the channel shall be declared inoperable. The Nominal Trip Setpoint and the methodology used to determine the Nominal Trip Setpoint, the predefined as-found acceptance criteria band, and the as-left setpoint tolerance band are specified in a document incorporated by reference into the Updated Final Safety Analysis Report. 18

L L__ I I Rev. 2 Change A-6 I lOR OTHER SPE D IE l CONDITIONS lIlCONDITIONl ALLOWABLE APPLIC A-__ VALUE MODES AC-TTION 7E

1. SAFETY INJECTION AND FEEDWATER ISOLATION

a. Manual Initiation 2 N.A. 1, 2, 3, 4 48

b. Automatic Actuation 2 N.A. 1, 2, 3, v , 36 6 Logic and Actuation Relays

c. Containment 3 5 5.3 psig 1, 2, 3 Pressure-High

d. Pressurizer 3 2 1852 psig 1, 44 Pressure-Low steam line 3

e. Steamline Pressure-Low 3/loeep 2 494 psig* 1 Q42E 44 3-

a. Automatic Actuation N.A. 1, 2, 3, 4 '%8 Loqic Coincident with Safety Injection Signal

b. Refueling Water 4 2 3 2 31' 8" and

31' 1, 2, 3, 4 6ZE Storage Tank Level- 10" Extreme Lo"Bases
Time constants utilized in the lead-lag controllers for Steam Line Pressure-Low are T1 2 50 seconds and T2* 5 seconds. ICHANNEL CALIBRATION shall ensure that these time constants are adjusted to these values.I BEAVER VALLEY - UNIT 2 3/4 3-16 Amendment No. 153 l A6 00 (D

JFr Rev. 2 Change A.6 A I REQUIRED ITABLE ()Continued " NIT`2 LJT FUNCTION Y

ENGINEERE SAFETY FEATURE A WATION SYSTE M INSTR MINIMUM ENTATION I OR OTHER SPECIFIED CONDITIONS CONDION I TGTAL-NO. CHANNELS CHANNEL ALLOWABLE APPLI

          ;UNCTTONAL UNIT                  GP CHANNELS        TO TRIP      PERABL        VALUE                   MODES          ______

2. CONTAINMENT SPRAY

a. Manual Initiation set 1 set N.A. 1,

(,~iQ petrain,2train st 2, 3, 4 w-/E 43

b. Automatic Actuation Logic and Actuation Relays A; 13:~

2 N.A. 1, 2, 3, 4

                                                                                                                                   -X/E

c. Containment Pressure-- 5 11.4 psig 1, 2, 3 High-High 46

3. CONTAINMENT ISOLATION

a. Phase "A" Isolation ( !44:4

1) Manual Initiation\ N.A.

1, 2, 3, 4 _q

2) Automatic Actuation LI.A. 1, 2, 3, 4 Logic and Actuation Relays

3) Safety Injection See Item 1. above for all Safety Injection initiating functions and requirements.

b. Phase "B" Isolation 43

1) Manual Initiation s _ N.A. 1, 2, 3, 4

2) Automatic Actuation N.A. 1, 2, 3, 4 Logic and Actuation Relays A13

3) Containment 4 \

11.4 psig 1, 2, 3[, 44 Pressure--High-High BEAVER VALLEY - UNIT 2 3/4 3-17 Amendment No. 153 l A-6 Co 0

AO-

                                                'I-IW--

(b) Except when al MSIVsare closed and deactivated.

Time constants utilized in the lead-lag controllers for Steam Line Pressure-Low are T. t 50 seconds and TS 5 seconds. I CHANNEL CALIBRATION shall ensure that these time constants are adjusted to these values. I BEAVER VALLEY - UNIT 2 3/4 3 -18 Aendment No.153 i A-6 CD

le-" k IkL-V-- BEAVER VALLEY - UNIT 2 3 /4 3-33 Amendment No.153 I A-* C0 CD

A-

                                                                                                                                                                                  -r L                                                                                                                                                                 C Channel Operational Test (COT), Trip Actuating Device Operattonal Test TADOT), Actuatoon Logic Test, Rpennnqp Timi*sarewithiniLlmit.               ~s._                                        Master Relay Test, and_ Slave Relay Sf            j     ie                            FunConal ni A                  19                                 Changes        to Modes ar ChangesSto                                                                      r                                                                     addressed In markup Functlons are .a -lati "B                             N                     SAFC T           STEMSR32                                                      of Table   3.3 3 addressed In,                                                    SURVEILLANCE A7                      REOUIREMENT                                      A   17
                                                                                                                                                         -t/

markup of Table \~ -

        -3.3-3                                                                     \                                                                     MODESN       IN WHICH

_CHANNEL CHNE IFNROA SURVEILLANCE/

               \      FUNCTIONAL UNIT                                      /           CH4ECK                CALIBRTO                    T~                     REQUIRED/

2 CONTAINMENT SPRAY /lSR 3.3.2.2, SR 3.3.2.3, SR 3.3-2-6 l R33.2.7l \/

                                 . Manual Initiation             o                 N.A.                   N.A.                                        1,2, 3, 4 ITS SR 3.3S2.93.3.2.2,SSAS                                                 3.3.2.3, SRCh3.3.2.6 Automatic

2. Actuat ogic N.A. N.A. it 3 4 Actuation and Re 3.3.2.8 S 3.3.2.4

                         . c   .       Containmnt         Preure         -                                                                              , 2       3                  A h-High/Hia\
                                                                                                          \/ITS Table 3.3.2-1Notes (e)& (1)

3. CONTAIEYT ISOT 2 / 34 3. enmen N / 1

a. Phas "All Z lation. 2

                                                                                                                                                .3-                     /

l1. Ms~lInitiation N.A. N.A. 1f, 2, 4

2. A atic Actuation N.A. N.A. ?4 4l+, 2, t figi and Actuation /\

                                         /   elays                                      SR 3.3.2.2,  SR 3.3.2.3, SR 3.3.2.6                                        /       \

3 Safet jection See Functional Unit l above for all safetA I jctior

                                                /       \                            ~Surveillance             Requirements./                                                  \

b. Phase "B" Isola nlSR 3.3.2.2, SR 3.3.2.3, SR 3.3.2.6 SR.27l /\

                              /    .       Manual     Inita         on                N.A.                   N.A.              \RA-                      l,2          3,4\
                            /    2.        Automatic A tu         ~on                 N.A.                   N.A.                       X                  l2,        3,     4\
                        /                ~~Logic    and Actuatxo/\
                     /Relays                                           \        lSR 3.3.2.1      l     lSR 3.3.2.8       ljS             ...

_/3. Containment Pressu & - G "'2) (3l, 2, 3, 4 \ lA-6 _ ' ~ Higth-High \M ITS Table 3.3.2-1 Notes (e)&(f)t BEAVER VALLEY - UNIT 2 3/4 3-34 Amendment No. 153 lA-6 CD CD

V '-.- K Changes to this Unit I material are addressed in the Unit 2 markup. l I Rev. 2 Change A-6

                                                                        \      TABLE      3.3-3    (Cdhtinued)\                                 DRF      PAG  FRO

_and ActuationRly .ED / \\ SAF&TY FEATURE ACTUATION

                                                                                                                  \               \DRAFT SYSTEM[:'STRUMENTATIONUnt LR#0 PAGE FROM
                                                  \                     <                       ~MINIMUM/                                                             /
                                         \TOTAL                  NO.         CHANNELS           CHANNELf      ALLOAL              \       PPLICABLE/

FUNCTIONAL UNIT \ OF CHANNELS TO TRIP OPERAB EVALUE \PMODESA

4. STEAM LINE ISOLATI

a. Manual \2/stea l m steam ! Not Applicable

b. Automatic Actuation 1 2 Not Applicable 1, 2, 3 Logic\/*\\

c. Containment Pre S 2 2 7.33 psig 1, 2, 3 14 Intermediate-High-High

d. Steamline Pressure-Low 3/loop \ 2/oop 2/loop > 495.8 psi 1, 2, 14 y loop any loop 3-ce3l

                                                                                       /                       ine          p   rsue*

e. Steamline Pressure Rate- 3/loop 2/lo0 2/operat-

104.2 psi with 3(2) 14 High Negative any loo ing loop a time constant

                                                                               /             \                2    5So  seconds/\

5. TURBINE TRIP & FEEDWATER ISOLATION Steam Generator Water 3/ oop 2 loop 2/loop ofgrrow 1, 2, 3 14 Level--High-High, P-14 in any in each range instrument l operating operating an each steam b loop loop g erator

a. Automatic Actuation Logic and Actuation Relays 2 Trains NA 1, 2, 3 G 5 Safety Injection

c. Refer to Function I (Safety Injection) for all Initiation functions and requirements.

Time constants utilized in the lead-lag controllers for Steam line Pressure-Low are Tl Ž 50 seconds an t2
5 seconds. CHANNEL CALIBRATION shall ensure that these time constants are adjusted to these values.

BEAVER VALLEY - UNIT 1 3/4 3-18 Amendment No. Note in Channel Calibration SR. co

r 4e-Moved to ITS LCO 3.3.5. Changes to CTS Function 6 are addressed In the markups and DOCs associated with ITS LCO 3.3.5. BEAVER VALLEY - UNIT 1 3/4 3-31 Amendment No.273 I A-8 0

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 CHANGE A-6 AFFECTEDPAGES FOR ITS SECTION 3.6 (CONTAINMENT) ITS SECTION 3.6 (CONTAINMENT) INDEX OF AFFECTED PAGES ITS MARKUPS No change ITS JFDS No change ITS BASES MARKUPS No change ITS BASES JFDS No change CTS MARKUPS PAGES: Unit 2- 162, 164,165,179, & 180. Unit I - 177. CTS DOCS No change.

CONTAINMENT SYSTEMS I Rev. 2 Change A-6 l SURVEILLANCE REQUIREMENTS lrequired lLn~cracwt it.l3 ach eentainment airyLocT shaIl

                                                                    -t            c demonstrated IGPERABLE ;-

a- By ,lerforming the a r lock leakage rate testing t the frequency specif ied in the Containment Leakage Rate OR 3.6.2.1 Testing Program: I I I Move to the Containment I1. Verify no detectable seal leakage when the gap between the door seals is pressurized for at least 2 minutes to: Le 3kage Rate Te sting a) Personnel air lock 2 Pa (44.9 psig). Program In Section 5.0 of b) Emergency air lock 2 10.0 psig. the Tech 4-Specs. or, quantifying the air lock door seal leakage to Changes for ensure that the leakage rate is

0.0005 La when both units are tested at 2 Pa (44.9 psig) for the personnel air lock shown In and
0.0005 La when tested at 2 10.0 psig for the Section 5.0. emergency air lock.

2. Conduct the overall air lock leakage tests,4 at 2 Pa (44.9 psig), and verify the overall air lock leakage A b rate is

0.05 La when tested at 2 Pa (44.9 psig):

a) At the freqiuency specified in the Containment T - -- - - 4 - - n n d.

                                  -eL LaES.     - U  -----       lC-lI l -*euem o         dor
 /

I face. At least once per months --- - by verifying that only one door i each air 1 k can be opened at a time. SR3A I 2436L12olM - -1

    -(7)l An inoperable air lock door does not invalidate the previouv l successful performance of the overall air lock leakage test.                                                l
    -(-8)lResults shall be evaluated                              against          the      acceptance         criteria applicable to LCO ;.6.l.2.

l SR3.6.1.1 l SR 3.6.2.1 Note 2 BEAVER VALLEY - UNIT 2 3/4 6-5a Amendment No. 153 I 162

CONTAINMENT SYSTEMS Rev. 2 Change A-6 NTERNAL PRESSURE [2ITS 3..i) [Contanment lS LIMITING CONDITION FOR OPERATION

     -G6-1--4  Containment internal air pressure shall be 2 12.8 psia and

14.2 psia.

APPLICABILITY: MODES 1, 2, 3 and 4. ACTION: With the containment internal air pressure not within the above limits, restore the internal pressure to within the limits within 1 hour or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours. SURVEILLANCE REQUIREMENTS

     .-.1-.-4  The containment internal pressure shall be determined to be within the limits at least once per 12 hours.

SR36A1 BEAVER VALLEY - UNIT 2 3/4 6-6 Amendment No. 153 I (next page is 3/4 6-8) 164

CONTAINMENT SYSTEMS Rev. 2 Change A-6 ]

         -VAIR TEMPERATURE      lITS 3.6.5 l

~J1y C)ntainment I e ILIMITING CONDITION FOR OPERATION

          *3-6-4-4   Containment   average   air  temperature   shall  be  Z   70'F
           < 105 0F.

APPLICABILITY: MODES 1, 2, 3 and 4. ACTION: With the containment average air temperature not within the above limits restore the average air temperature to within the limits within 8 hours or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours. SURVEILLANCE REQUIREMENTS 0.G.1. r The containment average air temperature shall be determined

        /to be within limits at least once per 24 hours.

LR3.6.5.1 BEAVER VALLEY - UNIT 2 3/4 6-8 Amendment No.153 I 165

CONTAINMENT SYSTEMSl UNIT I PAGE I I Rev. 2 Change A-6 At least once per 18 months, Cycling each valve in the chemical addition ath that is not testable during plant ration, thraght one complete cycl 1 travel.

2. Verifying that eac valve in the flow path actuates to it non test signal.

3. Veri hat each chemical inject mp starts omatically on a test signal.

Changes to this U1 material are addressed In the U2 Markup & DOCs. BEAVER VALLEY - UNIT 1 3/4 6-16 Amendment No.271 I 177

CONTAINMENT SYSTEMS L Rev. 2 Change A-6 I I Required Action and associated Completion time not met I LIMITING CONDITION FOR OPERATION (Continued) / _ With one or more penetration flow path with two containment isolation valves inoperable, isolate the FiAtion, affected penetration flow path within 1 hou by use of at least one closed and deactivated automati valve, closed [A~di~tionB manual valve, or blind flange. Otherwisc, be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours. I I I e-- With one or more penetration flow pat wit one containment isolation valve inoperable, isolate the affected penetration flow path within 72 rs by use of at least one closed and deactivated autoctic valve, closed manual valve, or blind flange; and verify the affected U penetration flow path is isolated at least once per 31 days. Ottwisc

                                              ,     be in at least HOT STANDBY within the IHTSJction       e     next 6 hours and in COLD SHUTDOWN within the following ConitionD 30 hours. Required Action and associated Completion time not met.

__ INSERT SR 3.6.3.3 From CTS 3.6.1.1 SURVEILLANCE REQUIREMENTS 4.6.3.1 Eahcnanetcaaono7c3.1beemnrtd OPERABLE*: a-- By verifying each purge supply and exhaust valve is ITSSR edeactivated in the closed position at least once per 3.6.3.1 31 days for valves outside containment and prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days for valves inside containment. beBverifying, at the frequency specified in the Inserv:.ce Testing Program, the isolation time of each automatic power ITS SR operated containment isolation valve that is not locked, sealed, or otherwise secured in position, and required to be closed during accident conditions is within limits. e-. B verify-ing, at least once per 18 months, each automatic power operated containment isolation valve that is not IrsSR locked, sealed, or otherwise secured in position, ind 3.6.3.5 required to be closed during accident conditions, actuates to the isolation position on an actual or simulated actuation signal. SR,3.6.3.2 & SR 3.6.3 3

       -    Lceked r scaled elese valves, emeept                      fer thc containment purge                            L supply and exhaust valves, may be opened en an intermittent baszies under administrative control.                                                                            _

BEAVER VALLEY - UNIT 2 3/4 6-16 Amendment No.153 I 179

Rev. 2 Change A-6 INTENTIONALLY BLANK PAGE This page previously contained surveillance 4.6.3.1.c. However, Amendment 153 (Implemented in Rev. 2 Change A-6) resulted in 4.6.3.1.c moving to the previous page (3/4 6-16). Although this was not a technical change it required changes to the markup of page 3/4 6-16 to accommodate the repagination. This blank page (formally 3/4 6-17) is no longer used after Amendment 153. Therefore, replace old page 3/4 6-17 with this blank page to maintain the consecutive page numbering (in lower right corner of page) the same as before. 180

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. Z96 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 CHANGE A-6 AFFECTED PAGES FOR ITS SECTION 5.0 (ADMINISTRATIVE CONTROLS) ITS SECTION 5.0 (ADMINISTRATIVE CONTROLS) INDEX OF AFFECTED PAGES ITS MARKUPS No change ITS JFDS No change ITS BASES MARKUPS No change ITS BASES JFDS No change CTS MARKUPS PAGES: Unit 2 -110 & 86. Unit 1 - 85 & 111. CTS DOCS No change.

A. Rev. 2 Change A H6 ADMINISTRATIVE CONTROLS CI ITS 5-5 l NT OFFS DOSE CALCULATION MANUAL (ODCM) (Continued)

c. Shal submitted to the Commission i e form of a complete, ible copy of the entire M as a part of or Changes to this Unit 1 material are addressed in the Markup catReletse and DOCs associated with the corresponding Unit 2 text. ntified by n rKings in Lnemargin or "nalcea pages, clear-ly indicating area of the page that aqWs changed, and shall a indica the date (e.g., month/year e change was

_<_ Iemented. 6 Moved to the PROCESS CONTROL PROGRAM. 6-.-4 Containment Leakage Rate Testing Program A program shall be established to implement the leakage rate testing of the containment as required by 10 CFR 50.54(o) and 10 CFR 50. Appendix J, Option B, as modified by approved exemptions'. 4.This program shall be in accordance with the guidelines contained in Regulatory Guide 1.163, "Performance-Based Containment Leak-Test Program," dated September 1995, except that the next Type A test performed after the May 29, 1993 Type A test shall be performed no later than May 28, 2008. fhe peak calculated containment internal pressure for the design

  /basis     loss of coolant accident, P., is 43.3 psig.

maximum allowable containment leakage rate, L., at P., s b 0.10% tainment air weight per day. Leakage Rate criteria are: 552.b a.* Changes to this Unit I material are addressed in the Markup lis 1-. 0 _L. l and DOCs associated with the corresponding Unit 2 text. L. for thie I fleakage rate (MNPLR) bass. 6 During the first>_ nit startup follow.ng testingjifF accordance with this progr the leakage rate a ance criteria are < 0.60 L. on a mum pathway 2 eakage rate (MXPLR)( ) basis for Type B and Ty tests I _and < 0.75 L. for Type A tests. (4- Exemptions to Appendix J of 10 CFR 50 dated November 19, 1984, December 5. 1984. and July 26. 1995. BEAVER VALLEY - UNIT 1 6-25 Amendment No.271 I 85

I M-Iev.S

                         -2 Lx~I~

FV.C 11dJUus9<a-I-r% -F Li-Ie U1 0 A e I A Al 4 j

                                                                                  ~ ITS 5.51 ADMINISTRATIVE CONTROLS tj 2 ]       ONTAINMENT LEAKAGE RATE TESTING PROGRAM (Continued)

The peak calculated containment internal pressure for the design basis loss of coolant accident, P., is 44.9 psig. The maximum allowable containment leakage rate, L., at P., shall be Fj32.cJ0.lo% of containment air weight per day. ELgeakage Rate acceptance criteria are: (j) ]pdotMOE4nr

a. Containment leakage rate acceptance criterion *s . -- o L Acfer+55o the ePeal A 7\ A _ealae _e And - .

fo-1 t\ -hTV 5.5.12.f Nothing in a--~kqert these Technical Type B and Type G tests en amnimum pathway Specilcations shall be 4WIPL-R) basis. During the first unit startup following construedtomodifythe testing in accordance with this program, the leakage rate testing Frequencies acceptance criteria are < 0.60 L. en a maximum pathway requir dby10CFR50, lcaleage rate (MXPLR+n) basis for Type B and e C tests ApieridixJ. nd < 0.7 L5T.for Type A tests. Insert Unit 2 AIr lock Criteria

                                                                                         \! 0.75 L,                 From CTS 3.6.1.3 l      b.      Air lock testing acceptance criteria and required acti[n                                                                  D-7 All\            1 are as stated in Specification 3.6.1.3 titled "Containment I.A6        jAir Locks."

lThe prov-sans - o $ecification 4.0.2 do n oo the Pl tesJ frequencies specified i eeavoent Leakage Rate Test:ing oram te provisions of Speifiat . are applicable to lhe Containment Leakage Rate Testing Program. SR3.3 Insert Unit I AirlokCkri;ra [ 6].16 TECHNICAL SPECIFICATIONS (TS) BASES CONTROL PROGRAM This program provides a means for processing changes to the Bases of these Technical Specifications.

a. Changes to the Bases of the TS shall be made under appropriate administrative controls and reviews.

b. Licensees may make changes to Bases without prior NRC approval provided the changes do not require either of tihe following:

1. a change in the TS incorporated in the license; or (2 For p ons which are isolated by use of vave) blind flange(s tivated valve(s), the MXPLR of the isolated d to be the measured aka e isolation device(s).

BEAVER VALLEY - UNIT 2 6-26 Amendment No. 15 l Ad 86

I Rev. 2 Change D-7 & A-6 Unit 2 CTS page for ITS 5.5.12 D7 CONTAINMENT SYSTEMS Containment Leakage Rate Testing Program SURVEILLANCE REQUIREMENTS 14.6.;13 baeh -cantainment air lock shall be demonstrte-ePE :I I NOTE: These requirements are contained In the Containment Systems section (3.6.2) of the Tech Specs consistent with the location of these requirements In the ISTS. Changes to this Information Is discussed and documented In Section 3.6 of the Tech Specs. Li---- ing Program: Verify no detectable seal leakage when the galp between 5 5.12.d.2.b) & the door seals is pressurized for at least 2 minute I5.512.d.2.c) l to: a) Personnel air lock 2 Pa (44.9 psig). H LLA)(j CLRTP b) Emergency air lock 2 10.0 psig. or, quantifthe air lock door seal leakage o ensure that the leakage rate is

0.0005 L. when tested at 2 Pa (44.9 psig) for the personnel air lock and
0.0005 La when tested at 2 10.0 psig for the emergency air lock.

I 5.512.d.2a) l>2- Conduct the overall air (44.9 psig), lock leakage tests,~atE and verify the overall air lock leakag ia rate is < 0.05 La when tested at 2 Pa (44.9 psig): a) At the frequency specified in the Contain Leakage Rate Testing Program, and / / b) Following maintenance performed o te o ier personnel air lock door which result n a ecrease in closure force on part of the door se ing surface. NOTE: These requirements are contained in the Containment Systems section (3.6.2) of the Tech Specs consistent with the location of these requirements in the ISTS. Changes to this information is discussed and documented in Section 3.6 of the Tech Specs. (7) An inope e air lock door does not invalid the previous succe ul performance of the overall air lock leaka est. (8) ults shall be evaluated against the acceptance c . ia applicable to LCO 3.6.1.2. BEAVER VALLEY - UNIT 2 3/4 6-5a Amendment No. 153 A4 110

r Rev. 2 Change D-7 & A- I l N 1 D-7 CONTAINMENT SYSTEMS[ Unit I CTS page for ITS 5.5.12 Containment Leakage Rate Testing Program CMi)[ k URVE I REQUIREMENTS ~I = I__ WOTE: These requirements are contained In the Containment Systems section (3.6.2) of the Tech Specs consistent with the location of these requirements in the ISTS. Changes to this information is discussed and documented in Section 3.X; of the Tech Specs. testing at tne rrequency specitlea in tne I - T-V-lnn D;nf-- Tic F-4",-rnr Verify no detectable seal leakage when the c' l5 5.12.d2.b) &l between the door seals is pressurized Ifor- a I 5.5.12.d2.c) l Ileast 2 minuteslto: ]G_ a) Personnel air lock > Pa (43.3 psig). CI iT b) Emergency air lock > 10.0 psig. or, quantify Xthe air lock door seal leakage to ensure that the leakage rate is < 0.0005 L. when tested at > Pa (43.3 psig) for the personnel air lock and < 0.0005 La when tested at > 10.0 psig for the emergency air lock. Conduct the overall air lock leakage testsig at 2 Pa (43.3 psig), and verify the overall air 1 5.512.d2.a lT-lock leakage rate is S 0.05 La when tested at. 2 Pa (43.3 psig): Aa)Lt Ene rrequency specifiea in tier Containment Leakage Rate Testing Pro am, and b) Following maintenance per ed on the outer personnel air lo door which may result in a decreas in closure force on NOTE: These requirements are contained in the Containment Systems section (3.6.2) of the Tech Specs consistent with the location of these requirements in the ISTS. Changes to this information is discussed and documented in Section 3.6 of the Tech Specs.

                                           --        r w- -\

(7) An aoper ir lock door does not inva the previous succ 1 performance of the overall air lock leak est. (8) ults shall be evaluated against the acceptance cria applicable to LCO 3.6.1.2. BEAVER VALLEY - UNIT 1 3/4 6-5b Amendment No.271 l A6 111

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 CHANGE A-7 This change incorporates Amendment numbers 272 (Unit 1) and 154 (Unit 2) issued by the NRC: on 216/06. The BVPS LARs numbers 318 (Unit 1) and 191 (Unit 2) proposed changes to implement the Westinghouse best-estimate loss-of-coolant accident (BELOCA) analysis methodology for BVPS and were approved in Amendment numbers 272 (Unit 1) and 154 (Unit 2). The technical specification impact of this amendment is a reference change in the Core Operating Limits Report requirements in SectiDn 5.0 (Administrative Controls). As this change was anticipated in the ISTS conversion documentation the change simply removes the 'Draft Page" annotation for LAR numbers 318 and 191 from the top of the page. Affected Pages: The following Table(s) list the affected pages by type (i.e., ITS markup, CTS markup, etc.). In order to facilitate review by ITS section, a separate table is provided for each ITS section affected by the change. The page numbers listed are the ITS section specific consecutive numbers found In the lower right comer of each page. Note: Because the affected page(s) for each change were extracted from a complete ITS section electronic file, the electronic hyperlinks (created In the complete ITS section file) do not work In the collection of affected pages that follow this cover page. ITS SECTION 5.0 (ADMINISTRATIVE CONTROLS) INDEX OF AFFECTED PAGES ITS MARKUPS No change ITSJFDS No change ITS BASES MARKUPS No change ITS BASES JFDS No change CTS MARKUPS PAGE: 79 CTS DOCS No change.

(i) Rev. 2 Change A-7 & A-9 (i)IILAR Draft Page from Unit 2

                                                                           # 173 A-7 A-S ADMINISTRATIVE CONTROLS REPORTING REOUIREMENTS            (Continued)

WCAP-8745-P-A, "Design Bases for the Therrmal Overtemperatirr AT and Thermal Overpower AT Trip

           -1Functions," Teptember 19861.

WCAP 12945-P-A Uol1(e /1 (Revision 2). and Volumes 2 through 5 I(Revision 1), "Code Qualification Document for Best Estimate LOCA Analysis," March 1998 (Westinghouse ( LA48M~rprieary) . WCAP-14565-P-A, "VIPRE-01 Modeling and Qualification for Pressurized Water Reactor Non-LOCA Thermal-Hydraulic Safety WCAP-10216-P-A, Revision lA "Relaxation of Constant Axial Offset Control-FQ Surveillance Technical Specification," WCAP-12610-P-A "VANTAGE+ Fuel Assembl Reference Core epor . WCAP-15025-P-A, "Modified WRB-2 Correlation, WRB-2M, for LA4 Predicating Critical Heat Flux in 17x17 Rod Bundles with 9 ~Modified LPD Mixing Vane Grids,"llApril 199l As described in reference documents listed above, when an initial assumed power level of 102% of rated thermal power is specified in a previously approved method, 100.6% of rated thermal power may be used when input for reactor lCOLR thermal power measurement of feedwater flow is by the l t leading edge flow meter (LEFM). Caldon, Inc. Engineering Report-SOP, "Improving Thermal

             \Power Accuracy and Plant           Safety While      I nr-rpneinqJ   Opp-rat in Power    Level   Using     the   LEFM4't    System,"     Revision     0,  Ma]A 1!4 .                                                 I Caldon,      Inc. Engineering        Report-160P,       "Supplement       to Topical    Report ER-80P:         Basis for a Power Uprate With the
     -        LEFM-P System,"       Revision 0,     May   2000.

BEAVER VALLEY - UNIT 2 6-20 Amendment No. 79

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) NOS. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 CHANGE A-8 This change incorporates Unit 1 Amendment number 273 issued by the NRC on 2/9106. The BVPS Unit 1 LAR number 320 (Amendment No. 273) proposed changes to support the replacement Steam Generators (RSG). LAR number 320 contains changes previously submitted in Unit 1 LAR number 302 for EPU. Therefore, Amendment number 273 includes Unit 1 changes that were previously identified as part of the EPU LAR (Unit 1 LAR # 302) in the ISTS conversion submittal documentation. In addition to the changes related to the Unit 1 RSG and EPU, this amendment includes the addition of a footnote to the Channel Functional Test and Channel Calibration SRs for the Unit 1 ESFAS Function that had a setpoint revised in this amendment. The new footnotes provide more detailed instructions regarding the SR results and further actions that may be required (for drift). The footnotes are the same as were added in Change A-5 at the request of the NRC. The ESFAS Function affected by this change is the Turbine Trip & FW Isolation on SG Level High-High. This change affects pages in Section 2.0 (Safety Limits), Section 3.3A (RTS), Section 3.3C (ESFAS), Section 3.4 (RCS), Section 3.5 (ECCS), Section 3.7 (Plant Systems), and Section 5.0 (Administrative Controls). As many of the changes were anticipated in the ISTS conversion submittal, the change for some pages may only be the removal of the 'Draft Page" annotation for LAR number 302 and or changing the Amendment number to 273. Affected Pages: The following Table(s) list the affected pages by type (i.e., ITS markup, CTS markup, etc.). In order to facilitate review by ITS section, a separate table is provided for each ITS section affected by the change. The page numbers listed are the ITS section specific consecutive numbers found in the lower right corner of each page. Note: Because the affected page(s) for each change were extracted from a complete ITS section electronic file, the electronic hyperlinks (created in the complete ITS section file) do not work in the collection of affected pages that follow this cover page. (continued)

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) NOs. 296 (UNIT 1) & 1 69 (UNIT 2) REVIS10N 2 Change A-8 (continued) ITS SECTION 2.0 (SAFETY LIMITS) INDEX OF AFFECTED PAGES ITS MARKUPS No change ITS JFDS No change ITS BASES MARKUPS No change ITS BASES JFDS No change CTS MARKUPS PAGE: 17 CTS DOCS No change. ITS SECTION 3.3A (RTS) INDEX OF AFFECTED PAGES ITS MARKUPS No change ITS JFDS No change ITS BASES MARKUPS No change ITS BASES JFDS No change CTS MARKUPS PAGES: Unit 1 - 118,121,122, & 123 CTS DOCS No change. ITS SECTION 3.3C (ESFAS) INDEX OF AFFECTED PAGES ITS MARKUPS PAGES: 15 & 18 ITS JFDS No change ITS BASES MARKUPS No change ITS BASES JFDS No change CTS MARKUPS PAGES: Unit 1 - 110,115 CTS DOCS No change. (continued)

EVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 Change A-8 (continued) ITS SECTION 3.4 (RCS) INDEX OF AFFECTED PAGES ITS MARKUPS No change ITS JFDS No change ITS BASES MARKUPS No change ITS BASES JFDS No change CTS MARKUPS PAGE: Unit 1 - 237 CTS DOCS No change. ITS SECTION 3.5 (ECCS) INDEX OF AFFECTED PAGES ITS MARKUPS PAGE: 5 ITS JFDS No change ITS BASES MARKUPS PAGES: 29 & 31 ITS BASES JFDS No change CTS MARKUPS PAGES: Unit 2 - 89. Unit 1 - 79. CTS DOCS No change. ITS SECTION 3.7 (PLANT SYSTEMS) INDEX OF AFFECTED PAGES ITS MARKUPS No change ITS JFDS No change ITS BASES MARKUPS PAGES: 106 & 113 ITS BASES JFDS No change CTS MARKUPS No change CTS DOCS No change. (continued)

EIVPS UNITS 1 & Z ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. Z96 (UNIT 1) & 1 69 (UNIT Z) REVISION Z Change A-8 (continued) ITS SECTION 5.0 (ADMINISTRATIVE CONTROLS) INDEX OF AFFECTED PAGES ITS MARKUPS PAGES: 34 & 35 ITS JFDS No change ITS BASES MARKUPS No change ITS BASES JFDS No change CTS MARKUPS PAGES: Unit 1 - 91, 92, 93, 94, 95, 95A, 96 & 97. CTS DOCS No change.

EVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 CHANGE A-8 AFFECTEDPAGES FOR ITS SECTION 2.0 (SAFETY LIMITS) ITS SECTION 2.0 (SAFETY LIMITS) INDEX OF AFFECTED PAGES ITS MARKUPS No change ITS JFDS No change ITS BASES MARKUPS No change ITS BASES JFDS No change CTS MARKUPS PAGE: 17 CTS DOCS No change.

2.0 Safety LimitsI(~s DRAFT PACE FRO] 2.0 SAFETY LIMITS UN(T2LAR#173

2. 1 SAFETY LIM Reactor Coolant System (RCS) highest loop average temperatur,3Hi

 -"REACTOR CORE                      In MODES                 2,S                     /and

1. he combination of THERMAL POWER, pressurizer pressure-,-nd c righzt operating loop coolant t.mperaturo C(Ta - shall not exceed the limits specified in the COLR; and the following Safe.

Limits shall not be exceeded: 2.1.1.1 The departure from nucleate boiling ratio (DNBR) shall be maintained 2 1.17 for WRB-1 DNB correlation for Vantage 5H (V5H) fuel assemblies, and 2 1.14 for WRB-2M DNB correlation for Robust Fuel Assemblies (RFA). 2.1.1.2 The peak fuel centerline temperature shall be maintained

4700 0 F.

APPLICABILITY: MODL'S 1 and 2. 2.2:flA<GN; l 2.2 Safety Limit Violations] MODES

\If       Safety Limit 2.1.1 is                  violated,             restore compliance and be in                          1I' TANDbWY within 1 hour.

be maintained [+REACTOR COOLANT SYSTEM PRESSURE Z l 21X3 s he Reactor Coolant System pressure shall net -eeeed 2735 psig. l ADPLI~ ILITY4 MOD, 1, 2, 2, 4, and-Si ACTI 2.2 Safety Limit Violations 12.2.2.1 In MODE I or 2, restor S vcompliance is .. and be in MODE 3 Mrs1an 2.. fL..2is violated: I /f Whenevcr the Reaeter __elant Sy tz . _ r has amoeA.ded 2735 psig, be in HGOT STANDBY with the Reaeter Coolant £Y)t.-em pressure within its limit within 1 hour. MIODJZS 3, 4, and 5 Whanever the Reaeter Coolant System pressure has zecccded

             /2735 poi,        reduce the Reaeter Coolant System pressure to with-in
             / ts-limit. within 5 minutes.

2.2.2.2 In MODE 3,4, or 5, restore compliance BEAVER VALLEY - UNIT 2 2-1 Amendment No. 17

KLj~ BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 CHANGE A-8 AFFECTED PAGES FOR ITS SECTION 3.3A (RTS) ITS SECTION 3.3A (RTS) INDEX OF AFFECTED PAGES ITS MARKUPS No change ITS JFDS No change ITS BASES MARKUPS No change ITS BASES JFDS No change CTS MARKUPS PAGES: Unit 1 - 118, 121,122, & 123 CTS DOCS No change.

C C- I l Changes to this Unit I material are addressed in the Unit 2 markup. Rev. 2 Change A-B _ .. ..I TABLE 3.3-1 (Continued) REACTOR TRIP SYSTEM INSTRUMENTATION UnitA MINIMUM \ L NO. CHANNELS C S ALLOWABLE PPLI iANNELS TO TRIP OPA BLE VALU DES 2 2 See Table 2 Notation (A) 2 2 See Table 2 Notation (B)

                                                              -   I.    -  -

BEA-VE+/- VALjEi - ZU.L .; / e ,-, c d.,..rt N.'^..2

                                                                                                                     .*n             73

TABLE 3.3-1 (Continued) l Rev. 2ChangeA-8 TABLE NOTATION

        )             unction may be manually bypassed in this Mode above P-1 (2)   Trip function ma             anually bypassed in thi     ce above P-6.

(3) W Changes to this Unit I material are addressed in the Unit 2 markup. land the control rod drive s capable of rod Wl. (8) In t ondition, source range Function does not provi rip ut does provide indication. i: Overtemperaue T Note I (Unit} 1) The Overtemperature AT Function Allowable Value shall not exceed the following nominal trip setpoint by more than 0.5% AT span for the AT channel, 0.5% AT span for the Tavg channel, -0.5% AT span for the Pressurizer Pressure channel and 0.5% AT span for the f(AI) channel. AT (I r4S) ATO [KI-K 2 (::- S) T)[T(l+ T] + K3 (P -W)-f(AI)] where: AT is measured RCS AT, OF. ATo is loop specific indicated AT at IRATED ERMAL-OPGWER, OF. T is measured RCS average temperature, *F RTP T' is Tavg at RATsED Tpecified in the COLR. t<1 j) P is measured pressurizer pressure, psia. P' is nominal pressurizer pressure specified in the COLR. _+rlS is the function generated by the lead-lag compensator 1+1-2 S for Tavg. 11 & 62 are the time constants utilized in the lead-lag compensator for Tavg specified in the COLR. 1_ is the function generated by the lag compensator for (I+r4 S) measured AT. I is the function generated by the lag compensator for (I+r5 S) measured Tavg. T4 & 'S are the time constants utilized in the lag compensators for the AT and Tavg, respectively, specified in the COLR. BEAVER VALLEY - UNIT 1 3/4 3-5 Amendment No.273 121

TABLE 3.3-1 (Continued) I Rev. 2 Change A-8 TABLE NOTATION (Continued) I S is the Laplace transform operator, sec . K1 is specified in the COLR. K2 is specified in the COLR. K3 is specified in the COLR. f(AI) is a function of the indicated difference between top and bottom detectors of the power-range nuclear ion chambers as specified in the COLR. BEAVER VALLEY - UNIT 1 3/4 3-5a Amendment No.27-1 122

I Rev. 2 Change A-8 TABLE 3.3-1 (Continued) Note 2 (Unit 1) TABLE NOTATION (Continued) 4k: Overpower AT The Overpower AT Function Allowable Value shall not exceed the follow.ng nominal trip setpoint by more than 0.5% AT span for the AT channel and 0..5% AT span for the Tavg channel. I __ _ _ _ _ __ _ _ _ _ _ _ __ _ _ _ _ _ _ _ AT (ITS <AT0 [K, -K 5 "I" 3 )T ~ - ,[T-1] (l + r ) <(1+-r 3 S) ((1 + r5 S) (1+rr5 S) where: AT is measured RCS AT, 'F. ATo is loop specific indicated AT at SMTt PGWER, -F. T is measured RCS average temperatre, 'F. T" is Tavg at RATED TIIERAL specified in the COLR. K4 is specified in the COLR. K5 is specified in the COLR. K6 is specified in the COLR. __s is the function generated by the rate lag compensator I+r 3 S for Tavg. 13 is the time constant utilized in the rate lag compensator for Tavg specified in the COLR. I is the function generated by the lag compensator for (I+r 4 S) measured AT. I is the function generated by the lag compensator for (I + r.S) measured Tavg. T4 &Tr5 are the time constants utilized in the lag compensators for the AT and Tavg, respectively, specified in the COLR. S is the Laplace transform operator, sec BEAVER VALLEY - UNIT 1 3/4 3-5b Amendment No. 272 l 123

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) NOS. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 CHANGE A-8 AFFECTEDPAGES FOR ITS SECTION 3.3C (ESFAS) ITS SECTION 3.3C (ESFAS) INDEX OF AFFECTED PAGES ITS MARKUPS PAGES: 15 & 18 ITS JFDS No change ITS BASES MARKUPS No change ITS BASES JFDS No change CTS MARKUPS PAGES: Unit i-110,115 CTS DOCS No change.

Rev. 2 Change A-5 (Unit 2) & A-8 (Unit 1) I ESFAS Instrumentation J 3.3.2 Table 3.3.2-1 (page 6 of 8) A-5 A-8 15

Rev. 2 Chances A-5. A-6, & A-8 The Notes were added by Change A-5. Changes A-6 & A-Z reference the Notes added by A-5 INSERTS FOR ITS 3.3.2 ESFAS INSERT 1 - SR 3.3.2.6 Frequency Note P[DS39 W4515k 92 days OR Note PA 9LMI provided a satisfactory contact loading analysis has been completed, and a satisfactory slave relay service life has been established, for the slave relay being tested. 12 Months AND Note Only applicable to Unit i 18 Months INSERT 2 - Table 3.3.2-1 Notes (e) & (f) (e) If the as-found channel setpoint is conservative with respect to the Allowable Value but outside its predefined as-found acceptance criteria band, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service. If the as-found instrument channel setpoint is not conservative with respect to the Allowable Value, the channel shall be declared A-5 inoperable. A-X AZ8 (f) The instrument channel setpoint shall be reset to a value that is within the as-left tolerance of the Nominal Trip Setpoint, or a value that is more conservative than the Nominal Trip Selpoint; otherwise, the channel shall be declared inoperable. The Nominal Trip Setpoint and the methodology used to determine the Nominal Trip Setpoint, the predefined as-found acceptance criteria band, and the as-left setpoint tolerance band are specified ina document incorporated by reference into the Updated Final Safety Analysis Report. 18

n A72TMTn Ta? ? tT¶ - MThTY'T I

                                 'Z4 wA-lQ. Amendment No. 273 0

it l BEAVER VALLEY - UNIT 1 3/4 3-31 Amendment No.273 I A-8 01

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 CHANGE A-8 AFFECTEDPAGES FOR ITS SECTION 3.4 (RCS) ITS SECTION 3.4 (RCS) INDEX OF AFFECTED PAGES ITS MARKUPS No change ITSJFDS No change ITS BASES MARKUPS No change ITS BASES JFDS No change CTS MARKUPS PAGE: Unit 1- 237 CTS DOCS No change.

RUNITO PAGE S I Rev. 2 Change A-8 I REACTOR COOLANT SYSTEM I ITS 3.4.6 & 3.4.7 l i'Ww 4 X IMITING CONDITION FOR OPERATION (Continued) z

a. th less than the above required loops OPERABLE, imm iately initiate corrective action to return the requi d loops to OPERABLE status as soon possible; be in COLD UTDOWN within 20 hours.

b. With no cool t loop in operation, spend all operation involving a red tion in boron conc tration of the Reactor Coolant system an immediately .itiate corrective acti.on t-o

                   . . . to r . .   . I. .I .
                                              -ho1=

ftunm rur 1 tI

                                                          . X. . En rnnl Lxnt )nn
                                                                              .d. . .c. . X- - inI-a . Cl F- nnorl-4nn E   _

Changes to this Unit I text are addressed in the corresponding Unit 2 Page Markups and DOCs Except for the Unit I specific SG Level Value used in ITS 3.4.6 & ITS 3.4.7

                                                                       . --I
            -T,                                                                            x                                                  I_

4.4.1.3.1 The required r gidual heat r oval loop(s) shall be determined OPERABLE per Sp ification 4.0.5. 4.4.1.3.2 The re ' ed reactor coolant pump ), if not in operation, shall be determined to be OPERABLE once er 7 days by verifying corre breaker alignments and mdi ted powler availability. 4.4.1.3.3 The required steam generator(s) shall be dete Xied rPE BLE Xy verifying secondary side level greater than or equal Mto 28 naX ow range at least once per 12 hours. X I

4. . 3.4 At least one coolant loop shall be verified to be in erat n and circulating reactor coolant at least once per 12 hours.

T Unit 1 Specific SG Level value used in ITS 3.4.6 and ITS 3.4.7 l BEAVER VALLEY - UNIT 1 3/4 4-2d Amendment No.27$ I 237

BVPS UNITS 1 & Z ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. Z96 (UNIT 1) & 1 69 (UNIT Z) REVISION 2 CHANGE A-8 AFFECTEDPAGES FOR ITS SECTION 3.5 (ECCS) ITS SECTION 3.5 (ECCS) INDEX OF AFFECTED PAGES ITS MARKUPS PAGE: 5 ITS JFDS No change ITS BASES MARKUPS PAGES: 29 & 31 ITS BASES JFDS No change CTS MARKUPS PAGES: Unit 2 - 89. Unit 1 - 79. CTS DOCS No change.

I Rev. 2 Change A-1 (Unit 2) & Change A-8 (Unit 1) I Accumulaton; 3.5.1

                    >6681 gallons and

gallns(UW o7645 1 )

[juFfij. [ SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.5.1.2 \Verify borated water volume in each accumulator is

                              \ 1 7853 gallons ( )% and f 8171 gallons ( %].

12 hours 0 SR 3.5.1.3 Verify nitrogen cover pressure in each accumulator is 12 hours I-C7E rs Vpsig and *4 I SR 3.5.1.4 Verify boron concentration in each accumulator is 31 days [rales 2300 ppm and < ;'j ppm. AND H/ \EE

                                                                                                - NOTE -

Only required to be performed for affected accumulators Once within 6 hours after each solution volume increase of ue I 2!1% of accumulator volume I indicated- evel ffgallons that is not the result of addition from the Icontrol circuit I refueling water storage tank SR 3.5.1.5 Verify power is remov from each accumulator 31 days [IT Vauel isolation valve operator when RCS pressure is

% ronnm mean

                              , [own rayW,0 sig WOG STS                                           3.5.1 -2                       Rev. 2, 04/30/01 5

Rev. 2 Change A-I (Unit 2) & Change A-8 (Unit 1) Accumulators B 3.5. The specified Technical Specification values for the usable accumulator volume, boron BASES concentration, and minimum nitrogen pressure are analysis values. Also, the values specified for nitrogen pressure and volume do not account for instrument uncertainty. APPLICA FY ANALYSES (continued) th higher nitrogen cover pressure results in a computed peak clad The accumulators temperature benefit. The maximum nitrogen cover pressure limit also discharge prevents accumulator relief valve actuation, and ultimately preserves following a SLB, accumulator integriy_ ___ ___ however their impact is minor with reE;pect The effects on containment mass and energy releases from the to meeting the accumulators are accounted for in the appropriate analyses (Refs4 design basis DIN limit. a B3). K II LOC The accumulators satisfy Crit 10 R 50.36(c)(2)(ii). The LCO establishes the min r~m conditions required to ensure that the accumulators are available to a~omplish their core cooling safety function following a LOCA. accumulators are required to ensure that 100% of the contents of of the accumulators _ will reach the core during a LOCA. This is consistent with the assumption that the contents of one accumulator spill through the break. If less than threen-accumulators are injected during the blowdown phase of a LOCA, the ECCS acceptance criteria of 10 CFR 50.46 (Ref. 2) could be violated. ( For an accumulator to be considered OPERABLE, the isolation valve must be fully open, power removed above 12000] psig, and the limits established in the SRs for contalnei*olurne, boron concentration, and nitrogen cover pressure must be met.' APPLICABILITY In MODES 1 and 2, and in MODE 3 with RCS pressure > 1000 psig, the accumulator OPERABILITY requirements are based on full power operation. Although cooling requirements decrease as power decreases, the accumulators are still required to provide core cooling as long as elevated RCS pressures and temperatures exist. This LCO is only applicable at pressures > 1000 psig. At pressures

1000 psig, the rate of RCS blowdown is such that the ECCS pumps can provide adequate injection to ensure that peak clad temperature remains below the 10 CFR 50.46 (Ref. 2) limit of 22000F.

In MODE 3, with RCS pressure

1000 psig, and in MODES 4, 5, and 6, the accumulator motor operated isolation valves are closed to isolate the accumulators from the RCS. This allows RCS cooldown and depressurization without discharging the accumulators into the RCS or requiring depressurization of the accumulators.

WOG STS 8 3.5.1 - 4 Rev. 2, 04/30/01 29

Rev. 2 Change A-1 (Unit 2) Accumulator. and Change A-8 (Unit 1) B 3.5.c BASES ACTIONS (continued) D.1 If more than one accumulator is inoperable, the plant is in a condition outside the accident analyses; therefore, LCO 3.0.3 must be entered immediately. SURVEILLANCE SR 3.5.1.1 REQUIREMENTS Each accumulato valve should be verified to be fully open every 12 hours. This verification ensures that the accumulators are available for injection and ensures timely discovery if a valve should be less than once power is removed fully open. If an isolation valve is not fully open, the rate of injection to the from the control circuit HI wall be reduced. Although a motor operated valve position should not changewith power removed, a closed valve could result in not meeting accident analyses assumptions. This Frequency is considered 2 reasonable in view of other administrative controls that ensure a mispositioned isolation valve is unlikely. The required accumulator Water volumes and minimum SR 3.5.1.2 and SR 3.5.1.3 the usable r itrogen pressure value are Enalysis values. The values Every 12 hoursborated water volume and nitrogen cover pressure are Epecified for volume do not verified for each accumulator.kThis Frequency is sufficient to ensure zccount for instrumentation Lrncertainty. Similarly, the adequate injection auring a LOCA. Because of the static design of the %aluesspecified for the accumulator, a 12 hour Frequency usually allows the operator to identify ritrogen cover pressure also changes before limits are reached. Operating experience has shown this c0o not account for Frequency to be appropriate for early detection and correction of off instrumentation uncertainty. normal trends. SR 3.5.1.4 l CTS Bases The boron concentration should be verifie to be within required limits for each accumulator every 31 days since the static design of the The value specified accumulators limits the ways in which the oncentration can be changed. for boron The 31 day Frequency is adequate to iden fy changes that could occur concentration isan from mechanisms such as stratification or i leakage. Sampling the analysis value. affected accumulator within 6 hours after a X volume increase will identify whether inleakage has caused a reduction in boron concentration to below the required limit. It is not necessary to verify boron concentration if the added water inventory is from the refueling water storage tank (RWST), because the water contained in the RWST is within the accumulator boron concentration requirements. This is consistent with the recommendation of NUREG-1366 (Ref. WOG STS B 3.5.1 - 6 Rev. 2, 04/30/01 31

lIUNIT I PZ~_ Rev. 2 Change A-8 UNIT P [ EMERGENCY CORE COOLING SYSTEMS (ECCS) 3/4.5.1 ACCUMULA (U1) Changes to this Unit I text are addressed in the corresponding Unit 2 markup and DOCs. 3.5.1 Each re coolant system accumu hall be OPERAELE

               .Th isn                                       vLA'

a. The isolation valve open, ZI Between 6681 gallons and 7645 gallons of us le l

borated water, I

c. Between 2300 and 2600 ppm of boron, and

d. A nitrogen cover-pressure of between 611 and 685 ps I

APPLIC ILITY: MODES 1, 2 and 3.* ACTION:

a. With one accumulator inoperable due to boron /oncentration not wthin limits, restore the inoperable accumulator to OPERABL status within 72 hours.

b. With one acumulator inoperable fo reasons other than Action a, re ore the inoperable cumulator to OPERABLE status within 2 hours.

c. With either Action or b no being completed within the specified completion time, e in at least HOT STANDBY Changes to this Unit I text are addressed in the corresponding Unit 2 markup and DOCs. ]

SURVEILLANCE REQUIREMENTS 4.5.1 Each accumula r shall be demonstra d OPERABLE:

a. At least o e per 12 hours by:

1. V rifying the usable borated water vo me and nitrogen cover-pressure in the tanks are within its, and Verifying that each accumulator isolation valve is

           /       P         sopen.
 /   ressurizer Pressure above 1000 psig.\

BEAVER VALLEY - UNIT 1 3/4 5-1 Amendment No. 273 I 79

Rev. 2 Change A-8 EMERGENCY CORE COOLING SYSTEMS I Draft Page from Unit 2 LAR V173 I 3/4.5.4 SEAL INJECTION FLOWITS3.5.5 LIMITING CONDITION FOR OPERATION 3.5.4 Reactor coolant pump seal injection flow shall be less than or equal to 28 gpm with the charging pump discharge pressure greater than or equal to 2457 psig and the seal injection fLow control valve full open. APPLICABILITY: MODES 1, 2, and 3. ACTION: onBases [= With the seal injection flow not within the limit, adjust manual seal injection throttle valves to give a flow within the limit ith the charging pump discharge pressure greater than or equal to 2457 psig and the seal injection flow control valve full open within 4 hours or be in at OD i east IO STANDBY- wi thin the next 6 hours and in i4GT LSHUTDOGWN Fit-hin'the followin hours. l( MODE3l a [ 4

     ,__~ztT    ANCE REQUIREMENTS,-

SR 3.5.5.1 A2 manual seal injection throttle-4.54 Verify at least once per 31 days that the valves are adjusted to give a flow the limit with the charging pump discharge at greater th or equal to 2457 psig and the seal injection flow control va ve full open.(l) l 28gpm SR3.5.5.1~~ L Notel (1+ Not required to be performed until 4 hours after the Reactor Coolant System pressure stabilizes at greater than or equal to 2215 psig and less than or equal to 2255 psig. BEAVER VALLEY - UNIT 2 3/4 5-7 Amendment No. 89

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REcIUEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION Z CHANGE A-8 AFFECTEDPAGES FOR ITS SECTION 3.7 (PLANT SYSTEMS) ITS SECTION 3.7 (PLANT SYSTEMS) INDEX OF AFFECTED PAGES ITS MARKUPS No change ITS JFDS No change ITS BASES MARKUPS PAGES: 106 & 113 ITS BASES JFDS No change CTS MARKUPS No change CTS DOCS No change.

AFW System I Rev. 2 Change A-4 (Unit 2) & A-8 (Unit 1) I B 3.7.5 BASES ACTIONS (continued) I for an inoperable turbine-driven AFW pump in MODE 3 I dictate that both Completion Times apply simultaneously, and the more restrictive must be met. Condition A is modified by a Note which limits the applicability of the Conditio to when the unit has not entered MODE 2 following a refueling. Condition A allows one AFW train to be inoperable for 7 days vice the 72 hour Completion Time in Condition B. This longer Completion Time is based on the reduced decay heat following refueling and prior to the reactor being critical.] Required Action B.1 is modified by a Note indicating that the Required Action is only ____} required applicable if both supply headers are DPERABLE. realign OPERABLE AFW pumps to separate train supply With one of the required AF rains (pump or flow path) inoperable in headers within 2 hours (if both MODE 1, 2, or 3 ffor reaso other than Condition Al, action must be train supply headers are taken t revetre OPERA E status within 72 hours. This Condition OPERABLE) and to restore the includes the loss of two team supply lines to the turbine driven AFW AFW train to pump The 72 hour Completion Time is reasonable, based on redundant ca ilities afforded by the AFW System, time needed for repairs, and Required Action B.1 to realign e low probability of a DBA occurring during this time period. the OPERABLE pumps to separate supply headers The second Completion Time for Required Action B establishes a limii preserves train separation and enhances system reliability. on the maximum time allowed for any combination of Cnditions to be _ The two hours allowed for this inoperable during any continuous failure to meet this LCO. 2 I ac:ion is reasonable based on operating experience to The 10 day Completion Time provides a limitation time allowed in this perform the specified task. specified Condition after discovery of failure to meet the LCO. This limit is considered reasonable for situations in which Conditions A and B are On entered concurrently. The AND connector between 72 hours and 10 day;, dictates that both Completion Times apply simultaneously, and the more restrictive must be met. a D.1 and D.2 B, B.2, C.1, or C.2 If twoAFW trainsare inoperable in MODE 1, 2, or henot be completed within the @

3for reasons other than Condition C,or required Completion Time, or if two AFW trains are inoporable in

                                                             ,the unit must be placed in a MODE in which the If one or two feedwater             LCO does not apply. To achieve this status, the unit must be placed in al injection headers are               least MODE 3 within 6 hours, and in MODE 4 within [1 8J hours.

inoperable in MODE 1, 2, or

3,or The allowed Completion Times are reasonable, based on operating If three AFW trains are experience, to reach the required unit conditions from full power ( AD inoperable in MODE 1, 2 or conditions in an orderly manner and without challenging unit systems.

3,but the turbine-driven AFW pump is inoperable solely due to one inoperable steam supply header B 3.7.5 - 5 Rev. 2, 04/30/01 Condition D is modified by a note that limits the applicability of the condition for three inoperable AFW trains to when the turbine-driven AFW train is inoperable solely due to one inoperable steam supply. In this condition, the status of the turbine-driven AFW train is adequate to support a reduction in operating MODE.

106

Rev. 2 Change A-4 (Unit 2) & Change A-8 (Unit 1) Am' 8. (From TSTF-359) Hi s REVIEWER'S NOTE-The LCO 3.0.4. Note propp n .0.4 oa b exception when entering MODE 1 if the plant for startup. If the plant does depend on A up, the Note should state, U o A Note prohibits the application of LCO 3.0.4.b to an inoperable AFW train-when entering MODE 11. There is an increased risk associated with [entering a MODE or other specified condition in the Applicability] [entering MODE 1-with an AFWtrain inoperable and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

9. With one inoperable AFW pump, the remaining two AFW pumps will be aligned to separate redundant headers capable of supplying flow to each steam generator.

A realistic analyses of a loss of normal feedwater event demonstrates that one motordriven AFW pump will maintain sufficient steam generator inventory to provide a secondary heat sink and prevent the RCS from exceeding applicable pressure and temperature limits. For Unit 1, the licensing basis has changed to a requirement for two of three AFW pumps to meet the flow requirements for the limiting DBAs. This change was necessitated by the installation of cavitating venturis in the AFW injection paths. The venturis protect the AFW pumps from runout conditions and allow for flow to be directed to the intact steam generators during a FWLB. Cavitating venturis in each individual injection path to the steam generators ensure that sufficient flow will be delivered to the two intact steam generators during a FWLB. Since no single failures are assumed to occur while in an Action Condition, adequate flow can be supplied by the two operable AFW pumps. Based on this, the Completion Time of 72 hours for one inoperable AFW pump continues to remain applicable. This change to the Unit I licensing basis is consistent with the original licensing basis for Unit 2. 113

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 CHANGE A-8 AFFECTEDPAGES FOR ITS SECTION 5.0 (ADMINISTRATIVE CONTROLS) ITS SECTION 5.0 (ADMINISTRATIVE CONTROLS) INDEX OF AFFECTED PAGES ITS MARKUPS PAGES: 34 & 35 ITS JFDS No change ITS BASES MARKUPS No change ITS BASES JFDS No change CTS MARKUPS PAGES: Unit 1 - 91, 92, 93, 94, 95, 95A, 96 & 97. CTS DOCS No change.

IRev. 2 Change At 8

                                            .2                                 Section 5.0 Inserts penetrations greater than 20 percent, and

2. Tubes in those areas where experience has indicated potential problems, and

3. A tube inspection (pursuant to Specification 5.5.5.1.4.a.8) shall be performed on each selected tube. If any selected tube does not permit the passage of the eddy current probe for a tube inspection, this shall be recorded and an adjacent tube shall be selected and subjected to a tube inspection.

c. The tubes selected as the second and third samples (if required by Table 5.5.5.1-2) during each inservice inspection may be subjected to a partial tube inspection provided:

1. The tubes selected for these samples include the tubes from those areas of the tube sheet array where tubes with imperfections were previously found, and

2. The inspections include those portions of the tubes where imperfections were previously found.

The results of each sample inspection shall be classified into one of the following three categories: Category Inspection Results C-1 Less than 5 percent of the total tubes inspected are degraded tubes and none of the inspected tubes are defective. C-2 One or more tubes, but not more than 1 percent of the total tubes inspected are defective, or between 5 percent and 10 percent of the total tubes inspected are degraded tubes. C-3 More than 10 percent of the total tubes inspected are degraded tubes or more than 1 percent of the inspected tubes are defective. Note: In all inspections, previously degraded tubes must exhibit significant (greater than 10 percent) further wall penetrations to be included in the above percentage calculations.

3. Inspection Frequencies - The above required inservice inspections of steam generator tubes shall be performed at the following frequencies:

a. The first inservice inspection of the Model 54F steam generators shall be performed after 6 Effective Full Power Months but within Section 5.0 Inserts Page 2 34

I Rev. 2 Change A-8 I Section 5.0 Inserts 1, ; 24 calendar months of initial criticality following steam generator replacement. Subsequent inservice inspections shall be performed at intervals of not less than 12 nor more than 24 calendar months after the previous inspection. If two consecutive inspections, not including the preservice inspection, result in all inspection results falling into the C-1 category or if two consecutive inspections demonstrate that previously observed degradation has not continued and no additional degradation has occurred, the inspection interval may be extended to a maximum of once per 40 months. Note: Inservice inspection is not required during the steam generator replacement outage.

b. If the results of the inservice inspection of a steam generator conducted in accordance with Table 5.5.5.1-2 fall into Category C-3, the inspection frequency shall be increased to at least once per 20 months. The increase in inspection frequency shall apply until the subsequent inspections satisfy the criteria of specification 5.5.5.1.3.a; the interval may then be extended to a maximum of once per 40 months.

c. Additional, unscheduled inservice inspections shall be performed on each steam generator in accordance with the first sample inspection specified in Table 5.5.5.1-2 during the shutdown subsequent to any of the following conditions:

1. Primary-to-secondary tube leaks (not including leaks originating from tube-to-tube sheet welds) in excess of the limits of LCO 3.4.13,

2. A seismic occurrence greater than the Operating Basis Earthquake,

3. A loss-of-coolant accident requiring actuation of the engineered safeguards, or

4. A main steamline or feedwater line break.

4. Acceptance Criteria

a. As used in this Specification:

1. Imperfection means an exception to the dimensions, finish or contour of a tube from that required by fabrication drawings or specifications. Eddy-current testing indications below 20 percent of the nominal tube wall thickness, if detectable, may be considered as imperfections.

2.

Dearadation means a service-induced cracking,

wastage, wear or general corrosion occurring on either inside or Section 5.0 Inserts Page 3 35

[5.5.5.1 UNIlTI SG TUBE SURVEILLANCE PROGRAM Rev 2 Chng 3/4.4.5 GENERATORS LIMITING CONDITION F OPERATION 3.4.5 Each steam generator all be OPE LE. NOTE: These requirements are contained in the Reactor Coolant System section (3.4.13) of the Tech Specs consistent with the location of these requirements Inthe ISTS. Changes to this Information are discussed and documented in Section 3.4 of the Tech Specs. generator(s) to OPE status 5.5.5 SG Tube Surveillance Program. This program provide; S Lrequirements for steam generator tube sample selection and SURVEILLANCE R .E 5.inspection. Each steam generator shall be inspected in accordance A16 with Table 5.5.5.1-1. 4.4.5.1 Steam nerator am]le Selection and Inspection - Each erator shall be dete min . T T)L. An by and inspecting at eas Surveillance Program of ste 4452 Steam Gen rator &ubejfAgm~! GeleetionA.n InT et - rhe steam generator tube <<inimum sample size, nspection result classification, a d the corresponding action requi ed shall be as specified in T le 44--2. The inservice inspec ton of steam generator tubes shall be performed at the frequencies pecified in 5 .5.5.Specification 4-4--3 and the inspected tubes shall verified L... 1acceptable per the acceptance criteria of Specification 4.4.5.-4.

         ,*Steam generator tubes shall be examined in accordance with Article 8 of Section V ("Eddy current Examination of Tubular Products") and Appendix         IV     to      Section       XI        ("Eddy          Current          Examination            of Nonferromagnetic Steam Generator Heat Exchanger Tubing")                                                of the
&..:aPnlicable year and addenda of the ASME Boiler and Pressure Vessel Code required by 10CFR50, Section 50.55a(g).                                The tubes selected :-or each inservice inspection shall include at least 3 percent of the total number of tubes in all steam generators; the tubes selected :or these inspections shall be selected on a random basis except:

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

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

1. All nonplugged tubes that previously had detectable wall penetrations greater than 20 percent, and BEAVER VALLEY - UNIT 1 3/4 4-8 Amendment No. 27^2 91

l 5.5.5.1 UNIT I SG TUBE SURVEILLANCE PROGRAM I I Rev. 2 Change A-8 I SURVEILLANCE REQUIREMENTS (Continued)

2. Tubes in those areas where experience has indicated potential problems, and

3. A tube inspection (pursuant to Specification

4. 4 .. A. a) shall be performed on each selected tube.

If any selected tube does not permit the passage of 5.5.5.1.4.a.8 the eddy current probe for a tube inspection, this shall be recorded and an adjacent tube shall be selected and subjnteit te1 a tube inspection.

c. The tubes selected as the second and third samples (if required by Table 1.4-2) during each inservice inspection may be subjected to a partial tube inspection provided:

1. The tubes selected for these samples include the tubes from those areas of the tube sheet array where tubes with imperfections were previously found, and

2. The inspections include those portions of the tubes where imperfections were previously found.

BEAVER VALLEY - UNIT I 3/4 4-9 Amendment No. 27:3 I 92

1 5.5.5.1 UNIT I SG TUBE SURVEILLANCE PROGRAM l REACTOR COOLANT SYSTEM [l vhange ] SURVEILLANCE REQUIREMENTS (Continued) The results of each sample inspection shall be classified into one of the following three categories: Categorv Inspection Results C-i Less than 5 percent of the total tubes inspected are degraded tubes and none of the inspected tubes are defective. C-2 One or more tubes, but not more than 1 percent of the total tubes inspected are defective, or between 5 percent and 10 percent of the total tubes inspected are degraded tubes. C-3 More than 10 percent of the total tubes inspected are degraded tubes or more than 1 percent of the inspected tubes are defective. Note: In all inspections, previously degraded tubes must exhibit significant (greater than 10 percent) further wall penetrations to be included in the above percentage calculations. 1.4.5.3 Inspection Frequencies - The above required inservice

/inspections           of    steam generator tubes shall be performed at the followin         frequencies:

5-5-51-3 la. The first inservice inspection of the Model 54F steam generators shall be performed after 6 Effective Full Power l IoI Months but within 24 calendar months of initial criticality following steam generator replacement. Subsequent inservice inspections shall be performed at intervals of not less than 12 nor more than 24 calendar months after the previous inspection. If two consecutive inspections, not including the preservice inspection, result in all inspection results falling into the C-l category or if two consecutive inspections demonstrate that previously observed degradation has not continued and no additional degradation has occurred, the inspection interval may be extended to a maximum of once per 40 months. Note: Inservice inspection is not required during the steam generator replacement outage. BEAVER VALLEY - UNIT 1 3/4 4-10 Amendment No. 273 93

1-;5.5.1 UNIT I SG TUBE SURVEILLANCE PROGRAM REACTOR COOLANT SYSTEM R 2 Beri SURVEILLANCE REQUIREMENTS (Continued)(8 l5.5.5.1-2 -

b. If the results of the inservice inspection of a steam generator conducted in accordance with Table 4.4-2 fall into Category C-3, the inspection frequency shall be increased to at least once per 20 months. The increase in inspection frequency shall apply until the subsequent inspections satisfy the criteria of specification 4--.5-3-a; the interval may then be extended to a maximum per 40 months. 5.5.5.1-2 15.5.5.1.3.aI1l

c. lAddtional, unscheduled inservice inspections shall be performed on each steam generator in accordanc with the first sample inspection specified in Table . during the shutdown subsequent to any of the following conditions: I LCO 3.4.13l

1. Primary-to-secondary tube leaks/(not including leaks originating from tube-to-tube Sheet welds) in excess of the limits of Specification 3.4.G.2,

2. A seismic occurrence greater than the Operating Basis Earthquake,

3. A loss-of-coolant accident requiring actuation of the engineered safeguards, or

4. A main steamline or feedwater line break.

Acceptance Criteria ia As used in this Specification:

1. Imperfection means an exception to the dimensiorLs, finish or contour of a tube from that required by fabrication drawings or specifications. Eddy-currEfnt testing indications below 20 percent of the nominal tube wall thickness, if detectable, may be considered as imperfections.

2. Degradation means a service-induced cracking, wastage, wear or general corrosion occurring on either inside or outside of a tube.

3. Degraded Tube means a tube containing imperfections greater than or equal to 20 percent of the nominal wall thickness caused by degradation.

4. Percent Degradation means the percentage of the tube wall thickness affected or removed by degradation.

BEAVER VALLEY - UNIT 1 3/4 4-lOa Amendment No. 273 94

5.5.5.1 UNIT I SG TUBE SURVEILLANCE PROGRAM 5.6..1 UNIT 1 STEAM GENERATOR TUBE INSPECTION REPORT Rev. 2 Change A-B SURVEILLANCE REQUIREMENTS (Continued)

5. Defect means an imperfection of such severity that it exceeds the plugging limit. A tube containing a defect is defective. Any tube which does not permit the passage of the eddy-current inspection probe shall be deemed a defective tube.

Th(,provisionsof 6. Plugging Limit means the imperfection depth at or SR3.0.2andSR beyond which the tube shall be removed from service by 3.0.3 are plugging because it may become unserviceable prior to applicabletothe the next inspection. The plugging limit is equal to SGTube 40 percent of the nominal tube wall thickness. Suiveillance Prgranm 7. Unserviceable describes the condition of a tube if it lnspection leaks or contains a defect large enough to affect its Frequencies, structural integrity in the event of an Operating Basis Earthquake, a loss-of-coolant accident, or a IIasteamline or feedwater line break as specified in 5.5.5.1.3 above.

8. Tube Inspection means an inspection of the steam generator tube from the point of entry (hot-leci side) completely around the U-bend to the top support of the cold-leg. 5 2 i5

b. The steam generator shall be determined OPERABLE after completing the corresponding actions (plug 'all tubes

_ exceeding the plugging limit) required by Table 4-4-2. 4.4.5.5 5.6.6.1 Unit I Steam Generator Tube Inspection Repcn

a. Within 15 days following the completion of each inservice inspection of steam generator tubes, the number of tubes plugged in each steam generator shall be submitted in a Special Report in accordance with 10 CFR 50.4.

b. The complete results of the steam generator tube inservice inspection shall be submitted in a Special Report in accordance with 10 CFR 50.4 within 12 months following the completion of the inspection. This Special Report shE11 include:

1. Number and extent of tubes inspected.

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

3. Identification of tubes plugged.

BEAVR VLMoved to Report Section (5.6)2 BEAVER VALLEY - UNIT 1 3/4 4-lob Amendment No. 273 l 95

5.6.6.1 UNIT I STEAM GENERATOR TUBE INSPECTION REPORT Rev. 2 Change YI SURVEILLANCE REQUIREMENTS (Continued)

c. Results of steam generator tube inspections which fall into

         --        Category   C-3    shall      be     reported      to     the   Commission n- -a prior to resumption of plant o)e operation. The written report shall provide a description of investigations conducted to determine the cause of the tube degradation and corrective measures taken to prevent recurrence.

1 5.6.6.1 Unit I Steam Generator Tube Inspection ReportI 7 I Moved to Report Section (5.6) of 5.0 BEAVER VALLEY - UNIT 1 3/4 4-lOc Amendment No. 27^ l 95A

c:: 5.5.5.1 UNIT 1 SG TUBE SURVEILLANCE PROGRAMPUNTR 4 -T T -A A_ - - - I Rev. 2 Change A-8 I MINIMUM NUMBER OF STEAM GENERATORS TO BE INSPECTED DURING INSERVICE INSPECTION Preservice Inspection No Yes No. of Steam Generators per Unit Three Three First Inservice Inspection All Two Second & Subsequent Inservice Inspections One (1) One (2) Table Notation: (1) The inservice inspection may be limited to one steam generator on a rotating schedule encompassing 9 percent of the tubes if the results of the first or previous inspections indicate that all steam generators are performing in a like, manner. Note that under some circumstances, the operating conditions in one or more steam generators may be found to be more severe than those in other steam generators. Under such circumstances the sample sequence shall be modified to inspect the most severe conditions. (2) The other steam generator not inspected during the first inservice inspection shall be inspected. The third and subsequent inspections should follow the instructions described in (1) above. CD BEAVER VALLEY - UNIT 1 3/4 4-lOd Amendment No. 273 l C,

rip l 5.5.5.1 UNIT 1 SG TUBE SURVEILLANCE PROGRAM UNTAI l Rev. 2 Change A-8 L (Paqe I of I 4. STEAM GENERATOR TUBE INSPECTION ( 1ST SAMPLE INSPECTION 2ND SAMPLE INSPECTION 3RD SAMPLE INSPECTION Sample Result Action Required Result Action Required Result Action Size Required A minimum C-l None N/A N/A N/A N/A of S tubes C-2 Plug defective tubes C-1 None N/A N/A per S.G. and inspect additional C-2 Plug defective tubes and C-l None 2S tubes in this S.G. inspect additional 4S tubes C-2 Plug defective in this S.G. tubes C-3 Perform action for C-3 result of first sample C-3 Perform action for C-3 N/A N/A _result of first sample C-3 Inspect all tubes in All other None N/A N/A this S.G., plug S.G. s are defective tubes and C-1 inspect 2S tubes in each other S.G. Some S.G.s iPerform action for C-2 N/A N/A Notification to NRC are C-2 result of second sample pursuant to but no Specification additional S.G.s are C-3 5.6.6.1 Additional Inspect all tubes in each N/A N/A S.G. is S.G. and plug defective C-3 tubes. Notification to NRC pursuant to Specification s = 9 % Where n is the number of steam generators inspected during an inspection. n BEAVER VALLEY - UNIT 1 3/4 4-10e Amendment No. 273 CD

yI4 rJw) BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) NOs. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 CHANGE A-9 This change incorporates Amendment numbers 274 (Unit 1) and 155 (Unit 2) issued by the NRC on 2/27/06. Amendments 274/155 approved changes in the BVPS technical specification requested in LAR numbers 310 (Unit 1) and 182 (Unit 2) to convert from CAOC to RAOC methodology for reactor core axial offset requirements in the technical specifications. As these changes were anticipated in the ISTS conversion submittal, this amendment only results in a format change to the presentation of Note 3 which the final amendment placed on both pages 3/4 2-5 & 6 instead of only on page 3/4 2-6 as anticipated in the draft implementation of this change. Therefore, implementation of this amendment consisted, for the most part, of putting the amendment number in the affected page footers. These amendments affect pages in Sections 3.2 (Power Distribution Limits), Section 3.3A (RTS), and Section 5.0 (Administrative Controls). Affected Pages: The following Table(s) list the affected pages by type (i.e., ITS markup, CTS markup, etc.). In order to facilitate review by ITS section, a separate table is provided for each ITS section affected by the change. The page numbers listed are the ITS section specific consecutive numbers found In the lower right comer of each page. Note: Because the affected page(s) for each change were extracted from a complete ITS section electronic file, the electronic hyperlinks (created In the complete ITS section file) do not work In the collection of affected pages that follow this cover page. ITS SECTION 3.2 (POWER DISTRIBUTION LIMITS) INDEX OF AFFECTED PAGES ITS MARKUPS No change ITS JFDS No change ITS BASES MARKUPS No change ITS BASES JFDS No change CTS MARKUPS PAGES: 96, 97, 98, 99, 100 & 102 CTS DOCS No change. (continued)

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 Change A-9 (continued) ITS SECTION 3.3A (RTS) INDEX OF AFFECTED PAGES ITS MARKUPS No change ITS JFDS No change ITS BASES MARKUPS No change ITS BASES JFDS No change CTS MARKUPS PAGES: 116 & 129 CTS DOCS No change. ITS SECTION 5.0 (ADMINISTRATIVE CONTROLS) INDEX OF AFFECTED PAGES ITS MARKUPS No change ITS JFDS No change ITS BASES MARKUPS No change ITS BASES JFDS No change CTS MARKUPS PAGE: 78 & 79 CTS DOCS No change.

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 CHANGE A-9 AFFECTEDPAGES FOR ITS SECTION 3.2 (POWER DISTRIBUTION LIMITS) ITS SECTION 3.2 (POWER DISTRIBUTION UMITS) INDEX OF AFFECTED PAGES ITS MARKUPS No change ITS JFDS No change ITS BASES MARKUPS No change ITS BASES JFDS No change CTS MARKUPS PAGES: 96, 97, 98, 99,100 & 102 K41w CTS DOCS No change.

a -] POWER DISTRIBUTION LIMITS 4 .2 Rev 2. Change N344=2.l AXIAL FLUX DIFFERENCE (AFD) lITS 3.2.3 l 3 LIMITING CONDITION FOR OPERATION 1.2.7 The AFD in % flux difference units shall be maintained within the limits(l) specified in the COLR. APPLICABILITY: MODE 1 with THERMAL POWER 2 50% RTII d ACTION: lCIZA With AFD not within the limits, reduce THERMAL POWER to < 50% of RTP within 30 minutes. SURVEILLANCE REQUIREMENTS

       ^.2.1.1        Verify AFD within limits for each OPERABLE excore channel
   / at least once per 7 days.

Lizi3..3.1l I Moved to Note In LCO 3.23 3

      -(4-)    The AFD shall be considered outside limits when two or mre l           OPERABLE excore channels indicate AFD to be outside limits.

(2) Sce Special Test Emeeptien 3 BEAVER VALLEY - UNIT 2 3/4 2-1 Amendment No. 155 (Next page is 3/4 2-4) 96

POWER DISTRIBUTION LIMITS lITS 3.2.1 Rev. 2 Change j HEAT FLUX HOT CHANNEL FACTOR-FQjLZ) Xi ] LIMITING CONDITION FOR OPERATION FQ(Z), as approximated by FQ(Z) and FQ(Z), shall be within the limits specified in the COLR. APPLICABILITY: MODE 1 ACTION: ic a-. With FQ(Z) not within limit~l): EA. in-- Reduce THERMAL POWER 2 1% RTP for each 1% F6(Z) C, exceeds the limit within 15 minutes after each F6(Z) determination; and E G-- Reduce the Power Range Neutron Flux-High Trip C Setpoints 2 1% for each 1% FQ(Z) exceeds the limit C within 72 hours after each FQ(Z) determination; and lA.3 Reduce the Overpower AT Trip Setpoints 2 1% for each C 1% FQ(Z) exceeds the limit within 72 hours after each F6(Z) determination; and l 3.2.1.2 lA.4 4- Perform Surveillance Requirements 4.2.2-2 a.L 4.2.:' prior to increasing THERMAL POWER above the limit of Action a.l. Cond. C l -i Otherwise, be in MODE 2 within the following 6 hours. b With F6(Z) not within limits(2): BE b-- Reduce AFD limits 2 1% for each 1% Fw(Z) exceeds limit within 4 hours, and t Iond.A

       -+4-     Action a.4 shall be completed whenever Action a. is entered.

2- Action b.4 shall be completed whenever Action b. is entered. _ l Note In Cond- B BEAVER VALLEY - UNIT 2 3/4 2-4 Amendment No. 155 97

POWER DISTRIBUTION LIMITS Rev. 2 Change A-9 LIMITING CONDITION FOR OPERATION (Continued)

                  .21  G-o-  Reduce   the    Power      Range       Neutron     Flux-High            Trip Setpoints 2 1% for each 1% that the maximum allowable power of the AFD limits is reduced within 72 hours; and                                               3.2.1.1 and 3.2.1.2     ]

E 13- Reduce the Overpower AT Trip Setpoints 2 1% for each 1% that the maximum allowable power of the FD limits is reduced within 72 hours; and [ B.4 4- Perform Surveillance Requirements 4.2.2.2 and 4.2.' prior to increasing THERMAL POWER above the maximum allowable power of the AFD limits. d-C 5-- Otherwise, be in MODE 2 within the following 6 hours. SURVEILLANCE REQUIREMENTS /0 I%

           . .2         hIe prevlilens  e:

f Speeifieatltn l1 - - ' arc~not ar~n I rnn I c F6(Z) shall be verified to be within the limit according to FSR 3.2.1.1 l the following schedulel3):

a. Once after each refueling prior to THERMAL POWER exceeding 75% RTP; and i"'LW

b. Once within 12 hours after achieving equilibrium conditions after exceeding, by 2 10% RTP, the THERMAL POWER at which c

F6(Z) was last verified; and C. At least once per 31 Effective Full Power Days thereafter. l Moved to Surveillance Requirement Note I (3) During power escalation at the beginning of each cycle, THERMAL POWER may be increased until an equilibrium power level has been achieved, at which a power distribution map is obtained. BEAVER VALLEY - UNIT 2 3/4 2-5 Amendment No. 155 I 98

POWER DISTRIBUTION LIMITS Rev. 2 Change A-9 I SURVEILLANCE REQUIREMENTS (Continued) F6(Z) shall be verified to be within limit() according to C jR 3.2.1.2 the following schedule(3):

a. Once after each refueling prior to THERMAL POWER exceedzng 75% RTP; and

b. Once within 12 hours after achieving equilibrium conditions after exceeding, by 2 10% RTP, the THERMAL POWER at which F6(Z) was last verified; and

c. At least once per 31 Effective Full Power Days, thereafter.

Moved to Surveillance Requirement Note I (3) During power escalation at the beginning of each cycle, THERM4AL POWER may be increased until an equilibrium power level has been achieved at which a power distribution map is obtained. (4) If measurements indicate that the maximum over z of [F6(Z)/K('3)] C has increased since the previous evaluation F6(Z):

a. Increase F6(Z) by the greater of a factor of 1.02 or by an appropriate factor specified in the COLR and reverify F6(Z) b.

is within limits, or Repeat JjI. Surveillanc Al Requirement 1.2 4.2.2.3 once per 7 Effective Full Power Days until Note (4)a abiove is met or two successive flux maps indicate that the miaximum over z of [F6(Z)/K(Z)J has not increased. l Note inSR 3.2.1.2 l BEAVER VALLEY - UNIT 2 3/4 2-6 Amendment No. 155 99

POWER DISTRIBUTION LIMITS Rev. 2 Change Is j NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR - FNITS 322 [2 Al within the limits specified In the CCii LIMITING CONDITION FOR OPERATION FXH shall be limited by the oaLAI CFH I 1 + PFAH (1laP)]I (!i) where: C The FNH limit at RATED AL POWER Relocated pr *ded in the CO OPERATING LIMETS to COLR REPR \/ Ad~-USAd A __ A_~.,,_I'm Not=AH=ne !a L rLcL muILcplIer Lor jUITH Note Required Action pr ded in the CO OPERATING LIMITS A.2 and A.3 must EPORT, and be completed wheiever THERMAL POWER Con lition A Is entered RATED THERMAL POWER APPLICABILITY: MODE 1 ACTION: A1.1 Restore to within limit or [ond.] With FNH exce ing its limit: _ ac duce THERMAL P R t ess than 50% of RATED THERI4AL POWER within hours and re uce the Power Range Neutron A.1.. 1 *2 L Flux-High Trip Setpoints to

55% of RATED THERMAL POWER within the next 4 hou Perform SR 3.2.2.1 in-core mapping to be percent of RATED THERMAL POWER prier -te lrTfnXNT . - .*-- . .- l . - - -ar-na--- rnf RATED THERMAL POWER prier to Beheading this TIIER AL pewei I and within 24 hours after attaining 95 perce t or greater RATED THERMAL POWER.I Perform SR 3.2.2.1 prior to Thermal Power exceeding I andl BEAVER VALLEY - UNIT 2 3/4 2-7 '\'/ Amendment No. 155 Note r LTHERMAL POWER does not have to be reduced to comply with this Action.I 100

POWER DISTRIBUTION LIMITS Rev. 2 Change A-9 QUADRANT POWER TILT RATIO (OPTR) l ITS 3.2.4 . LIMITING CONDITION FOR OPERATION '--a 3.2.4 The QUADRANT POWER TILT RATIO shall be less than or equal to 1.02. APPLICABILITY: MODE 1 greater than 50 percent of RATED THERMAL POWER.+ ACTION: With the QPTR not within the limit: A Within 2 hours, reduce THERMAL POWER greater t n or equal to 3 percent from RATED THERMAL POWr (TP) each 1 percent of QPTR greater than 1.00, and determine QPTR F A. b-. Within 12 hours and once per 12 hours thereafter, Surveillanee Requirement 4.24 and reduce THERMAL POWER e rm greater than or equal to 3 percent from RTP for each 1 percent of QPTR greater than 1.00, and Within 24 hoursA and once per 7 days thereafter, perform Surveillance Requirements*4.2.2.2, 4.2.2.3, and 4.2..-47, and SR 3.2.1.1, SR 3.2.1.2, and SR 3.2.2.1 Pri r to increasing THERMAL POWER above the limit of ACTION l L3. a or-b above, re-evaluate the safety analyses and confirm the results remain valid for the duration of o e under this condi tion a restore IAI to ivthimit v1-rr ,_ ' / He1 After ACTION f above is com leted and/prior to inc easing THERMAL POWER above the limit of A TION a-e b above, normalize the excore detectors to QPTR less a e equal to 1.02, an>.17A] E [IK I f-.- YAfter ACTION 4above is completedIand within 24 hours after reaching IZTP or within 48 hours fter increasing THERMAL POWER abo e the limit of ACTION Ma er b above, perform Surveillan Requirements 4.2.2.2 4.2.2.3, and 4.2.3.1. nI g-. Otherwise, r uce THERMAL POWER to\ less than or equal to 50 percent RTP wthin 4 hours. SR 3.2.1.1, SR 3.2.1.2, and SR 3.2.2.1

           --        equilibrium conditions at RTP not to exceed ml r

ITS Action A.5 NOTE

                                              ~.rZ         ,n      s        a          s.       Required Action A.6 shall be
                  . ~~                  __-_                     .

x --- --- so- A2 completed whenever Required Action A.5 is performed. BEAVER VALLEY - UNIT 2 3/4 2-9 Amendment No. 15; I 102

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 CHANGE A-9 AFFECTEDPAGES FOR ITS SECTION 3.3A (RTS) ITS SECTION 3.3A (RTS) INDEX OF AFFECTED PAGES ITS MARKUPS No change ITS JFDS No change ITS BASES MARKUPS No change ITS BASES JFDS No change CTS MARKUPS PAGES: 116 (Unit 2) & 129 (Unit 1) K.) CTS DOCS No change.

Adjust power range channel If calorimetric heat balance calculation results exceed power range channel output by more the n + 2% RTP. Not required to be performed until 24 hours I Rev. 2 Change A-9 after THERMAL POWER isk 15% RTP.

                                                             /TABLEB4.

1ly4 [SR3,1.2 \ L 2 TABLE NOTATIO Not required to be performed until 7 days after THERMAL POWER is

                   )-. -           If   not performed in                revious 31 days.               250%RTP.
                                -   Ileat balanoe            only, abovc 15 pereent of RATED THERMAL POWE]                                          i

_ At least once every 31 Effective Full Power Days (EFPD)

            -R     4             compare incore to excore axial imbalance above 50 percent

[N. of RATED THERMAL POWER. Reealibratbef sh1Ite difference greater than or equal to 3 percent. >AdJui t (Not Used). FrequencyofSR3.3.1.4&SR3.3.1.5 XSX - Each train tested every other month on a STAGGERED TE3STl IBASIS. l (C) - INeutron detectors may be excluded from CHANNEL CALIBRATION-] (-8)- - Below P-6, not required to be performed for source range instrumentation prior etoentering MODE 3 from MODE 2 unt~il Aprlicabiity 12 hours after entry into MODE 3 power has been reduced below F-6. (9) (Not 3.3.1.12 Bases (10)- - The CHANNEL FUNCTIONAL TEST shall independently verify the OPERABILITY of the undervoltage and shunt trip circuits i-or the Manual Reactor Trip Function. The test shall a:Lso verify the OPERABILITY of the Bypass Breaker trip "4Ljj circuit(s).

                   -(11)      -      The CHANNEL FUNCTIONAL TEST shall independently verify t:he OPERABILITY of the undervolta e and shunt trip attachments of the        Reactor Trip Breakers.l                           S3.14Bae
                  -(4-)-      -      Local         manual        shunt       trip       prior      to     placing         breaker        jnj

{service. _ JAutomai uer3..4BasNo 3.3.112R In 3.3.1. or (42-)- - lAutomatic undervoltage trip. SR3.3.1.12 Bases , BEAVER VALLEY - UNIT 2 3/4 3-13 Amendment No. 155 I 116

Rev. 2 Change A.<- TABLE 4.3-1 (Continued) \4N) 5 Chngesto tis Unit I material are addressed in the Unit 2 markup. (1)- If no-pqrormed in previous 31 days. (2) _ Heat balance on ove 1 ATED THERMAL POWER. (3) - At least once ev E ve Full Power Days (EFP'D) compare inco o excore axial i- nce above 50 percent of RAT ERMAL POWER. Recalibrate if lute difference er than or equal to 3 percent. _-4-41 - (Not Used) -;-- (5) - Each train tested every other month nTAGGRDl

               -   Neutron detectors may be excluded from CHANNEL CALIBRATION.

(7) X Below P-10. (8) - elow P-6, not required to be performed for sou e range intrumentation prior to entering MODE 3 from E 2 until 12 h rs after entry into MODE 3. (9) - (Not Use (10) - The CHANNEL CTIONAL TEST shall i ependently verify the OPERABILITY of e undervoltage a shunt trip circuits for the Manual Reactbk; Trip Funct n. The test shall also verify the OPERAB ITY of the Bypass Breaker trip circuit(s). (11) - The CHANNEL FUNCTIONAL ES shall independently verify the OPERABILITY of the dervolt e and shunt trip attachments of the Reactor T Breakers. (12) - Local manual shunt trip prior t placing breaker in service. (13) - Automa c undervoltage trip. (14) - W. the reactor trip system breakers cbos and the ontrol rod drive system capable of rod withdrawal. (15) - Surveillance Requirements need not be performe on alternate detectors until connected and required OPERABILITY.

            'I Changes to this Unit I material are addressed in the Unit 2 markup.

BEAVER VALLEY - UNIT 1 3/4 3-13 Amendment No. 274 129

lw, ) BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQ;UEST (LAR) NOS. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 CHANGE A-9 AFFECTEDPAGES FOR ITS SECTION 5.0 (ADMINISTRATIVE CONTROLS) ITS SECTION 5.0 (ADMINISTRATIVE CONTROLS) INDEX OF AFFECTED PAGES ITS MARKUPS No change ITS JFDS No change ITS BASES MARKUPS No change ITS BASES JFDS No change CTS MARKUPS PAGE: 78 &79 CTS DOCS No change.

I Rev. 2 Change A-9 I ADMINISTRATIVE CONTROLS REPORTING REQUIREMENTS (Continued) 6.9.4 DOlEOtE El 6.9.5CORE OPERATING LIMITS REPORT (COLR)

a. Core operating limits shall be established prior to each reload cycle, or prior to any remaining portion of a reload cycle, and shall be documented in the COLR for the following: LCO 3.1.1 SHUTDOWN MARGIN (SDM)

                               -   _     LCO 3.1.3 ModeratorTemperature Coefficient (MTC)          A IO r__

I5 iz1" 2.1.-1 IeaL,6U.L : C .La Ly L ILJ.L;L 3.l.g Shutdown Insertion Limits 3.1.+--6 Control RedrInsertion Limits Bank

                 ,3.2._        Axial Flux Difference-Relaxed Axial Offset I   Control Heat Flux Hot Channel Factor-FQ(Z)

Nuclear Enthalpy Rise;Hot Channel Factor-FNA _B Par-a__ et____ I RCS Pressure, Temperature, and Flow Departure from Nucleate Boiling (DNB) Limits I i3.3 .-1 Reactor Trip Sysbelle LI1bL.LULLtzIlLdLLOL -- Overtemperature and Overpower AT Set-ei-lu parmeer alesLCO03.9.1 Boron Concentration lo l0Qj

b. The analytical methods used to determine the core operating limits shall be those previously reviewed and approved by the NRC, specifically those described in the following documents:

WCAP-9272-P-A, "WESTINGHOUSE RELOAD SAFETY EVALUATION METHODOLOGY," July 1985 (Westinghouse Proprietary) . BEAVER VALLEY - UNIT 2 6-19 Amendment No.155' I 78

i) lRev. 2 Change A-7 & A-9 l Draft Page from Unit 2 A-7 LAR # 173 A-9 ADMINISTRATIVE CONTROLS REPORTING REQUIREMENTS (Continued) WCAP-8745-P-A, "Design Bases for the Thermal Overtemperateire AT ane, Thermal Overpower AT Trip Functions,,, Iseptember 19861. WCAP 1294r,-P-A, 17 11u through 5 (Revision 1) Best Estimate LOCA Ar froprietary). WCAP-14565-P-A, "VIPRE-01 Modeling and Qualification for Pressurized Water Reactor Non-LOCA Thermal-Hydraulic Safety WCAP-10216-P-A, Revision lA1 "Relaxation of Constant Axial Offset Control-FQ Surveillance Technical Specification," February 19940 WCAP-12610-P-A. "VANTAGE+ Fuel Assembly Reference Ccre eport pril 1995 (Westinghouse Proprietary). WCAP-15025-P-A, "Modified WRB-2 Correlation, WRB-2M, for LAVA Predicating Critical Heat Flux in 17x17 Rod Bundles with J Modified LPD Mixing Vane Grids,"llApril 1999l. As described in reference documents listed above, when an initial assumed power level of 102% of rated thermal power is specified in a previously approved method, 100.6% of rated thermal power may be used when input for reactor COLR thermal power measurement of feedwater flow is by the leading edge flow meter (LEFM). Caldon, Inc. Engineering Report-80P, "Improving Thermal

         \Power Accuracy         and Plant Safety While         I ,rrAncinm    npornt-ina Power      Level    Using   the   LEFMIP     System,"     Revision   0,   Mayr
           -L997.                                                 J 4    Caldon,        Inc. Engineering        Report-160P,       "Supplement     to Topical Report ER-80P:             Basis for a Power Uprate With the LEFM'P'System,"JRevision 0, May 2000.1 COLR BEAVER VALLEY - UNIT 2                       6-20                       Amendment No.

79

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 169 (UNIT 2) REVISION 2 CHANGE B-1 TSTF- 479-A, Rev. 0 This change implements NRC approved TSTF-479 as modified by Change C-1 3 (which limits the application of the testing interval extension of SR 3.0.2 to intervals of 2 years or less). This TSTF revises the Section 5.0 Inservice Testing (IST) Program to provide a more direct reference to the ASME Code for Operations and Maintenance (ASME OM Code) instead of Referring to ASME Section IX (which includes the OM Code). The Reference to SR 3.0.2 in the IST Program is also revised to apply to more IST intervals than before. The change includes revising various sections of the ITS Bases that reference ASME Code Section IX. The ASME Code Section IX Bases references are revised to the ASME Code for Operation and Maintenance of Nuclear Power Plants. This change affects pages in ITS Section 3.4 (RCS), Section 3.5 (ECCS), Section 3.6 (Containment), Section 3.7 (Plant Systems), Section 3.8 (Electrical Power Systems), and Section 5.0 (Administrative Controls). Affected Pages: The following Table(s) list the affected pages by type (i.e., ITS markup, CTS markup, etc.). In order to facilitate review by ITS section, a separate table is provided for each ITS section affected by the change. The page numbers listed are the ITS section specific consecutive numbers found In the lower right comer of each page. Note: Because the affected page(s) for each change were extracted from a complete ITS section electronic file, the electronic hyperlinks (created In the complete ITS section file] do not work In the collection of affected pages that follow this cover page. ITS SECTION 3.4 (RCS) INDEX OF AFFECTED PAGES ITS MARKUPS PAGES: 38 & 81 ITS JFDS No change ITS BASES MARKUPS PAGES: 138,144,145,172 & 173 ITS BASES JFDS No change CTS MARKUPS PAGE: 270 & 272 CTS DOCS 370 & 371 (continued)

EVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 Change B-1 (continued) ITS SECTION 3.5 (ECCS) INDEX OF AFFECTED PAGES ITS MARKUPS No change ITS JFDS No change ITS BASES MARKUPS PAGE: 40 ITS BASES JFDS No change CTS MARKUPS No change CTS DOCS No change. ITS SECTION 3.6 (CONTAINMENT) INDEX OF AFFECTED PAGES ITS MARKUPS No change ITS JFDS No change ITS BASES MARKUPS PAGES: 124, i25, 133 & 135 ITS BASES JFDS No change CTS MARKUPS No change CTS DOCS No change. ITS SECTION 3.7 (PLANT SYSTEMS) INDEX OF AFFECTED PAGES ITS MARKUPS No change ITS JFDS No change ITS BASES MARKUPS PAGES: 79, 80, 86, 87,108 &110 ITS BASES JFDS No change CTS MARKUPS No change CTS DOCS No change. (continued)

iJJe.Jt BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 Change B-1 (continued) ITS SECTION 3.8 (ELECTRICAL POWER SYSTEMS) INDEX OF AFFECTED PAGES ITS MARKUPS No change ITS JFDS No change ITS BASES MARKUPS PAGES: 81 & 97 ITS BASES JFDS No change CTS MARKUPS No change CrS DOCS No change. ITS SECTION 5.0 (ADMINISTRATIVE CONTROLS) INDEX OF AFFECTED PAGES ITS MARKUPS PAGES: 13 & 14 ITS JFDS No change ITS BASES MARKUPS No change ITS BASES JFDS No change CTS MARKUPS PAGE: 90 CTS DOCS No change.

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 169 (UNIT 2) REVISION Z CHANGE B-1 AFFECTED PAGES FOR ITS SECTION 3.4 ITS SECTION 3.4 (RCS) INDEX OF AFFECTED PAGES ITS MARKUPS PAGES: 38 & 81 ITSJFDS No change ITS BASES MARKUPS PAGES: 138,144,145,172 & 173 ITS BASES JFDS No change CTS MARKUPS PAGES: 270 & 272 CTS DOCS PAGES: 370 & 371

I Rev. 2 Chanige B-1 I RCS PIV Leakage 3.4.14 SURVEILLANCE REQUIREMENTS . _= SURVEILLANCE FREQUENCY SR 3.4.14.1

                                                     - NOTES -

1 Nnt renuired In hp nerfnrmrd in MODFSI 3 and 4

                              ......           ---               ... A        -..-

2. Not required to be performed on the RCS PIVs located in the RHR flow path when in the shutdown cooling mode of operation.

Prior to entering MODE 2 after the plant is placed in MODE 5 for refueling 5 Verify leakage from each RCS PIV is equivalent to Acordance/

0.5 gpm per nominal inch of valve size up to a with vice maximum of 5 gpm at an RCS pressure 2 [2215] psig Testi m, and s 122551 psig. month J AND

                                             -NOTE-Only applicable to PfVs requiring additional testing as specifically           Prior to entering identified in the list of PlVs.                                                MODE 2 whenever the unit has been in MODE 5 for 7 days or more, if 4                                                                         leakage testing has not been performed in the

3. The RCS PIV leakage may be verified at a pressure lower than 'N previous 9 month; the specified RCS pressure range provided the observed leakage rates are adjusted to the function maximum pressure D/

in accordance with ASME OM Code.

4. Leakage rates > 0.5 gpm/inch diameter but s 5.0 gpm are W~ith 24 ho s acceptable if the latest measured rate has not exceeded the followi v~e rate determined by the previous test by an amount that actuatio ue to reduces the margin between measured leakage rate and the autom ic maximum permissible rate of 5.0 gpm by 2 50%. ma actio r figN through the Halve WOG STS 3.4.14 - 3 Rev. 2, 04130/0'I 38

Rev. 2 Cha~ng~e B-1 BVPS ISTS Conversion 3.4 Reactor Coolant System Enclosure 1 Changes to ISTS The proposed ITS note 3 (CTS note 5) is consistent with the ISTS 3.4.14 bases for the PIV LCO requirements which states:

              "Reference 7 [ASME code for Operation and Maintenance of Nuclear Power Plants or ASME OM Codel permits leakage testing at a lower pressure differential than between the specified maximum RCS pressure and the normal pressure of the connected system during RCS operation (the maximum pressure differential) in those types of valves inwhich the higher service pressure will tend to diminish the overall leakage channel opening.

In such cases, the observed rate may be adjusted to the maximum pressure differential by assuming leakage is directly proportional to the pressure differential to the one half power." The proposed ITS note is acceptable because it maintains the CTS requirements and is consistent with the intent of the ISTS and the ASME OM Code as explained in the ISTS Bases. Due to the ISTS surveillance requiring a specific RCS pressure (2215-2255 psig) for leakage rate verification, the provision in the CTS Note that allows verification at a lower pressure is retained within the proposed BVPS specific surveillance SR 3.4.14.1 as Note

3. As a surveillance note, the allowance provided by the CTS Note is more clearly established than if a description contained only in the Bases is relied on for this interpretation. The CTS TS note together with the ISTS bases description will provide a more complete description of the intended provisions of the surveillance.

The retention of these BVPS notes maintains the proposed ITS consistent with the current BVPS licensing basis as documented in the CTS.

5. The ISTS surveillance 3.4.14.1 Frequency is revised to be consistent with the corresponding CTS frequency for performing this surveillance. In the CTS, two separate surveillances identified the required frequencies for verifying the RCS PIV leakage is within limits. One frequency identified in CTS 4.4.6.3.1 is applicable to all RCS PIVs listed on Table 4.4-3 and requires leakage to be verified prior to entering Mode 2 after each refueling.

CTS 4.4.6.3.2 identified a second frequency for verifying the RCS PIV leakage that was only applicable to certain valves identified on Table 4.4-3. The second frequency required leakage verification of select valves more often than the first Frequency or prior to entering Mode 2 after each time the plant is placed in Mode 5 for more than 72 hours (7 days in the ISTS) unless testing has been performed within the previous 9 months. The two CTS frequencies described above correspond closely with the first two ISTS 3.4.14.1 surveillance frequencies. However, the CTS does not contain any frequency similar to the third ISTS frequency of "within 24 hours following valve actuation due to automatic or manual action or flow through the valve." Therefore, the third ISTS frequency is deleted. The CTS PIV requirements were reviewed and approved by the NRC in Unit 1 Amendment 124 (issued 5/2/88). This amendment revised the entire BVPS PIV TS including the surveillance requirements. The Unit 2 requirements are the same as those reviewed and approved in this Unit 1 amendment. Regarding the two CTS Frequencies for verifying PIV leakage, the NRC Safety Evaluation Report (SER) for Amendment 124, explained that the additional leakage testing required by 4.4.6.3.2 was intended for "Event BVPS Units 1 & 2 Page 27 Revision 2,4/06 81

Rev. 2 Change B-1 Pressurizer Safety Valves I I B 3.4.1C BASES The lift setting shall correspond to ambient conditions of the valve at nominal temperatre and pressure. Nominal temperature and pressure includes MODE 3 operating conditi a provided in the Applicability Note allowing 54 hours for testing and examination of the ACTIONS (continued) v in MODE 3. power and pressure), lowers the pot for large pressurizer insurges, and thereby removes the need for o brrssure protection by [three] pressurizer safety valves./ SURVEILLANCE SR 3.4.10.1 REQUIREMENTS SRs are specified in the Inservi e Testing Program. Pressurizer safety s are +/- 3% of 2485 psig valves are to be tested in acco ance with the requirements ef SeGcien Xi I for Unit 1 and +1.6%/-3% of the ASME Code (Ref. 4), w ich provides the activities and Frequencies of 2485 psig for Unit 2 necessary to satisfy the SRs. o additional requirements are specified. of 2485 The pressurizer safety valve setpoinp fr 03}% psig however, the valves are reset to +/- 1 the Surveillance to allow for REFERENCES 1. ASME, Boiler and Pressure Vessel Code, Section IlIl.

2. FSAR, Ghaptei:-K4- (Uit

3. / CAP-7769, Rev. 1,June 197 rASME, Boiler and Prercuro Vescel Code, Santion Xi.

l code for Operation and Li WCAP-7769, October 1971 (Unit 1') and Maintenance of Nuclear Power Plants. Referenced in Unit 1 UFSAR I. UFSAR Chapter 14 (Unit 1), and UFSAR Chapter 15 (Unit 2) WOG STS B 3.4.10-4 Rev. 2, 04/30/0-1 138

Pressurizer PORVs, B 3.4.11 IhRv.2 hnge B-1I BASES ACTIONS (continued) 0- ~-aaea to tme onme smii PIO1II .

L :-- lo:- s TEK Gnallenoes Me GYstemF GURinn 1R1s and provide the operato time to correct the situation.

The Required Actions F.1, F.2, and F.3 are modified by a Note stating that the Required Actions do not apply if the sole reason for the block valve being declared inoperable is a result of power being removed to comply with other Required Actions. In this event, the Required Actions for inoperable PORV(s) (which require the block valve power to be removed once it is closed) are adequate to address the condition. While it may be desirable to also place the PORV(s) in manual control, this may not be possible for all causes of Condition B or E entry with PORV(s) inoperable and not capable of being manually cycled (e.g., as a result of failed control power fuse(s) or control switch malfunctions(s)). G.1 and G.2 If the Required Actions of Condition F are not met, then the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours and to MODE 4 within 12 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. In MODES 4 and 5, automatic PORV OPERABILITY may be required. See LCO 3.4.12. SURVEILLANCE SR 3.4.11.1 REQUIREMENTS Block valve cycling verifies that the valve(s) can be opened and closed if needed. The basis for the Frequency of 92 davs is the ASME Code-SeGtionXI (Ref. 3). The Note This SR is modified by tNotes. modifies this SR by stating that it is not required to be performed with the block valve closed in 3 accordance with the Required Actions of this LCO. Opening the block valve in this condition increases the risk of an unisolable leak from the RCS since the PORV is already inoperable. Note 2 modifies this SR to allow entry into and operation in MODE 3 prior to perfomming the SR. This allows the test to be performod in MODE 3 under operating temperature and pressure conditions, prior to entering MODE 1 or 2. [In aGcordance with Reforonne 4, administrative controls require this,tort he pe^ounmed in MODE 3 or 4 to adequately s&mulate opeating temperature _and nrruro offocts en POR' onerationi WOG STS B 3.4.11 - 6 Rev. 2, 04/30/01 144

Rev. 2 Change B-1 Pressurizer PORVW B 3.4.11 BASES .1 and SR 3.4.11.2.2 In addition, the Unit 1 surveillance (SR 3.4.11.2.1) requires that each PORV be cycled using both the normal air supply and the backup nitrogen supply. Cycling the Unit I PORVs using both the norma! and VVEILLANCE RREQUIREMENTS I Echeck(c tinued) backupvalves supplytosystems actuates ensure that the normal both the solenoidand control valves backup and are supplies S SR 1fully functional. rhese Unit 1 and 2 3.4.11.2 Surveillances requires a complete cycle of each ORV. Operating a PORV through one complete cycle ensures th t the PORV can be 3 The surveillances manually actuated for mitigation of an SGTR. The Frequency of arte modified by f1 8-months is based on a typical refueling cycle and industry accepted Nctes that identify practice. The Note modifies this SR to allow entry into and operation in MODE ior to performing the SR. This allows the test to be performed i E 3 under operating temperature and pressure condition nor to enterl MODE 1 or 2. [In accordance with Reference 4, a inistrative controls uire this test be performed in MODE 3 or 4 adequately simulate op iting temperature and pressure effect n PORV operational [ SR 3.4.11.3 Operating the solenoid control valvend check valves on the air accumulators ensures the V co ol system actuates properly when called upon. The Frequency o nths is based on a typical refueling cycle and the Frequ cythe other Surveillances used to demonstrate PORV OPE ILITY.] tSR 3.4.11.4 /\ This Surveilla e is not required for plants with p anent I E power supplies the valves.\ Therveillance demonstrates that emergency power canprovided is performed by transferring power from normal to emerge supply and cycling the valves. The Frequency of [18] months is based on typical refueling cycle and industry accepted practice. ] REFERENCES 1. Regulatory Guide 1.32, February 1977. WOG STS B 3.4.11 - 7 . Rev. 2, 04/30/01 145

I Rev. 2 Change B-1 I RCS PIV Leakage B 3.4.14 BASES

a. I

                                  /0, I -
                                /The                               list of valves for which this surveillance is LiII]               for all PiVs listed in the tiRM prior to CUS;SURVEIL                    NCE         SR 3.4.14.1        applicable is contained in the LRM.

Ac REQUR/ET / Mode 2 arfer the To satisfy ALARA Performance of leakage testing on each RCS PIV or iso on valve used plant is requirements, leakage may to satisfy Required Action A.1 and Required is required to placed in be measured indirectly (as verify that leakage is below the specified limit and to identify each leaking MODE 5 from the Performance of valve. The leakage limit of 0.5 gpm per inch of nominal valve diameter up for refueling. accomplished in accordance to 5 gpm maximum applies to each valve. Leakage testing requires a with approved procedures stable pressure condition. and supported by computations showing that the method is capable of For the two PlVs in series, the leakage requirement applie each valve demonstrating compliance individually and not to the combined leakage across valves. If the within the valve leakage criteria. In addition, for those PIVs are not individually leakage tested, one val y have failed valves where the leakage completely and not be detected if the other e in series meets the rate can be continuously leakage requirement. In this situation prot provided by monitored during plant operation, no other leakage redundant valves would be lost. f rate testing is required. The leakage rate of valves Testing is to be performed continously monitored shall be recorded at intervals that . pln de Rat go into )The satisfy the required Frequenc consistent with 10 CFR 50.55a(f (Ref4 as contain d in the surveillance Frequency. Inserv Testing Program, is within frequency allowed by the Am ican

   .which results intesting the            So'ty of Mechanical Engineers (ASME) Code, SecGon Xi (Ref. ), and is PIVs approximately every              Abased on the need to perform such surveillances under the conditions thal However. this 18 months, is within the                apply during an outage and the potential for an unplanned transient if the ddoes not requirements of                         Surveillance were performed with the reactor at power.                                       rireclude performance of Insting               must be performed once after the valve h                              IIthis surveillance at opened by fib        ercised to ensure tight resea                        s disturbed in    ppower, if the performance of th                   lance sho              e tested unless                 necessary to documentation shows that an i                    ng loop cannot practically be              confirm C WPERABILITY, An additional Frequency of
'Frior to entering MODE 2 avoided. Testing muW               erformed with                urs after the valve has       when it can be wienever the unit has been                 been resea      . ithin 24 hours is a reasonable an                      al time limit     ccornplished iri a safe in MODE 5 for 7 days or more, if leakage testing has foe       rming this test after opening or reseating a valve.                                nmanner.

not been performed in the pi evious 9 months' is The leakage limit is to be met at the RCS pressure associated with \ applicable to certain PIVs. MODES I and 2. This permits leakage testing at high differential Ttuis additional Frequency Is modified by a note that pressures with stable conditions not possible in the MODES with lower cd3rifies that this Frequency Is P~-Irauertidons. higher only applicable to PyVs specifically identified in the lirt of PlVs in the LRM. The Entry into MODES 3 and 4 is allowed to establish additional testing is specified differential pressures and otabl conditions to allow for performance of this Surveillance. The Note that Ilows this provision is complementary to f for PIVs identified as 'Event K V (potential loss of coolant acident outside the Frequency of prior to entry in MODE 2 whcnovor the unit has boon cantainment) type PlVs in MODE 5 for 7 days or-meFe, if I akage testing has not been performed consistent with References 2 in the previous 9 months. In additi n, this Surveillance is not required to and 3. I if necessary I WOG STS B 3.4.14 - 5 Rev. 2, 04/30101 172

RCS PIV Leakage B 3.4.14, I Rv.2hange B-1I BASES SURVEILLANCE REQUIREMENTS (continued) Note 3 provides the allowance be performed on the RHR System when the RHR System is aligned to that the RCS PIV leakage may be the RCS in the shutdown cooling mode of operation. PIVs contained in veiified at a pressure lower than the RHR shutdown cooling flow path must be leakage rate tested after the required RCS pressure range provided the observed leakage RHR is secured and stable unit conditions and the necessary differential rates are adjusted to the function pressures are established. maximum pressure in accordance witi ASME OM Code (Ref. 4). R 3.4.14.2 and SR 3.4.14.3 Note 4 provides an exception to the 0.5 gpmlinch diameter leakage limit of the LCO. The Verifyn t the RHR autoclosure interlocks are OPERABLE rs Note allows leakage rates > 0.5 that RCS pre re will not pressurize the RHR system be 125% of gpin/inch diameter but s 5.0 gpm its design pressur [600] psig. The interlock setpoi at prevents the total provided the latest measured rate has not exceeded valves from being open is set so the actual R ressure must be the rate determined by the < [425] psig to open the valv This setpo nsures the RHR design previous test by an amount that pressure will not be exceeded an -reliefe valves will not lift. The rec uces the margin between measured leakage rate and the [18] month Frequency is based o ed to perform the Surveillance maximum permissible rate of 5.0 under conditions that apply d g a plant o ge. The [18] month gpin by 2 50%. Frequency is also accep e based on consid gon of the design reliability (and co ng operating experience) of th ipment. These SR emodified by Notes allowing the RHR autoclos function to be bled when using the RHR System suction relief valves fo Id o pressure protection in accordance with SR 3.4.12.7. ] I Unit I UFSAR Appendix 1A, "1971 AEC General Design Criteria Conformance" and Unit 2 UFSAR Section 3.1, "Conformance with U. S. Nuclear Regulatory Commission General Desiln Criteria' WASH-1400 (NUREG-75/014), Appendix V, October 1975. I NUREG-0677, May 1980. I code for Operation and Maintenanco of Nuclear Power Plants. l LE4iKZ Gocument conRtai A CRMF D~Irn-l Iss Of

                                                                   . :_   he pdlvs.

D--c.-ro , %1--I A_ j , r,-A-A"C VI I

8. 10 CFR 50.55a(g):

WOG STS B 3.4.14 - 6 Rev. 2, 04/30/01 173

I Rev. 2 Change B-1 I e rates greater than 0.5 gpm/inch diameterJ ea-IEss i)L than o latest measuir aul to 5.0 gpm are considered unac te exceeded the r le if the etermined by the previous test by an ut th ces the margin between measured leakage rate aximum permissible rate of 5.0 gpm by 50 pe or greater.

4. L e rates greater than 5.0 gpm a dered

__-- nacceptable. StR3.4.14.1 Note 3 -S--lObserved leakage rates shall be adjusted to the function maximum pressure in accordance with ASME Xi iAV 341. L Minimum test differential pressures shall not be less th n F (e) 150 psid. Leakage rate continuously monitored during plant operation, no I OM C:ode. n other leakage rate testing required. Leakage rate acceptance criteria shall be as stated in (a) and (b) above and shall be (e) recorded at intervals as noted in paragraph 4.4.6.3.1 as a minBimum, [Bot suveilanes ,4.E a;-af 4 .6..2 are required. I. .Ba

                                        -    SR 3.4.14.1 Frequency Note A14                                                         ~ -~AB Both frequencies of SR 3.4.14.1 are applicable. Therefore, SR 3.4.14.1 must be met every 18 months, and prior to entering Mode 2 whenever the unit has been in MODE 5 for 7 days or more, if leakage testing has not been performed in the previous 9 months.

BEAVER VALLEY - UNIT 2 3/4 4-23 270

I Rev. 2 Change B-1 ITS 3.4.14 INSERTS

                                            -NOTES-                                            4

1. Separate Condition entry is allowed for each flow path.

2. Enter applicable Conditions and Required Actions for systems made inoperable by an inoperable PIV.

2.

                                            -NOTES-                                          \

1. Not required to be performed in MODES 3 and 4. LI)

> 2. Not required to be performed on the RCS PIVs located in the RHR flow path when in the shutdown cooling mode of operation.

3. The RCS PIV leakage may be verified at a pressure lower than the specified RCS pressure range provided the observed leakage rates are adjusted to the function maximum pressure in accordance with ASME OM Code.

4. Leakage rates > 0.5 gprn'inch diameter but

5.0 gpm are acceptable if the latest measured rate has not exceeded the rate determined by the previous test by an amount that reduces the margin between measured leakage rate and the maximum permissible rate of 5.0 gpm by 2 50%.

3.

                                             -NOTE-Each valve used to satisfy Required Action A.1 must have been verified to meet SR 3.4.14.1 and be in the reactor coolant pressure boundary or the high pressu portion of the system.
                                                                                    -S 272

Rev.2 Change B .1 BVPS ISTS Conversion 3.4 Reactor Coolant System Enclosure 3 Changes to C:TS measured rate exceeded the rate determined by the previous test by an amount that reduces the margin between measured leakage rate and the maximum permissible rate of 5.0 gpm by 50 percent or greater." and CTS Table 4.4-3 Note 4 specifies that "Leakage rates greater than 5.0 gpm are considered unacceptable." The corresponding ISTS surveillance SR 3.4.14.1 does not contain provisions similar to these CTS Notes. The CTS is revised to conform to the ISTS. This changes the CTS by eliminating these Notes from the TS. The proposed change (deleting CTS Notes 3 and 4) is acceptable because the CTS Notes being deleted re-state the same limits as CTS Notes I and 2. CTS Notes 1 and 2 state acceptable leakage limits and have been retained in the ISTS SR 3.4.14.1. CTS Notes 3 and 4 state the same limits as Notes 1 and 2 but in terms of what is unacceptable instead of what is acceptable. CTS Notes 3 and 4 do not contain new or different limits than CTS Notes 1 and 2. The only difference between these Notes is how the limit is stated (i.e., one Note states what the maximum acceptable leakage is and the other Note states that anything greater than that limit is unacceptable). In the ISTS, the TS limits are typically only stated in terms of the maximum or minimum acceptable limit. In the ISTS, surveillance results outside the acceptable limit are automatically considered unacceptable. Therefore, once the TS limits are stated, it is not necessary to explain in the TS that values outside the limit are unacceptable. The proposed change is designated administrative as the CTS leakage limits remain unchanged. A.13 CTS Table 4.4-3 Note 5 specifies that "observed leakage rates shall be adjusted to the function maximum pressure in accordance with ASME Xl IWV 3423." The corresponding ISTS 3.4.14 does not have a similar provision in the specification. However, the ISTS 3.4.14 Bases for the PIV LCO requirements states:

              "Reference 7 [ASME code for Operation and Maintenance of Nuclear Power Plants or ASME OM Code] permits leakage testing at a lower pressure differential than between the specified maximum RCS pressure and the normal pressure of the connected system during RCS operation (the maximum pressure differential) in those types of valves in which the higher service pressure will tend to diminish the overall leakage channel opening.

In such cases, the observed rate may be adjusted to the maximum pressure differential by assuming leakage is directly proportional to the pressure differential to the one half power." The CTS reference to ASME X I[WV 3423 is the same provision of the ASME code as is cited in the ISTS bases (above). Although the ISTS contains this provision in the Bases, the CTS Note 5 provision is retained in the TS as Note 3 in proposed BVPS specific SR 3.4.14.1. The BVPS Note is re-stated to read: "The RCS PIV leakage may be verified at a pressure lower than the specified RCS pressure range provided the observed leakage rates are adjusted to the function maximum pressure in accordance with ASME OM Code." The proposed change is acceptable because it maintains the CTS requirements. The retention of CTS Table 4.4-3 Note 5 in the TS is consistent with the intent of the ISTS and the ASME OM Code as explained in the ISTS Bases. However, due to the ISTS surveillance requiring a specific RCS pressure (2215-2255 psig) for leakage rate verification, the provision of the CTS Note that allows verification at a lower pressure is retained within the proposed BVPS specific surveillance SR 3.4.14.1 as Note 3. As such, the allowance provided by the CTS Note is more clear BVPS Units I &2 Page 77 Revision 2, 4/06 2/05 370

lREV. 2 Change B-1 BVPS ISTS Conversion 3.4 Reactor Coolant System Enclosure 3 Changes to CTS than a description contained only in the Bases. The CTS note together with the ISTS bases description will provide a more complete description of the intended provisions of the surveillance. The CTS note is revised to fit more appropriately into the ISTS surveillance as an exception to the ISTS pressure requirement for leakage verification. In addition, the CTS reference to the specific ASME Xl subsection I\W 3423 is revised to simply reference ASME OM Code consistent with the ISTS Bases reference. This was done to eliminate the need to change the ASME code subsection references for different ASME editions that the plant may commit to in the future. In addition to the surveillance note, the full text explaining the ASME provision will be retained in the associated Bases in the same manner as the ISTS with another reference to the ASME Code. Therefore, the retention of the CTS Note and the proposed revisions to the Note do not change the technical requirements applicable in the CTS or that are applicable in the ISTS. As such, the proposed change is designated administrative. A.14 CTS Table 4.4-3 Note (d) specifies that "both surveillances 4.4.6.3.1 and 4.4.6.3.2 are required." This CTS Note indicates which RCS PlVs must meet both frequency requirements of the CTS PIV leakage surveillance. Since the ISTS does not include a list of valves in the TS, the ISTS does not contain a corresponding Note. The removal of this CTS Table from the TS consistent with the ISTS is addressed by another DOC. The CTS note is BVPS specific and is associated with the list of valves. Therefore, it is retained in Table 4.4.3 and revised to be consistent with the ISTS format and presentation of the referenced ITS surveillance requirements. The proposed change is acceptable because the revised CTS Note accomplishes the same function in the ITS as it did in the CTS. The proposed change does not involve a technical change to the CTS requirements. The format and presentation of the Note is revised to more closely match the corresponding ISTS surveillance and provide additional explanation that takes into consideration that the Table is no longer part of the TS. The Note continues to specify that both the PIV leakage surveillance frequencies must be met for the required valves. The proposed change is designated administrative because it does not result in a technical change to the CTS requirements. BVPS Units 1 & 2 Page 78 Revision .2,4/06 2/05 371

BVPS UNITS 1 & 2 yjJJ ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 CHANGE B-1 AFFECTED PAGES FOR ITS SECTION 3.5 (ECCS) ITS SECTION 3.5 (ECCS) INDEX OF AFFECTED PAGES ITS MARKUPS No change ITS JFDS No change ITS BASES MARKUPS PAGE: 40 ITS BASES JFDS No change CTS MARKUPS No change CTS DOCS No change.

ECCS - Operating B 3.5.2 Rev 2 Change B-1 BASES SURVEILLANCE REQUIREMENTS (continued) or securing. A valve that receives an actuation signal is allowed to be in a nonaccident position provided the valve will automatically reposition within the proper stroke time. This Surveillance does not require any testing or valve manipulation. Rather, it involves verification that those valves capable of being mispositioned are in the correct position. The 31 day Frequency is appropriate because the valves are operated under administrative control, and an improper valve position would only affect a single train. This Frequency has been shown to be acceptable through operating experience.

                        .5.2.3/

Wihtex n of the operating centrifugal charging p t e E pumps are normyia standby, nonoperating mod s such, flow path piping has the potenti evelop voids and p e~ts of entrained gases. Maintaining the piping from tC p to the RCS full of water ensures that the system willppefp rly, injecting its full capacity into the RCS upon demand. will als event water hammer, pump cavitation, and pumpin oncondensible gai .. , air, nitrogen, or hydrogen) into the ctor vessel following an SI sig or during shutdown co g. The 31 day Frequency takes into cons ation the gradua ure of gas accumulation in the ECCS piping and the

              ,prdural controls governing system operation.

SR 3.5.2.4 Periodic surveillance testing of ECCS pumps to detect gross degradation caused by impeller structural damage or other hydraulic component problems is required by SeGtio Xi ef the ASME Code. This type of testing may be accomplished by measuring the pump developed head at I only one point of the pump characteristic curve. This verifies both that the measured performance is within an acceptable tolerance of the original uat the performance at the test flow is

               'greater than or equal t the performance assumed in thepbnt-zy analysis. SRs are specified in the Inservice Testing Program.-wWh encompas6o6 Section XI of the ASME Code. SeGtin X-XIefhe ASME Code provides the activities and requencies necessary to satisfy the I

requirements. 1 SR 3.5.2.5 and SR 3.5.2.6 These Surveillances demonstrate that each automatic ECCS valve actuates to the required position on an actual or simulated SI signal and WOG STS B 3.5.2 - 8 Rev. 2, 04/30/01 40

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 CHANGE B-1 AFFECTEDPAGES FOR ITS SECTION 3.6 (CONTAINMENT) ITS SECTION 3.6 (CONTAINMENT) INDEX OF AFFECTED PAGES ITS MARKUPS No change ITS JFDS No change ITS BASES MARKUPS PAGES: 124,125,133 & 135 ITS BASES JFDS No change CTS MARKUPS No change CTS DOCS No change.

IJ l Rev. 2 Change B-1 I BASES SURVEILLANCE REQUIREMENTS (continued) pumpsanet-beiested with flow through the spra h ae tested on bypass flow. - point on the pump design curve and is ina perforeests romnonent 0PFRARIIlIY trnd ntrfnrmanre and detecr A incipient failures by indicating abnormal performancn. The Frequency of this SR is in accordance with the Inservice Testing Program. SR 3.6.60.3and SR 3.6.6D.4 These SRs ensure that each OS automatic valve actuates to its correct position and each QS pump starts upon receipt of an actual or simulated containment spray actuation signal. This Surveillance is not required for valves that are locked, sealed, or otherwise secured in the required position under administrative controls. Thef18] month Frequency is based on the need to perform these Surveillances under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillances were performed with the reactor at power..* Operating experience has shown that these components usually pass the Surveillances when performed at an41 83-month Frequency. Therefore, LIII1 the Frequency was concluded to be acceptable from a reliability standpoint. I 94--d -f l -r-nn not n*hidA -f 3-_ this surveillance at power when it can be This SR is performed following SR 3.6.6D.5 accomplished in a sate manner. maintenance when the potential for nozzle blockage - I* -J ha,; been determined to exist ltrI ;nnA of -n-, -~aI-tiC - I-,, n- -e,..- ;r

                                                                                          -   -r n- L-            h

k. lns..n UlIIIUU Ul vile bUIUtlUII IUW Ul1vtaUI-v vil Ul villUllvCI veal Ut: UIUVVII tIIIUUUII Awn

                                                                                                                             -  n-n e,,nk by an engineering evaluation.

ThiX required evaluation will test connectionsa. This SR ensures that each spray nozzle is als: specify an appropriate test unobstructed and that spray coverage of the containment during an method for determining the accident is not degraded. Due to the passive nature of the design of the CTS SR spray header OPERABILITY. nozzle, a test atthe l t -Fefelir an atq ear-integine is conside red adequate to detect obstruction of the nozzles. _ following maintenance that results in the potential for nozzle blockage REFERENCES 1. FSAR Section46.4.

2. 10 CFR50.49 Unit I UFSAR Chapter 14, and Unit 2 UFSAR Section 6.2.

3. 10 CFR 50, Appendix K.

4. ASME, Boikad Pressure Vossel Code, Section Xl.

code for Operation and Maintenance of Nudear Power Plants. I WOG STS B 3.6.60- 5 Rev. 2, 04130/01 124

Rev. 2 Change B-1 ITS 3.6.6 BASES INSERTS

1. The appropriate single failure is assumed in the safety analysis. However, the maximum calculated peak containment pressure results from a LOCA postulated to occur in the RCS hot leg. The calculated peak containment pressure from this location occurs during the blowdown phase, prior to the actuation of any safety related equipment, consequently there is no single failure assumed in this analysis. The SLB resulted in the maximum calculated peak containment temperature and containment liner temperature.

The Unit 1 SLB that resulted in the peak containment temperature occurred at 100% RTP, with the worst case single failure of a main steam check valve. The Unit 1 SLB that resulted in the peak containment liner temperature occurred at 30% RTP, with the worst case single failure of a main steam check valve. The Unit 2 SLB that resulted in the peak containment and containment liner temperature occurred at 0% RTP, with the worst case single failure of a main steam isolation valve.

2. maintained within the limits of LCO 3.6.4, Containment Pressure.

3. Verifying that each QS system pump's developed head at the flow test point is greater than or equal to the required developed head ensures that QS system pump performance has not degraded during the cycle. The term 'required developed head" refers to the value that is assumed in the Containment Integrity Safety Analysis for the QS pump's developed head at a specific flow point. This value for the required developed head at a flow point is defined as the Minimum Operating Point (MOP) in the Inservice Testing (IST) Program. The verification that the pump's developed head at the flow test point is greater than or equal to the required developed head is performed by using a MOP curve. The MOP curve is contained in the IST Program and was developed using the required developed head at a specific flow point as a reference point. From the reference point, a curve was drawn which is a constant percentage below the current pump performance curve. Based on the MOP curve, a verification is performed to ensure that the pump's developed head at the flow test point is greater than or equal t6 the required developed head. Flow and differential head are normal test parameters of centrifugal pump performance required by Section Iiof the ASME Code (Ref. 4). Since the QS system pumps cannot be tested with flow through the spray headers, they are tested on bypass flow. This test confirms one point on the pump design curve and is indicative of overall performance. Such inservice tests confirm component OPERABILITY, trend performance, and detect incipient failures by indicating abnormal performance.

4. The containment air temperatures resulting from DBAs are used to establish EQ requirements (Ref. 2) for equipment inside containment. The EQ requirements provide assurance the equipment inside containment required to function during and after a DBA performs as designed during the adverse environmental conditions resulting from a DBA. Air temperature profiles (containment air temperature vs time) are calculated for each DBA to establish EQ design requirements for the equipment inside containment.

The equipment inside containment required to function during and after a DBA is confirmed to be capable of performing its design function under the applicable EQ requirement (i.e., air temperature profile). 125

I 0-v I P.h-na R_1 I I IUV. o WI ldlvly - 1 RS System (Sbamspe-- BASES I CTS S following maintenance that results in SURVEILLANCE REQUIREMENTS (continued th /oeta o nzl lcae [the first refueling and at] 10 is considered adequate for Mdetecting obstruction of the nozzles. REFERENCES 1. FSAR,Soction[16.1 UnitlIUFSAR Chapter14,and Unit2 UFSAR Section 6.2.

2. 10 CFR 50.49. Unit 2 UFSAR S

3. 10 CFR 50, Appendix K.

4. ASMEBoieiand-Prcssu¶ Vesel Code, Section IX.

code for Operation and Maintenance of Nuclear Power Plants WOG STS B 3.6 -8 Rev. 2, 04/30/01 133

I Rev. 2 Change B-1 I RECIRCULATION SPRAY SYSTEM BASES INSERTS Unit 2.

5. The appropriate single failure is assumed in the safety analysis. However, the maximum calculated peak containment pressure results from a LOCA postulated to occur in the RCS hot leg. The calculated peak containment pressure from this location occurs during the blowdown phase, prior to the actuation of any safety related equipment, consequently there is no single failure assumed in this analysis. The SLB resulted in the maximum calculated peak containment temperature and containment liner temperature. The Unit I SLB that resulted in the peak containment temperature occurred at 100% RTP, with the worst case single failure of a main steam check valve. The Unit 1 SLB that resulted in the peak containment liner temperature occurred at 30% RTP, with the worst case single failure of a main steam check valve. The Unit 2 SLB that resulted in the peak containment and containment liner temperature occurred at 0% RTP, with the worst case single failure of ;3 main steam isolation valve (Ref. 1).

6. Verifying that each RS system pump's developed head at the flow test point is greater than or equal to the required developed head ensures that RS system pump performance has not degraded during the cycle. The term "required developed head" refers to the value that is assumed in the Containment Integrity Safety Analysis for the RS pump's developed head at a specific flow point. This value for the required developed head at a flow point is defined as the Minimum Operating Point (MOP) in the IST Program. The verification that the pump's developed head at the flow test point is greater than or equal to the required developed head is performed by using a MOP curve. The MOP curve is contained in the 1ST Program and was developed using the required developed head at a specific flow point as a reference point. From the reference point, a curve was drawn which is a constant percentage below the current pump performance curve. Based on the MOP curve, a verification is performed to ensure that the pump's developed head at the flow test point is greater than or equal to the required developed head. Flow and differential head are normal test parameters of centrifugal pump performance required by SeGtioR XI of the ASME Code (Ref.4). Since the RS system pumps cannot be tested with flow through the spray headers, they are tested on bypass flow. This test confirms one point on the pump design curve and is indicative of overall performance. Such inservice tests confirm component OPERABILITY, trend performance, and detect incipient failures by indicating abnormal performance.

7. The containment air temperatures resulting from DBAs are used to establish EQ requirements (Ref. 2) for equipment inside containment. The EQ requirements provide assurance the equipment inside containment required to function during and after a DBA.

performs as designed during the adverse environmental conditions resulting from a DBA. Air temperature profiles (containment air temperature vs time) are calculated for each DEIA to establish EQ design requirements for the equipment inside containment. The equipment inside containment required to function during and after a DBA is confirmed to be capable of performing its design function under the applicable EQ requirement (i.e., air temperature profile).

8. of 354.40 F (Unit 1) and 335.1 OF (Unit 2) and the maximum containment liner temperature of 254.1OF (Unit 1) and 247.70F (Unit 2) 135

BVPS UNITS I & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 CHANGE B-1 AFFECTEDPAGES FOR ITS SECTION 3.7 (PLANT SYSTEMS) ITS SECTION 3.7 (PLANT SYSTEMS) INDEX OF AFFECTED PAGES ITS MARKUPS No change ITS JFDS No change ITS BASES MARKUPS PAGES: 79, 80, 86, 87,108 &110 ITS BASES JFDS No change JL& CTS MARKUPS No change CTS DOCS No change.

MSSVs B 3.7.1 I Rev. 2 Change B-1 I BASES ACTIONS (continued) The maximum THERMAL POWER corresponding to the heat removal ca aci of the remainin OPERABLE MSSVs is determined via a Ilas aboe l conservative heat balance calculation asliersribod in the attacrhmnnt to Refer.nce 6, with an appropriate allowance for Nuclear Instrumentation System trip channel uncertainties. A__ I 0 0 I To determine the table 3.7.1-1 Maximum Allowable Power for Required I Maximum NSSS Power GatGU~ated u is reduced by 191% RTP J (2>) \,-L I Insert 5 I ILZZ LJ-- to account for Nuclear Instrumentation System trip channel uncertainties. i Required Action B.2 is modified by a Note, indicating that the Power Range Neutron Flux-High reactor trip setpoint reduction is only required in MODE 1. In MODES 2 and 3 the reactor protection system trips specified in LCO 3.3.1, "Reactor Trip System Instrumentation," provide sufficient protection. The allowed Completion Times are reasonable based on operating experience to accomplish the Required Actions in an orderly manner without challenging unit systems. C.1 and C.2 If the Required Actions are not completed within the associated Completion Time, or if one or more steam generators have 2 j4J inoperable MSSVs, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours, and in MODE 4 within 12 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. SURVEILLANCE SR 3.7.1.1 and the reguirements. REQUIREMENTS This SR verifies e OPERABILITY of the MSSV by the verification of each MSSV Ii etpoint in accordance with the I service Testing Progra ASME Code, Sectien Xi (Ref. 4) roquiroc that safety and (5 \ _ relief valve tests be performed in accordance with ANSI/ASME I OM 11987 (Ref. 5). AXG _ding to Reference 5, the following teSte are. fIT qnuviw

                                               .                            vrrrod+v WOG STS                                        B 3.7.1 - 6                         Rev. 2, 04/30/01 79

MSSVs B 3.7.1 I Rev. 2 Change B-1 I BASES SURVEILLANCE REQUIREMENTS (continued) sal examination,/

b. Seat Ietg dermination, 5 c. Setpoint pressure nation (lif et,

d. Compliance with ovine t citria, and

e. Verific alancing device integrit o valves.

I The /ASME Standard requires that all valves be tested ev years. and a minimum of 20% of the valves be tested every 24 mon Table 3.7.1-2a (Unit 1)and The ASME Code specifies the activities and fre uencies necessary to Table 3.7.1-2b (Unit 2) specify satisfy the requirements. Table 3.7.1 2 allows- 13]°/1% setpoint the required _ tolerance for OPERABILITY; however, the valves are reset to +/- 1% (D during the Surveillance to allow for drift. The lift settings, acecrding to Table 3.7.1 -2, correspond to ambient conditions of the valve at nominal operating temperature and pressure. This SR is modified by a Note that allows entry into and operation in MODE 3 prior to performing the SR. The MSSVs may be either bench tested or tested in situ at hot conditions using an assist device to simulate lift pressure. If the MSSVs are not tested at hot conditions, the lift setting pressure shall be corrected to ambient conditions of the valve at operating temperature and pressure. Al(Unit 1)and Sedo 103. REFERENCES 1. ,k FSAR, Section [1 -3.1j l (Unit 2)

2. ASME, Boiler and Pressure Vessel Code, Section 1II, Article NC-7000, Class 2 Components.

() 3.

                                   ~~~~   FSAR, Sectio4--4 l
                                          ~~1                           14.1 (unit 1) and Section 9; ffItnit 91I                In code for

4. ASMEi,6008F adr12F ~e sar r ! Y Maintenance of ci Nuclear Power

5. ANSASME M 7. Plants.

6. NRC Information Notice 91 60, "Potential OvorprF6curization of the I Main Steam System," Auguct 22, 1091.

WOG STS B 3.7.1 - 7 Rev. 2, 04/30/01 80

MSIV'; B 3.7.2 lRev. 2 Change -l BASES ACTIONS (continued) operating experience, to reach the required unit conditions from MODE 2 conditions in an orderl manner and without challenging unit systems. (Iga gnrtoplsMIcou e Ii) within the limit specified in the Licensing l SURVEILLANCE SR 3.7.2.1 Requirements Manual (Ref. 5). l REQUIREMENTS lu I_ This SR verif s that MSIV closure time is+- The MSIV I tota nelation spo tim s assumed in the accident and containment analyses. 1E due toW Surveillance is normally performed upon returning the unit to operation

                      @~     following a refueling outage The MSIVs shiold not he tested at power-,

n ven exrcise incrashe risk of a valve closure when the unit is generating power. As the MSIVs are nof'tested at power, they are exempt from the ASME Code, SeGtioen X . requirementsl during operation in MODE I or 2. L e allowed to b The Frequency is in accordance with the Inservice Testing Program. This test id conducted in MODE 3 with the unit at operating temperature and pressure. This SR is modified by a Note that allows entry into and operation in MODE 3 prior to performing the SR. This allows a delay o testinrg until MODE 3, to estbl;ish conditions consistent yith thene gndeo which the acceptance criterion was generated. Zautomatic and manual SR 3.7.2.2 This SR verifies that each MSIV can close on an actual or simulated G Xctuation signal. Thi:surveilance is normally performed upon returning the plant to operation following a refueling outage. The Frequency of MSIV testing is every f 181 months. The [118 month Frequency for testing is based on the refueling cycle. Operating experience has shown that these components usually pass the Surveillance when performed at the 118] month Frequency. Therefore, this Frequency is acceptable from a reliability standpoint. REFERENCES 1. FSAR, Section X10.3}. FR Chapter 14 (Unit 1)and FSAR, S~TV~ . Section 6.2 (Unit 2). (I FSAR, Section [-i.

4. tOFR 100.11. l14.2.5.1 (Unit 1)and (i WOG STS B 3.7.2 - 5 Rev. 2, 04/30/01 86

Rev. 2 Change B-I MSIVW B 3.7.,2 BASES E5. AbMbe helleF and w-ressumr VOrI Goa. SCetiun 0 code for Operation and Maintenance of Nuclear Power Plants I I WOG STS B 3.7.2 - 6 Rev. 2, 04/30/01 87

AFW System B 3.7.5 l Rev. 2 Change B-1 I BASES SURVEILLANCE REQUIREMENTS (continued) generator level control, if it is capable of being manually (i.e., remotely or locally, as appropriate) realigned to the AFW mode of operation, provided it is not otherwise inoperable. This exception allows the system to be out of its normal standby alignment and temporarily incapable of automatic initiation without declaring the train(s) inoperable. Since AFW may be used during startup, shutdown, hot standby operations, and hot shutdown operations for steam generator level control, and these manual operations are an accepted function of the AFW System, OPERABILITY (i.e., the intended safety function) continues to be maintained. I The 31 day Frequency is based on engineering judgment, is consistent with the procedural controls governing valve operation, and ensures The term "required devoeloped correct valve positions. heac " refers to the valuee that is assumed in the AFW sfE ifety SR 3.7.5.2 analyIsis for developed Ihead at a flow point. This value f()r required Verifying that each AFW pump's developed head at the flow test point is developed head at a flow point is greater than or equal to the required developed head ensures that AFW defired as the Minimury Operating Point (MOP) >inthe Inseivice Testing Progr. am. Flow pump performance has not degraded during the cycle.Feew and differential head are normal tests of centrifugal pump performance Q and differential head ana normal required by SeGtiGA.XI Gf the ASME Code (Ref 2). Because it is test parameters undesirable to introduce cold AFW into the steam generators while they are operating, this testing is~performed on recirculation flow. 4This test O confirms one point on the pump design curve and is indicative of overall performance. Such inservice tests confirm component OPERABILITY, trend performance. and detect incipient failures by indicating abnormal l s euires performance. Performance of inservice testingvgsGw~sed in the ASME Code, Soetion Xi (Ref. 2) (only required at 3 month intorvals) satisfies this I. Fo, Unit 1, The recirct : I requirement. flow rate is assumed to be a fixed value since the [This SR is modified by a Note indicating that the SR should be deferred recirculation line flow until suitable test conditions are establisher This deferral is required resistance remains coinstant. because there is insufficient steam pressurk to perform the test. I FoPUnit 2, the recircu lation flow rate is adjusted tc a) SR 3.7.5.3 for testing the turbine driven AFW pump (ok) specific value. This SR verifies that AFW can be delivered to the appropriate steam generator in the event of any accident or transient that generates an ESFAS, by demonstrating that each automatic valve in the flow path 0 actuates to its correct position on an actual or simulated actuation signal. This Surveillance is not required for valves that are locked, sealed, or otherwise secured in the required position under administrative controls. The f 181 month Frequency is based on the need to perform this WOG STS B 3.7.5 - 7 Rev. 2, 04/30/01 108

AFW System I Rev. 2 Change D-1 & B-1 1 B 3.7.5 BASES Ncte 3 indicates the SR is no: required to be met in REQUIREMENTS (continued) MODE 4 when steam gelerator(s) are relied upon for heat removal. In MODE used during startup, shutdown, hot standby operations, and hot shutdown 4, :he heat removal operations for steam generator level control, and these manual requirements are less such operations are an accepted function of the AFW System. OPERABILITY thz t more time is available (i.e., the intended safety function) continues to be maintained. ', for operator action to (I I rriznually initiate AFW if SR 3.7.5.5 mulative nlex:ssary.{R3.55Jcmltv e eThis SR verifies tha FW is properly aligned by verifying the flow paths from th e each steam generator prior to entering MODE 2 A7 PPDWST (WT-TK-10 after more than 3> ays in any combination of MODE 5 or 6 or defueled. for Unit land 2FWE- OPERABILITY of AFW flow paths must be verified before sufficient core TK210 for Unit 2) heat is generated that would require the operation of the AFW System during a subsequent shutdown. The Frequency is reasonable, based on engineering judgement and other administrative controls that ensure that ID-1 I D-1 flow paths remain OPERABLE. To further ensure AFW System alignment, flow path OPERABILITY is verified following extended outages. to determine no misalignment of valves has occurred. This SR ensures hat the flow path from th aligned. I PPDWST to the steam generators is properly (D 0 This SR is insttEVIEWER'S not required by to NOI tueAFW for normal startup REFERENCES 1. FSAR, Section WA-. I 10.3.5.2.2 (Jnit 1) and Section 10.4.9 ASME iei: an4pr Pcsuro VeRNOAol Code, Soction Xl. (Unit 2) (0U2. I code for Operation and Maintenance of Nuclear Power Plants I B-1 WOG STS B 3.7.5 - 9 Rev. 2, 04/30/0-1 110

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 169 (UNIT 2) REVISION 2 CHANGE B-1 AFFECTEDPAGES FOR ITS SECTION 3.8 (ELECTRICAL POWER SYSTEMS) ITS SECTION 3.8 (ELECTRICAL POWER SYSTEMS) INDEX OF AFFECTED PAGES ITS MARKUPS No change ITS JFDS No change ITS BASES MARKUPS PAGES: 81 & 97 ITS BASES JFDS No change CTS MARKUPS No change CTS DOCS No change.

AC Sources - Operating Rev. 2 Change B-1 B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) SR 3.8.1.6 o p i This Surveillance demonstrates that each required fuel oil transfer pump operates and transfers fuel oil from its associated storage tank to its associated day tank. This is required to support continuous operation of standby power sources. This Surveillance provides assurance that the 2 t uel oil transfer pump is OPERABLE, the fuel oil piping system is intact, the very piping is not obstructed, and the controls and control systems fort fuel transfer systems are OPERABLE. f-The Frequency for this SR is varipde individual system design, with up to a 1921 day The 192] day Frequency corresponds to the testing requirements for pumps as contained in the / ASME CodeSeGtien Xl (Ref. I1); however, the design of fuel tranefel SYMtMSs i6such that pumnps operate automatically oF mAust be started manually in order to maintain an adequate volume of fuel oil in the day [and engine mounted] tanks during or following DG testing. In such a rcswe, a 31 day Frequeny is appropriate. Since proper operation of fuel traos~feF systems is an inheren;t part of DG OPERABILITY, the Froquency bK6AG19 01 MS b maificd to Feflect inaividual designe. j Trnfr of each E4.1B kES bus] power supply from the nfst circuit to the offsite circuit demonstrates the OPERABILITY of the alternate circuit distribution network to power the shutdown loads. The 118 month) Frequency of the Surveillance is based on engineering judgment, taking into consideration the unit conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths. Operating experience has shown that these components usually pass the SR when performed at the 118 month] Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint. mThtiodified by a Note. The reason for the Notesng operation withM recritical, performan i R could cause perturbations to the electical nsystems that could challenge continued stea tion and, asafety <} set.is restriction from normally performing the e in WOG STS B 3.8.1 - 17 Rev. 2, 04/30/01 81

Rev. 2 Change 1 l AC Sources - Operating B 3.8.1

13. License Amendment Nos. 268 (Unit 1)and 150 (Unit 2) and associated NRC BASES Safety Evaluation Report issued September 29, 2005.

REFERENCES (conti ued) / [O b97 (Unit2) l codeforOperation Insert For Action Section of and MaintenanWe Bases. This text is from the cTS 10. RegulatoRuid 1.1 e of Nuclear Pover Bases as revised by Amendments R Plants Nos. 268 (Unit 1)and 150 (Unit 2) 11 ASS , Boler and Pro- VseCodS-ction iureo Xl. issued 929/05 for the 14-day DG AOT. TAC Nos. MC3331 & 1t r 1-1971 an Unit IVC3332. 12 EE Standard30 pu 4 u Requirements for applying the 14-day DG Completion Time The ACTION Conditions for inoperable AC sources provide a 14-day Completion Time when one DG is inoperable. The 14 day Completion Time includes the normal 72 hour Completion Time which is not risk informed, followed by an 11 day extension period that is based on a plant specific risk analysis performed to establish the overall Completion Time (Ref 13). As a defense indepth measure, when the option of an extended Completion Time (i.e., a time beyond the normal 72 hours) for a DG is exercised, alternate AC (AAC) power will be provided with capability of supplying safe shutdown oaids during a station blackout without the need for rescheduling of safety system operation in the unaffected unit. For unplanned DG outages, capability to supply AAC power will be available upon entering the Completion Time extension (i.e. by 72 hours into the Completion Time). For outages planned to exceed an initial 72-hour Completion Time, MC power will be provided within one hour of entering the Adion Condition for an inoperable DG. In any event, if AAC power of the required capacity is not available after entering the extended Completion Time (after 72 hours into the CompletiDn Time), the Required Actions of Action Condition G become applicable (i.e., Be in MODE 3 in 6 hours and Be in MODE 5 in 36 hours). The following criteria would apply to any AAC source used as a defense in depth measure:

1. An AAC power source may be of a temporary or permanent nature and would not be required to satisfy Class 1E requirements.

2. Dynamic effects of an AAC power source failure (GDC-4 events) would not adversely affect safety related plani.

equipment.

3. An MC power source would not be required to be protected against natural phenomena (GDC-2 events) or abnormal environmental or dynamic effects (GDC4 events).

4. An MC power source would be capable of starting and carrying designated loads required for safe shutdown, including maintaining adequate voltage and frequency such that performance of powered equipment is acceptable.

Prior to relying on its availability, a temporary AAC power source would be determined to be available by: (1) starting the MC source and verifying proper operation; (2)verifying that sufficient fuel is available onsite to support 24 hours of operation; and (3)ensuring that the MC source is in the correct electrical alignment to supply power to designated safe shutdown loads. Subsequently, when not in operation, a status check for availability will also be performed once every 72 hours. This check consists of (1)verifying the MC source is mechanically and electrically ready for operation; (2)verifying that sufficient fuel is available onsite to support 24 hours of operation; and (3)ensuring that the MC sourze is in the correct electrical alignment to supply power to designated safe shutdown loads. Prior to relying on its availability, a permanent MC power source would be determined to be available by starting the MC source and verifying proper operation. In addition, initial and periodic testing, surveillance, and maintenance conform to NUMARC 87-00, Revision 1, Appendix B,"Alternate AC Power Criteria guidelines. The guidelines include provisions for quarterly functional testing, timed starts and load capacity testing on a fuel cycle basis, surveillance and maintenance consistent with manufacturer's recommendations, and initial testing of capability to power required shutdown equipment within the necessary time. WOG STS B 3.8.1 - 33 Rev. 2, 04/30/01 97

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 169 (UNIT 2) REVISION 2 CHANGE B-1 AFFECTEDPAGES FOR ITS SECTION 5.0 (ADMINISTRATIVE CONTROLS) ITS SECTION 5.0 (ADMINISTRATIVE CONTROLS) INDEX OF AFFECTED PAGES ITS MARKUPS PAGES: 13 & 14 ITS JFDS No change ITS BASES MARKUPS No change ITS BASES JFDS INo change CTS MARKUPS IPAGE: 90 CTS DOCS INo change.

I Rev. 2 Change B.1 I Programs and Manuals 5.5 5.5 Programs and Manuals "I 5 7 Reactor Coolant Pump Flywheel Inspection Program (continued) z

                    \                                      ~-REVIEWER'S NOTES -/

t.The inspection interval and scope for RCP flywheels stated~~v cn be

                    \pplied to plants that satisfy the staff requirements in thaft                                 evaluation Tpical Report, WCAP-1 4535A, "Topical Repr oeactor Coolant Pur Flywheel Inspection Elimination."

2. License hall confirm that the flywheels arade of SA 533 B material.

Further, licen es having Group-i5 flyw Is (as determined in WCAP-14535A, "Topi eport on Reactor olant Pump Flywheel Inspection Elimination") need demonstrate at material properties of their A516 material is equivalent SA 53 material, and its reference temperature, RT, is less than 30 "F.

3. For flywheels not mad f SA B or A516 material, licensees need to either demonstrate at the flywhe aterial properties are bounded by those of SA 533 material, or provide e minimum specified ultimate tensile stres e fracture toughness, an he reference temperature, RTNDT, for at material. For the latter, the Ii nsees should employ these mater properties, and use the methodology in e topical report, as ext ded in the two responses to the staff's RAI, t rovide an assessment justify a change in inspection schedule for their pla X45 Licensees with Group-10 flywheels need to confirm that the ywheels have an adequate shrink fit to preclude loss of shrink fit of the flywh at the maximum overspeed, or to provide an evaluation demonstrating t t no detrimental effects would occur if the shrink fit was lost as maximum overspeed.

applicable to the ASME Code for Operations and Maintenarce of 5.5~ Inservice Testing Program Nudear Power Plants (ASME OM Code) This program provides controls for inservice testing of ASME Code Class 1, 2, and 3 components. The program shall include the following: T__ tnr iI

                                                               -I :.. LI              -t &L-   AtA       r e 'Ir Q_    e               I Drnet~ble,, ,r . leuoimz  ('nlia   nAtt   nn,.Mkn         lEnI-         n      In,,

JF1.VUvjV UUU16U0 C30 lullv"Q. CM I ASME Boilor and Prossure Required Frequencies for Vessel Code and applicable performing inservice testing Addenda terminology for activities inservice testing activities Weekly At least once per 7 days WOG STS 5.5 - 5 Rev. 2, 04/30/01 13

I Rev. 2 Change B-1 & C-13 Programs and Manuals 5.5i 5.5 Programs and Manuals 5.5. Inservice Testing Program (continued) I B-1 ASME Boiler and PressurI Required Frequencies for Vessel Code and applicable performing inservice testing Addenda terminology for activities inservice testing activities Monthly At least once per 31 days (Oindrhoiv ^r a~vanr 'A mnnfhe At lknet nnrn nor 09 Hiv p34 Semiannually or every 6 months Every 9 months Yearly or annually At least once per 184 days At least once per 276 days At least once per 366 days arid to other normal Biennially or every 2 years At least once per 731 days arid accelerated Frequencies specified

a. 2 years or less in b. The provisions of SR 3.0.2 are applicable to the above required th3 Inservice Testing Frequenciesor performing inservice testing activities, B C-13 Pa gram I c. The provisions of SR 3.0.3 are applicable to inservice testing activities, and

d. Nothing in the ASME Boiler and Pre I Code shall be construed l B-1 to supersede the requirements of any TS.

SlOM 5.5.2 Steam Generator (SG) Tube Surveillance Program The provisions of SR 3.0.2 re applicable to the SG Tube Surveillance Program test frequencies. a S 5.56 Secondary Water Chemistry Program This program provides controls for monitoring secondary water chemistry to inhibit SG tube degradation and low prossure turbine disc stross corrosion -- Gr~akin. The program shall include:

a. Identification of a sampling schedule for the critical variables and control points for these variables,

b. Identification of the procedures used to measure the values of the critical variables, WOG STS 5.5 - 6 Rev. 2, 04/30/0'1 14

[I I CTS Page for ITS 5.5.4 I Rev. 2 Change B-1 & C-13 APPLICABILITY Testing frequencies applicable to the ASME Code for Operations Farla. REQUIRI:MENTS and Maintenance of Nuclear Power Plants (ASME OM Code) su{ iI .17U E3-1 urveillane intervas ifid in ecetien XI of the AGM-I- R- npplieable Addenda for .- he

                -- se-           ~ ,inspection                    and Wts-                             ----------               requrlld by the ASME

_R- ru Vessel GedecY and applicable Addenda shall -e 1'--I D1e

                                   -_IF1 -     - -
                                              -tl as      IlOW I

a t - _A_

                                                                   !_4 fI-  __,,__

__v_ ric' r-rnla .. o - -eclc~

               -z   v-         -      '     1     Ad ___                      -  ..  -                           '     '--'-1---------'---

B-1 ASME Beiler and Pressure VeCs; Required frequencies for l Code and applicable Addenda performing inservice in yfor inservice linspection and testing lnsvecton and testing activities activities Weekly At least once per 7 days ' Monthly At least once per 31 days Quarterly or every 3 months At least once per 92 days Semiannually or every 6 months At least once per 184 days Every 9 months At least once per 276 days Yearly or annual 3..2 At least once per 366 days The provisions of Cpciification 4.0.2 are applicable tv*-he above required frequencies Rfor performing inservice lins ect:ij and testing activities. lerve inservic and test:ng acb ecifed Surveillance I _ Nothing in the ASMEj B/oiler and Przszturc Vessel Code shall be IBI1 construed to supersede the requirements of any Technical Specification. -_ A14 and to other normal and accelerated Frequencies IC-13 14 specified as 2 years or less in the Inservice Test

c. The provisions of SR 3.0.3 are applicable to inservice testing activities.

l Biennially or every 2 years At least once per 731 days 3rqi BEAVER VALLEY - UNIT 2 3/4 0-4 Amendment No. 144 90

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 CHANGE C-1 Database # 200505251129 NRC Commenter: C. Schulten Requested Section 3.3.A DOC LA.1 be revised to clarify the procedural nature of the information being relocated and identify that the relocated requirement is effectively replaced by the ISTS defined test term for Staggered Test Basis. The DOC is revised as requested. This change only affects DOC LA.1, however, due to the revision the subsequent DOC pages were repaginated resulting in a large number of affected pages for this relatively small change. Affected Pages: The following Table(s) list the affected pages by type (i.e., ITS markup, CTS markup, etc.). In order to facilitate review by ITS section, a separate table is provided for each ITS section affected by the change. The page numbers listed are the ITS section specific consecutive numbers found in the lower right corner of each page. Note: Because the affected page(s) for each change were extracted from a complete ITS section electronic file, the electronic hyperlinks (created in the complete ITS section file) do not work in the collection of affected pages that follow this cover page. ITS SECTION 3.3A (RTS) INDEX OF AFFECTED PAGES ITS MARKUPS No change ITS JFDS No change ITS BASES MARKUPS No change ITS BASES JFDS No change CTS MARKUPS No change CTS DOCS PAGES: 164,165,166,167,168,169,170,171,172,173,174,175,176,177, 178,179,180,181,182,183,184,185,186& 187

I Rev.2Change C. lBVPS ISTS Conversion

                             . C1                                 3.3A RTS Instrumentation Enclosure 3 Changes to CTS measures for inoperable Power Range Neutron Flux- Low Trip Function channel(s) that address the potential for an RWFS in the new Applicable Modes.

The proposed changes are acceptable because they provide additional protection in the TS for an RWFS event. The proposed changes provide additional assurance that the plant will be operated in a safe manner when the potential for an RWFS event exists. Together with the new ITS LCO 3.1.10, "RCS Boron Limitations < E-00 OF," the proposed changes provide a more complete set of TS requirements (for both above and below an RCS temperature of 500 OF) that address the potential for an RWFS event. As such, the proposed changes do not adversely affect the safe operation of the plant. As the proposed changes include new operating restrictions (TS requirements) the changes are designated as more restrictive. Removed Detail Changes (LA) LA.1 (Type 3 - Removing Procedural Details for Meeting Tech Spec Requirements) CTS Surveillance 4.3.1.1.3 specifies that response time testing be performed for the RTS instrument Functions. The CTS surveillance includes details for performing the testing that specify "Each test shall include at least one logic train such that both logic trains are tested at least once per 36 months". The corresponding ISTS surveillance requirement specifies the same test be performed on a Staggered Test Basis. The CTS is revised to conform to the ISTS and the CTS details for performing response time testing on logic trains (replaced by the ISTS defined test term Staggered Test Basis) is moved into the bases for the response time test surveillance. This change also includes the editorial revisions made to the corresponding Unit 1 response time testing surveillance (not shown) to change the Unit 1 CTS wording from 'test' and "tested" to the more common ISTS descriptive terms of "verify" and 'verified" which is also consistent with the corresponding Unit 2 surveillance. The replacement of the procedural detail in the CTS surveillance requirement with the defined term (Staggered Test Basis) used in the ISTS is acceptable because the detailed CTS description of the required testing is not necessary to be included in the TS to provide adequate protection of public health and safety. The defined Test term used in the ITS is adequate to describe the required testing. The editorial changes (test to verify) made to the Unit I information being removed are acceptable because they do not affect the technical intent of the surveillance. The proposed ITS surveillance requirement continues to assure that response time testing be performed for the required instrument Functions in the same manner as before. The procedural details for implementing staggered testing on logic trains specified in the CTS is not required in order for the LCO operability requirements to be applicable and enforced. The ISTS defined test term used in place of the CTS requirement (i.e., Staggered Test Basis) provides a more complete and standardized method for implementing the required testing. The editorial change; to the Unit I material being removed are made solely to conform to the ISTS presentation of this information and with the current Unit 2 terminology. Also, the removal of the procedural detail is acceptable because this type of procedural detail will be adequately controlled in the ITS Bases consistent with the format and content of the ISTS. Changes to the Bases are controlled by the TS Bases Control Program BVPS Units 1 &2 Page 34 Revision :2,4/06 164

REMAINING DOC PAGES INCLUDED ONLY DUE TO REPAGINATION FROM CHANGE C-1 BVPS ISTS Conversion 3.3A RTS Instrumentation Enclosure 3 Changes to CTS KJW specified in the Administrative Controls Section of the TS. This program provides for the evaluation of changes to ensure the Bases are properly controlled and that prior NRC review and approval is requested when required. This change is designated as a less restrictive removal of detail change because procedural detail is being removed from the TS. LA.2 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) The Channels To Trip column in CTS Table 3.3-1 is deleted consistent with the ISTS. The corresponding ISTS RTS Table 3.3.1-1 does not include this information. The channels required to initiate an RTS function trip is described in the ITS Bases for each RTS Function. The proposed change is acceptable because the Channels To Trip column in CTS Table 3.3-1 contains information describing the design of the RTS which is not required to ensure the RTS system is maintained operable. The ISTS "Required Channels" specifies the necessary channels to maintain the RTS operable and the ISTS Actions provide the appropriate measures when the Required Channels are not met. RTS design features are also described in the UFSAR. Changes to the plant design as described in the FSAR are subject to the review requirements of 10 CFR 50.59. In addition, the requirements for the RTS design are also controlled by the required industry standards (IEEE 279, etc.), federal regulations (General Design Criteria), and specific NRC requirements and guidelines pertaining to the RTS. Changes to these plant design requirements are in turn controlled in accordance with the Quality Control Programs that are required by federal regulations (10 CFR 50.54). Also, this change is acceptable because the design description information will be retained within the ITS bases for each RTS Function and changes to the ITS Bases are controlled by the TS Bases Control Program specified in the Administrative Controls Section of the TS. This program provides for the evaluation of changes to ensure the Bases are properly controlled and that prior NRC review and approva is requested when required. This change is designated as a less restrictive removal of detail change because design detail is being removed from the TS. LA.3 (Type I - Removing Details of System Design and System Description, Including Design Limits) The CTS RTS Functions 12 and 13 (Loss of Flow) contain operational descriptions of how these Functions work. CTS Function 12, is effective above the P-8 interlock and provides a reactor trip with low flow in a single RCS loop. CTS Function 13 is effective above the P-7 interlock and below the P-8 interlock and provides a reactor trip with low flow in two RCS loops. However, these CTS Functions utilize the same instrumentation and setpoints. In the ISTS, the operation of this RTS Function above and below the P-8 interlock is described in the RTS bases and the ISTS only specifies a single low flow Function that requires the affected instrument channels operable above the P-7 interlock. The CTS is revised consistent with the ISTS. This changes the CTS by moving the description of the Function design and operation into the associated RTS bases. The proposed change is acceptable because the information removed from the CTS Table 3.3-1 is not required in the TS to ensure the affected RTS instrumentation is maintained operable. The TS still requires the affected instrumentation to be operable in the applicable modes or specifies the appropriate Action to be taken in a similar manner as before. The description of how this function is designed to operate above or below the P-8 interlock is not required in the TS to ensure the BVPS Units 1 & 2 Page 35 Revision :2, 4106 165

REMAINING DOC PAGES INCLUDED ONLY BVPS ISTS Conversion DUE TO REPAGINATION FROM CHANGE C-1 3.3A RTS Instrumentation Enclosure 3 Changes to C:TS appropriate RTS instrumentation is maintained operable. Also, this change is acceptable since changes to the ITS Bases are controlled by the TS Bases Control Program specified in the Administrative Controls Section of the TS. This program provides for the evaluation of changes to ensure the Bases are properly controlled and that prior NRC review and approval is requested when required. This change is designated as a less restrictive removal of detail change because design detail is being removed from the TS. LA.4 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) The allowable values specified for CTS Functions 11, 13, 14, 23d, and 23e on Table 3.3-1 contain design related descriptions that help to describe the allowable values (e.g., % of instrument span, % of indicated flow, or whether the setpoint is applied going up or down in power). The corresponding ISTS allowable values specified on Table 3.3.1-1 do not contain this additional descriptive information and simply present the allowable values as numerical values denoted as a percent. The CTS allowable values are revised to conform more closely to the corresponding ISTS allowable values. This changes the CTS by moving the design details associated with each allowable value listed above into the Bases description of the associated RTS Function. The proposed change is acceptable because it is necessary to conform more closely to the ISTS and because the design description associated with each affected allowable value is not required in the TS to ensure the operability of the associated RTS Function. The ITS continues to specify the setpoint in a simplified format and require that the associated RTS instrumentation be maintained operable. In addition, the design information associated with allowable values is documented in the RTS setpoint methodology referenced in the RTS bases. The setpoint methodology documents the design basis of the RTS Function allowable values, not the TS. In addition, the design information being moved from the affected allowable values specified in CTS Table 3.3-1 will be retained in the RTS bases for each of the associated RTS Functions. As such, this change is also acceptable because changes to the ITS Bases are controlled by the TS Bases Control Program specified in the Administrative Controls Section of the TS. This program provides for the evaluation of changes to ensure the Bases are properly controlled and that prior NRC review and approval is requested when required. This change is designated as a less restrictive removal of detail change because design detail is being removed from the TS. LA.5 (Type 3 - Removing Procedural Details for Meeting Tech Spec Requirements) CTS Action Note 6 modifying CTS Action 7 (applicable to the OverTemperature (OT) and OverPower (OP) RTS Functions) states; "An OPERABLE hot leg channel consists of: 1) three RTDs per hot leg, or 2) two RTDs per hot leg with the failed FRTD disconnected and the required bias applied." The corresponding ISTS Action Condition E does not contain this level of detail describing the system operability requirements. The CTS is revised to conform to the ISTS. This changes the CT'S by removing the descriptive detail contained in Note 6 and placing it in the ISTS bases for the OT and OP RTS Functions. The proposed change is acceptable because the information removed from the CTS Actions is not required in the TS to ensure the affected RTS instrumentation is maintained operable. The TS still requires the affected instrumentation to be operable in the applicable modes or specifies the appropriate Action to be taken ina BVPS Units 1 & 2 Page 36 Revision;!, 4106 166

BVPS ISTS Conversion 3.3A RTS Instrumentation Enclosure 3 Changes to CTS similar manner as before. The detailed operability description of this RTS Function is more appropriately contained in the bases description of the RTS Function. The ISTS typically contains this type of information in the bases. Also, this change is acceptable because changes to the ITS Bases are controlled by the TS Bases Control Program specified in the Administrative Controls Section of the TS. This program provides for the evaluation of changes to ensure the Bases are properly controlled and that prior NRC review and approval is requested when required. This change is designated as a less restrictive removal of detail change because operability details are being removed from the TS. LA.6 (Type 3 - Removing Procedural Details for meeting Tech Spec Requirements) Unit 2 only (Unit 1 does not have Action 44). Action 44 is applicable to the Unit 2 RTS Interlock Functions (i.e., P-6, P-8, P-9, etc.). CTS Action 44 specifies the following for an affected interlock; "determine by observation of the associated permissive annunciator window(s) that the interlock is in its required state for the existing plant condition." The corresponding ITS Action Conditions 0 and P require the following; "verify interlock is in required state for existing unit conditions." The CTS Action is revised to conform to the ISTS. This changes the CTS by removing the specific procedural guidance explaining how to verify the interlock status (by observation of the associated permissive annunciator window(s)) from the TS and placing this guidance in the associated TS Bases. The proposed change is acceptable because the information removed from the CTS Actions is not required in the TS to ensure the affected RTS instrumentation is maintained operable. The TS still requires the affected instrumentation to be operable in the applicable Modes or specifies the appropriate Action to be taken in a similar manner as before. The procedural detail for completing the required actions is more appropriately contained in the bases description of the Action. The ISTS typically contains this type of information in the bases. Also, this change is acceptable because changes to the ITS Bases are controlled by the TS Bases Control Program specified in the Administrative Controls Section of the TS. This program provides for the evaluation of changes to ensure the Bases are properly controlled and that prior NRC review and approval is requested when required. This change is designated as a less restrictive removal of detail change because procedural details are being removed from the TS. LA.7 (Type 3 - Removing Procedural Details for meeting Tech Spec Requirements) The refueling surveillance requirement on CTS Table 4.3-1 for the Manual Reactor Trip Function is modified by Note 10. CTS Note 10 states "The CHANNEL FUNCTIONAL TEST shall independently verify the OPERABILITY of the undervoltage and shunt trip circuits for the Manual Reactor Trip Function. The test shall also verify the OPERABILITY of the Bypass Breaker trip circuit(s)". The corresponding ISTS surveillance requirement does not contain this procedural detail for testing the Manual Reactor Trip Function. The CTS is revised to conform to the ISTS. This changes the CTS by moving the procedural instructions in CTS Note 10 to the bases for the affected surveillance requirement. The proposed change is acceptable because the information removed from the CTS Surveillance Requirement is not required in the TS to ensure the affected RTS instrumentation is maintained operable. The TS still requires the surveillance testing to be performed on the affected RTS Function. The procedural detail for completing the surveillance testing is more appropriately contained in the bases description of the Surveillance Requirement. The ISTS typically contains this type BVPS Units 1 & 2 Page 37 Revision 2,4/06 167

BVPS ISTS Conversion 3.3A RTS Instrumentation Enclosure 3 Changes to CTS of information in the bases. Also, this change is acceptable because changes to the ITS Bases are controlled by the TS Bases Control Program specified in the Administrative Controls Section of the TS. This program provides for the evaluation of changes to ensure the Bases are properly controlled and that prior NRC review and approval is requested when required. This change is designated as a less restrictive removal of detail change because procedural details are being removed from the TS. LA.8 (Type 3 - Removing Procedural Details for meeting Tech Spec Requirements) The CTS surveillance requirements for the Reactor Trip Breakers (RTBs) specified on Table 4.3-1 require a Channel Functional Test (CFT). The CTS CFT is modified by

     . a note (#11) that states "The CHANNEL FUNCTIONAL TEST shall independently verify the OPERABILITY of the undervoltage and shunt trip attachments of the Reactor Trip Breakers." The corresponding ISTS surveillance (SR 3.3.1.4) specifies a Trip Actuating Device Operational Test (TADOT) be performed on the RTBs. The ISTS surveillance does not contain the same note as the CTS CFT. The CTS is revised to conform to the ISTS. This changes the CTS by moving the CTS surveillance note into the ITS Bases associated with the surveillance. The change in defined test terms from CFT to TADOT was addressed in TS Section 1.0, Definitions.

This DOC is only intended to address moving the CTS note into the TS Bases. The proposed change is acceptable because the information removed from the CTS Surveillance Requirement is not required in the TS to ensure the affected RTS instrumentation is maintained operable. The TS still requires the surveillance testing to be performed on the affected RTS Function. The procedural detail for completing the surveillance testing is more appropriately contained in the bases description of the Surveillance Requirement. The ISTS typically contains this type of information in the bases. Also, this change is acceptable because changes to the ITS Bases are controlled by the TS Bases Control Program specified in the Administrative Controls Section of the TS. This program provides for the evaluation of changes to ensure the Bases are properly controlled and that prior NRC review and approval is requested when required. This change is designated as a less restrictive removal of detail change because procedural details are being removed from the TS. LA.9 (Type 3 - Removing Procedural Details for meeting Tech Spec Requirements) The CTS monthly CFT surveillance for the RTB Bypass Breakers specified in Table '..3-1 is modified by a note (#12) that states "Local manual shunt trip prior to placing breaker in service." The CTS Note provides a test Frequency "prior to placing the breaker in service" and procedural detail for performing the test "local manual shunt trip." The corresponding ISTS surveillance (SR 3.3.1.4) contains a note that specifies the surveillance must be performed on the RTB Bypass Breakers prior to placing the Bypass Breakers in service. The CTS surveillance requirement is revised to conform to the ISTS. This changes the CTS requirement by moving the procedural guidance for performing the surveillance (the inclusion of the local manual shunt trip) to the TS Bases associated with the surveillance. The proposed change is acceptable because the information removed from the C:TS Surveillance Requirement is not required in the TS to ensure the affected RTS instrumentation is maintained operable. The TS still requires the surveillance testing to be performed on the affected RTS Function. The procedural detail for completing the surveillance testing is more appropriately contained in the bases description of the Surveillance Requirement. The ISTS typically contains this type BVPS Units I &2 Page 38 Revision :, 4/06 168

BVPS ISTS Conversion 3.3A RTS Instrumentation Enclosure 3 Changes to CTS of information in the bases. Also, this change is acceptable because changes to the ITS Bases are controlled by the TS Bases Control Program specified in the Administrative Controls Section of the TS. This program provides for the evaluation of changes to ensure the Bases are properly controlled and that prior NRC review and approval is requested when required. This change is designated as a less restrictive removal of detail change because procedural details are being removed from the TS. LA.10 (Type 3 - Removing Procedural Details for meeting Tech Spec Requirements) The CTS refueling CFT surveillance for the RTB Bypass Breakers specified in Table 4 .3-1 is modified by a note (#13) that states "Automatic undervoltage trip." The CTS Note provides procedural guidance for performing the required test. The corresponding ISTS surveillance requirement does not contain a similar note. The CTS surveillance is revised to conform to the ISTS surveillance. This changes the CTS by moving the procedural guidance for performing the surveillance into the TS Bases associated with the surveillance. The proposed change is acceptable because the information removed from the CTS Surveillance Requirement is not required in the TS to ensure the affected RTS instrumentation is maintained operable. The TS still requires the surveillance testing to be performed on the affected RTS Function. The procedural detail for completing the surveillance testing is more appropriately contained in the bases description of the Surveillance Requirement. The ISTS typically contains this type of information in the bases. Also, this change is acceptable because changes to the ITS Bases are controlled by the TS Bases Control Program specified in the Administrative Controls Section of the TS. This program provides for the evaluation of changes to ensure the Bases are properly controlled and that prior NRC review and approval is requested when required. This change is designated as a less restrictive removal of detail change because procedural details are being removed from the TS. Administrative Changes (A) A.1 In the conversion of the Beaver Valley Power Station current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering or order, etc.) are made to obtain consistency with NUREG-1431, Rev. 2, "Standard Technical Specifications-Westinghouse Plants" (ISTS). Due to the large number of such changes, A.1 changes may not always be marked on each CTS page. Marked or unmarked, all A.1 changes are identified by a single annotation of A.1 at the top of the first page of each CTS. These changes include all non-technical modifications of requirements to provide consistency with the ISTS, including all significant format changes made to update the older NUREG-0452 Technical Specification presentation to the ISTS format. This type of change is also associated with the movement of requirements within the Technical Specifications and with changes made to the presentation of Technical Specifications requirements to combine the Unit I and 2 Technical Specifications into one document and highlight the differences between the Unit 1 and 2 requirements. BVPS Units 1 &2 Page 39 Revision ;, 4/06 169

BVPS ISTS Conversion 3.3A RTS Instrumentation Enclosure 3 Changes to CTS These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS requirements. A.2 The CTS 3/4.3.1 LCO statement, Applicability, and Actions are revised consistent with the ISTS format and presentation of this information. The CTS LCO statement is revised to eliminate the phrase "as a minimum". The LCO requirements for a system or component are the minimum requirements by definition of the term "Limiting Condition for Operation" (LCO) in 10 CFR 50.36. Therefore, the CTS term

     .as a minimum" is not necessary to describe the LCO requirement and has been deleted. The CTS LCO statement is revised to address the instrument Functions in ISTS Table 3.3.1-1 instead of the channels and interlocks in CTS Table 3.3-1. The Functions listed in ISTS Table 3.3.1-1 include the channels and interlocks referenced in the CTS LCO. The Applicability of CTS 3/4.3.1 is revised to refer to the ISTS Table 3.3.1-1 instead of the corresponding CTS Table. In addition, the CTS 314.3.1 Actions are revised consistent with the ISTS. In addition, the CTS 3/4.3.1 Action reference to Table 3.3-1 is replaced with the ISTS Condition A whi.h states the condition of one or more Functions (on Table 3.3.1-1) with one or more inoperable channels or trains. The ISTS Condition A Action provides the reference to the applicable Action Condition for each instrument Function listed on ISTS Table 3.3.1-1. The ISTS Condition A, effectively accomplishes the same thing as the CTS Action it replaces by referencing the Table containing the applicable Actions for each Function.

The proposed changes are acceptable because they are format and presentation changes necessary to conform to the LCO, Applicability, and Action requirements in the ISTS. The proposed changes to the format and presentation of the CTS do nDt represent technical changes. Therefore, the proposed changes are designated administrative. A.3 The CTS surveillance requirements 4.3.1.1.1, 4.3.1.1.2, and 4.3.1.1.3 contain the overall surveillance requirements for the RTS instrument functions. CTS 4.3 1.1.1 specifies Channel Checks, Channel calibrations and channel functional tests for ihe RTS Functions. CTS 4.3.1.1.2 describes the required testing for the RTS interlock functions and CTS 4.3.1.1.3 specifies response time testing be performed on the RTS Functions. In addition to the general requirements specified above, CTS Taible 4.3-1 contains the specific surveillance tests associated with each RTS instrument function. CTS Table 4.3-1 is a separate Table for surveillance requirements that duplicates much of the information already presented for each RTS function in CTS Table 3.3-1. The ISTS does not include general instrument surveillance requirements that correspond to CTS 4.3.1.1.1, 4.3.1.1.2, and 4.3.1.1.3. The ISTS contains a list of all the surveillance requirements associated with each of the RTS instrument Functions. Each ISTS RTS surveillance is numbered and states a specific surveillance test requirement and performance frequency. The ISTS lists the surveillance requirements by number that are applicable to each RTS instrument function on one master Table (ISTS 3.3.1-1). The single ISTS Table 3.3.1-1 contains all the requirements for each RTS function. The list of surveillance requirements applicable to each RTS instrument function on ISTS Table 3.3.1-1 is different in presentation and format from the CTS general surveillances (4.3.1.1.1, 4.3.1.1.2, and 4.3.1.1.3) and CTS surveillance Table 4.3-1, but contains similar information regarding the surveillance requirements associated with each RTS instrument Function. The CTS surveillance requirement presentation is revised lo conform to the ISTS. This changes the CTS by eliminating the general surveillance BVPS Units 1 & 2 Page 40 Revision 2, 4/06 170

BVPS ISTS Conversion 3.3A RTS Instrumentation Enclosure 3 Changes to C;TS requirements 4.3.1.1.1, 4.3.1.1.2, and 4.3.1.1.3 and the separate Surveillance Table (4.3-1). This change also includes the editorial revisions made to the corresponding Unit l response time testing surveillance (not shown) to change the Unit 1 CTS wording from 'demonstrated" to the more common ISTS descriptive term 'verified' which is also consistent with the corresponding Unit 2 surveillance. The proposed change is acceptable because it represents a change in the format; and presentation of the RTS surveillance requirements that is necessary to conform to the ISTS. The proposed changes consolidate the RTS surveillances associated with each instrument function and eliminate the repetition of requirements. Specifically, the elimination of the general surveillance requirements 4.3.1.1.1, 4.3.1.1.2, and 4.3.1.1.3 is acceptable because the technical requirements of the CTS surveillances are retained in the corresponding ISTS requirements listed in ISTS Table 3.3.1-1. The ISTS list of surveillances for each RTS Function includes a specific response time surveillance requirement assigned to each RTS Function that has response time limits associated with it. The assignment of individual response time verification requirements to each RTS Function that has response time limits associated with it assures the general response time requirement in CTS 4.3.1.1.3 is preserved without technical changes. In addition, any technical changes to the detailed surveillance requirements listed on CTS Table 4.3-1 are identified and discussed in the markup of that CTS Table. Therefore, the elimination of the general surveillances described in 4.3.1.1.1, 4.3.1.1.2, and 4.3.1.1.3 and re-organization of the CTS surveillance requirements is designated an administrative change. A.4 CTS surveillance 4.3.1.1.3 requires that response time testing be performed on the RTS functions and specifies that the testing be performed on "one channel per function such that all channels are verified at least once every N times 18 months where N is the total number of redundant channels in a specific reactor trip function as shown in the "Total No. of Channels" column of Table 3.3-1". The corresponding ISTS surveillance for response time testing requires that the testing be performed on a "Staggered Test Basis". The CTS is revised to conform to the ISTS. This changes the CTS by replacing the explanation of how each channel must be tested with a simple reference to the TS defined term of "Staggered Test Basis". The change to the Total Number of Channels column referenced in the CTS is discussed in another DOC that addresses the change from Total Number to Required channels. This change also includes the editorial revisions made to the corresponding Unit 1 response time testing surveillance (not shown) to change the Unit 1 CTS wording from 'tested" to the more common ISTS descriptive term "verified" which is also consistent with the corresponding Unit 2 surveillance. The proposed change is acceptable because the CTS requirement explaining how the response time of each channel should be verified is the same as verifying the channel response time on a staggered basis as defined in the ISTS. The proposed change is consistent with the format and presentation of this requirement in the ISTS. The ISTS requirements reference defined terms instead of repeating this information in each surveillance. The proposed change does not introduce a technical change to the CTS requirements. The specified interval remains the same. The proposed change simplifies the presentation of the surveillance BVPS Units 1 & 2 Page 41 Revision ;, 4/06 171

BVPS ISTS Conversion 3.3A RTS Instrumentation Enclosure 3 Changes to CTS requirement without changing the intent. Therefore, the proposed change is designated administrative. A.5 Unit 2 only. Unit I does not have footnote 1. CTS Surveillance 4.3.1.1.1 requires, that the RTS instrument functions be demonstrated operable in accordance with the requirements of Table 4.3-1. The CTS surveillance is modified by footnote 1. Footnote I states "For the automatic trip logic, the surveillance requirements shall be the application of various simulated input combinations in conjunction with each possible interlock logic state and verification of the required logic output including, as a minimum, a continuity check of output devices." The corresponding ISTS RTS surveillance requirements do not include a similar footnote. In the ISTS, the corresponding surveillance test requirements are identified in the defined terms of Section 1.0 of the TS. Individual ISTS surveillance requirements reference the defined terms of TS Section 1.0 as necessary. The CTS is revised to conform to the ISTS. This changes the CTS by moving the description of the test requirements for automatic trip logic to the definition section of the TS. The specific definition that defines this type of testing is the ISTS ACTUATION LOGIC TEST. Additionally, Ihe CTS surveillance for automatic trip logic is revised to reference the performance of an ACTUATION LOGIC TEST (as defined in Section 1.0 of the TS). The proposed change is acceptable because the change only re-organizes the existing CTS requirements to conform to the ISTS. The placement of the affected test requirements in a defined term in Section 1.0 of the TS does not introduce a technical change to the CTS and retains the required testing within the TS. Therefore, the proposed change is designated administrative. A.6 The column headings for Functional Unit, Applicable Mode, and Action in CTS Table 3.3-1 are revised to conform to the corresponding column headings in ISTS Table 3.3.1-1. In the ISTS, the corresponding column headings are Function, Applicable Mode or Other Specified Condition, and Condition. The proposed change is acceptable because the change in column headings on the RTS table represents a change in presentation only that is necessary to conform to the ISTS. Changing Functional Unit to Function is a change in title only that does not introduce a technical change to the CTS requirements. Adding "or other specified condition" to the CTS column heading for Applicable Mode provides a clarification that encompasses the CTS use of footnotes to modify the applicable Modes with additional conditions. For example, the Applicable Mode for CTS Functional Unit 1 is modified by Footnote 3 which places the following condition on certain Modes; "with the reactor trip system breakers in the closed position and the control rod drive system capable of rod withdrawal." As such, the addition of "or other specified condition" to the CTS Applicable Mode column is consistent with the CTS use of notes to modify the applicability with additional conditions and does riot represent a technical change to the CTS. Changing the CTS Table 3.3-1 column heading "Action" to "Condition" is necessary due to the format of ISTS Actions. The ISTS Actions are expressed in three separate parts i.e., a specific Condition (e.g., one channel inoperable) with an associated Required Action (e.g., place the channel in trip) and a Completion Time for that Action (e.g., 6 hours). Although the CTS Actions contain the separate components used in the ISTS example above, in the CTS, the components are combined together in a paragraph or two and simply labeled "Action". These components are physically separated in the ISTS presentation of Actions. The separation of these components provides better BVPS Units I & 2 Page 42 Revision :2, 4/06 172

BVPS ISTS Conversion 3.3A RTS Instrumentation Enclosure 3 Changes to CTS human factoring of the TS and allows the user to quickly identify the applicable condition and determine the requirements associated with it. As such, the change from "Action" heading" to "Condition" heading is purely one of format and presentation of the same information. The proposed changes do not involve technical changes to the CTS and are designated administrative changes. A.7 The CTS Table 3.3-1 table heading titled "Total Number of Channels" is revised to be 'Required Channels" consistent with the corresponding ISTS Table 3.3.1-1 Table headings. In addition, the Minimum Channels Operable column of CTS Table 3.3-1 is deleted consistent with the content of the corresponding ISTS Table 3.3.1-1. The proposed change is acceptable because the revisions described above do not result in technical changes to the number of instrument channels required operatle or the applicable Actions when the required channels are not met. All Actions for an inoperable instrument channel in the ISTS key off the Required Channels specified for the affected function. The new ISTS Conditions assigned to each Instrument Function will specify the appropriate action when one or more "Required" instrument channels are inoperable. The minimum channels column used in the CTS to identify the number of operable channels for which continued operation is permissible is no longer used or required in the TS. The ISTS Actions encompa5ss the concept of the minimum required channels, i.e., the plant would be required to be placed in a Mode or Condition outside the Applicable Mode when the minimum number of channels for continued operation is not met. The ISTS Actions accomplish this without a specific reference to the minimum required channels. As such the proposed changes described above do not introduce a technical change to the CTS requirements. In addition, any technical changes to the CTS Actions associated with the RTS instrument functions are identified in the markup of those Actions and addressed in the DOCs associated with the changes to the CTS Actions. This DOC is intended to address the reformat of the CTS Table 3.3-1 to conform to the corresponding ISTS Table 3.3.1-1. Therefore, this change is designated administrative. A.8 The CTS Table 3.3-1 Allowable Value column title is revised by the addition of Unit specific designations. The corresponding ISTS Table does not include Unit specific designations. However, the BVPS specific implementation of the ISTS includes both Unit 1 and Unit 2 requirements in one set of TS. As each BVPS Unit may have different setpoints, the resulting BVPS ITS Table 3.3.1-1 is proposed with separate Unit I and Unit 2 Allowable Value columns for each RTS function. The proposed change is acceptable because the CTS Allowable Values are not changed. The proposed change merely combines the Unit 1 and Unit 2 Allowable Values into the same ITS RTS Instrument Function Table. As such, the proposed change is designated administrative. A.9 CTS Functional Unit 6b (Source Range Neutron Flux without rod withdrawal capability) on CTS Table 3.3-1 is modified by two footnotes (8 and 9). CTS footnote 8 states that "Alternate detectors may only be used for monitoring purposes Without Rod Withdrawal Capability until detector functions are modified to permit equivalent alarm and trip functions." Footnote 8 applies to Unit 2 only. CTS Unit 2 footnote 9 (footnote 8 for Unit 1) states "In this condition, source range Function does not provide reactor trip but does provide indication." In addition, CTS Table 4.3-1 contains BVPS Units I & 2 Page 43 Revision ;', 4/06 173

BVPS ISTS Conversion 3.3A RTS Instrumentation Enclosure 3 Changes to CTS Note 15 which modifies the surveillance requirements associated with "Alternate" neutron flux detectors used for indication purposes. CTS Functional Unit 6b specifies requirements for source range indication only and contains no reactor trip requirements. This CTS Function is assigned a specific Action (5) that is associated only with this RTS Function. The Action is modified by footnote 7 which is also specific to this RTS Function. The ISTS RTS requirements do not address indication only functions. The corresponding ISTS RTS TS contains requirements for reactor trip instrumentation only. The CTS is revised consistent with the ISTS. This changes the CTS by moving the source range neutron flux instrument indication requirements (including all associated notes form Tables 3.3-1 and 4.3-1 and Action 5) out of the RTS TS and into a separate source range indication TS (ITS 3.3.8). The proposed change is acceptable because the CTS requirements are moved within the TS without introducing a technical change to the requirements. The affected CTS requirements do not address an RTS function and do not belong in the RTS TS. The ISTS contains a generic Boron Dilution Protection System (BDPS) LCO, ISTS 3.3.9. Although the BDPS system addressed by ISTS 3.3.9 is not part of the BVPS design, it contains some requirements that are similar to the BVPS CTS source range indication requirements. As such, ISTS 3.3.9 (BVPS ITS 3.3.8) will be revised to address the CTS source range indication requirements so that they may continue to be specified in the TS separate from the reactor trip system requirements. The proposed change makes the CTS more closely conform to the ISTS presentation of these requirements. The proposed change only moves requirements within the TS and is therefore, designated administrative. A.10 Unit 2 only. The

footnote in CTS Table 3.3-1 provides an explanation of the acroymn RTP ( Rated Thermal Power) used in some of the Allowable Values specified in the Table. The corresponding ISTS Table 3.3.1-1 does not include this footnote to explain RTP. The CTS is revised to conform to the ISTS. This changes the CTS by eliminating the footnote explanation of the acroymn RTP from CTS Table 3.3-1. In addition, this change addresses the removal of the
from each place it is used in CTS Table 3.3-1 to reference the RTP footnote.

The proposed change is acceptable because the change is necessary to conform to the ISTS format and presentation conventions. In the ISTS, the term Rated Thermal Power (including the acoynm RTP) is a defined term in Section 1.0 of the TS. The defined term, including acroynm, is explained once in the front matter of the ISTS. The ISTS then utilizes the acroynms of defined terms throughout the TS without explaining the acroynms each time they are used. The proposed change does not introduce a technical change to the CTS and is made to conform to the ISTS format and presentation conventions for defined acroynms. Therefore, the proposed change is designated administrative. A.1 1 The CTS Table 3.3-1 Source Range Neutron Flux Function title "With Rod Withdrawal Capability" is deleted. The corresponding ISTS Function does not use this Function title to identify the source range instrumentation. In the ISTS, this information is contained in the plant condition specified in the Applicability for the Source Range RTS Function. The CTS is revised consistent with the ISTS. This changes the CTS by eliminating a separate reference to the specified plant condition of the Applicability for this RTS Function. The plant condition of "with rod withdrawal capability" continues to be specified in the Applicability for Modes 3, 4, and 5 (CTS Note 3). BVPS Units 1 & 2 Page 44 Revision 2, 4/06 174

BVPS ISTS Conversion 3.3A RTS Instrumentation Enclosure 3 Changes to C;TS The proposed change is acceptable because it is necessary to conform to the IS-S presentation of this information and because it does not introduce a technical change to the CTS requirements. The requirement for the source range instrumentation to be operable with rod withdrawal capability is retained in the Applicability requirements for the source range instrumentation consistent with th location of this information in the ISTS. The affected CTS Function title is a specific plant condition for which the RTS function must be applicable and therefore, is part of the Applicability for the Function. As such, the proposed change only affects the presentation of the RTS requirements and conforms to the ISTS. The proposed change is designated administrative as it does not introduce a technical change to the CTS requirements. A.12 Unit 2 only. The Allowable Value for CTS Functional Unit 9 (Pressurizer Pressure-Low) on Table 3.3-1 is modified by a ** footnote that specifies the time constants associated with the Allowable Value. In addition to the time constants (which are part of the Allowable Value) the footnote also specifies that "Channel calibration shall ensure that these time constants are adjusted to those values." The corresponding ISTS Functions in CTS Table 3.3.1-1 do not include footnotes with requirements for the channel calibration of the function. The ISTS includes the requirement to verify the time constants associated with a Function in the Channel Calibration Surveillance Requirement for that Function. The ISTS includes notes in the channel calibration surveillance that clarify or modify the requirements for that surveillance. The CTS is revised to conform to the ISTS. This changes the CTS by moving the note affecting channel calibration from the list of functions on CTS Table 3.3-1 into the RTS channel calibration surveillance requirement. The proposed change is acceptable because the change is necessary to conform to the ISTS presentation of this information, the change does not result in a technical change to the CTS requirement, and because the CTS requirement is retained within the TS. The proposed change simply re-organizes the CTS requirement consistent with the ISTS. As the proposed change does not introduce a technical change to the CTS, it is designated administrative. A.1 3 The CTS Loss of Flow Functions 12 and 13 on CTS Table 3.3-1 have been combined into one Function, ITS Function 10, Reactor Coolant Flow - Low, consistent with the ISTS. CTS Function 12, is effective above the P-8 interlock (30% RTP) and provides a reactor trip with low flow in a single RCS loop. CTS Function 13 is effective above the P-7 interlock (10% RTP) and below the P-8 interlock (30% RTP) and provides a reactor trip with low flow in two RCS loops. However, these CTS Functions utilize the same instrumentation that is required operable from 10% to 100% RTP. As such, the corresponding ISTS Function is presented as a single RTS Function, that requires the affected instrument channels to be operable above the P-7 interlock (10% RTP). The CTS is revised to be consistent with the ISTS. This changes the CTS by combining Functions 12 and 13 and eliminating essentially redundant information from CTS Table 3.3-1. The proposed change is acceptable because it is necessary to conform to the presentation of this information in the ISTS and because it does not introduce a technical change to the CTS requirements. The combination of the two separate RTS functions into one Function is possible because the instrumentation used for each of the affected CTS functions is the same. In addition, the applicable Action and setpoints are also the same. In the CTS, this instrumentation was divided into BVPS Units I & 2 Page 45 Revision :2,4/06 175

BVPS ISTS Conversion 3.3A RTS Instrumentation Enclosure 3 Changes to CTS two separate functions to better describe the operation of the function above and below the P-8 permissive (one or two loop trip). In the ISTS, this description of channel operation is retained in the bases description for this RTS Function (see associated LA DOC). The ISTS simplifies the presentation of this RTS function arid retains the essential requirement that the instrument channels be operable above P-7 or the appropriate Action must be taken. Regardless of the one or two RCS locp trip operation of the Function, all channels are required operable above the P-7 interlock. The affected channels, including Allowable Values, are not changed and continue to be required operable above P-7 the same as the CTS. The proposed change only simplifies the presentation of these requirements. The proposed change is designated administrative because it does not introduce a technical change to the CTS requirements. A.14 The CTS Table 3.3-1 contains Function 21 for the Reactor Trip Breakers (RTBs). This CTS function includes Actions specifically for the undervoltage and shunt trip mechanisms associated with the RTBs as well as Actions for an RTB inoperable for other reasons. The corresponding ISTS Table 3.3.1-1 contains separate line item Functions for the RTBs and the RTB undervoltage and shunt trip mechanisms. The ISTS assigns the specific Actions for the undervoltage and shunt trip mechanisms to that Function line item and the Actions applicable to the RTB Function to the RTE Function line item. The CTS is revised to conform to the ISTS. This changes the CTS by creating a new separate Function line item for undervoltage and shunt trip mechanisms in CTS Table 3.3-1. This Doc addresses the change that creates a separate line item function for the RTB undervoltage and shunt trip mechanisms. Other changes to the RTS RTB Functions are addressed in other DOCs. The proposed change is acceptable because it is necessary to conform to the IS-FS presentation of this information and because the separation of these items into two RTS Functions does not introduce a technical change to the CTS requirements. The new RTB undervoltage and shunt trip mechanism Function is required operable in the same Modes as before and if inoperable requires the same Actions as before. The separation of these RTB Functions serves to clarify the different Action Condition and Completion Time applicable for the RTB undervoltage and shunt trip mechanisms. The proposed change only represents a change in the presentation of this information. As such, the proposed change is designated administrative. A.15 The CTS allowable value for the RTS P-13 Function is expressed as "% RTP turbine first stage pressure equivalent". The corresponding ISTS P-1 3 Function is simply expressed as "% turbine power'. The CTS is revised to conform to the ISTS. This changes the CTS by expressing the P-13 function allowable value as % turbine power instead of % RTP turbine first stage pressure equivalent. The proposed change is acceptable because the ISTS allowable value is a simplified form of the CTS allowable value and does not represent a technical change to the CTS. In addition, the CTS explanation that the turbine power is "RTP turbine first stage pressure equivalent" is being retained in the corresponding bases discussion of this Function to further explain the measured parameter. The P-13 Function is a measure of turbine power used together with a measure of reactor power (P-10) to provide the P-7 interlock function (low power permissive). At approximately 10% RTP or turbine power the P-7 interlock enables several RTS Functions. As such; the ISTS naming convention for the P-13 interlock allowable value is acceptable and more clearly labels the parameter as related to turbine BVPS Units 1 & 2 Page 46 Revision ,%4/06 176

BVPS ISTS Conversion 3.3A RTS Instrumentation Enclosure 3 Changes to CTS power. The proposed change is designated administrative as the change is not intended to introduce a technical change to the CTS. A.16 CTS Note 3 in Table 3.3-1 states the following; " With the reactor trip system breakers in the closed position and the control rod drive system capable of rod withdrawal." This CTS Note is 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 removing the reactor trip breakers (RTBs) from the applicability requirement and adding the requirement to the applicability of whenever one or more rods are not fully inserted. This DOC is intended to address the elimination of the RTBs from the CTS note. The CTS Applicability requires the associated RTS Functions to be operable when the possibility of an inadvertent or uncontrolled rod withdrawal accident exists. The associated RTS Functions provide reactor trip actuations to mitigate the consequences of a rod withdrawal event. In order to assure the availability of the required protection Functions the CTS Applicability requires the associated RTS Functions to be operable whenever the RTBs are closed and when the rod control system is capable of rod withdrawal. However, the possibility of rod withdrawal may be precluded if the rod control system is not capable of rod withdrawal (the RTBs must be closed for the rod control system to be capable of rod withdrawal). The note need only specify that th a rod control system is capable of rod withdrawal to adequately address the condition where the RTS Functions are required operable. A specific reference to the RTBs in the note is not required as the capability of the rod control system to withdraw rods is dependent on the RTB breaker position. As such, this portion of the proposed change to CTS Note 3 is acceptable as it simplifies the CTS note and does not introduce a technical change to the intent of the CTS note. As the proposed change does not introduce a technical change to the CTS, it is designated administrative. A.17 The CTS Actions specify "With the number of channels OPERABLE one less thar required by the Minimum Channels OPERABLE requirement...." or "With the number of channels OPERABLE one less than required by the Total Channels OPERABLE requirement...." These CTS Actions are based on the minimum channels operable or total channels specified in CTS Table 3.3-1 for each RTS Function. The ISTS does not contain a "minimum channels operable" or "total channels" requirement. The ISTS uses the single term "Required" channels or trains for all RTS Functions. In the ISTS, all Actions are based on one or more "Required" channels or trains inoperatle. The ISTS Required Channels is equivalent to the CTS Total Channels requirement. The CTS is revised to conform to the ISTS. This changes the CTS by eliminating the Action references to the Minimum or Total channels operable and simply specifying "one channel inoperable". In some cases, the ITS Action Conditions are specific to a single RTS Function and may contain the Function name (e.g., one Turbine Trip channel inoperable). In addition, the ISTS Action Conditions may identify the RTS Function by "train" instead of by "channel" where applicable (e.g., the automatic trip logic RTS Function is not a channel and is referred to by trains of automatic trip logic). The proposed change is acceptable because the number of channels (or trains) on which the CTS Actions are based is not changed. The ISTS Required Channels is equivalent to the CTS Total Channels requirement. In cases where the CTS Actiol is based on the Minimum Channels requirement, the Minimum Channels requirement is BVPS Units 1 & 2 Page 47 Revision 2, 4/06 177

BVPS ISTS Conversion 3.3A RTS Instrumentation Enclosure 3 Changes to CTS equivalent to the CTS Total Channels Requirement. Therefore, the ISTS use of Required Channels simplifies the CTS presentation of this information without introducing a technical change to the number of channels used for initiating an Action requirement. The use of the term trains in the ISTS for certain Functions is also acceptable as it more accurate identifies the associated RTS Functions that are designed with train A and train B systems and that are technical not instrumentation channels (e.g., automatic actuation logic). The CTS Minimum Channels requirement is also used within an Action statement where the continued operation of the plant is permitted "providing the Minimum Channels operable requirement is met". The ISTS does not use this convention tc indicate where continued operation is permitted. If an Action exists in the ISTS for a specific Condition, operation may continue in accordance with that Action. However, if an Action is not included in the ISTS for a specific condition (e.g., an RTS Function with two required channels inoperable), LCO 3.0.3 must be entered and the plant placed in a condition where the RTS Function is no longer required. Therefore, the proposed change to eliminate the phrase "operation may continue" from the CTS Actions is also acceptable. The ISTS format, presentation and conventions of use have eliminated the need for the CTS Action references to "Total Channels" or "Minimum Channels" and such phrases as "operation may continue" without introducing technical changes to the number of channels required to be operable by the RTS TS or the conditions under which continued operation is permitted. As the proposed changes involve revisions to the format and presentation of the CTS Action requirements without introducing technical changes to those requirements, the changes are designated administrative. A.18 CTS Action 2, assigned to the Power Range Neutron Flux RTS Functions 2, 3, and 4 in CTS Table 3.3-1, is comprised of two parts (a and b). CTS Action 2a addresses the Power Range High Neutron Flux channels and CTS Action 2b addresses all the other Power Range Neutron Flux channels. CTS Action 2 is modified by footnote 4, applicable to both parts of the Action and footnote 5 which is applicable only to CTS Action 2a. The corresponding ISTS Actions are contained in Conditions D and E. The ISTS Conditions contain the same notes as the CTS but in the ISTS Note format with the Actions not as footnotes. ISTS Condition D corresponds to CTS Action 2a for the Power Range Neutron Flux High channels and ISTS Condition E corresponds to CTS Action 2b for the other Power Range Neutron Flux channels. The CTS is revised to conform to the ISTS presentation of these Action requirements. This changes the CTS by dividing CTS Action 2 into separate ISTS Action Conditions (E) and E) and reformatting the CTS Actions into the ISTS format. The technical changes made to CTS Action 2 are addressed in the DOCs associated with that CTS Action. This DOC addresses the presentation changes to CTS Action 2. The proposed change is acceptable because no technical changes are being made to CTS Action 2. The CTS Action is simply reformatted into the separate ISTS Action conditions described above. As such, the proposed change is designated administrative. A.19 The Source Range RTS Function in CTS Table 3.3-1 is assigned Action Statement

4. CTS Action statement 4 is comprised of parts a, b, and c. CTS Action 4a is identified as applicable to Mode 2 below P-6, CTS Action 4b is identified as applicable to Modes 3, 4, and 5, and CTS Action 4c is identified as applicable to Mode 2 below P-6 and Modes 3, 4, and 5. The Corresponding ISTS Action BVPS Units I & 2 Page 48 Revision !, 4/06 178

BVPS ISTS Conversion 3.3A RTS Instrumentation Enclosure 3 Changes to CTS Conditions are H, I, and J. ISTS Condition H is identified as applicable to Mode 2 below P-6, ISTS Condition I is identified as applicable to Mode 2 below P-6 and Modes 3, 4, and 5, and ISTS Condition J is identified as applicable to Modes 3, 4, and 5. The CTS Actions are revised to conform to the ISTS Action Conditions. This changes the CTS by reformating the single CTS Action statement 4 into 3 separate ISTS Action Conditions. This DOC is only intended to address the reformat of the CTS Action into separate ISTS Conditions. Any technical changes to the CTS Action are addressed in other DOCs. The proposed change is acceptable because the separate ISTS Action Conditions correspond directly to parts a, b, and c of CTS Action 4 and the proposed change only represents a change in format and presentation of the CTS Action. The Actions associated with the Source Range RTS Function remain essentially the same. The ISTS Table 3.3.1-1 format assigns the Action Conditions by Applicable Mode such that ISTS Conditions H and I are assigned to Mode 2 below P-6 and ISTS Conditions I and J are assigned to Modes 3, 4, and 5. The assignment of these Conditions in the ISTS Table 3.3.1-1 effectively corresponds to the CTS assignment of Action Statement 4 parts a, b, and c. As the proposed change only involves the format and presentation of the CTS requirements it is designated administrative. A.20 CTS Action 7b provides the allowance that "the inoperable channel may be bypassed for up to 4 hours for surveillance testing of other channels per Specification 4.3.1.1.1." The corresponding ISTS Action Condition Note (in Conditions E, L, and K) states that "the inoperable channel may be bypassed for up to 4 hours for surveillance testing of other channels." The CTS is revised to conform to the ISTS. This changes the CTS by eliminating the reference to Specification 4.3.1.1.1 from the CTS Action 7b. CTS Specification 4.3.1.1.1 states the surveillance requirements applicable to the RTS Functions. The surveillance requirements of 4.3.1.1.1 are such that they may have to be performed on the affected RTS instrumentation while operating in the applicable Mode where the RTS Function is required operable. Surveillance testing of instrument channels requires that the channel be placed in the trip condition at some point during testing to verify correct channel operation. If the affected RTS Function already has an inoperable channel in the trip condition, placing a second channel in trip for verification during testing may result in a reactor trip. Failure to perform the required surveillances within the specified interval plus any applicable extensions would require that the affected RTS channel be declared inoperable (per the rules of TS). Declaring a channel inoperable due to a missed surveillance will also result in a plant shutdown if another RTS channel in that Function was already inoperable (LCO 3.0.3 applies to two inoperable channels in the same RTS Function). Therefore, the CTS contains the allowance to bypass inoperable channels for a limited time to allow the required surveillance testing to proceed on the remaining operable channels in an RTS Function and thus to allow for continued operation of the plant. The proposed change is acceptable because it accomplishes the same thing as the CTS requirement. The inclusion of a reference to the specific surveillance (4.3.1.1.1) is not required to ensure the remaining channels of an RTS Function are properly tested with the inoperable channel bypassed. The ISTS Action Note accomplishes: this task with a simpler presentation and without introducing a technical change to the BVPS Units 1 & 2 Page 49 Revision 2.,4/06 179

BVPS ISTS Conversion 3.3A RTS Instrumentation Enclosure 3 Changes to CTS CTS requirements. The proposed change is designated administrative because no technical change is made to the CTS requirements. A.21 CTS Action 7 requires that the affected RTS channel be placed in the trip condition in 6 hours. CTS Action 7 is common to several RTS Functions. The corresponding ITS Action Conditions (E, K, and L) contain the same Action to place the channel in trip in 6 hours plus an additional default Action that is applicable if the Action to place the channel in trip can not be met. The ISTS default Action requirement is based on the applicable Mode of the RTS Function and serves to remove the plant from the applicable Mode of the affected RTS Function if the Action to place a channel in trip is not met. As such, the corresponding RTS Functions in the ISTS have different Action Conditions assigned to them depending on the applicable Mode of the RTS Function. The default Action of ISTS Condition E requires that the plant be placed in Mode 3 and is applicable to RTS Functions that are required operable in Modes I and 2. The default Action of ISTS Condition K requires that the power be reduced to < P-7 and is applicable to RTS Functions that are required operable at power levels 2 P-7. The default Action associated with ITS Condition L requires that the power be reduced lo < P-9 and is applicable to the Turbine Trip RTS Functions that are required operable at power levels 2 P-9. The CTS action 7 is split to conform to ISTS Actions E, K, and L. This changes the CTS by assigning different Actions to the RTS Functions depending on the applicable Mode of the Function. The specific technical changes to CTS Action 7 to convert to ISTS Conditions E and K are discussed in the DOCs associated with Action 7. This DOC is only intended to address the presentation difference that results from the technical changes introduced by the new ISTS Conditions. The proposed change assigns specific Actions to each RTS Function that are tailored to better fit the Mode of applicability for each of the Functions. The proposed change is acceptable because the change is necessary to conform to tlhe ISTS format and presentation of Action Conditions and because the change K4,Jfr addressed in this DOC does not include a technical change to the CTS Actions. As this change addresses the format and presentation of the Actions it is designated administrative. A.22 CTS Action 1 provides the allowance that "one channel may be bypassed for up to 4 hours for surveillance testing per Specification 4.3.1.1.1 provided the other channel is operable." The corresponding ITS Action Condition M Note states that "one train may be bypassed for up to 4 hours for surveillance testing provided the other train is operable." The CTS is revised to conform to the ITS Condition Note. This changes the CTS by eliminating the reference to Specification 4.3.1.1.1 from the CTS Action 1. The change in terminology from channel to train is addressed in another DOC. CTS Specification 4.3.1.1.1 states the surveillance requirements applicable to the RTS Functions. The surveillance requirements of 4.3.1.1.1 may have to be performed on the RTS instrumentation while operating in the applicable Mode where the RTS Function is required operable. Surveillance testing of instrument channels or trains requires that the channel or train be placed in the trip condition at some point during testing to verify correct channel operation. In the case of RTS inputs such as the SI input, the input is a train A and train B function such that a trip from either train would actuate a reactor trip. Therefore, the CTS contains the allowance to bypass a channel for a limited time to allow the required surveillance testing to be performed without causing a reactor trip. BVPS Units 1 & 2 Page 50 Revision ;, 4/06 180

BVPS ISTS Conversion 3.3A RTS Instrumentation Enclosure 3 Changes to CTS The proposed change is acceptable because it accomplishes the same thing as thE! CTS requirement. The inclusion of a reference to the specific surveillance (4.3.1.1.1) is not required to ensure the RTS Function is properly tested without causing a reactor trip. The ISTS Action Note accomplishes this task with a simpler presentation and without introducing a technical change to the CTS requirements. The proposed change is designated administrative because no technical change is made to the CTS requirements. A.23 CTS Action 40b provides the allowance that "one channel may be bypassed for up to 2 hours for surveillance testing per Specification 4.3.1.1.1, provided the other channel is operable." The corresponding ITS Action Condition N Note 1 states that "one train may be bypassed for up to 2 hours for surveillance testing provided the other train is operable." The CTS is revised to conform to the ITS Condition Note. This changes the CTS by eliminating the reference to Specification 4.3.1.1.1 from the CTS Action 40b. The change in terminology from channel to train is addressed in another DOC. CTS Specification 4.3.1.1.1 states the surveillance requirements applicable to the RTS Functions. The surveillance requirements of 4.3.1.1.1 may have to be performed on the RTS instrumentation while operating in the applicable Mode where the RTS Function is required operable. Surveillance testing of instrument channels or trains requires that the channel or train be placed in the trip condition at some point during testing to verify correct channel operation. The CTS and ITS Actions are applicable to the reactor trip breakers (RTBs). In the case of the RTBs a trip from either RTB would actuate a reactor trip. Therefore, the CTS contains the allowance to bypass a channel for a limited time to allow the required surveillance testing to be performed without causing a reactor trip. The proposed change is acceptable because it accomplishes the same thing as the CTS requirement. The inclusion of a reference to the specific surveillance (4.3.1.1.1) is not required to ensure the RTS Function is properly tested without causing a reactor trip. The ISTS Action Note accomplishes this task with a simpler presentation and without introducing a technical change to the CTS requirements. The proposed change is designated administrative because no technical change is made to the CTS requirements. A.24 CTS Action 40 contains different Action requirements for the reactor trip breakers (RTBs) and for the undervoltage and shunt trip features that comprise the diverse tip mechanisms of the RTBs. The corresponding ISTS action Conditions N and Q separate the Actions applicable to the RTBs and the undervoltage and shunt trip mechanisms into two Action Conditions (Condition N for one inoperable RTB and Condition Q for one trip mechanism inoperable for one RTB. In addition, the CTS Action 40 allowances for bypassing the RTBs are retained as two notes in ITS Action Condition N for the RTBs. The CTS is revised to conform to the ISTS presentation of these Action requirements. This changes the CTS by separating the Actions for the RTBs from the Actions for the individual trip mechanisms. This DOC is only intended to address the re-organization of the CTS Action to conform to the ISTS. The other DOCs associated with CTS Action 40 address other changes to that Action. The proposed change is acceptable because it is necessary to conform to the ISTS and because it provides a more clear set of Actions by separating the CTS Action requirements into two separate Action Conditions. In addition, the proposed change is acceptable because it does not introduce a technical change to the CTS requirements. The proposed change only involves revising the format and BVPS Units I & 2 Page 51 Revision 2, 4/06 181

BVPS ISTS Conversion 3.3A RTS Instrumentation Enclosure 3 Changes to CTS presentation of the Action requirements and Notes within the Actions. As such, the proposed change is designated administrative. A.25 Unit 1 only. The Unit I CTS RTS Function 14, Steam Generator (SG) Water Level - Low - Low, is modified by reference to a "Loop Stop Valves Open" permissive. The corresponding ISTS and Unit 2 CTS RTS Functions do not contain a similar reference. The Unit 1 CTS is revised to conform to the ISTS and Unit 2 CTS. This. changes the Unit 1 RTS Function 14 by deleting the reference to the "Loop Stop Valves Open" permissive. The Unit I RTS Function for low SG level trip was originally designed with a permissive interlock with the RCS loop stop valves. The original intent of this design was to defeat the SG low level trip for a SG when the associated RCS loop was removed from service. This design would permit the water level in a SG removed from service to be below the reactor trip setpoints without actuating a reactor trip and allow continued plant operation with only two RCS loops in service. BVPS never licensed two loop operation and the permissive interlock with the RCS loop stop valves was removed by a plant design change. In addition, the CTS and proposed ITS require that all three RCS loops be in operation when the SG Water level RTS trip Function is required operable. As such, the reference to the permissive interlock with the RCS loop stop valves no longer has a technical impact in the TS. The proposed change to delete the reference to this permissive interlock from the Unit 1 RTS TS is acceptable because the permissive interlock with the RCS loop stop valves is no longer part of the Unit 1 design and because the TS require that all three RCS loops be in service when this RTS Function is required operable. The proposed change makes the CTS conform more closely to the current plant design and does not result in a technical impact to the CTS requirements. As such, the proposed change is designated administrative. A.26 The Unit 1 and Unit 2 BVPS Units have different Turbine Trip RTS Functions. The Unit I Function 18.a is Auto Stop Oil Pressure. The Unit 2 Function 18.A is Emergency Trip Header Low Pressure. The corresponding ISTS Turbine Trip Function simply lists Low Fluid Oil Pressure. These Unit 1 and Unit 2 CTS RTS Functions are revised into a single RTS line item similar to the ISTS. This changes the CTS by combining the Unit 1 Auto Stop Oil Pressure and the Unit 2 Emergency Trip Header Pressure under one RTS "Low Pressure" Turbine Trip Function item on ITS Table 3.3.1-1. The Unit I and Unit 2 Turbine Trip RTS Functions monitor and actuate from different turbine parameters with different setpoints. Although the parameter monitored for this Function is different for each Unit, the RTS Function is the same, i.e., provide Ihe necessary turbine trip signal to the RTS to actuate a reactor trip. The proposed B\/PS ITS consists of a single TS for both Units. As the number of instrument channels, Applicable Modes, and surveillance requirements are the same, these two RTS Functions may be combined into a single RTS Function in ITS Table 3.3.1-1 withoit introducing a technical change to the CTS requirements. The proposed BVPS ITS Table 3.3.1-1 contains separate Allowable Value columns for Unit 1 and Unit 2. Therefore, the applicable CTS requirements for these RTS Functions may be retained in a single line item on BVPS ITS Table 3.3.1-1 that has a Unit 1 Allowable Value and a Unit 2 Allowable Value. The proposed change is acceptable because it does not introduce a technical change to the CTS requirements and because it is necessaqr to combine the different Unit Functions into a single TS. As the proposed change only BVPS Units 1 &2 Page 52 Revision 2,4/06 182

BVPS ISTS Conversion 3.3A RTS Instrumentation Enclosure 3 Changes to CTS represents a change in the format and presentation of the CTS, it is designated as administrative. A.27 Not used. A.28 The CTS RTS TS contains a separate Table (4.3-1) that contains the surveillance requirements associated with each RTS Function. In addition to the RTS Function surveillance requirements, CTS Table 4.3-1 contains a list of the RTS Functions and the Applicable Modes for each RTS Function. Certain Table 4.3-1 Notes are also specifically associated with the Applicable Modes. The List of Functions and Applicable Modes in CTS Table 4.3-1 is essentially redundant to the list of RTS Functions and Applicable Modes in CTS Table 3.3-1. The purpose of CTS Table 4.3-1 is to clearly specify the surveillance requirements associated with each RTS Function. The repetition of the RTS Function titles and Applicable Modes in Table 4.3-1 is for convenience and ease of identification. The repetition of this information on CTS Table 4.3-1 is not intended to introduce technical changes to the corresponding requirements in CTS Table 3.3-1. In order to simplify and consolidate the RTS Function requirements, the corresponding ISTS for RTS presents all the RTS requirements in a single Table (3.3.1-1). ISTS Table 3.3.1-1 contains a single list cf RTS Functions and a single list of Applicable Modes for each Function. The CTS is revised to conform to the ISTS. This changes the CTS by consolidating CTS Tables 3.3.1 and 4.3.1 into a single Table (ITS 3.3.1-1). The essential technical content of Table 4.3-1 (the surveillance requirements) is moved into the consolidated ITS Table. This DOC is intended to address the consolidation of the two CTS Tables and addresses the redundant list of Function titles and Applicable Modes (including any Notes) for which the changes have already been described in the markup of CTS Table 3.3-1. Other DOCs address any technical differences between the consolidated ISTS Table and CTS Table 4.3-1. The proposed change is acceptable because it conforms to the ISTS and because it does not introduce technical changes to the CTS requirements. The proposed change consolidates the RTS requirements in one table. The RTS information addressed by this DOC is redundant to the information contained in CTS Table 3.3-1. Technical changes to the RTS requirements affected by this DOC have already been identified and discussed in the markup of CTS Table 3.3-1. As such, the proposed change only affects the format and presentation of the RTS requirements and doe<. not introduce technical changes to those requirements. As the proposed change involves only the format and presentation of the RTS requirements, it is designated administrative. A.29 CTS Table 4.3-1 contains the surveillance requirements for the RTS Functions. The CTS specifies a Channel Functional Test for certain RTS Functions. In place of the Channel Functional Test, the ISTS specifies the following surveillance tests depending on the Function: Channel Operational Test (COT) Trip Actuating Device Operational Test (TADOT), and Actuation Logic Test The CTS is revised to replace the single Channel Functional Test requirement with the 3 new ISTS test requirements. The CTS Channel Functional Test as well as the new ISTS surveillance tests are defined terms specified in Section 1.0 of the TS. The BVPS Units 1 & 2 Page 53 Revision ;!, 4/06 183

BVPS ISTS Conversion 3.3A RTS Instrumentation Enclosure 3 Changes to CTS addition of the new ISTS defined terms for surveillance testing and the changes to the CTS Channel Functional Test are addressed in the changes made to TS Section 1.0, Definitions. Any technical changes to the requirements for individual RTS Functions will be addressed in the detailed markup of those requirements in CTS Table 4.3-1. This DOC is intended to address the replacement of the Channel Functional Test requirement in Table 4.3-1 with one of the 3 new ISTS test terms. The ISTS COT is intended to address those RTS instrument channels that encompass equipment intended to process the source signal (e.g., convert current input to voltage output). The ISTS TADOT is intended to address those RTS instrument channels that consist of a more simple input such as a manual switch or other device that simply opens or closes contacts in the RTS. The ISTS Actuation Logic Test is intended to address the actuation logic in the RTS where the individual instrument channel inputs are combined to produce the required logic output. The CTS Channel Functional Test is currently utilized for testing all these different RTS Functions. Although the RTS Functions can be adequately tested using a single general test definition such as the Channel Functional test, some interpretation of the Channel Functional Test definition is necessary to adequately address the different RTS Functions. The specific ISTS test definitions provide accurate descriptions of the testing that is actually performed on each type of RTS Function. The proposed change is acceptable because the new test terms contain specific test requirements applicable to the RTS Functions that more accurately describe the required testing for each Function. The proposed change does not introduce a technical change to the method by which each type of Function is currently tested. The proposed change only results in the use of defined terms that more accurately describe the current test method for each RTS Function. As such, the RTS Functions continue to be tested in a similar manner as before but the testing being performed is more consistent with the TS defined terms being used to specify the required testing. The proposed change is designated administrative because it does not introduce technical changes to the surveillance testing currently performed for each RTS Function. A.30 CTS surveillance 4.3.1.1.3 requires that "The REACTOR TRIP SYSTEM RESPONSE TIME of each reactor trip function shall be demonstrated to be within its limit...." The CTS surveillance is a general requirement that is interpreted to be applicable to those RTS Functions with response time limits assumed in the safety analyses. The list of RTS Functions with response time requirements that must be verified is maintained outside of the TS in the Licensing Requirements Manual (LRM). The ISTS provides a specific response time surveillance requirement that is assigned to each RTS Function that has required response time limits. The CTS is revised to conform to the ISTS. This changes the CTS by assigning a response time surveillance requirement to each individual RTS Function that has a required response time limit identified in the LRM. The proposed change is acceptable because it more accurately identifies the RTS Functions with response time requirements and assures each of those Functions are assigned the response time surveillance requirement. The proposed change revises the presentation of the requirement to perform response time verification but does not change the intent of the requirement. In addition, the proposed change does not change the RTS Functions that are tested, the method of testing, or the frequency of testing. As such, the proposed change does not introduce any BVPS Units 1 & 2 Page 54 Revision 2, 4/06 184

BVPS ISTS Conversion 3.3A RTS Instrumentation Enclosure 3 Changes to CTS technical changes to the CTS. Therefore, the proposed change is designated administrative. A.31 The CTS surveillances for the Safety Injection Input from ESF and the RCP Breaker Position RTS Functions specified on Table 4.3-1 require a Channel Functional Test (CFT) to be performed once per refueling (18 months). The corresponding ISTS surveillance for these RTS Functions requires a Trip Actuating Device Operational Test (TADOT) to be performed once per 18 months. The ISTS surveillance is modified by a note that specifies "verification of setpoint is not required." The CTS surveillance is revised to conform to the ISTS surveillance. This changes the CTS by explicitly stating that setpoint verification is not required for these two RTS Functions. The change from the CTS CFT defined term to the ISTS TADOT defined term is addressed in the DOCs associated with TS Section 1.0, Definitions. This DOC is only intended to address the addition of the ISTS note that excepts the verification of setpoints. The proposed change is acceptable because the affected RTS Functions do not have a setpoint to verify. The Safety Injection Input Function simply initiates a reactor trip whenever a Safety Injection is initiated. The RCP Breaker Position Function initiates a reactor trip based on RCP breaker position (two-out-of-three RCP breakers open initiate a reactor trip). In addition, the proposed change is acceptable because it is consistent with the CTS CFT definition which does not require setpoints to be verified. Since the affected Functions do not have setpoints to verify, the proposed change does not introduce a technical change to the CTS requirements. As such, the proposed change is designated administrative. A.32 CTS Table 4.3-1 contains a line item for the RTB Bypass Breakers. The CTS Table specifies two CFT surveillances for the RTB Bypass Breakers a monthly CFT and a refueling interval CFT. The corresponding ISTS Table 3.3.1-1 does not contain a specific line item for the RTB Bypass Breakers. The ISTS combines the surveillance requirements for the Bypass Breakers with the RTBs and the manual reactor trip function. The ISTS specifies one monthly (on a staggered test basis) TADOT for the RTBs and one 18 month TADOT for the manual reactor trip function. The CTS is revised to conform to the ISTS. This changes the CTS by eliminating a specific line item for the RTB Bypass Breakers and combining the CTS surveillances for the RTB Bypass Breakers with the RTB and manual reactor trip function surveillances. The differences between the CTS CFT defined term and the ISTS TADOT defined term are addressed in the DOCs associated with TS Section 1.0, Definitions. This DOC is intended to address the changes to the CTS Table 4.3-1 line item for the RTB Bypass Breakers. The purpose of the CTS monthly CFT specified in Table 4.3-1 for the Bypass Breakers is stated in the associated Note # 12. CTS Note 12 requires a local manual shunt trip prior to placing the Bypass Breakers in service. The intent of tie CTS requirement is to test the Bypass Breakers (locally) each time they are placed in service to allow testing of the RTBs. The testing of the Bypass Beakers and RTBs are linked by the fact the Bypass Breaker must be placed in service before the RTB can be tested. The ISTS addresses this by footnote (g) applicable to the RTB line item on ISTS Table 3.3.1-1. Footnote (g) specifies that the RTB requirements in Table 3.3.1-1 (including the surveillance requirement) are applicable to the bypass breakers when they are racked in and closed for bypassing an RTB. The proposed change to this surveillance (combining with the RTB surveillance) is acceptable BVPS Units 1 & 2 Page 55 Revision 2, 4/06 185

BVPS ISTS Conversion 3.3A RTS Instrumentation Enclosure 3 Changes to CTS because the ISTS RTB surveillance retains the requirement to perform the surveillance on the Bypass Breakers prior to placing them in service and normally the Bypass Breaker is placed in service prior to testing the associated RTB. Thu:;, the Bypass Breakers continue to be tested in the same manner as before. The proposed change re-organizes the CTS to conform more closely to the relationship between the RTBs and the Bypass Beakers and the actual frequency of testing. The purpose of the refueling interval CFT specified on CTS Table 4.3-1 for the RrB Bypass Breakers is stated in the associated Note 13. CTS Note 13 states "automatic undervoltage trip." The intent of this surveillance is to allow the automatic undervoltage trip function on the Bypass Breakers to be tested during shutdown conditions when this trip Function can be actuated by the manual reactor trip switch. The undervoltage trip function can not be tested on line and is normally tested by actuating the manual reactor trip switch. The proposed change to this CTS surveillance (combining with the manual reactor trip Function) is acceptable because the Bypass Breaker undervoltage trip function continues to be tested in the same manner as before. The proposed change only re-organizes the surveillance requirements to more closely correspond to the actual testing performed using th a manual reactor trip switch. The proposed changes are designated administrative because the affected Functions continue to be tested in the same manner as before. A.33 Unit 1 only. CTS Table 4.3-1 Note 5 states "each train tested every other month.' The CTS Note is applicable to the surveillance requirements for the RTB and Automatic Trip Logic RTS Functions. The corresponding ISTS surveillance requirements for these RTS Functions specify that the surveillance is performed monthly on a STAGGERED TEST BASIS. The CTS is revised to conform to the ISTS. This changes the CTS by revising Note 5 from requiring that each train be tested every other month to the Function being tested monthly on a staggered tes;t Ulty basis. The proposed change is acceptable because it does not introduce a technical change to the CTS surveillance requirements. The ISTS utilizes the defined term "Staggered Test Basis". The use of this term in a monthly surveillance results in each train of the affected RTS Functions being tested every other month. Thus, the proposed change results in the same surveillance frequency as the CTS. The proposed change simply adopts the ISTS terminology for this type of surveillance frequency. As the proposed change does not result in a technical change to the CTS requirements it is designated administrative. A.34 The CTS surveillance requirements specified on Table 4.3-1 for the Overtemperature AT RTS Function include a channel check, channel functional test, and channel calibration. The corresponding requirements in the ISTS include two additional surveillances. The ISTS includes the surveillances that require that the excore nuclear instrumentation be adjusted and calibrated to agree with the incore instrumentation. The incore/excore calibration requirements (SR 3.3.1.3 and SR 3.3.1.9) are also specified for the power range neutron flux high setpoint RTS Function. The CTS is revised to conform to the ISTS. This changes the CTS by assigning two additional surveillances to the Overtemperature AT RTS Function. The incore/excore calibration requirements are necessary to assure the f(AI) input to the Overtemperature AT RTS Function is accurate. As these surveillance BVPS Units I & 2 Page 56 Revision ;, 4/06 186

BVPS ISTS Conversion 3.3A RTS Instrumentation Enclosure 3 Changes to CTS requirements support the operability of the Overtemperature AT RTS Function they should be associated with that Function. The proposed change is acceptable because it clarifies the association of these surveillance requirements with the Overtemperature AT RTS Function. The proposed change does not result in a technical change to the CTS. The surveillances continue to be performed in a similar manner as before and only the presentation of this information in the TS is affected. As such, the proposed change provides a clarification regarding the purpose of the affected surveillances without impacting the performance requirements. The proposed change is designated administrative as it does not introduce a technical change to the CTS. A.35 CTS Note 3 in Table 4.3-1 states "At least once every 31 Effective Full Power Days (EFPD) compare incore to excore axial imbalance above 15 percent of RATED THERMAL POWER. Recalibrate if absolute difference greater than or equal to 3 percent." The corresponding ISTS surveillance SR 3.3.1.3 is similar except that it states " Adjust NIS channel if absolute difference is Ž 3%." The CTS is revised to conform to the ISTS. This changes the CTS by rewording the Note modifying the monthly comparison of the incore and excore detectors. The proposed change involves the specific surveillance instructions for equalizing the excore detector Al indications to the incore readings if the difference exceeds the limit. In actual practice the resetting (or adjustment) of the power range channel Al indications involves recalibration of the nuclear instrumentation system (NIS) to incorporate the new settings. The proposed change is acceptable because it does not substantially effect the necessary actions to incorporate any adjustments into the NIS. As such, the affected surveillance will continue to be performed in the same manner as before. The proposed change does not result in any reduction in the required surveillance testing of the NIS. The proposed change continues to provide adequate assurance that the NIS is maintained operable and performing within a known tolerance. As the proposed change does not result in a technical change to the method for performing the surveillance or the surveillance acceptance criteria, it is designated administrative. BVPS Units 1 & 2 Page 57 Revision 2, 4/06 187

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 CHANGE C-2 Database # 200507061636 NRC Commenter: R. Hernandez BSI-18 BVPS agreed to withdraw the change proposed in BSI # 18. This change results in the restoration of ITS 3.7.9 (UHS) Action A to the same as the corresponding CTS Action (i.e., if the UHS temperature limit is exceeded shutdown Actions are entered instead of the proposed action to average the UHS temp. over next 24 hours). This change only affects the technical specification requirements for ITS 3.7.9 (UHS). Affected Pages: The following Table(s) list the affected pages by type (i.e., ITS markup, CTS markup, etc.). In order to facilitate review by ITS section, a separate table is provided for each ITS section affected by the change. The page numbers listed are the ITS section specific consecutive numbers found in the lower right corner of each page. Note: Because the affected page(s) for each change were extracted from a complete ITS section electronic file, the electronic hyperlinks (created in the complete ITS section file) do not work in the collection of affected pages that follow this cover page. ITS SECTION 3.7 (PLANT SYSTEMS) INDEX OF AFFECTED PAGES ITS MARKUPS PAGE: 27 ITS JFDS PAGE: 63 ITS BASES MARKUPS PAGE: 133 ITS BASES JFDS No change CTS MARKUPS PAGE: 238 CTS DOCS PAGE: 308

Rev. 2 Change C-2 UH ; 3.7.9 3.7 PLANT SYSTEMS 3.7.9 Ultimate Heat Sink (UHS) LCO 3.7.9 The UHS shall be OPERABLE. APPLICABILITY: MODES 1, 2, 3, and 4. ACTIONS

    - REE        R'S NOTE -      I The [ ]OF is the li     urn allowed UHS temperatur         ue and is based on temperature limitations of the equipment that is relied upon for accident mitigation and safe shutdown of the unit.

WOG STS 3.7.9- 1 Rev. 2, 04/30/01 27

I REV. 2 Change C-2 I BVPS ISTS Conversion 3.7 Plant Systems Enclosure 1 Changes to ISTS ITS 3.7.9 Ultimate Heat Sink (UHS) JUSTIFICATION FOR DEVIATION (JFD)

1. The ISTS Actions and Surveillance Requirements are edited to insert BVPS specific values consistent with the CTS. ISTS Action A is deleted as BVPS does not use cooling towers in the ultimate heat sink system. ISTS Action B is deleted because BVPS does not utilize a licensing basis temperature limit consistent with the requirements specified in ISTS Action B. Additionally, since the BVPS UHS is the Ohio River and no cooling towers or fans are used, this change also eliminates references to cooling towers and fans in the Surveillances.

2. ISTS Action Condition C is revised to ITS Action Condition A. The text of ISTS Condition C is completely replaced with the simple statement that the UHS is inoperable.

Consistent with the single BVPS CTS Action, when the required UHS water level or UHS, temperature is not within limit, the UHS is inoperable, and a plant shutdown is required. The revised ISTS Action C implements the CTS requirements consistent with the ISTS format for such Action Conditions. The UHS limits remain in the corresponding SRs consistent with the ISTS location of the required limits. BVPS Units 1 and 2 Page 12 Revision 2, 4/06 63

UH'S B 3.7.9 p.l> l Rev. 2 Change C-2 I BASES ACTIONS (continuedI) e letion Time is reasonable based on the low 0I an accident occurrin inoperable (in one or more systems, and the ire e a st at on reasona c r fan is t e nu er of available Required Ac

                                             \                ~-REVIEWER'S NOTE -/

The [ ]0F the maximum allowed UHS temperature value a is based on temperat limitations of the equipment that is relied on for accident mitigat and safe shutdown of the unit. With water temperature he UHS > [90]0 F, t design basis 0 assumption associated with tial UHS temerature are bounded provided the temperature of the HS a raged over the previous 24 hour period is * [90]OF. With the water term cooling capability of the EC erature of the UHS > [90]OF, long lo s and DGs may be affected. Therefore, to ensure long te ooling ability is provided to the ECCS loads when water temperare of the UHS is [90]OF, Required Action B.1 is provided to more equently monitor the ter temperature of the UHS and verify the perature is < [90]OF when avraged over the previous 24 hour eriod. The once per hour Completi Time takes into consideration S temperature variations and the increaed monitoring frequency eded to ensure design basis assumptions and uipment imitatio are not exceeded in this condition. If the water temp ature of the S exceeds [90]OF when averaged over the previous 24 hou eriod o he water temperature of the UHS exceeds [ ]'F, Condition C must 0, FT I entered immediately l

                                   .:J:anr-.2 mey m-e fth            d AGicUonc aRG tompg

{ P;le Iimos ot UOfnQ 1J" or bA ro O If either the UHS Fthe UHS is nopable for reasons other than ConditionA, the temperature or level / unit must be placed in a MODE in which the LCO does not apply. To requirements are not achieve this status, the unit must be placed in at least MODE 3 within rnet, the UHS is 6 hours and in MODE 5 within 36 hours. I operable and The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.3 WOG STS B 3.7.9 - 3 Rev. 2, 04/30/0'l 133

I Rev. 2 Change C-2 k d4uY PLANT SYSTEMS EI 3/4.7.5 ULTIMATE HEAT SINK -HI--RIVER ( LIMITING CONDITION FOR OPERATION 3.7.-5.1 The ultimate heat sink shall be OPERABLE with: 7.9 A minw level wate r at apoveorelevation 654 Sea. an Level, at the intake,structure,l-an_ Bases IA I I-; An average water temperature A< 890 F. APPLICABILITY: MODES 1, 2, 3 and 4. l 0 ACTION: Unit I CTS value *90 F (Unit 1) I retained With the requireRmnnts of the above specification not satisfied, be in

          /at least HOT STANDBY within 6 hours and in COLD SHUTDOWN within the following, n hours.

aUHS inoperable. SURVEILLANCE REQUIREMENTS The ultimate heat sink shall be determined OPERABLE at least once per 24 hours by verifying the average water temperature and water level to be within their limits. 1t.1I lZ'37.9.1 BEAVER VALLEY - UNIT 2 3/4 7-13 Amendment No. 20 238

BVPS ISTS Conversion I Rev. 2 Change C-2 I 3.7 Plant Systems Enclosure 3 Changes to CTS CTS 3.7.5.1 ULTIMATE HEAT SINK - OHIO RIVER ITS 3.7.9 Ultimate Heat Sink (UHS) DISCUSSION OF CHANGE (DOC) Less Restrictive Chanqes (L) L.1 Not used. More Restrictive Chanqes (M) None BVPS Units I & 2 Page 40 Revision 2, 4/06 308

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 CHANGE C-3 Database # 200508221254 NRC Commenter: D. Nguyen BSI-19 BVPS agreed to withdraw the change proposed in BSI # 19. The withdrawal of BSI-1 9 will delete the phrase "or based on operating experience" from the SR Notes that allow the DGs to be accelerated gradually when started. The revised Notes will only refer to the vendor recommendations instead of both vendor recommendations and operating experience. The withdrawal of BSI-19 affects Surveillance Requirements 3.8.1.2 and 3.8.1.3 in ITS 3.8.1. In addition, to maintain consistency with the withdrawal of this change, the Bases for ITS Surveillance Requirements 3.8.1.14 and 3.8.1.15 were also revised to remove the option 'or based on operating experience." Affected Pages: The following Table(s) list the affected pages by type (i.e., ITS markup, CTS markup, etc.). In order to facilitate review by ITS section, a separate table is provided for each ITS section affected by the change. The page numbers listed are the ITS section specific consecutive numbers found in the lower right corner of each page. Note: Because the affected page(s) for each change were extracted from a complete ITS section electronic file, the electronic hyperlinks (created in the complete ITS section file) do not work in the collection of affected pages that follow this cover page. ITS SECTION 3.8 (ELECTRICAL POWER SYSTEMS) INDEX OF AFFECTED PAGES ITS MARKUPS PAGE: 8 ITS JFDS PAGE: 48 ITS BASES MARKUPS PAGES: 78, 80, 95 & 96 ITS BASES JFDS PAGE: 162 CTS MARKUPS PAGE: 178 & 189 CTS DOCS PAGE: 222

Rev. 2 Change C-3 AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.8.1.2

                                                        - NOTES -

1. All DG starts may be preceded by an engine prelube period and followed by a warmup period 1-C~

prior to loading. . _ . f 2. A modified DG start involving idling and gradual ii06 V and s438 V(Uhif -, acceleration to synchronous speed may be use v r!U I2 for this SR as recommended by the manufacturer. l^tAn,-

                                      --  ^ifAr-e       to-.t ---- ,^

MOM-t FM-.%I-u

                                                                        - Ir   -
                                                                             ^rA    . -- AIPA                       Ih             I time, voltage, and fro9quency tolorancs otf SR 3.8.1.7 must bo metI Verify each DG starts from standby conditions qpdd achieves steady state voltage a 437140] V an-C-[4580]V, and frequency 5 [58.8] Hz and s [61.2] Hz.

SR 3.8.1.3

                                                                                              - 58.8 Hz and s61.2 Hz (Unit 1)

1. IDG loadings may include gradual loading as 9 } g 21 recommended by the manufacturer.

2. Momentary transients outside the load range do not invalidate this test.

3. This Surveillance shall be conducted on only one DG at a time.

4. This SR shall be preceded by and immediately follow without shutdown a successful performance of SR38A n R .84.

Q-- =--71 Verify each DG is synchronized and loaded and 31 days Fj-Ts operates for > 60 minutes at a load a [1450] kW and YiMo kW ad-s-2600W(IU-1 ) s4[5 O O O . - EWAQW1 I I A VewF each day tank [and Inaine mounted tank] 31 -day SR~344 contains Ž [220] gal of fuel Gil: S Check for and remove accumulated water from each {313 days s7farS i!! !!!mne .. MMed WHsn.I . Insert SRs 3.8.1.4.1 and 3.8.1.4.2 3.81 5 Insert SRs 3.8.1.5.1 and 3.8.1.5.2 /30/0 1 (i)2 8

I Rev.2 Change C-3 BVPS ISTS Conversion 3.8 Electrical Power System; Enclosure I Changes to ISTS) generator by the vendor or during preoperational testing to demonstrate adequate design and construction. Since this test imposes more severe service than is required by plant design, periodic performance of this test would only serve to repeatedly demonstrate suitable design or sizing of the units and is beyond what is necessary to demonstrate operability or reliability. Testing on a periodic basis is unnecessary and is inconsistent with the goals of Generic Letter 84-15 by providing conditions which could increase diesel generator degradation and reduce reliability. The diesel generator may occasionally be run to demonstrate its capability to operate for prolonged periods (24 hours or longer) when it is determined that such operation is prudent."

15. ISTS SR 3.8.1.15 requires the hot fast re-start of each DG to rated voltage and frequency after operating for at least 2 hours every 18 months. This test is normally associated with the requirement to perform a 24-hour run (to establish the required 'hot' conditions). This surveillance requirement is not added to the BVPS ITS because current licensing basis does not require the performance of this test. This is acceptable for Unit 1 because Safety Guide 9, the Unit's current licensing basis, did not require the performance of this surveillance. For Unit 2 this is acceptable because it is the current licensing basis described by the NRC's initial SER and the Unit 2 UFSAR which took exception to such testing requirements as explained in JFD 14 above. The ISTS SRs that follow are re-numbered to reflect this SR deletion.

16. ISTS SR 3.8.1.20 requires the verification that each DG when started simultaneously from a standby condition can achieve rated voltage and frequency within 10 seconds.

ITS SR 3.8.1.15 requires the performance of the test for Unit 2 only. A Note is added to SR to specify that it is applicable to Unit 2 only. This is acceptable because the current licensing basis does not require the SR for Unit 1 and not required by Safety Guide 9, the Unit's current licensing basis.

17. Not used.

18. ISTS LCO 3.8.1 states 'The following AC electrical sources shall be OPERABLE: Two qualified circuits between the offsite transmission network and the onsite Class I E AC Electrical Power Distribution System, b. Two diesel generators (DGs) capable of supplying the onsite Class 1E power distribution subsystem(s), and c. Automatic load sequencers for Train A and Train B." ITS LCO 3.8.1 states "The following AC electrical sources and sequencer timer(s)shall be OPERABLE: Two qualified circuits between the offsite transmission network and the onsite Class 1E AC Electrical Power Distribution System, b. Two diesel generators (DGs) capable of supplying the onsite Class 1E power distribution subsystem(s), and c. Automatic load sequencer timer(s) for each required BVPS Units 1 & 2 Page 4 Revision 2, 4/06 48

AC Sources - Operating B 3.8.1 I Rev. 2 Change C-3 BASES SURVEILLANCE REQUIREMENTS (continued) art an5.8 Hz and 64.. H.:, respcveoly. These values ar eqa t f iu OUld nomninalFHrEqueny OR nu arU UurFIV'U Prm itt recomenaauinr given in Regulatoyr, Guide 1.0 (Rof. 3). SR 3.8.1.1 This SR ensures proper circuit continuity for the offsite AC electrical power supply to the onsite distribution network and availability of offsite AC electrical power. The breaker alignment verifies that each breaker is in its correct position to ensure that distribution buses and loads are connected to their preferred power source, and that appropriate independence of offsite circuits is maintained. The 7 day Frequency is adequate since breaker position is not likely to change without the operator being aware of it and because its status is displayed in the control room. SR 3.8.1.2andSR 3.8.1.7 I These SRs help o ensure the availability of the standby electrical power supply to mitigate DBAs and transient"ns o maintain the unit in a safe shutdown condition. is To minimize the wear on moving pa Ihat do not get lub icaed when the! engine is not running, these SRs am modified by a Nott SR 3.8.1.2 and Note for -SR 3.8.1.7) to indicate that all DG starts for thesug j Surveillances may be preceded by an engine prelube period and followed 1 1 by a warmup period prior to loading. For the purposes of SR 3.8.1.2 and SR 3.8.1.7 testing, the DGs are started from standby conditions. Standby conditions for a DG mean that Baring of the engine may be the diesel engine coolant and oil are being continuously circulated and performed prior to DG start temperature is being maintained consistent with manufacturer with out invalidating the recommendations requirement for starting from I standby conditions. [In

                              - order to reduce stress and wear on diesel engines, some manufacturers recommend a modified start in which the starting speed of DGs is limited, warmup is limited to this lower speed, and the DGs are gradually accelerated to synchronous speed prior to loading. These start procedures are the intent of Note 2, which is only applicable when such modified start procedures are recommended by the manufacturer. I I

si 3.8.1.7 reauIros that, at a 184 day Frequency { the DG starts from

                              ^      A, I

( I F-s~tzaRD cORmonsts aOn aGrcev rociuireA vomltag ana ;reaUncRGYiWnIn WOG STS B 3.8.1 - 14 Rev. 2, 04/30/01 78

AC Sources - Operating B 3.8.i l Rev. 2 Change C-3 BASES SURVEILLANCE REQUIREMENTS (continued) outside the normal This SR is modified by four Notes. Note 1 indicates that diesel engine operating range uns for this Surveillance may include gradual loading, as recommended

                                          \by       anufacturer, so that mechanical stress and wear on the diesel engine are         imized. Note 2 states that momentary transients, because greater than or equal to the          of changing bus s, do not invalidate this test. Similarly, momentary required fuel oil inventory.           power factor transients                    do not invalidate the test. Note 3 The required Unit 1 inventory          indicates that this Surveillance should be conducted on only one DG at a is expressed as an equivalent         time in order to avoid common cause failures that might result from offsite is Selected to ensure the DG          circuit or grid perturbations. Note 4 stipulates a prerequisite requirement ca l operate for more than 1          for performance of this SR. A successful DG start must precede this test hoar at full load plus 10%.           to credit satisfactory performance.

_~~~~~? _r I ;nzwaz.:- I

SR 3.8.1.4.1 and SR 3.8.1.4.2 I Ive1fln2m hisSR provides Ication that the o uel oilin the day tank {td A For Unit 1 this engine mounted tank] is-or-above in au I.malicall' added. To leovel is expressed as an equivalent volume co nbination For WLiit 2, this SR provides gallons, and is selected to ensure adequate fuel oil for a minimum of %vith the verification that the inventory of fuel l Hour of IDG operation at full lead plu6 10.

oil in t.he day tank is greater than or equal to the required fuel oil inventory. The required Unit 2 The 31 day Frequency is adequate to assure that a sufficient supply of inventory is expressed as an fuel oil is available, since low level alarms are provided and facility equivalent usable volume in gallons operators would be aware of any large uses of fuel oil during this period. s and is selected to ensure adequate fuel oil for a minimum of 1 hour of cry < a 1 r The SRs are modified by Notes that specify the applicable unit. DG operation at full load plus 10 %. I I

                                          /Microbiological fouling is a major cause of fuel oil degradation. There are                2
                                            ,umerous bacteria that can grow in fuel oil and cause fouling, but all must L.8.1.5.1 and SR 3.8.1.5.2 ave a water environment in order to survive. Removal of water from the, tfuel oil        [n            m ted1tanks once every4311days eliminates 2          e neceasary environment for bacterial survival. This is the most effective means of controlling microbiological fouling. In addition, it eliminates the potential for water entrainment in the fuel oil during DG                   9 operation. Water may come from any of several sources, including condensation, ground water, rain water, contaminated fuel oil, and m                   breakdown of the fuel oil by bacteria. Frequent checking for and removal of accumulated water minimizes fouling and provides data regarding the watertight integrity of the fuel oil system. The Surveillance Frequencies F consistent with                               Regulatory Guide 1.137 (Ref. 10). This SR is for preventative maintenance. The presence of water does not necessarily represent failure of this SR, provided the accumulated water is removed during the performance of this Surveillance.

WOG STS B 3.8.1 - 16 Rev. 2, 04/30/01 80

AC Sources - Operating B3.8.1 kia$ I Rev. 2 Change C-3 I BASES SURVEILLANCE REQUIREMENTS (continued) bnce of the SR will not cause perturbations to an el ._.ectrical is n systems that could result . a le to steady state operation ant ems, and 3 C. Perform nc gR orfiueo h f ause, or result wihattendant challenge to plant saft _, SR 3.8.1.4§ . I (i) In the event of a DBA coincident with a loss of offsite power, the DGs are required to supply the necessary power to ESF systems so that the fuel, RCS, and containment design limits are not exceeded. This Surveillance demonstrates the DG operation, as dicG Baseo for SR 3.8.1.141, during a loss of offsite power actuation test signal in conjunction with an ESF actuation signal. In lieu of actual demonstration of connection and loading of loads, testing that adequately ___ shows the capability of the DG system to perform these functions is Barring of The 10-second start acceptable. This testing may include any series of sequential, the engine req jirement supports the overlapping, or total steps so that the entire connection and loading may be assumptions of the design sequence is verified. performed basis accident analyses prior to DG described inthe UFSAR (Ref. 5). The 10-second The Frequency of [18 months] takes into consideration unit conditions start without invalidating timing requirement begins required to perform the Surveillance and is intended to be consistent wit the when the DG start signal is an expected fuel cycle length of f18 months]. requirement A

      -I.;Ivc  hy 1VV;Jvru WY I h

for starting circuit and dc)es not include This SR is modified by two Notes. The reason for Note 1 is to mini efrom the time it tatkes the w ed on the DGs during testing. For the purpose of this sting standby instrumentati ion to detect a loss; of voltagle on the t9J Tfie DGs must be started from standby conditions, that is, with e engin conditions. emergency t fusses. coolant and oil continuously circulated and temperature m tained consistent with manufacturer recommendations for DGs. The reason for Nt'eJ 2 is,that the nerfnrmrnr-P of the Siurveililnt-c woiuld remonvp a required offsite circuit from service, perturb the electrical distribution 1 2 3,or 4 system, and challenge safety systems. This restriction from normally performing the Surveillance in ODE is further amplified to allow portions of the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed partial Surveillance, a successful partial Surveillance, and a perturbation of the offsite or onsite system WOG STS B 3.8.1 - 31 Rev. 2, 04/30/01 95

AC Sources - Operatingi B 3.8.1 Rev. 2 Change C-3 _ BASES NUREG-1431, Rev. 3

          \SURVEILLANC E REQUIREMENTS (continued)
                                  -     when they are tied together or operated independently for the partial Credit may be             Surveillance; as well as the operator procedures available to cope with taken for               \hese outcomes. These shall be measured against the avoided risk of a that satisfy ths SR.            shutdown and startup to determine that plant safety is maintained or enha d when portions of the Surveillance are performed in MODE                   M

2. Risk i hts or deterministic methods may be used for the assessment. [ 23or4 SR 3.8.1.

This Surveillance demonstrates that the DG starting independence has not been compromised. Also, this Surveillance demonstrates that each engine can achieve proper speed within the specified time when the DGs are started simultaneously. The 10 year Frequency is consistent with the recommendations of Regulatory Guide 1.108 (Ref. 9 lfwoNoes second This SR is modified by a-No^, e reason or heJ~tso e miInimize wear on the 0esting. For the purpose of this testing, the DGs l Note 1states that the SR Soaededrfromstandby conditions, that is,with the engine coolant is applicable to Unit 2 only. and oil continuously circulated and temperature maintained consistent 10 with manufacturer recommendations. Unit 1 UFSAR Appendix 1A, "1971 AEC: ( / >General Design Criteria Conformance" and

     )' REFERENCES                      1. J,                         AUnit
                                                                        ,                 2UFSAR Section 3.1, TConformance
     \      RE                      ,                                                with U.S. Nuclear Regulatory Commission Barring of the                         2v FSAR, Chapter 8..GeraDsinCtra' ergine    mayprior be to performed                              3. Regulatory Guide 1.9,          .         UFSAR Section        for Unit I and UFSAR De( start without              U                                                   Chapter 1.8 - 1 for Unit 2.

inialidating the . FSAR, Chapter 161. requirement for starting from 5. FSAR, Chapterr5d 1 standby conditions. 6

6. Regulatory Guide 1.93, Rev. 0, December 1974.

7. Generic Letter 84-15, "Proposed Staff Actions to Improve and Maintain Diesel Generator Reliability," July 2, 1984. ,

                                                                                           .   .           Unit 1 UFSAR Appendix IA,

8. 10 CFR 50, Appendix A, GDC 8. "1971 AEC General Design Criteria Conformarce" and

9. Regulatory9 Guide 1.108, Rev. 1, August 197 Unit 2 UFSAR Section 3.1.

                                                                                                          "Conformance with U. S.

Nuclear Regulatonr Commission Gene al (Unit 2) Design Criteria.' WOG STS . B 3.8.1 - 32 Rev. 2, 04/30/01 96

BVPS ISTS Conversion Rev. 2 Change C-3 3.8 Electrical Power Systems Enclosure 2 Changes to The ISTS Bases yJ2i ITS 3.8.1 AC Sources - Operating Bases JUSTIFICATION FOR DEVIATION (JFD)

1. The ITS Bases are modified by moving descriptive information from the CTS specifications.

2. Changes to the ITS Bases are made to reflect changes in the ITS Specifications.

3. Editorial change made with the removal of the Reviewer's Note to be consistent with the ISTS writers' guide.

4. Bracketed description is replaced with information from UFSAR Chapter 8.

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

6. Section / Chapter references are changed to reflect a unit specific reference (i.e.,

Accident analysis for Unit 1 is Chapter 14 and for Unit 2 is Chapter 15), if applicable.

7. A bracketed portion of the Bases for ITS SR 3.8.1.6 is modified to reflect the ITS Specification.

8. The criteria of the NRC Final Policy Statement on Technical Specifications Improvements have been included in 10 CFR 50.36 (c)(2)(ii). Therefore, references in the ISTS Bases to the NRC Final Policy Statement are revised in the ITS Bases to reference 10 CFR 50.36.

9. This is an editorial change for clarity, for consistency with the Improved Technical Specifications Writers' Guide, or consistency with similar statements in the other ITS llit Bases.

10. The BVPS Unit 1 and 2 UFSAR each contain a section that describes how the unit complies with the GDC. The ISTS Bases references to the GDC have been replaced with references to the appropriate section of each BVPS Unit's UFSAR that describes compliance with the GDC. Supplement each reference to the "10 CFR 50, Appendix A General Design Criteria" in the ISTS Bases with the phrase "as discussed in Reference 1".

11. ISTS SR 3.8.1.2, SR 3.8.1.19, and SR 3.8.1.20 become ITS SRs 3.8.1.2, 3.8.1.14, and 3.8.1.15. Each of these SRs requires the DG to be started from standby conditions. The Bases for each SR states that standby conditions are with the engine's coolant and oil continuously circulated and temperature maintained consistent with manufacturer recommendations. The Bases for each SR is modified by adding the following sentence, 'Barring of the engine may be performed prior to DG start without invalidating the requirement for starting from standby conditions."

This change is acceptable because cycling the DG (barring, rolling, or cranking) with the petcocks open to detect water in the cylinders is an acceptable preconditioning example in NUREG-1216 as documented in the NRC Inspection Manual Section 9900 "Technical Guidance/Maintenance/ Precondition of SSC before determining OPERABILITY." BVPS Units 1 & 2 Page 1 Revision :2, 4/06 162

IRev. I to 2/2 8105 suulE _ Rev. 2 Change C-3 - ELECTRICAL POWER SYSTEMS ITS 3.8.1 & 3.8.3 SURVEILLANCE REQUIREMENTS (Continued) (i?) 4.8.1.1.2 Each diesel generator shall be X onstrated OPERABLE:

a. At least once per 31 days on a STAGCERED TEST BASIS by: /

I SR 3-8-1-4-2 14. Verifying the fuel level in the day tank, co ntains 350 gallons I SRY383 Verifying the fuel level in the fuel storage tan 1*T3 (Deleted) contains Ž 53,225 gallons of fuel oil. A 1 4. Verifying the fuel transfer pump can be started and SR3.8.1.6 transfers fuel from the storage system to the day tan InertSR notes I A17 4

5. Verifying he iesel starts trom standbyconlton ( M12)

SR 3.8.1.2 and achieves steady state voltqge3 of 2 3994 volts and < 4368 volts and frequency of 2 59.9 Hz and. < 60 3 H Insert SR notes SR 3.8.13 6- Verifying enerator is synchronized, Ioaa eal SR34 23 kw, 8 and operates for > 60 minutes, _ _nse l

7. Verifying thodiesel gen1rato is aligned toe prev yd standby power to the associated emergency bussce, at 1A4 8 Verifying the lubricating oil inventory gj7773 r.R

      @               At least once per 18 months during shut-d                                          21

1. (Deleted) )

2. Verifying the generato apability to re)e cg load

                             '-825 I-w        without      tripping             and       wit              exceed:Lng S3.1864.4               Hz;                                            cr-SR .81. 64 4       Z;                 single largest post-accddenl l       nser tme, V. & Hz limlK13t (3)     The values for voltage and frequency are analysis values.                                            Th!se value bands shall be appropriately reduced to account fo                                                            .1-L~A6            measurement uncertainties.

Ct(4) All diesel generator starts may be preceded by an engine prelube A1~) period and followed by a warmup period prior to loading. (5) Diesel generator loadings may include gradual loading as recommended by the manufacturer. I

                                                     ' Rhall                aroRn riatcl-(7)     The    value for frcau1nc;                           b       A                          redueId          -tH account for measurement unece
                                                            *-_____An

I-t BEAVER VALLEY - UNIT 2 3/4 8-4 Amendment No.15C0 178

Rev. 2 Change C-3 & C-14 Inserts 3.8.1 (continued) SR 3.8.1.8 surveillance notes SR 3.8.1.8

                                      - NOTES-1 This surveillance shall not normally be performed in MODE I or 2. However, the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

2 If performed with DG synchronized with offsite power, it shall be performed at a power factor s 0.89. C-1 4 However, if grid conditions do not permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as dose to the limit as practicable. SR 3.8.1.3 surveillance notes SR 3.8.1.3

                                     - NOTES -

1 DG loading may include gradual loading as recommended by the manufacturer. G3 2 Momentary transients outside the load range do not invalidate this test. 3 This Surveillance shall be conducted on only one DG at a time. 4 This SR shall be preceded by and immediately follow without shutdown a successful performance of SR 3.8.1.2. SR 3.8.1.2 surveillance notes SR 3.8.1.2

                                     - NOTES-1  All DG starts may be preceded by an engine prelube period and followed by a warmup period prior to loading.

2 A modified DG start involving idling and gradual acceleration to synchronous speed may be used for this SR as recommended by the manufacturer. c-3 C LCO Sequence Timers

c. Automatic load sequencer timer(s) for each required DG.

189

BVPS ISTS Conversion I Rev. 2 Change C-3 I 3.8 Electrical Power System<; Enclosure 3 Changes to CT'S L.19 Not used. L.20 (Category 4 - Relaxation of Required Action) CTS LCO 3.8.1.1 requires each diesel generator to have a separate fuel oil storage system with a minimum number of gallons of fuel oil. Unit 1 is 17,500 gallons and Unit 2 is 53,225 gallons. ITS LCO 3.8.3 Condition A states 'One or more DGs with fuel oil inventory < 17,500 gal and 2 15,000 gal (Unit 1) or

     < 53,225 gal and 2 45,625 gal (Unit 2)." The Required Action of the ITS states that the fuel oil inventory to be restored within limits in 48 hours. This changes the CTS by allowing the fuel oil inventory to less than the minimum number of gallons for 48 hours.

The purpose of ITS Condition A is to allow for a decrease in DG fuel oil inventory for a short period of time. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a design basis accident occurring during the repair period. The fuel oil inventory must remain above the six day limit for the required DGs. The Required Action ensures the DG remains capable of performing its safety function while allowing the replacement of fuel oil. The ITS requirements are consistent with the ISTS wording for these requirements. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS. L.21 (Category 4 - Relaxation of RequiredAction) Unit 2 CTS LCO 3.8.1.1 requires each diesel generator to have a separate lube oil storage inventory within the specified volume. ITS LCO 3.8.3 Condition B allows less than the specified volume of lube oil (if the BVPS UnitsI & 2 Page 10 Revision 2, 4/06 222

EVPS UPITS 1 & Z ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 169 (UNIT Z) REVISION 2 CHANGE C-4 Database # 200508041317 NRC Commenter: C. Lauron BSI-20 BVPS agreed to withdraw the change proposed in BSI # 20. The withdrawal of the change proposed in BSI-20 will result in the affected Unit 1 surveillance requiring both the diesel generator fuel oil day and engine mounted tanks be checked for water instead of just the lower tank (i.e., the engine mounted tank) being checked for water. This change affects the Unit 1 Surveillance Requirement 3.8.1.5.1. This change does not affect Unit 2 as the Unit 2 diesel generators only have fuel oil day tanks (which are required to be checked for water) and do not have the additional engine mounted tanks as do the Unit 1 diesel generators. Affected Pages: The following Table(s) list the affected pages by type (i.e., ITS markup, CTS markup, etc.). In order to facilitate review by ITS section, a separate table is provided for each ITS section affected by the change. The page numbers listed are the ITS section specific consecutive numbers found in the lower right corner of each page. Note: Because the affected page(s) for each change were extracted from a complete ITS section electronic file, the electronic hyperlinks (created in the complete ITS section file) do not work in the collection of affected pages that follow this cover page. ITS SECTION 3.8 (ELECTRICAL POWER SYSTEMS) INDEX OF AFFECTED PAGES ITS MARKUPS PAGE: 21 ITS JFDS PAGE: 46 &47 ITS BASES MARKUPS No change ITS BASES JFDS No change CTS MARKUPS PAGE: 184 CTS DOCS PAGES: 221 & 228

Rev. 2 Change C-4 Inserts for ITS LCO 3.8.1 Insert SR 3.8.1.5.1 and 3.8.5.2 SURVEILLANCE FREQUENCY

                                -Note -

SR 3.8.1.5.1 Check and remove accumulated water from 31 days each day tank and engine mounted tank.

                                - Note -

SR 3.8.1.5.2 Check and remove accumulated water from 31 days each day tank. 21

Rev. 2 Change C-4 l BVPS ISTS Conversion 3.8 Electrical Power Systems Enclosure I Changes to IST'S determines the safety of the plant is maintained or enhanced. ITS SR 3.8.1.7 states

      'Verify automatic and manual transfer of AC power sources from the unit circuit to system offsite circuit." This change is acceptable because the SR reflects the plant specific nomenclature and the current requirement. The proposed ITS requirement does not place a MODE restriction on the performance of this SR. This change is acceptable because the transfer to the system circuit has been performed in MODES 1 and 2 and the SR does not cause a perturbation to any of the electrical distribution systems. The performance of this surveillance requirement in the CTS is not restricted by MODE requirements. Therefore, the Note is deleted from the ITS SR 3.8.1.7.

6. ISTS SR 3.8.1.10 requires verification every 18 months that each DG will not trip and will maintain voltage within a maximum limit on a full load rejection test. This test is not included in the ITS requirement for the DG. A full load rejection test is not required by the CTS requirements. Each DG will continue to perform the largest post-accident load rejection test every 18 months. This change isacceptable because the DG output breaker utilizes a greater current trip than from individual loads. Therefore, the individual loads will trip the associated breaker instead of tripping the DG output breaker. Tripping of the DG output breaker is the most likely way to cause a 100% load rejection. Testing of the largest post-accident load rejection is sufficient to ensure DG reliability. The ISTS SRs that follow are re-numbered to reflect this SR deletion.

7. ISTS SR 3.8.1.16 requires the DG synchronization with offsite power source while loaded with emergency loads and upon a simulated restoration of offsite power, transfers loads to offsite power source. The DG is then required to return to the ready-to-load condition. ITS SR 3.8.1.11 requires each DG be synchronized with offsite power source while loaded with emergency load and upon a simulated restoration of offsite power transfers loads to offsite power source. Upon the transfer of load to the offsite source, the Unit 2 DG is required to return to the ready-to-load condition and the Unit 1 DG is required to proceed through its shutdown sequence. This change is acceptable because Unit 1 DGs are not required by current licensing basis or designed to return to the ready-to-load condition.

8. ISTS SR 3.8.1.17 verifies, with a DG operating in test mode and connected to its bus, an actual or simulated ESF actuation signal overrides the test mode by returning DG to ready-to-load operation. ITS SR 3.8.1.12 verifies, with a DG operating in test mode and connected to its bus, an actual or simulated ESF actuation signal overrides the test mode by returning DG to ready-to-load operation for Unit 2 DGs only. This is designated with the addition of a note to the SR that states that the requirement is applicable to Unil 2 DGs only. This change is acceptable because Unit 1 DGs are not required by current licensing basis or designed to return to the ready-to-load condition.

9. ISTS LCO 3.8.1 requires AC sources shall be OPERABLE. Part c states 'Automatic load sequencers for Train A and Train B." ITS LCO 3.8.1 part c requires the automatic load sequence timer(s) for each required DG to be OPERABLE. This change is acceptable because the system nomenclature for these components is a sequence timer(s). These components are associated with the DG.

10. ISTS SR 3.8.1.5 states 'Check for and remove accumulated water from each day tank

[and engine mounted tank].' ITS SR 3.8.1.5.1 states 'Check for and remove accumulated water from each day tank and engine mounted tank." A Note modifies the BVPS Units 1 & 2 Page 2 Revision 2, 4/06 46

BVPS ISTS Conversion Rev. 2 Change C4 & C-15 3.8 Electrical Power Systems. Enclosure I Changes to ISTS SR that states 'Only applicable to Unit 1." ITS SR 3.8.1.5.2 states 'Check for and remove accumulated water from each day tank." A Note modifies the SR that states

     'Only applicable to Unit 2." These changes to the SRs are acceptable because only the Unit 1 DGs have both day and engine mounted tanks that must be checked for water.                 C-4 For Unit 2, the day tank is the appropriate tank to verify because Unit 2 does not have an engine mounted tank.

11. ISTS SR 3.8.1.7 requires the fast start of each DG to rated voltage and frequency every 184 days. This requirement is not added because the units are licensed in accordance with applicable Safety Guide or Regulatory Guide and does not require the performance of this test and a fast start is performed once every 18 months. The Unit 1 DGs will not field flash on fast start unless an undervoltage signal is present. The Unit 1 DGs can not be emergency started from the control room. This change will minimize the fast starts for the DGs. The ISTS SRs that follow are re-numbered to reflect this SR deletion.

12. ISTS SR 3.8.1.11 requires the fast start of each DG to rated voltage and frequency on an actual or simulated loss of offsite power every 18 months. This requirement is not added because the units are licensed in accordance with applicable Safety Guide or Regulatory Guide and do not require the performance of this test and a fast start is performed on a loss of offsite power concurrent with an ESF signal once every 18 months. The loss of offsite power concurrent with an ESF signal performs some of the technical requirements listed in this SR. The ISTS SRs that follow are re-numbered to reflect this SR deletion.

13. ISTS SR 3.8.1.12 requires the fast start of each DG to rated voltage and frequency on an actual or simulated ESF actuation (SI) signal every 18 months. This requirement is not added because the units are licensed in accordance with applicable Safety Guide or Regulatory Guide and do not require the performance of this test and a fast start is performed on a loss of offsite power in conjunction with an ESF signal once every 18 months. This is another fast start of the DG with the machine not loading and the emergency buses continued to be powered from the offsite source. The ISTS SRs that follow are re-numbered to reflect this SR deletion.

14. ISTS SR 3.8.1.14 requires the performance of a 24-hour run for each DG every 18 months. This requires a minimum 2-hour run at 105 % to 110 % of rated load and the remaining time of 90 % to 100 % of rated load. ITS SR 3.8.1.10 requires a 2-hour run at C-15 a load of the CTS requirement of 2750 kW for Unit 1 and 4238 kW for Unit 2 to the 2000 hour load limit for each DG (Unit 1 2850 kW and Unit 2 4535 kW). The performance of the two-hour run within the specified load band ensures the capability of the DG to C-15 sustain the full emergency loading requirements without excessive loading. This is acceptable for Unit 1 because Safety Guide 9, the Unit's current licensing basis, did not require the performance of the 24-hour run. For Unit 2 this is acceptable because it is the current licensing basis described in the UFSAR. As stated in the Unit 2 UFSAR Section 1.8, 'Conformance to NRC Regulatory Guides," with regard to the testing requirements of Regulatory Guide 1.108:

              'Paragraph C.2.a(3) suggests a periodic 24-hour, full-load-carrying capability test consisting of 22 hours at the continuous diesel generator rating and 2 hours at the 2-hour rating. Such a test is appropriate only for initial qualification of the diesel BVPS Units 1 & 2                           Page 3                                    Revision 2, 4/06 47

I Rev. 2 Change C-4I ELECTRICAL POWER SYSTEMS I ITS 3.8.1 UNIT I PAGE] ik.djl SURVEILLANCE REQUIREMENTS (Continued) 3 Simulating a loss of offsite power in conjunction th a ety injection signal, and: Note that changes to this ergization of t ergency busses portion of the UnitITS ing from th rgency busses. are addressed in the el starts from standby markup of the Unit 2 TS. e au art signal, energizes Lle11C ciY busses with nently connected la in S 10 seconds, energ the aut:o-onnected emergency loads through e load sequencer and operates for 2 5 minutes wh .ts nnmrntfr ; A 1r w, th th- r 1 Atter energization ot these loads, the steady state voltage and frequency shall be maintained at 2 4106 volts and < 4368 volts, and 2 60.0 Hz and < 60.4 Hz. _12 Verifying that on loss of'"pewer to the emergenu busses, all sel generator trips, except eng-. overs enerator differential and overcurrent, al matically disabledI I Insei BEAVER VALLEY - UNIT 1 3/4 8-4a Amendment No. 230 184

BVPS ISTS Conversion Rev. 2 Change C-4 3.8 Electrical Power System!; Enclosure 3 Changes to CT'S start simultaneously. The DGs continue to be tested at least once per 10 years. The design change program controls any modification that could challenge the DG independence and would require appropriate testing. The ITS requirements are consistent with the ISTS wording for these requirements. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS. L.17 (Category 7- Relaxation Of Surveillance Frequency) CTS LCO 3.8.1.1.b.3 states for the DGs to be OPERABLE, each DG must have a separate fuel transfer pump. CTS SR 4.8.1.1.2.a.4 states that at least once per 31 days the fuel transfer pump can start and transfer fuel from the storage tank to the day tank. CTS SR 4.8.1.1 .2.a.4 for Unit I additionally specifies this requirement includes the transfer of fuel to the engine mounted tank. ITS SR 3.8.1.6 states, 'Verify the fuel oil transfer system operates to transfer fuel oil from storage tank to the day tank." The SR must be performed every 92 days. This changes the CTS by requiring the SR to be performed every 92 days in the ITS where the CTS required it to be performed every 31 days. This change also deletes the requirement for the engine mounted tank for Unit 1. The purpose of ITS SR 3.8.1.6 is to ensure the fuel oil transfer system is tested at a frequency consistent with ASME Section Xl test requirements. This change is acceptable because the new Surveillance Frequency provides an acceptable level of equipment reliability. The change in surveillance frequency from 31 to 92 days is acceptable because the SR corresponds to the frequency required by ASME inservice testing of pumps. Operating experience has shown that the surveillance requirement is performed with a satisfactory result. The deletion of the engine mounted tank for Unit I is acceptable because the fuel oil transfer pump only directly transfers fuel oil to the day tank. The day tank is above the engine-mounted tank and supplies the engine-mounted tank by gravitr. Thus, this change clarifies the intent of the surveillance requirement. In addition, the elimination of the reference to the Unit 1 engine mounted tank helps to make the Unit 1 and Unit 2 requirements more consistent. The proposed ITS requirements are consistent with the ISTS wording for these requirements. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS. L.18 Not used. BVPS Units I & 2 Page 9 Revision 2, 4/06 221

Rev. 2 Change C-4 BVPS ISTS Conversion 3.8 Electrical Power Systems Enclosure 3 Changes to CT'; The purpose of the power factor is to ensure the DG is tested under load conditions that are as close to design basis conditions as possible. This change is acceptable because the power factor is representative of the actual inductive loading a DG would see under design basis accident conditions. Under certain conditions, however, Note 2 allows the surveillance to be conducted at a power factor other than the limit. These conditions occur when grid voltage is high, and the additional field excitation needed to get the power factor to the limit. Under these conditions, the power factor should be maintained as close as practicable to the limit while still maintaining acceptable voltage limits on the emergency busses. In other circumstances, the grid voltage may be such that the DG excitation levels needed to obtain a power factor of the limit may not cause unacceptable voltages on the emergency busses, but the excitation levels are in excess of those recommended for the DG. In such cases, the power factor shall be maintained as close as practicable to the limit without exceeding the DG excitation limits. The ITS requirements are consistent with the ISTS wording for this requirement. This change is designated as more restrictive because it adds additional surveillance requirement that the CTS does not require. M.12 CTS surveillance requirement 4.8.1.1 .2.a.6 requires the verification that the generator is synchronized, loaded to the bus at a specific kW rating, and operated for 60 minutes or longer. ITS SR 3.8.1.3 requires the verification that each DG is synchronized and load and operates for 2 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. The purpose of the ITS notes are to set specific limitations for testing of a DG. These changes are acceptable because they place limitations on testing of the DGs that are currently practiced. The ITS requirements are consistent with the ISTS wording for this requirement. This change is designated as more restrictive because it adds additional surveillance requirement that the CTS does not require. M.1 3 CTS surveillance 4.8.1.1.2.c.1 requires the diesel generator day tank to be checked for water and the accumulated water removed. The corresponding ITS SR 3.8.1.5.1 requires 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. The purpose of the SR is to provide assurance that accumulated water will not go undetected in the DG fuel oil supply. The proposed change to check the engine mounted tank as well as the day tank provides additional assurance that any water accumulation in the DG fuel oil system will not go undetected. This change is designated as more restrictive because it adds an additional requirement to the CTS surveillance. BVPS Units 1 & 2 Page 16 Revision 2, 4/06 228

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 CHANGE C-5 Database# 200510131504 & 200601181405 NRC Commenter: K. Wood & K. Desai BSI-7,8,9,10&11 BVPS agreed to withdraw the changes proposed in BSI #s 7-10 and modify the change proposed in BSI 11 to be more consistent with the ISTS. This change affects the performance notes in Surveillance Requirements 3.4.5.3, 3.4.6.3, 3.4.7.3, 3.4.8.2, and 3.9.5.2. The purpose of the surveillances is to verify power available to the required standby pumps every 7 days. For the Section 3.4 surveillances, this change results in restoring the time allowed to perform the surveillance after a pump is shutdown to 24 hours (as specified in the corresponding ISTS surveillances) instead of the 7 days originally proposed by BVPS for these surveillances. The affected note was not present in ISTS Surveillance Requirement 3.9.5.2. BSI 11 added the Note to the Section 3.9 surveillance consistent with the similar ISTS surveillance notes in Section 3.4. The addition of the note to Surveillance Requirement 3.9.5.2 by BSI 11 is not withdrawn. However, the Note proposed in BSI 11 is modified by this change to incorporate the ISTS 24 hour allowance for performing this surveillance instead of the originally proposed 7 days. In addition, the Bases for ITS Surveillance Requirement 3.9.5.2 was revised to be consistent with the Bases of the similar Surveillance Requirements in Section 3.4. The result of this change is to make the original BVPS proposed notes in Sections 3.4 and 3.9 conform to the corresponding ISTS notes in Section 3.4. Affected Pages: The following Table(s) list the affected pages by type (i.e., ITS markup, CTS markup, etc.). In order to facilitate review by ITS section, a separate table is provided for each ITS section affected by the change. The page numbers listed are the ITS section specific consecutive numbers found In the lower right corner of each page. Note: Because the affected page(s) for each change were extracted from a complete ITS section electronic file, the electronic hyperlinks (created in the complete ITS section file) do not work in the collection of affected pages that follow this cover page. (continued)

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT 2) REVIS11N 2 Change C-5 (continued) ITS SECTION 3A (RCS) INDEX OF AFFECTED PAGES ITS MARKUPS PAGES: 13,15,18 & 20 ITS JFDS PAGES: 59, 60, 61, 62, 63, 64, 67 & 68 ITS BASES MARKUPS PAGES: 116, 121,126 & 129, ITS BASES JFDS No changes CTS MARKUPS PAGES: 227, 229, 232 & 235 CTS DOCS PAGES: 304, 312, 319 & 326 ITS SECTION 3.9 (REFUELING OPERATIONS) INDEX OF AFFECTED PAGES ITS MARKUPS PAGE: 16 ITS JFDS PAGES: 29 & 30 ITS BASES MARKUPS PAGE: 60 ITS BASES JFDS No change CTS MARKUPS PAGE: 91 CTS DOCS No change

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) NOs. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 CHANGE C5 AFFECTED PAGES FOR ITS SECTION 3.4 ITS SECTION 3.4 (RCS) INDEX OF AFFECTED PAGES ITS MARKUPS PAGES: 13,15, 18 & 20 ITS JFDS PAGES: 59, 60,61, 62, 63, 64, 67 & 68 ITS BASES MARKUPS PAGES: 116,121,126 & 129, ITS BASES JFDS No changes CTS MARKUPS PAGES: 227, 229, 232 & 235 CTS DOCS PAGES: 304, 312, 319 & 326

I Rev. 2 Change C-5 I RCS Loops - MODE 3 I_!- -i-j~ 3.4.5 SURVkANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.4.5.2 \^Verify steam generator secondary side water levels are 12 hours x I17Ž4 for required RCS loops. SR 3.4.5.3

                                             - NOTE -

Not required to be performed until 24 hours after a required pump is not in operation. Verify correct breaker alignment and indicated power 7 days are available to each required pum not inoperatio iL WOG STS 3.4.5 -3 Rev. 2, 04/30/01 13

I Rev. 2 Change C-5 I BVPS ISTS Conversion 3.4 Reactor Coolant System Enclosure I Changes to ISTS ITS 3.4.5 RJCS Loops - Mode 3 JUSTIFICATION FOR DEVIATION (JFD)

1. ITS 3.4.5 Condition D is revised to be consistent with the BVPS specific design and CTS requirements. In ITS 3.4.5, one or two of the three RCS loops are required to be in operation depending on whether or not the rod control system is capable of rod withdrawal or not. ITS Condition C addresses the condition where I required loop out of two is not in operation. In order for ITS Condition C and Condition D to work properly, Condition D should address the condition where no RCS loops are operating. ITS Condition D contains the immediate Actions appropriate for a loss of function similar to CTS Action statement c. If ITS Condition D specifies "Required" loops not in operation (as it appears in the ISTS) it may be considered to be applicable at the same time as Condition C (1 required loop not in operation) and cause confusion. Therefore, Condition D is revised to more consistent with the corresponding CTS Action statement c (with no reactor coolant loop in operation).

This maintains the current BVPS licensing basis for this Action as specified in the CTS.

2. Not used.

BVPS Units I & 2 Page 5 Revision 2, 4/06 59

BVPS ISTS Conversion I Rev. 2 Change C-5 I 3.4 Reactor Coolant System Enclosure I Changes to ISTS

3. ISTS surveillance 3.4.5.3 requires the verification of correct breaker alignment and indicated power to each required pump every 7 days. The corresponding CTS surveillance (4.4.1.2.2) specifies a similar requirement with one important clarification. The corresponding CTS surveillance is only applicable to the non-operating pumps. The ISTS surveillance is revised to incorporate the CTS clarification that the surveillance is only applicable to the non-operating pumps.

The CTS clarification is reasonable and appropriate since the verification of correct breaker alignment and indicated power is not necessary for operating equipment. A separate surveillance continues to verify the required pump/loop(s) are in operation and provides adequate verification of the operating equipment. Considering that the operating pump/loop must be verified in operation every 12 hours, the ISTS requirement to verify the breaker alignment and power availability to the same operating pump every 7 days does not add a significant safety benefit. The proposed change makes the two surveillances (operating and non-operating equipment verifications) work together logically to provide adequate verification of the required pump/loop status and to assure the plant is operated in a safe manner. The proposed change is consistent with the similar Mode 6 ISTS surveillance (SF' 3.9.6.2) that verifies the breaker alignment and power availability to the required RHR pump that is not in operation. The proposed change is also consistent with the current licensing basis for BVPS as approved by the NRC in the CTS. Therefore, the proposed change is acceptable and does not reduce the level of assurance provided by the TS. BVPS Units 1 & 2 Page 6 Revision ;, 4/06 60

Rev. 2 Change C-5 RCS Loops - MODE 4 3.4.6 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME A.2

                                                    - NOTE -

Only required if RHR loop is OPERABLE. Be in MODE 5. 24 hoursl[UEG-143I, Rev.3 B. Two required loops B.1 Suspend operations that Immediately inoperable. would cause introductions K into the RCS-coolant-with of coolantl OR boron concentration less than required to meet SDM Required loop not in of LCO 3.1.1.. operation. AND B.2 Initiate action to restore Immediately one loop to OPERABLE status and operation. l28%O (Unit 1), Ž2hS~U 2H E SURVEILLANCE REQUIREMENTS/= SURVEILLANCE FREQUENCY SR 3.4.6.1 Verify required RHR or RCS loop is in operationZ 12 hours SR 3.4.6.2 Verify SG secondary side water levels are 2 474% for 12 hours required RCS loops. SR 3.4.6.3

                                      - NOTE -

Not required to be performed until 24 hours after a required pump is not in operation. i not inoperation.i I Verify correct breaker alignment and in ed power 7 days are available to each required pum WOG STS 3.4.6 -2 Rev. 2, 04/30/01 15

BVPS ISTS Conversion Rev. 2 Change C-5 I 3.4 Reactor Coolant System Enclosure 1 Changes to ISTS ITS 3.4.6 RCS Loops - Mode 5 JUSTIFICATION FOR DEVIATION (JFD)

1. ISTS 3.4.6 LCO Note 2 specifies limitations applicable to starting RCPs at low RC S temperature conditions. The standard ISTS note is revised to incorporate the provisions of the corresponding CTS 3.4.1.3 note. The significant changes to the ISTS note are the applicability of the note being changed to the start of the first RCP and qualifying the application of the note to non-isolated loops only. These changes are consistent with the CTS and have already been reviewed and approved by the NRC. In summary, once the first pump is started, sufficient mixing in non-isolated loops assures the temperature limit is met for subsequent pump starts. In addition, loop isolation valves are part of the BVPS design and loops may be isolated during shutdown conditions. Therefore, unlike many Westinghouse plants, the BVPS specific version of this note must address whether or not the loop is isolated.

2. Not used.

BVPS Units 1 & 2 Page 7 Revision 2, 4/06 61

I Rev. 2 Change C-5 1 BVPS ISTS Conversion 3.4 Reactor Coolant System Enclosure I Changes to ISTS

3. ISTS surveillance 3.4.6.3 requires the verification of correct breaker alignment and indicated power to each required pump every 7 days. The corresponding CTS surveillance (4.4.1.3.2) specifies a similar requirement with one important clarification. The corresponding CTS surveillance is only applicable to the non-operating pumps. The ISTS surveillance is revised to incorporate the CTS clarification that the surveillance is only applicable to the non-operating pumps.

The CTS clarification is reasonable and appropriate since the verification of correct breaker alignment and indicated power is not necessary for operating equipment. A separate surveillance continues to verify the required pump/loop(s) are in operation and provides adequate verification of the operating equipment. Considering that the operating pump/loop must be verified in operation every 12 hours, the ISTS requirement to verify the breaker alignment and power availability to the same operating pump every 7 days does not add a significant safety benefit. The proposed change makes the two surveillances (operating and non-operating equipment verifications) work together logically to provide adequate verification of the required pump/loop status and to assure the plant is operated in a safe manner. The proposed change is consistent with the similar Mode 6 ISTS surveillance (SF' 3.9.6.2) that verifies the breaker alignment and power availability to the required RHR pump that is not in operation. The proposed change is also consistent with the current licensing basis for BVPS as approved by the NRC in the CTS. Therefore, the proposed change is acceptable and does not reduce the level of assurance provided by the TS. BVPS Units 1 & 2 Page 8 Revision 2,4/06 62

RCS Loops - MODE 5, Loops Filled I Rev. 2 Change C-5 I 3.4.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.7.1 Verify required RHR loop is in operation. 12 hours SR 3.4.7.2 Verify SG secondary side water levels is Ž-17A in 12 hours required SGs. X1 o (Uni1), 2 SR 3.4.7.3

                                   - NOTE -

Not required to be performed until 24 hours after a LCTS required pump is not in operation. I Verify correct breaker alignment and indicated power 7 days are available to each required RHR pumas not in operation. WOG STS 3.4.7 - 3 Rev. 2, 04/30/0-1 18

Rev. 2 Change C-5 BVPS ISTS Conversion 3.4 Reactor Coolant System Enclosure 1 Changes to ISTS ITS 3.4.7 RCS Loops - Mode 5, Loops Filled JUSTIFICATION FOR DEVIATION (JFD)

1. ISTS 3.4.7 LCO Note 3 specifies limitations applicable to starting RCPs at low RC:S temperature conditions. The standard ISTS note is revised to incorporate the provisions of the corresponding CTS 3.4.1.3 note. The significant changes to the ISTS note are the applicability of the note being changed to the start of the first RCP and qualifying the application of the note to non-isolated loops only. These changes are consistent with the CTS and have already been reviewed and approved by the NRC. In summary, once the first pump is started, sufficient mixing in non-isolatec' loops assures the temperature limit is met for subsequent pump starts. In addition, loop isolation valves are part of the BVPS design and loops may be isolated during shutdown conditions. Therefore, unlike many Westinghouse plants, the BVPS specific version of this note must address whether or not the loop is isolated.

2 The ISTS LCO 3.4.7 requirement for the secondary side steam generator water level contains an option for how many steam generators are required. The LCO requirement is based on the number of steam generators required to assure a sufficient heat sink to remove decay heat via natural circulation. For BVPS, a single steam generator has sufficient capacity to remove decay heat via natural circulati n. The LCO, and corresponding Actions, are revised accordingly.

3. ISTS surveillance 3.4.7.3 requires the verification of correct breaker alignment and indicated power to each required pump every 7 days. The corresponding CTS surveillance (4.4.1.3.2) specifies a similar requirement with one important clarification. The corresponding CTS surveillance is only applicable to the non-operating pumps. The ISTS surveillance is revised to incorporate the CTS clarification that the surveillance is only applicable to the non-operating pumps.

The CTS clarification is reasonable and appropriate since the verification of correct breaker alignment and indicated power is not necessary for operating equipment. A separate surveillance continues to verify the required pump/loop(s) are in operation and provides adequate verification of the operating equipment. Considering that the operating pump/loop must be verified in operation every 12 hours, the ISTS requirement to verify the breaker alignment and power availability to the same operating pump every 7 days does not add a significant safety benefit. The proposed change makes the two surveillances (operating and non-operating equipment verifications) work together logically to provide adequate verification of the required pump/loop status and to assure the plant is operated in a safe manner. The proposed change is consistent with the similar Mode 6 ISTS surveillance (SR 3.9.6.2) that verifies the breaker alignment and power availability to the required RHR pump that is not in operation. The proposed change is also consistent with the current licensing basis for BVPS as approved by the NRC in the CTS. Therefore, the proposed change is acceptable and does not reduce the level of assurance provided by the TS.

4. Not used.

BVPS Units 1 & 2 Page 9 Revision 2, 4/06 63

I Rev. 2 Change C-5 I BVPS ISTS Conversion 3.4 Reactor Coolant System Enclosure I Changes to ISTS

5. The ISTS 3.4.7 and ISTS 3.4.8 applicability of Mode 5 with RCS loops filled (3.4.7) and Mode 5 with RCS loops not filled (3.4.8) are revised to take into account the BVPS RCS loop isolation valves. The BVPS specific version of the ISTS 3.4.7applicability is "Mode 5 with one or more RCS Loops Unisolated and Filled".

The BVPS specific version of the ISTS 3.4.8 applicability is " All RCS Loops Isolated or Unisolated RCS Loops not Filled." BVPS Units 1 & 2 Page 10 Revision 2, 4/06 64

RCS Loops - MODE 5, Loops Not Filled I Rev. 2 Change C-5l 3.4.8 lant ACTIONS (continued) CONDITION I REQUIRED ACTION A COMPLETION TIME B. No required RHR loop B.1 Suspend operations that Immediately I OPERABLE. would cause introductiov into the RCS, cGolan with OR boron concentration less than required to meet SDM l NUREG-1431, in Required RHR loop not in of LCO 3.1.1. operation. AND B.2 Initiate action to restore Immediately one RHR loop to OPERABLE status and operation. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.8.1 Verify required RHR loop is in operation. 12 hours SR 3.4.8.2

                                     - NOTE -

Not required to be performed until 24 hours after a required pump is not in operation. Verify correct breaker alignment and indicated power 7 days are available to each required RHR pump'

                                                                  \n      no    op r t o .l       -II:

WOG STS 3.4.8 - 2 Rev. 2, 04/30/01 20

BVPS ISTS Conversion I Rev. 2 Change C-5 I 3.4 Reactor Coolant System Enclosure 1 Chanaes to lISTS proposed change makes the two surveillances (operating and non-operating equipment verifications) work together logically to provide adequate verification of the required pump/loop status and to assure the plant is operated in a safe manner. The proposed change is consistent with the similar Mode 6 ISTS surveillance (SR 3.9.6.2) that verifies the breaker alignment and power availability to the required RHR pump that is not in operation. The proposed change is also consistent with the current licensing basis for BVPS as approved by the NRC in the CTS. Therefore, the proposed change is acceptable and does not reduce the level of assurance provided by the TS.

3. Not used.

BVPS Units 1 & 2 Page 13 Revision;!, 4/06 67

BVPS ISTS Conversion I Rev. 2 ChagC- l 3.4 Reactor Coolant System Enclosure 1 Changes to lSTS BVPS Units 1 & 2 Page 14 Revision '2,4/06 68

RCS Loops - MODE 3 B 3.4.5 IRev. 2 Change C-5 BASES SURVEILLANCE REQUIREMENTS (continued) notin operation SR 3.4.5.3 Verification that each required RCP is OPERABLE ensures that safety analyses limits are met. The requirement also ensures that an additional RCP can be placed in operation, if needed, to maintain decay heat emoval and reactor coolant circulation. Verification is performed by v ifying proper breaker alignment and power availability to each required RC R. Alternatively, verification that a pump is in operation also verifies proper breaker alignment and power availability. This SR is modified by a Note that states the SR is not required to be performed until 24 hours after a required pump is not in operation. REFERENCES None. WOG STS B 3.4.5-6 Rev. 2, 04/30/01 116

RCS Loops - MODE 4 B 3.4.6 Rev. 2 Change C-5 BASES SURVEILLANCE REQUIREMENTS (continued) indications available in the control room to alert the operator to the loss of SG level. l not inoperain ok R3.63 rification that each required pump is OPERABLE ensures that an ad al RCS or RHR pump can be placed in operation, if needed, to maintain cay heat removal and reactor coolant circulation. Verification 2 is performed verifying proper breaker alignment and power available to each required pu . Alternatively, verification that a pump is in operation also verifies proper breaker alignment and power availability. The Frequency of 7 days is considered reasonable in view of other administrative controls available and has been shown to be acceptable by operating experience. This SR is modified by a Note that states the SR is not required to be performed until 24 hours after a required pump is not in operation. REFERENCES None. WOG STS B 3.4.6-5 Rev. 2, 04/30/01 121

lRev. 2 Change C-5 RCS Loops - MODE 5, Loops Filled B 3.4.7 BASES EHD 28 orUito 2 15.5% for Unit 2 SURVEILLANCE REQUIREMENTS (continuedl) SR 3.4.7.2 1 nuiolated l X /l Verifying that at least SG6 aeOPERA E by ensuring secondary side narrow range water levels are Ž 0 ensures an alternate decay heat removal method via natural circulation in the event that the second RHR loop is not OPERABLE. If both RHR loops are OPERABLE, this Surveillance is not needed. The 12 hour Frequency is considered adequate in view of other indications available in the control room to alert the operator to the loss of SG level. SR 3.4.73 S 28% for for 15.5% UnitUnit I or2> 1 one unisoatdI Verification that each requi ed RHR pump is PERABLE ensures that an additional pump can be plqced in operation, needed, to maintain decay not Inoperation. eat removal and reactor/coolant circulatio Verification is performed by ye proper breaker lignment and po er available to each required RHR pun Alternativey, verification thafa pump is in operation also verifies proper breake alignment and p er availability. If secondary side water level is 2 Ot in at least tA SGs, this Surveillance is not needed. The Frequency of 7 days is considered reasonable in view of other administrative controls available and has been shown to be acceptable by operating experience. This SR is modified by a Note that states the SR is not required to be performed until 24 hours after a required pump is not in operation. REFERENCES 1. NRC Information Notice 95-35, "Degraded Ability of Steam Generators to Remove Decay Heat by Natural Circulation."

2. Westinghouse Letter # FENOC-04-228, "Beaver Valley Units 1 and 2 Mode 5, Loops Filled Natural Circulation Cooling Assessment, dated January 31, 2005."

WOG STS B 3.4.7 - 5 Rev. 2, 04/30/01 126

RCS Loops - MODE 5, Loops Not Filled B 3.4.8 Rev. 2 Change C-5 BASES ACTIONS (continued) assure continued safe operation. With coolant added without forced circulation, unmixed coolant could be introduced to the core, however coolant added with boron concentration meeting the minimum SDM maintains acceptable margin to subcritical operations. The immediate Completion Time reflects the importance of maintaining operation for heat removal. The action to restore must continue until one loop is restored to OPERABLE status and operation. SURVEILLANCE SR 3.4.8.1 REQUIREMENTS This SR requires verification every 12 hours that the required loop is in operation. Verification includes flow rate, temperature, or pump status monitoring, which help ensure that forced flow is providing heat removal. The Frequency of 12 hours is sufficient considering other indications and alarms available to the operator in the control room to monitor RHR loop performance. SR 3.4.8.2 Verification that each required pump is OPERABLE ensures that an additional pump can be placed in operation, if needed, to maintain decay not in operation heat removal and reactor coolant circulation. Verification is performed by ifying proper breaker alignment and power available to each required

                      .pumt.Alternatively, verification that a pump is in operation also verifies (Di                 proper breaker alignment and power availability. The Frequency of 7 days is  considered reasonable in view of other administrative controls available and has been shown to be acceptable by operating experience.

This SR is modified by a Note that states the SR is not required to be performed until 24 hours after a required pump is not in operation. REFERENCES None. WOG STS B 3.4.8 - 3 Rev. 2, 04/30/01 129

I Rev. 2 Change C-5 REACTOR COOLANT SYSTEM I SR 3.4.5.1 The required RCS loops 0 >SURVEILLANCE REQUIREMENTS / = at least two cooling loops shall be verified to be in operation and circu ating reactor coo ant at lnwqt opce per 12 hours. l 14A A 1 9 9 Witfh -ha r-A -nn- tr_ I .at-m nr~nnnr at m in 1-hn-Ai-at least two cooling loops, if not in operation, shall be determined to be OPERABLE once per 7 days by verifying correct breaker alignments and indicated power availability. T at least one coolin be in operation anc circulatinr reac.tor -~-j I/ SR 3.4.5.3 NOTE Not required to be performed until 24 hours after a required pump is not In operation. I Verify correct breaker alignment and Indicated power are available to each required pump not In operation every 7 days. SR 3.4.5.2 Verify steam generator secondary side water levels are 2 28% (Unit 1) 15.5% (Unit 2) for required RCS loops every 12 hours. M4 BEAVER VALLEY - UNIT 2 3/4 4-2a Amendment No. 131 227

BVPS ISTS Conversion Rev. 2 Change C-5 3.4 Reactor Coolant System Enclosure 3 Changes to CTS proposed change continues to ensure that the plant is operated within the assumptions of the safety analyses. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS. L.3 (Category 7 - Relaxation of Surveillance Frequency) CTS surveillance 4.4.1.2.2 specifies that the RCS loops not in operation be verified operable once per 7 days by verifying correct breaker alignments and indicated power availability. The proposed ITS surveillance SR 3.4.5.3, although simplified when compared to the CTS surveillance, requires the same verifications every 7 days but includes a note that states the surveillance is " Not required to be performed until 24 hours after a required pump is not in operation." The CTS is revised to conform to the proposed ITS surveillance SR 3.4.5.3. This changes the CTS by allowing credit to be taken for recent pump operation to meet the surveillance such that the surveillance is not required to be performed until 24 hours after the pump is removed from operation. The CTS surveillance verifies the readiness (operability) of the standby pumps by breaker alignment and power available checks. This provides reasonable assurance that the pump can be started when needed. The CTS surveillance does not require that a pump be started or run to provide this assurance. The proposed change provides the allowance to consider this surveillance requirement met at the time a pump is removed from operation. The proposed change is acceptable because it continues to provide an equivalent level of assurance that the pump is ready to start. The proposed change is also consistent with the ISTS SR 3.4.5.3 Bases explanation that verification of a pump in operation also verifies proper breaker alignment and power availability. The fact that the pump was just in operation provides better assurance of pump operability than simply verifying power available and breaker alignment without operating the pump. Therefore, a pump just removed from service may be considered operable (for the purposes of this surveillance) for up to 24 hours. Re- verifying the power availability and breaker alignment of a pump that has just been in operation is unnecessary. This change is designated as less restrictive because less frequent surveillances will be performed in the ITS than were in the CTS. More Restrictive Changes (M) M.1 The CTS 3.4.1.2 LCO item a specifies that two RCS loops be in operation when the rod 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. The purpose for the CTS and ISTS requirement regarding RCS loops in Mode 3 is to ensure adequate RCS flow to remove decay heat and to ensure the accident analyses limits are met for an inadvertent control rod withdrawal from subcritical conditions. The proposed change is acceptable because it is consistent with the BVPS Units 1 & 2 Page 11 Revision ;, 4/06 304

LITS 3.4.6 RCS Loops - MODE 4 REACTOR COOLANT SYSTEM Rev. 2 Change:C-5l LIMITING CONDITION FOR OPERATION Note: Only required if RHR loop is operable.i ACTION: Lo-

            \    a.Fih              1es        than oke above re qui-r-ed loops- GPERABvI,~

_ mediately initias corrective action to return tetL icopinoperabte required loops to OPE ABLE status as soon as possible; be _ic in COLD SHUTDOWN within 4 hours, or two required loops inoperablk b.

                 @       With no coolant loop in                   operatio ,           suspend all operaticns irvligCreduetien                    in      bercRn       P. ncznnr-at~isn         Cf       h4eM lInsert                      Rc-ctorCoolant System and immediately initiate corrective                                       -

action to return the required coolant loop to operationw, and OPERABLE status. SURVEILLANCE REQUIREMENTS 4.4.1.3.1 The requived-re9ilhtrC~iLtd lops)sall determined OPERM TtE pl SpecltlCati

       + .4. . B.            The required reactor coolant pump(s),                                       if      not      in operation,          shall be determined to be OPERABLE once per 7 days by verifying            correct         breaker           alignments             and       indicated            power
        ,Lva; IqAbility.

SR 3.4.6.3 l

3.3 The required steam generator(s) shall be determined OPERABLE by verifyin secondary side level greater than or equal to 15.5 percent narrow ran e at nce per 12 hours.

4.A1.3A At least one coo ant oop all be verified to be in operatio and circulating reactor coolantlat st once per 12 hours. SR 3.4. SR 3.4.6.1 l Not required to be performed until 24 hours after a required pump is not In operation. BEAVER VALLEY - UNIT 2 3/4 4-4 Amendment No.14E 229

BVPS ISTS Conversion Rev. 2 Change C-5 3.4 Reactor Coolant System Enclosure 3 Changes to CTS provides reasonable and adequate test requirements to verify RHR system operability for the functional requirements of normal shutdown operations. This change is acceptable because the deleted Surveillance Requirement is not necessary to verify that the equipment used to meet the LCO can perform its required functions. The proposed change is also acceptable because the tests and inspections required by the ASMIE code will continue to be performed in accordance with the applicable federal regulations and the ITS Inservice Testing Program. Therefore, the RHR systems will continue to be tested in a manner and at a frequency necessary to give confidence that the equipment can perform its assumed function. This change is designated as less restrictive because Surveillances which are required in the CTS will not be required in the ITS. L.4 (Category 7 - Relaxation of Sunreillance Frequency) CTS surveillance 4.4.1.3.2 specifies that the RCS loops not in operation be verified operable once per 7 days by verifying correct breaker alignments and indicated power availability. The proposed ITS surveillance SR 3.4.6.3, although simplified when compared to the CTS surveillance, requires the same verifications every 7 days but includes a note that states the surveillance is " Not required to be performed until 24 hours after a required pump is not in operation." The CTS is revised to conform to the proposed ITS surveillance SR 3.4.6.3. This changes the CTS by allowing credit to be taken for recent pump operation to meet the surveillance such that the surveillance is not required to be performed until 24 hours after the pump is removed from operation. The CTS surveillance verifies the readiness (operability) of the standby pumps by breaker alignment and power available checks. This provides reasonable assurance that the pump can be started when needed. The CTS surveillance does not require that a pump be started or run to provide this assurance. The proposed change provides the allowance to consider this surveillance requirement met at the time a pump is removed from operation. The proposed change is acceptable because it continues to provide an equivalent level of assurance that the pump is ready to start. The proposed change is also consistent with the ISTS SR 3.4.6.3 Bases explanation that verification of a pump in operation also verifies proper breaker alignment and power availability. The fact that the pump was just in operation provides better assurance of pump operability than simply verifying power available and breaker alignment without operating the pump. Therefore, a pump just removed from service may be considered to be operable (for the purposes of this surveillance) for up to 24 hours. Re- verifying the power availability and breaker alignment of a pump that has just been in operation is unnecessary. This change is designated as less restrictive because less frequent surveillances will be performed in the ITS than were in the CTS. More Restrictive Changes (M1 BVPS Units 1 & 2 Page 19 Revision 2, 4/06 312

7ITS 3.4.7 RCS Loops - MODE 5 Loops Filled REACTOR COOLANT SYSTEM I Rev. 2 Change C-5 C) LIMITING CONDITION FOR OPERATION

  \     ACTIC                                                                                                                AN:

a-. With less than the above required loops OPERABLE, - immediately initiate corrective action to return the required loops to OPERABLE status as seen as pessible-t-iCLD SHUTDGWN within 20 heurz. or no required RHR loops operable loop in operatio , suspend all operaticns ) a Aedete :n ns : d^ncatienof the fReactor Coolant System and immediately initiate corrective action to return the required loop o to olantoperation*_ pert1 l/ land operable tam

    -+1.      .  ..         The      required          reactor        coolant         pump(s),           if     not       in operation, shall be determined to be OPERABLE once per 7 days by verifying            correct          breaker          alignment             and        indicated            power t       avilaility.

SR 3A..7.3 l 1h.4 1.3.3 The required steam generator(s) shall be determined

    /OPERABLE by verif inq se ondary side level greater than or equal to
            ! 1 rcentinarrow range at leastonc                               r 12 hours.              Ml SR 3.4..2 I                                               _/    RH                               Tml At least one eele                 t loop shall be verified to be in Kope-ationnand circulating reactor coolant at least once per 12 hours.

g R 3.4.7.1 1 A_ 1lasesLA NOTE Not required to be performed until 24 hours after a required pump Is not In operation. L5 I BEAVER VALLEY - UNIT 2 3/4 4-4 Amendment No. 145 232

lRev._C-5 2 Change BVPS ISTS Conversion 3.4 Reactor Coolant System Enclosure 3 Changes to CrS L.5 (Category 7 - Relaxation of Sunreillance Frequency) CTS surveillance 4.4.1.3.2 specifies that the RCS loops not in operation be verified operable once per 7 days by verifying correct breaker alignments and indicated power availability. The proposed ITS surveillance SR 3.4.7.3, although simplified when compared to the CTS surveillance, requires the same verifications every 7 days but includes a note that states the surveillance is " Not required to be performed until 24 hours after a required pump is not in operation." The CTS is revised to conform to the proposed ITS surveillance SR 3.4.7.3. This changes the CTS by allowing credit to be taken for recent pump operation to meet the surveillance such that the surveillance is not required to be performed until 24 hours after the pump is removed from operation. The CTS surveillance verifies the readiness (operability) of the standby pumps by breaker alignment and power available checks. This provides reasonable assurance that the pump can be started when needed. The CTS surveillance does not require that a pump be started or run to provide this assurance. The proposed change provides the allowance to consider this surveillance requirement met at the time a pump is removed from operation. The proposed change is acceptable because it continues to provide an equivalent level of assurance that the pump is ready to start. The proposed change is also consistent with the ISTS SR 3.4.7.3 Bases explanation that verification of a pump in operation also verifies proper breaker alignment and power availability. The fact that the pump was just in operation provides better assurance of pump operability than simply verifying power available and breaker alignment without operating the pump. Therefore, a pump just removed from service may be considered to be operable (for the purposes of this surveillance) for up to 24 hours. Re- verifying the power availability and breaker alignment of a pump that has just been in operation is unnecessary. This change is designated < s less restrictive because less frequent surveillances will be performed in the ITS than were in the CTS. More Restrictive Changes (Mi M.1 CTS 3.4.1.3 requires that two coolant loops must be OPERABLE in MODES 4 ani 5 and 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 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. The purpose of the TS cooling loop requirements is to assure an adequate means of decay heat removal is maintained to assure the safe operation of the plant. The proposed change is acceptable because ISTS 3.4.7 is only applicable in Mode 5 while the CTS requirements must fit both Modes 4 and 5. In MODE 5, the RHR BVPS Units I & 2 Page 26 Revision 2, 4/06 319

ITS 3.4.8 RCS Loops - Mode 5 Loops Not Filled REACTOR COOLANT SYSTEM I Rv.2 hanne C-5 LIMITING CONDITION FOR OPERATION ACTION:AiN

onerequired RHR loop Inoperable With the above required loops OPEMBIG, I\ immediately initiate corrective action to return the

__ r~equired loops to OPERABLE status as soon as possible; be or no required RHR loop operableN With loop in operationO, suspend all operations

                                                                                               -__- -  l: -_ -                   -P    S A.,

dULLlUII 111 UU Ull L'C9IIL L IILIflLlUII UL Lo1 Reactor Coolant System. and immediately initiate corrective action to return the required loop to operations, r I and operable status SURVEILLANCE REQUIREMENTS I/ 4.4.1.3.1 Te requllred--re-& i s) sha determined OP

        .1    .              The      required            reactor       voolant               pump (s),                 if      not        in operation,                shall be determined to be                              ERABLE once                      per 7 days by verifying                   correct          breaker              alignments                 and            i        cated           power

-=xrn i I = t lity. R SR 3.4.8.2 . s

               *         .uired                         steam       qenerator~s                   s-hajll           be--dLet-m~1r~e I

BEAVER VALLEY - UNIT 2 3/4 4-4 Amendment No. 14E 235

BVPS ISTS Conversion s 3.4 Reactor Coolant System Enclosure 3 Changes to CTS automatically or perform continuously at maximum design pressure and flows that are specific assumptions of a safety analysis. The RHR system only functions to remove decay heat and provide mixing of the reactor coolant. Demonstrating the operability of the required RHR loops may be accomplished by the verification of adequate flow in the operating loop to remove decay heat and verification of available power and breaker alignment of the standby loop (ITS SR 3.4.8.1 &SR 3.4.8.2). In addition, the RHR system is routinely operated during shutdown Modes and the RHR loops are instrumented so that significant degradation of the RHR system could be determined from the RHR System flow and temperature instrumentation in the Control Room. This change conforms to the ISTS and provides reasonable and adequate test requirements to verify RHR system operability for the functional requirements of normal shutdown operations. This change is acceptable because the deleted Surveillance Requirement is not necessary to verify that the equipment used to meet the LCO can perform its required functions. The proposed change is also acceptable because the tests and inspections required by the ASME code will continue to be performed in accordance with the applicable federal regulations and the ITS Inservice Testing Program. Therefore, the RHR systems will continue to be tested in a manner and at a frequency necessary to give confidence that the equipment can perform its assumed function. This change is designated as less restrictive because Surveillances which are required in the CTS will not be required in the ITS. L.4 (Category 7 - Relaxation of Surveillance Frequency) CTS surveillance 4.4.1.3.2 specifies that the RCS loops not in operation be verified operable once per 7 days by verifying correct breaker alignments and indicated power availability. The proposed ITS surveillance SR 3.4.8.2, although simplified when compared to the CTS surveillance, requires the same verifications every 7 days but includes a note that states the surveillance is " Not required to be performed until 24 hours after a required pump is not in operation." The CTS is revised to conform to the proposed ITS surveillance SR 3.4.8.2. This changes the CTS by allowing credit to be taker, for recent pump operation to meet the surveillance such that the surveillance is not required to be performed until 24 hours after the pump is removed from operation. The CTS surveillance verifies the readiness (operability) of the standby pumps by breaker alignment and power available checks. This provides reasonable assurance that the pump can be started when needed. The CTS surveillance does not require that a pump be started or run to provide this assurance. The proposed change provides the allowance to consider this surveillance requirement met at the time El pump is removed from operation. The proposed change is acceptable because it continues to provide an equivalent level of assurance that the pump is ready to start. The proposed change is also consistent with the ISTS SR 3.4.8.2 Bases explanation that verification of a pump in operation also verifies proper breaker alignment and power availability. The fact that the pump was just in operation provides better assurance of pump operability than simply verifying power available and breaker alignment without operating the pump. Therefore, a pump just removed from service may be considered to be operable (for the purposes of this surveillance) for up to 24 hours. Re- verifying the power availability and breaker alignment of a pump that has just been BVPS Units 1 & 2 Page 33 Revision 2, 4/06 326

BVPS UNITS 1 & 2 surf ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 169 (UNIT 2) REVISION 2 CHANGE C5 AFFECTED PAGES FOR ITS SECTION 3.9 (REFUELING OPERATIONS) ITS SECTION 3.9 (REFUELING OPERATIONS) INDEX OF AFFECTED PAGES ITS MARKUPS PAGE: 16 ITS JFDS PAGES: 29 & 30 ITS BASES MARKUPS PAGE: 60 ITS BASES JFDS No change CTSMARKUPS PAGE: 91 CTS DOCS No change

RHR and Coolant Circulation - Low Water Level I Rev. 2 Change C-5 l 3 . ACTIONS (contin ued) CONDITION REQUIRED ACTION COMPLETION TIME B.5.2 Verify each penetration is 4 hours capable of being closed by an OPERABLE Containment Purge and Exhaust Isolation System. SURVEILLANCE REQUIREMENTS _ SURVEILLANCE FREQUENCY SR 3.9 .1 Verify one RHR loop is in operation and &Gulatinq 12 hours

        /reac-tor            co        anta flvow rate- of >![2800] qpm.

SR 3.9.6.2 Veri correct breaker alignment and indicated power 7 days ava ble to the required RHR pump that is not in op ration. NOTE Not required to be performed until 24 hours afler a required pump is not in operation. 1' I WOG STS -3 Rev. 2, 04/30/01 16

I__ IBVPS ISTS Conversion Rev. 2 Change C-5 3.9 Refueling Operations Enclosure I Changes to ISTS ITS 3.9.5 RHR and Coolant Circulation - Low Water Level JUSTIFICATION FOR DEVIATION (JFD)

1. The ISTS surveillance for verifying RHR operation is revised to make the ISTS more consistent with the BVPS CTS. The proposed change eliminates the specific RHR flow rate specified in the surveillances of ISTS Section 3.9. The proposed change would make the operating RHR loop verification surveillances consistent with the corresponding RHR surveillances in ISTS Section 3.4, RCS. In Section 3.4, the bases for the operating RHR loop verification (SR 3.4.7.1) states that verification of operation includes verification of flow rate. The Bases for the corresponding Section 3.9 RHR loop verification surveillances is revised to be consistent with the Section 3.4 Bases and includes the requirement to verify the RHR flow. In addition, the proposed change is consistent with the corresponding CTS requirements applicable during normal operation (i.e., no dilution or reduced inventory operations). In conditions other than dilution or reduced inventory operations, the CTS does not specify a minimum flow rate for RHR.

The BVPS safety analyses do not assume a boron dilution event occurs in Modes 4, 5, and 6. In these Modes, TS requirements assure the unborated water source isolation valves are secured closed and accidental dilution precluded. Therefore, the specific RHR flow needed during Mode 6 operations is not the assumption of any safety analysis but is dependent on plant conditions which may vary through Mode 6 operation. The minimum RHR flow is dependent on plant conditions, such as water level, decay heat load, and component cooling water temperature. In some plant conditions (i.e., reduced inventory) maintaining a fixed high rate of flow could increase the likelihood of pump cavitation and loss of RHR cooling. The proposec change would allow some operating flexibility in determining the RHR flow at various plant conditions without adversely affecting plant safety. As such, the proposed surveillance requirement will continue to adequately verify the required RHR loop is operating and able to provide forced RCS flow for heat removal and prevent thermal and boron stratification.

2. A Note is added to ISTS SR 3.9.6.2 that allows the surveillance to be considered met for an RHR pump that was just removed from operation such that the next required performance of the surveillance is 24 hours after the pump is removed frcm service. The addition of this note is consistent with the fix that TSTF-265 implemented for other surveillances with the same requirements as ISTS SR 3.9.6.2 in Revision 2 of NUREG-1431. However, TSTF-265 did not address ISTS SR 3.9.6.2 even though it is the same surveillance as the others addressed in TSTF-265.

TSTF-265 recognized that some confusion could be introduced when RHR pumps are swapped under the current requirements of ISTS 3.9.6. The Surveillance that verifies the standby pump breaker alignment and power availability may be considered to be immediately not met for the RHR pump removed from operation. This interpretation is possible if a surveillance procedure must be performed in order to verify the standby RHR pump is available and this procedure can not be performed until the pump is removed from service. In this case, an Action entry BVPS Units 1 &2 Page 10 Revision 2, 4/06 29

BVPS ISTS Conversion IRev. 2 Change C-5 I 3.9 Refueling Operations Enclosure I Changes to ISTS would be required until the surveillance procedure was performed to verify the status of the standby RHR pump. TSTF-265 proposed a change that would allow 24 hours after a pump is removed from service to verify breaker alignment and power availability. The existing ISTS surveillance normally allows 7 days between verifications of breaker alignment and power availability. TSTF-265 justified this change in part by stating that "if a pump is verified to be in operation, this is also sufficient to verify the correct breaker alignment and indicated power availability". This statement was incorporated into the ISTS bases for the surveillances revised by TSTF-265. The ISTS SR 3.9.6.2 is revised to incorporate the fix implemented by TSTF-265 for other similar surveillances in Section 3.4. The change is acceptable because adequate assurance exists that the pump is I aligned to the correct breaker with power available because, prior to being removed from operation, the pump was verified to be operating. Verification of pump operation is a better indicator of operability and readiness than simply verifying the breaker alignment and power available. In addition, the proposed change is consistent with the changes implemented by TSTF-265. Therefore, the proposed change is acceptable. ISTS SR 3.9.6.2 represents a new surveillance for BVPS. BVPS Units I &2 Page 11 Revision :2, 4/06 30

RHR and Coolant Circulation - Low Water Level Rev. 2 ChangeZC-J5 B 'Ij. BASES SURVEILLANCE SR 3.9.6.1 REQUIREMENTS This Surveillance demonstrates that one RHR loop is in operation and circulating ractor coolant.l~e~w rate is determ v A i

                                      .ror                  n strtfcto intc             lI  dition, during operation of the RHR loop with the water level in the vicinity of the teacto-
                              , vessel nozzles, the RHR pump suction requirements must be met. The I R 3.-9.5.2  C Verification that the required pump is OPERABLE ensures that an additional RGS oeRHR pump can be placed in operation, if needed, to maintain decay heat removal and reactor coolant circulation. Verification is performed by verifying proper breaker alignment and power available to the required pump. The Frequency of 7 days is considered reasonable in view of other administrative controls available and has been shown to be acceptable by operating experience.

1 REFERENCES 1. A FSAR Seafic..insr, _ r This SR is modified by a Note that states the SR is not required to be performed until 24 hours after a required pump is not in operation. The Frequency of 12 hours is sufficient considering other indications and alarms available to the operator in the control 5 room to monitor RHR loop performance. Unit 1 UFSAR, Appendix 1A, I1971 AEC General Design Criteria Conformance". Unit 2 UFSAR, Section 3.1. "Conformance with NRC General Design Criteria'. I __d Verification includes flow rate, temperature, or pump status monitoring, which help ensure that forced flow is providing heat removal and to prevent thermal and boron stratification in the core. WOG STS B 3.9- 4 Rev. 2, 04/30/01 60

I ITS3.9-l (D i Rev. 2 Change C-5 l.2 REFUELING OPERATIONS 1h RHR and Coolant Circulation - and one RHR 'oop WATER LEVEL shall be in operation 9.5InsertLCONotes I &2

  \LIMITING CONDITION FOR OPERATION                                    _--~

u3.9.8.2 le moval (RHR) loops shall be OPERABLE.* APPLICABILITY: MODE 6 when the water level above the top of the reactor pressure vessel flange is less than 23 feet. b OR A.2 Initiate action to establish 2Ž23 ftof'Bater above ACTION:l Insert LCO Not 3 immediately the top of the reactor vessel flange immediately. [ With less than the requi ed RHR loops OPERABLE, imadieft y _ initiate corrective actio to return the re RHR loops to OPERABLE status as s sas Poiblc

b. Th provis s of Specification 3.0.3 arc not applicable. A Insert Condition B "No RHR Loop in operation" and Actions B.1 throuzh 1.5. 1 Insert Action B.5.2 (

SURVEILLANCE REQUIREMENTSE

 )  L .9.8.2         The       required            Rcsidual              IHcat        Refmeval           loops            -

shall M determined OPERABLE per specification 4.0. .

          \     tR.9.5.1,            Verify one RIRloop is inoperation every 12 hours.                   A NOTE Not required to be pcrformcd until 24 hours after the required pump is not in operation.

SR 3.9.5.2 Verify correct breaker alignment and indicated power available to the required RHR pump that is not in operation every 7 days. The normal or emergency power seuree may be inoperable for caek ziR leep. \ BEAVER VALLEY - UNIT 2 3/4 9-9 91

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 CHANGE C-6 Database # N/A NRC/BVPS Telecon on 12/22/05 NRC Commenter: D. Nguyen BSI- 27 BVPS agreed to a partial withdrawal of the BSI-27 proposed changes. BSI-27 was based on changes proposed in TSTF-451-T. The NRC reviewer objected to the change in this TSTF that affected ITS 5.5.13.b (the Battery Monitoring and Maintenance Program). BVPS agreed to withdraw the affected portion of BSI-27. The withdrawal of this part of BSI-27 results in ITS 5.5.13.b being restored to the ISTS wording. The ISTS wording (of 5.5.13.b) requires cells with electrolyte level below the minimum established design limit to be equalized and tested. The change proposed in BSI-27 would only require cells to be equalized and tested if the electrolyte level is found below the top of the plates. Thus, this change results in ITS 5.5.13.b conforming to the ISTS. This change also requires that the bases description of ITS 3.8.6 Actions C.1, C.2' and C.3 (which refer to the requirements of ITS 5.5.13.b) be revised to match the new requirement specified in ITS 5.5.13.b. Therefore this change affects pages in Section 5.0 and 3.8. Affected Pages: The following Table(s) list the affected pages by type (i.e., ITS markup, CTS markup, etc.). In order to facilitate review by ITS section, a separate table is provided for each ITS section affected by the change. The page numbers listed are the ITS section specific consecutive numbers found in the lower right corner of each page. Note: Because the affected page(s) for each change were extracted from a complete ITS section electronic file, the electronic hyperlinks (created in the complete ITS section file) do not work in the collection of affected pages that follow this cover page. (continued)

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 Change C-6 (continued) ITS SECTION 3.8 (ELECTRICAL POWER SYSTEMS) INDEX OF AFFECTED PAGES ITS MARKUPS No change ITS JFDS No change ITS BASES MARKUPS PAGE: 134 ITS BASES JFDS No change CTS MARKUPS No change CTS DOCS No change ITS SECTION 5.0 (ADMINISTRATIVE CONTROLS) INDEX OF AFFECTED PAGES ITS MARKUPS PAGE: 23 ITS JFDS No change ITS BASES MARKUPS No change ITS BASES JFDS No change CTS MARKUPS PAGE: 123 CTS DOCS No change

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 CHANGE C6 AFFECTEDPAGES FOR ITS SECTION 3.8 (ELECTRICAL POWER SYSTEMS) ITS SECTION 3.8 (ELECTRICAL POWER SYSTEMS) INDEX OF AFFECTED PAGES ITS MARKUPS No change ITS JFDS No change ITS BASES MARKUPS PAGE: 134 ITS BASES JFDS No change CTS MARKUPS No change CTS DOCS No change

Battery Parameter; B 3.8.6 I Rev. 2 Change C-6 I BASES ACTIONS (continued) reasonable of the amount of the previous discharge and the recharge characteristic of the battery. Thus there is assurance of fully recharging the battery within f121 hours, avoiding a premature shutdown with its own attendant risk. If the condition is due to one or more cells in a low voltage condition but still greater than 12.071 V and float voltage is found to be satisfactory, this is not indication of a substantially discharged battery and 112] hours is a reasonable time prior to declaring the battery inoperable. Since Required Action B.1 only specifies "perform," a failure of SR 3.8.4.1 acceptance criteria does not result in the Required Action not met. However, if SR 3.8.4.1 is failed, the appropriate Condition(s), depending on the cause of the failure, is entered. C.1, C.2. and C.3 With one or more batteries in one train with one or more cells electrolyte Inaccordance with level above the top of the plates, but below the minimum established eure ctin 0 design limits, the battery still retains sufficient capacity to perform the

   \  ____\_intended                           function. Therefore, the affected battery is not required to be Within 31 days.                 considered inoperable solely as a result of electrolyte level not met.

__\hnL- d4ays the minimum established design limits for electrolyte level 4.. must be re-established. is (7s Condition C ismodified by a Note that requires the With electrolyte level below the to f the plates there is a potential for / completion of Required Action dryout and plate degradation. R uired Actions C.1 and C.2 address thisg (.2 if the electrolyte level was £ I; , rtrg.e;Ane god r<*-I 4t7 r/* } l.44...

                                                                                                                     - A <

wt9 8t> DolerillBl as HE Lyle VvEll v DFOred v- we-

f und below the top of the Flates. In this case, the visual and Maintenance Program). hey are modified by a Note that indicates inspection for leakage they are only applicable if e ctrolyte level is below the top of the plates.

specified in Required Action Within 8 hours level is re ired to be restored to above the top of the C0.2 must be performed prior plates. The Required A ion C.2 requirement to verify that there is no t0 exiting Condition C even if t ie electrolyte level is leakage by visual insp ction 3nd the Specification 5.5.17.b item to initiate restored to greater than or action to equlz ar ontinanadnc it anuat-rer equal to the minimum recommendation `7 taken from Annex D of IEEE Standard 450-1995. established design limit. ~,They arprformed following the restoration of the electrolyte level to abov'the top of the plates. Based on the results of the manufacturer's rhe visual inspection repommended testing the batter(Aies] may have to be declared and requirements of vhoperable and the affected cell1s] replaced. Specification 5.5.13.b , In addition to these required Actions, Specification 5.5.13.b requires that action be initiated to equalize and test battery cells that have been discovered with electrolyte level below the minimum established design limit. WOG STS B 3.8.6 - 4 Rev. 2, 04/30/01 134

BVPS UNITS 1 & 2 ~AA&Q ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 CHANGE C6 AFFECTED PAGES FOR ITS SECTION 5.0 (ADMINISTRATIVE CONTROLS) ITS SECTION 5.0 (ADMINISTRATIVE CONTROLS) INDEX OF AFFECTED PAGES ITS MARKUPS PAGE: 23 ITS JFDS No change ITS BASES MARKUPS No change ITS BASES JFDS No change CTS MARKUPS PAGE: 123 CTS DOCS No change

Programs and Manuals I Rev. 2 Change C-6 5.'i 5.5 Programs and Manuals 5.5.16 tainment Leaka e Rate Testing Program (continued)

e. Theprovissr eContainment Leakage Rate Testing Program 1ngn these Technical Specifications shall bemfy the testing Frequencies required by 10 CFR 50, Apendix J.

5.5. Battery Monitoring and Maintenance Program This Program provides for battery restoration and maintenance, based on [the recommendations of IEEE Standard 450-1995, "IEEE Recommended Practice for Maintenance, Testing, and Replacement of Vented Lead-Acid Batteries for Stationary Applications," or of the battery manufacturer] including the following:

a. Actions to restore battery cells with float voltage <2.13J V, and

b. Actions to equalize and test battery cells that had been discovered with electrolyte level below the minimum established design limit. I WOG STS 5.5 - 15 Rev. 2, 04/30/01 23

I Rev.2ChangeC-6&D-5 l

c. The SFDP identifies where a loss of safety function exists. If a loss of safety D-5 function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered. When a loss of safety function is caused by the inoperability of a single Technical Specification support system, the appropriate Conditions and Required Actions to enter are those of the support system.

INSERT 3 5.5.13 Battery Monitoring and Maintenance Program This Program provides for battery restoration and maintenance, based on [the recommendations of IEEE Standard 450-1995, "IEEE Recommended Practice for Maintenance, Testing, and Replacement of Vented Lead-Acid Batteries for Stationary Applications," or of the battery manufacturer] including the following:

a. Actions to restore battery cells with float voltage <2.13 V, and

b. Actions to equalize and test battery cells that had been discovered with electrolyte c-I level below the minimum established design limit.

INSERT 4 5.5.9 Diesel Fuel Oil Testing Program A diesel fuel oil testing program to implement required testing of both new fuel oil ard stored fuel oil shall be established. The program shall include sampling and testing requirements, and acceptance criteria, all in accordance with applicable ASTM Standards. The purpose of the program is to establish the following: INSERT 5 5.6.5 Post Accident Monitoring ReDort When a report is required by Condition B or F of LCO 3.3.3, "Post Accident Monitoring (PAM) Instrumentation," 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. 123

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 CHANGE C-7 Database # 200512191552 NRC Commenter: R. Clark The NRC reviewer requested a clarification be made to the Bases for ITS Surveillance Requirements 3.8.1.8 and 3.8.1.10. The affected surveillances contain a note that provides an exception for the requirement to meet the specified power factor when loading the diesel generators. The Bases explanation for when the Note may be used was revised to delete the first example provided and edit the remaining text. The actual Surveillance Requirement note and power factor requirement specified in the ITS are changed by C-14. This change only edits the Bases description of the requirements. Affected Pages: The following Table(s) list the affected pages by type (i.e., ITS markup, CTS markup, etc.). In order to facilitate review by ITS section, a separate table is provided for each ITS section affected by the change. The page numbers listed are the ITS section specific consecutive numbers found in the lower right corner of each page. Note: Because the affected page(s) for each change were extracted from a complete ITS section electronic file, the electronic hyperlinks (created in the complete ITS section file) do not work in the collection of affected pages that follow this cover page. ITS SECTION 3.8 (ELECTRICAL POWER SYSTEMS) INDEX OF AFFECTED PAGES ITS MARKUPS No change ITS JFDS No change ITS BASES MARKUPS PAGES: 83,84 & 91 ITS BASES JFDS PAGE: 163 CTS MARKUPS No change CTS DOCS No change

AC Sources - Operating B 3.8.1 Rev. 2 Change C-7, D-11 & C-14 BASES SURVEILLANCE REQUIREMENTS ( nu and 80% res vly SR 3.8.1.8.a equal to 60% f a typical 5 second load sequence interval associated with l-1 sequencing of the largest load. The voltage and frequency specified are SR 3.8.1.8.b consistent with the design range of the equipment powered by the DG.

                                  \' .8 corresponds to the maximum frequency excursion, while
                                                           .are     steady state voltage and frequency SR 3.8.1.8.c         values to which the system must recover following load rejection. The f18 month] Frequency is consistent with the recommendation of Regulatory Guide 1.108 (Ref. 9).

This SR is modified by two Notes. The reason for Note 1 is that during operation with the reactor critical, performance of this SR could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and, as a result, unit safety systems. This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allow the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g. post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system NUREG-1431, Rev 3 when they are tied together or operated independently for the Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a be plant shutdown and startup to determine that plant safety is maintained or Credit may be enhanced when the Surveillance is performed in MODE 1 or 2. Risk unolanned events insights or deterministic methods may be used for this assessment.",_ [] that satisfy this SR. Note 2 ensures that the DG is tested under load conditions that are as close to design basis conditions as possible. When synchronized with offsite power, testing should be performed at a power factor of s ".. This power factor is representative of the actual inductive loading at der design basis accident conditions. Under ce conditions, ho t~e2 allows the surveillance to o Wpower factor other than S .. These conditions en WOG STS B 3.8.1 - 19 Rev. 2, 04/30101 83

AC Sources - Operating B 3.8.1 Rev. 2 Change C-7 & C-14 BASES SURVEILLANCE REQUIREMENTS (continued) such asthis, any applicabfe burlor, but the 9Xcibtic are in excess those recommended for C-7 1 the DG. In suGh casesp e power factor shall e maintained as close as practicable to {without exceeding on limits. 1C14

                             \              - RE       ER'S NOTE -/

The a o ODE restrictions may be deleted if it can be de ~rted tc the staff, on apet specific basis, that performing the S~f the reactor in any of the restric MODES can satisfy the follo criteria, as 2 applicable:\/

a. Performance of the SR. oaren sRfeil system or component inoperable,,

b. Performance of the SFwig1 not cause piains n of the electrical distribu lesystems that could retacalnge to steady sa ertion or to plant safetysytm,

c. Pe ance ofthe SR, or failure of the SR, will no cau - ,r result an AOO with attendant challenge to plant safety systems.

3.8.1.10 / This eillance demonstrates the DG capability to reject a ful d without o speed tripping or exceeding the predetermined v fage limits. The DG full I rejection may occur because of a syste ault or inadvertent brea tripping. This Surveillance ensur proper engine generator load resp e under the simulated test nditions. This test simulates the loss of the tal connected load t t the DG experiences following a full load rejectio nd verifies thatthe DG does not trip upon loss of the load. These accep ce crita provide for DG damage protection. While the DG is not ex ed to experience this transient during an event and continues to a ilable, this response ensures that 2 the DG is not degraded for fu re applica including reconnection to the bus if the trip initiator n be corrected o lrated. The {18 month} Fre ncy is consistent with the re mendation of Regulatory Gui 1.108 (Ref. 9) and is intended to be nsistent with expected f ycle lengths. This Shas been modified by two Notes. The reason for Note that duping operation with the reactor critical, performance of this SR co ause perturbation to the electrical distribution systems that could WOG STS B 3.8.1 - 20 Rev. 2, 04/30/01 84

AC Sources - Operating B3.8.1~ FiLAtJ l Rev. 2 Change C-7 & C-14 l BASES SURVEILLANCE REQUIREMENTS (continued) may ,forexample, operation with the reactor critical, pe rmance of this Surveill nce could cause perturbations to the electrical di tribution systems that ould 2 challenge continued steady state oper ion and, as a result, nit safety systems Note 3 ensures that the OG is sted under load nditions that ar cose to design basis conditions as ossible. When ynchronized with offsite power, testing should 0.89 C-14 s p e e t ee tive alr of te act ctive loading _ a DG would see under design basis acciden ions. Under certain conditions, however, Note 3 allows eilla ce to b conducted as a power factor other than < .hese condition occur hen grid veltag§ is high, and the additional field excitation needed to got the power factor to 10.9] results OF; 'oltages on the emergency busees that are too high. U er these condition6, the power factor should be maintained as cnlos 1 as practicable to [0.91 while still maintaining acceptable voltage limits on C-7 the omorgency busses. in other circumrtaneos, the grid voltage t-such that the DG excitation levels needed to obtain a power factor of 104.9 ray not cau6e naGceptabie voltages on the emergency burres, but the exitation levels are in excess of those recommended for the DG. In A Gases, the power factor shall be maintained close as practicable to {oad-without exceedinq the Gvitatie. limits. I his restriction from normally 1 performing the furveie or ite 1 or 2 is further amplified to allowr the Surveillance to be perfo rpose of reestablishing cases such IUREG-1431, Rev. 3 A OPERABILITY (e.g., post withthese corrective maintenance, as this corrective modification, deficient or incompleteshutdonce testing, and other unanticipated OPERABILITY concemns) provide sessment Credit may be determines plant safety is maintained or enhanced hienth taken for .shnall, as a minmumconsider the potential outcomes andt anit ly unplanned events acted with a failed Surveillance, a successful Surveillne n tpial that satisfy this SR. perturba-iot of the offsite or onsite system when they are tied together or operated inde ently for the Surveillance; as well as the operator procedures availa lethocope with these outcomes. These shall be measured against the avitdd risk of a plant shutdown and startup to determine that plant safety is m-bR~ined or enhanced when the Surveillance is performed in MODE . Risk insights or deterministic methods may be used for this assessment. S 5 This Surveillance dei tes that the di gne can restart from a hot condition, such as subsequ utdown from normal Surveillances, and achi e required v and frequency within [10] seconds. 0] second time is derived fro uirements of tea ent analysis to respond to a design basis large brea WOG STS B 3.8.1 - 27 Rev. 2, 04/30/01 91

I Rev. 2 Change C-7 & C-14 l BVPS ISTS Conversion 3.8 Electrical Power Systems Enclosure 2 Changes to The ISTS Bases

12. A statement is added to the Surveillance Requirement section of the Bases to indicate the loading requirements for the DGs specified in various SRs are indicated kW and power factor values. This change is acceptable because these values C-14 reflect a range of kW values produced by the DG. The kW values are based on manufacturer limitations (listed in the UFSAR) or the accident analysis assumption for loads of the DG. The power factor value is intended to simulate the accident loading conditions of the DG. Any indication uncertainties associated with these values are not critical to adequately demonstrate the ability of the DG to accept the required loading at the expected power factor.

13 The Bases for ITS SR 3.8.1.8 and ITS SR 3.8.1.10 discuss the conditions under C-7 which the power factor requirement of the SRs may not be met. These discussions are revised to delete the statements that imply the DGs can raise the grid voltage. The changes to these SR Bases were made at the request of the NRC. BVPS Units 1 & 2 Page 2 Revision 2, 4/06 163

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 CHANGE C-8 Database # 200601111555 NRC Commenter: R. Clark The NRC reviewer requested a clarification be made to Bases discussion of ITS Surveillance Requirement 3.8.2.1. BVPS agreed to revise the Bases discussion of surveillance Note 2. Surveillance Note 2 provides an exception to the requirements of Surveillances 3.8.1.13 and 3.8.1.14 during the shutdown conditions applicable for Surveillance Requirement 3.8.2.1. The revision added the clarification that the load verifications of Surveillance Requirements 3.8.1.13 and 3.8.1.14 must be met prior to entering Modes 1, 2, 3, and 4 in accordance with SR 3.0.4. This change only affects the Bases of Section 3.8. Affected Pages: The following Table(s) list the affected pages by type (i.e., ITS markup, CTS markup, etc.). In order to facilitate review by ITS section, a separate table is provided for each ITS section affected by the change. The page numbers listed are the ITS section specific consecutive numbers found in the lower right corner of each page. Note: Because the affected page(s) for each change were extracted from a complete ITS section electronic file, the electronic hyperlinks (created in the complete ITS section file) do not work in the collection of affected pages that follow this cover page. ITS SECTION 3.8 (ELECTRICAL POWER SYSTEMS) INDEX OF AFFECTED PAGES ITS MARKUPS No change ITS JFDS No change ITS BASES MARKUPS PAGE: 105 ITS BASES JFDS No change CTS MARKUPS No change CTS DOCS No change

lRev. 2 Change C-8l B 3.8.2 INSERTS The current fuel handling accident safety analysis does not rely on the automatic actuation of any systems or components to mitigate the accident. Furthermore, the current fuel handling accident analysis does not assume isolation or filtration to mitigate the event. However, in order to limit the control roon dose following a fuel handling accident, Unit 1 must purge the control room atmosphere for 30 minutes following termination of the release (2 hours after the accident). The required Unit 1 purge is a manual action for which the Technical Specifications require power (LCO 3.8.2) and ventilation system (LCO 3.7.11) OPERABILITY when moving any irradiated fuel assemblies or fuel assemblies over any irradiated fuel assemblies. The Unit I requirement to purge the control room after a fuel handling accident involving any type of irradiated fuel is the reason for the difference in the fuel movement applicability for each unit in LCO 3.8.2 and LCO 3.7.11. Although not a specific assumption of the safety analyses, this specification requires that the DG automatically start, connect to the emergency bus, and automatically sequence the required loads. This capability in conjunction with the loss of voltage relays required OPERABLE by LCO 3.3.5, "Loss of Power (LOP) DG Start and Bus Separation Instrumentation," assures that a reliable source of AC power is promptly available in the event offsite power is lost. Inaddition, this capability provides automatic protection against degraded voltage conditions (via the degraded voltage sensing relays required OPERABLE in LCO 3.3.5) that could damage equipment required to maintain the unit in a safe shutdown condition. Therefore, the prompt availability of reliable backup emergency power provides additional assurance that the unit can be maintained in a safe shutdown condition in the event the grid becomes unstable. Current requirements based on the decay time of the fuel prevent the movement of recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 100 hours). However, the Technical Specifications continue to address fuel movement involving recently irradiated fuel to support requirements for isolation or filtration that may be necessary to mitigate a fuel handling accident involving recently irradiated fuel. The retention of requirements within the Technical Specifications, in case the requirements are necessary to support fuel movement involving recently irradiated fuel, is consistent with the guidance of Ref. 1.

2. During normal plant operation, electrical power for the onsite circuits comes from either the main generator through 22 kV to 4.36 kV unit station service transformers or from the two independent offsite 138KV buses through 138KV to 4.36 kV system station service transformers. The secondary windings of the transformers are connected to four separate 4.16 kV normal buses, A, B, C and D. Buses A and D provide power for the two redundant Class IE 4.16 kV emergency buses AE and DF, respectively. During plant shutdown, the emergency buses receive power from the system station service transformers, or may receive power from the unit station service transformers by backfeeding the main transformer.

Automatic and manual transfer capabilities to the system station service transformers are available when the offsite source(s) are required to be OPERABLE.

3. Note 2 limits the scope of the requirement to verify the automatic load sequencing functions. The Note recognizes that the majority of equipment automatically sequenced on the emergency bus is not required to assure safe operation of the plant in shutdown MODES. The Note limits the verifications required by SR 3.8.1.13 and SR 3.8.1.14 to those loads required in the Applicable MODES of LCO 3.8.2. The required loads are the loads required OPERABLE by Technical Specifications and loads necessary ta support the OPERABILITY of the loads required OPERABLE by Technical Specifications. Prior to entry into MODE 4, the verifications required by SR 3.8.1.13 and SR 3.8.1.14 must be complete for all loads required in MODES 1, 2, 3, and 4 in accordance with SR 3.0.4 Note 3 clarifies the requirements of SR 3.8.1.14 such that only the DG response to the loss of offsite power must be verified to confirm OPERABILITY in the shutdown conditions addressed by LCO 3.8.2.

No ESF (i.e., SI) actuation of the DG is required to be verified during the shutdown conditions addressed by LCO 3.8.2. Note 3 does not preclude the verification of ESF actuations and is only intended to clarify that an ESF actuation is not required to confirm DG or emergency bus OPERABILITY during the shutdown conditions addressed by LCO 3.8.2. 105

EVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nois. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 CHANGE C-9 Database# 200601111521 NRC Commenter: R.Clark The NRC reviewer requested that the Action Condition for two inoperable channels listed on Post Accident Monitoring (PAM) Table 3.3.3-1 for Function 19 be revised from N/A to Condition B with a footnote to clarify that Condition B is applicable for Functions with one required channel. Function 19 is the only single channel PAM Function listed on the table, and was not originally provided with a specific Action Condition for two inoperable channels. The requested change clarifies that Action Condition B provides an adequate Action for single channel Functions. BVPS Agreed to incorporate the change. The change affects several pages in Section 3.3B of the conversion submittal. Affected Pages: The following Table(s) list the affected pages by type (i.e., ITS markup, CTS markup, etc.). In order to facilitate review by ITS section, a separate table is provided for each ITS section affected by the change. The page numbers listed are the ITS section specific consecutive numbers found in the lower right corner of each page. Note: Because the affected page(s) for each change were extracted from a complete ITS section electronic file, the electronic hyperlinks (created in the complete ITS section file) do not work inthe collection of affected pages that follow this cover page. ITS SECTION 3.3B (REMAINDER OF INSTRUMENTATION) INDEX OF AFFECTED PAGES ITS MARKUPS PAGE: 8 ITS JFDS PAGE: 38 ITS BASES MARKUPS PAGE: 74 ITS BASES JFDS No change CTS MARKUPS PAGE: 142 CTSDOCS PAGE: 219

I Rev. 2 Change C-9, D-1 & D-12 BVPS PAM TABLE (combined Unit 1 and 21 CONDITION REFERENCED FROM REQUIRED FUNCTION REQUIRED CHANNELS ACTION D.A

1. Power Range Neutron Flux 2(g) E

2. Intermediate Range Neutron Flux 2(gt) E D-1 2

3. Source Range Neutron Flux 2(f) E

4. Reactor Coolant System (RCS) Hot Leg 2 E Temperature (Wide Range)

5. RCS Cold Leg Temperature (Wide Range) 2 E

6. RCS Pressure (Wide Range) 2 E

7. Reactor Vessel Water Level 2 F

8. Containment Sump Water Level (Wide Range) 2 E

9. Containment Pressure (Wide Range) 2 E

10. Containment Area Radiation (High Range) 2 F

11. Pressurizer Water Level 2 E

12. Steam Generator (SG) Water Level (Wide Range) 3 E

13. SG Pressure a) SG'A 2 E b) SG B- 2 E c) SG'C' 2 E

14. Primary Plant Demineralized Water Storage Tank 2 E Level

15. Refueling Water Storage Tank Level (Wide Range) 2 E

16. Penetration Flow Path Containment Isolation Valve 2 per penehttapn flow E Position path

17. Core Exit Temperature a) Quadrant 1 2 (c) E b) Quadrant 2 2(c) E c) Quadrant 3 2(c) E d) Quadrant 4 2 (c) E

18. Secondary Heat Sink Indication a) SG'A' 2 (d) E b) SG6B- 2 (d) E c) SG-C' 2 (d) E

19. Hiah Head SI Automatic Iniection Header Flow I l G-9 (d) The required channels may be satisfied by using any combination of SG Water Level (Narrow Range) channels and Auxiliary Feedwater Flow channels such that 2 channels are OPERABLE for each SG.

(e) Condition B contains the appropriate Action for Function(s) with one required channel.---------,(

                                                                                                 ..      )     9 (f) Source Range neutron detectors are not required to be energized above the P-6 Intermediate Range Neutron Flux Interlock.                                                                                 D-12 (g) Not required in MODE 3.                                                                                  1 8

REV. 2 Changes C-9 & BVPS ISTS Conversion Repagination due to C-11 3.3 B Instrumentation Enclosure 1 Changes to ISTS Function considering that the Function is not required to be in the PAM ITS and that it does not meet the stringent design requirements of the other Functions that are required to be in the PAM TS. In addition, acceptable alternate indications exist in the control room to confirm automatic high head SI initiation. An alternate method of verifying Si initiation can be provided by the High Head SI pump amperage indication, the High Head SI header pressure indication, and the SI automatic valve position indication. A combination of these indications provides an acceptable long tenn alternate method to verify automatic SI initiation until the single channel of high head flow indication is restored to operable status.

6. The proposed PAM TS includes Function number 18, " Secondary Heat Sink Indication" and the associated footnote "d" which states " The required channels may be satisfied by using any combination of SG Water Level (Narrow Range) channels and Auxiliary Feedwater Flow channels such that 2 channels are OPERABLE for each SG." The proposed new Function combines the instrument channels for SG level (narrow range) and Auxiliary Feedwater Flow (AFW). The CTS for PAM only includes the AFW Flow indication. The addition of the SG Level (Narrow Range) represents a new TS requirement for the BVPS units. The ability to maintain the SG level within the NR indication also confirms an adequate water volume for decay heat removal as well as confirming the associated AFW system capability to feed the SG. The addition of the SG Water Level NR channels to the PAM TS makes the proposed change possible. The allowance to combine these indications into a single Function is acceptable as these indications serve a similar purpose (i.e., the maintenance of SG level to provide an adequate heat sink). The use of either indicator for this purpose is consistent with the Westinghouse Emergency Response Guidelines as implemented in the BVPS Unit 1 and Unit 2 Emergency Operating Procedures. In addition, the Unit 1 AFW Flow is not a Regulatory Guide 1.97 Type A or Category 1 instrument, and only one channel is available per SG. As such, the proposed new Function that allows AFW flow and SG level to be combined permits Unit 1 to have 2 channels of indication for each SG and makes both units the same. In addition, the use of the combined "Secondary Heat Sink Indication" Function in the PAM ITS was previously approved by the NRC for the D. C.

Cook plant in their conversion to the ISTS.

7. The proposed PAM Table 3.3.3-1 is revised by the addition of new Note (e) in the table column intended to provide direction when two or more inoperable channels are not restored to operable status in the specified time. The addition of the new note is associated with Function 19 on the table. Function 19 is the only Function with one required channel. The addition of Note (e) is intended to clarify that Condition B is the correct Condition for Functions with only one required channel and that Conditions E and F (applicable for Functions with 2 or more required channels) do not apply for Functions with only one required channel. This note was added at the request of the NRC.

BVPS Units 1 and 2 Page 10 Revision 2, 41D6 38

ITS 3.3.3 BASES INSERTS I Rev. 2Change C- 3 This indication provides confirmation of adequate SG inventory to ensure the required heat sink(s) are available. The availability of SG(s) for heat removal is important to safety to ensure adequate core cooling. This indication can also be used by the operator to confirm that the AFW System is in operation and delivering sufficient flow to each SG. AFW system initiation is important to safety because it provides information necessary for operator action to initiate alternate feedwater sources in the event of a failure of the AFW system. INSERT 8 BVPS HIGH HEAD Si AUTOMATIC INJECTION HEADER FLOW BASES

19. Hiqh Head Safety Iniection (SI) Flow High Head Safety Injection (SI) Flow is classified as a Category 2 variable.

High Head Si Flow indication is used to confirm automatic safety injection initiation following a design basis accident. Therefore, the required flow indicator for this PAM Function is the total flow indicator installed in the automatic High Head SI flow path. Failure to manually initiate SI flow when the automatic initiation fails can lead to a significant increase in core damage frequency. Operator action is based on the ECCS flow indication in the control room. Only high head safety injection is important for all accident sequences except the unlikely double-ended guillotine rupture of the largest reactor coolant pipe. Therefore, only the High Head Sl Flow indication is required. This instrumentation was not designed to meet Regulatory Guide 1.97 Category 1 or Type A requirements. Only a single channel is available and required OPERABLE for each unit. The requirement for a single OPERABLE channel of this indication is acceptable due to design requirements for this instrument (i.e., not Category 1) and the additional information available in the control room to confirm high head SI initiation. For example, if the total High Head SI Flow indication is not available, alternate methods of verifying Si initiation can be provided by the High Head Si pump amperage indication, the High Head Si header pressure indication, and the SI automatic valve position indication. As only one channel of High Head SI Flow indication is required OPERABLE, the information associated with this Function on Table 3.3.3-1 is modified by footnote (e). Footnote (e) clarifies that Action Condition B is the only applicable Action Condition for Functions with only one required channel that can not be restored to OPERABLE status within the Completion Time specified in Action Condition A. As Footnote (e) and Condition B are in the Table column for Conditions referenced from Required Action D.1, this Table notation also clarifies that Action Conditions C, D, E, and F are not applicable to Functions that only require a single OPERABLE channel. INSERT 9 BVPS ACTION CONDITION F BASES The following are examples of acceptable alternate indication methods for Reactor Vessel Water Level and Containment Area Radiation: Reactor Vessel Water provides information to indicate whether the core cooling safety function is being accomplished. As such, the core exit temperature and subcooling (RCS Pressure and Temperature) indications may be used in lieu of Reactor Vessel Water indication. Radiation monitor RM-IRM-201 (Unit 1) and 2RMR-RQ202B (Unit 2) or a portable radiation monitor (with appropriate multiplier if necessary) can be used as an alternate method of indication for Containment Area Radiation High Range. Page 4 74

Rev. 2 Change C-9, D-1& D-12 INSERTS for ITS 3.3.3 Table 3.3.3-1 NEW PAM FUNCTIONS Ml~ CONDITION REFERENCED FROM REQUIRED FUNCTION REQUIRED CHANNELS ACTION D.1

1. Power Range Neutron Flux 2 (g) E

2. Intermediate Range Neutron Flux E D-12 2 (g)

3. Source Range Neutron Flux 2 (O E

4. Reactor Coolant System (RCS) Hot Leg 2 E Temperature (Wide Range)

5. RCS Cold Leg Temperature (Wide Range) 2 E

6. RCS Pressure (Wide Range) 2 E

10. Containment Area Radiation (High Range) 2 F

12. Steam Generator (SG) Water Level (Wide Range) 3 E

13. SG Pressure a) SG"A 2 E b) SG "B" 2 E c) SG C 2 E

14. Primary Plant Demineralized Water Storage Tank 2 E D-1 1

Level

15. Refueling Water Storage Tank Level (Wide Range) 2 E

16. Penetration Flow Path Containment Isolation Valve 2 per penetXn flow E Position path

18. Secondary Heat Sink Indication a) SG "A" 2 (d) E b) SG "B" 2 (d) E c) SG "C 2 (d) E

19. High Head SI Automatic Injection Header Flow I Bte) I C-9 (a) Not required for isolation valves whose associated penetration is isolated by at least one closed and deactivated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured.

(b) Only one position indication channel is required for penetration flow paths with only one installed control room indication channel. (e) Condition B contains the appropriate Action for Function(s) with one required channel. I C-9 (Q) Source Range neutron detectors are not required to be energized above the P6 Intermediate Range Neutron Flux Interlock. (g) Not required in MODE 3. l D-12 142

BVPS ISTS Conversion Rev. 2 Change C-9 3.3 B Instrumentation Enclosure 3 Changes to CTS As the addition of ITS Function number 18 represents a relaxation in the CTS PAM requirements for AFW Flow indication, it is discussed in DOC L.4. All the PAM Functions listed above are used to monitor Regulatory Guide 1.97 Type A and or Category 1 variables (consistent with the guidance in NUREG-1431) except for the following Functions:

Unit 2 Refueling Water Storage Tank (RWST) Level (Wide Range) is added to the proposed PAM TS. The Unit 2 RWST Level (Wide Range) indication is classified as a Regulatory Guide 1.97 Type D, Category 2 variable. However, this Unit 2 indication was determined to provide important information similar to the Unit 1 RWST Level indication which was classified as a Regulatory Guide 1.97 Type A, Category 1 variable. The inclusion of this Unit 2 indication will help to make the PAM requirements for both units consistent. The inclusion of this indication in the PAM TS represents a new TS requirement for both units.
Unit 2 Containment Isolation Valve Position Indication is added to the proposed PAM TS. The Unit 2 Containment Isolation Valve Position indication is classified as a Regulatory Guide 1.97 Type C, Category 2 variable. However, this Unit 2 indication was determined to provide important information similar to the Unit 1 Containment Isolation Valve Position indication which was classified as a Regulatory Guide 1.97 Type B, Category 1 variable. The inclusion of this Unit 2 indication will help to make the PAM requirements for both units consistent. The inclusion of this indication in the PAM TS represents a new TS requirement for both units.
Unit 1 and Unit 2 High Head Safety Iniection (SI) Automatic Iniection Header Flow is added to the proposed PAM TS. The High Head SI Automatic Injection Header Flow (i.e., high head SI total flow) indication is classified as a Regulatory Guide 1.97 Type D, Category 2 variable for both units. As this variable is not classified as a Type A or Category 1 variable it was not designed as such. There is only a single channel of control room indication available for each unit. This variable has been identified as the preferred control room indication for confirming automatic SI initiation. Confirming automatic SI initiation is important in order to determine if manual action is needed to assure high head SI initiation. Therefore, it is included in the proposed PAM TS for both units. Although this variable does not meet the criteria for inclusion in the PAM ITS (i.e., it is not classified as a Regulatory Guide 1.97 Type A or Category 1) it is included in the proposed ITS in recognition of its importance in confirming automatic high head SI initiation. Table note (e) is assigned to this new PAM Function.

The proposed additions include specifying (2) Required Channels for each of the new Functions except for the SG Water Level (Wide Range) Function which requires (3) total channels operable and the High Head SI Automatic Injection Header Flow (discussed above) which only requires a single operable channel. The requirement for two operable channels satisfies the PAM requirement for redundant channels to ensure at least one channel is operable in post accident BVPS Units 1 & 2 Page 7 Revision 2, 4/06 219

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 CHANGE C-10 Database # 200507061635 NRC Commenter: R. Hernandez BSI 15 & 16 In BSI 15 and 16 BVPS proposed alternative Actions for the Component Cooling Water (CCVW) and Service Water (SW) technical specifications (i.e., new Action Condition C for ITS 3.7.7 and 3.7.8). The proposed action would address the plant condition where two trains of cooling water were inoperable such that the plant could not be placed or maintained in Mode 5. The proposed Action Condition C for both these ITS required Action be initiated immediately to implement an alternate method of decay heat removal. The NRC reviewer requested that the proposed Actions be revised to initiate action to restore one train of [CCW or SW as applicable] to operable status immediately. The requested change would replace the original action to implement an alternate means of decay heat removal. BVPS agreed to revise the action as requested. This change affects ITS 3.7.7, ITS 3.7.8, and associated Bases. Affected Pages: The following Table(s) list the affected pages by type (i.e., ITS markup, CTS markup, etc.). In order to facilitate review by ITS section, a separate table is provided for each ITS section affected by the change. The page numbers listed are the ITS section specific consecutive numbers found in the lower right corner of each page. Note: Because the affected page(s) for each change were extracted from a complete ITS section electronic file, the electronic hyperlinks (created in the complete ITS section file) do not work in the collection of affected pages that follow this cover page. ITS SECTION 3.7 (PLANT SYSTEMS) INDEX OF AFFECTED PAGES ITS MARKUPS PAGES: 22 & 26 ITS JFDS PAGES: 59,60,61 ITS BASES MARKUPS PAGES: 124,129 & 130 ITS BASES JFDS No change CTS MARKUPS PAGES: 234,237 CTS DOCS PAGES: 297, 298, 303 & 304

i Rev. 2 Change C-10 I CCW Systern 3.7.7 ih,-, 3.7 PLANT SYSTEMS 3.7.7 Component Cooling Water (CCW) System LCO 3.7.7 Two CCW trains shall be OPERABLE. APPLICABILITY: MODES 1, 2, 3, and 4. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One CCW train A.1 inoperable. - NOTE - Enter applicable Conditions and Required Actions of LCO 3.4.6, "RCS Loops - MODE J." for residual heat remova oops made (RHR) inoperable by CCW. Restore CCW train to 72 hours OPERABLE status. B. Required Action and B.1 Be in MODE 3. 6 hours associated Completion Time of Condition A not AND met. B.2 Be in MODE 5. 36 hours 7-NOTE NOTE Only applicable In MODE 4 with inadequate LCO 3.0.3 and all other LCO Actions CCW flow to the RHR heat exchangers to requiring a MODE change From support the required decay heat removal MODE 4 to MODE 5 are suspended needed to maintain the Unit in MODE 5. until adequate CCW flow to the RHR heat exchangers is established to maintain the unit in MODE 5. (211 C. Two CCWtrains inoperable. c. Initiate action to restore one Immediately train of CCW to OPERABLE status. WOG STS 3.7.7-1 Rev. 2, 04/30/01 22

Rev. 2 Change 0-10 BVPS ISTS Conversio:i 2C3.7 Plant Systems Enclosure 1 Changes to ISTS ITS 3.7.7 Component Cooling Water (CCW) JUSTIFICATION FOR DEVIATION (JFD)

1. ISTS SR 3.7.7.2 and SR 3.7.7.3 and associated Bases are edited to delete the surveillance requirements. The purpose of the ISTS SR 3.7.7.2 requirement is to verify automatic operation of the CCW valves on an actual or simulated actuation signal. The purpose of the ISTS SR 3.7.7.3 requirement is to verify the automatic operation of the CCW pumps on an actual or simulated signal. These SRs ensure the operability of the CCW Systems for responding to the design basis accident (DBA) LOCA. The CCW system described in the ISTS assumes the CCW System removes DBA post LOCA heat loads from the containment. The CCW System at BVPS serves no DBA LOCA mitigation function. The CCW System design consists of redundant trains to ensure performance of the cooling function in the event of a single failure. The principal function of the CCW System is the removal of decay heat from the reactor via the RHR System.

The RHR System does not perform a DBA LOCA mitigation function at BVPS.

2. ISTS 3.7.7 Actions and associated Bases are revised to include a new Condition (Condition C) for two CCW trains inoperable with insufficient CCW flow to the RHR heat exchangers to support the required decay heat removal in Mode 4. The proposed change to the ISTS (and CTS) provides a more appropriate Action than the application of LCO 3.0.3 when two CCW trains are inoperable and can not supply the RHR system with the necessary cooling water to support a cooldown to reach and maintain the plant in Mode 5. The proposed Action Condition is similar to a Condition provided in the AFWA' System specification for three inoperable AFW trains that requires the restoration of at least one AFW train before reducing operating Modes.

LCO 3.0.3, which would otherwise be applicable with two inoperable trains of CCW, simply requires that the plant be placed in Mode 5 within the specified time. However, the CCW System at BVPS functions to supply the RHR heat exchangers with cooling water to cool the unit from RHR entry conditions to Mode 5. Without the cooling capacity of the CCW, the ability of the plant to transition from Mode 4 to Mode 5 and to stay in Mode 5 may be adversely affected. The proposed new Condition for two CCW trains inoperable in Mode 4 with inadequate flow to the RHR heat exchangers provides a more appropriate Action for the specified plant condition than LCO 3.0.3. LCO 3.0.3 would remain applicable for transitioning from Modes 1 to 4 if two trains of CCW were inoperable. However, once in Mode 4, if the RHR cooling capability is adversely affected, the proposed new Condition would provide the appropriate Actions instead of LCO 3.0.3. If the required RHR cooling capacity to place the unit in Mode 5 is not affected, the proposed new Condition would not be applicable. Therefore, LCO 3.0.3 would remain applicable for the condition of two inoperable CCW trains and result in the unit being placed in Mode 5 within the time specified in LCO 3.0.3. The proposed change includes an immediate Completion Time for initiating action to restore one CCW train to OPERABLE status. As such, the proposed change assures BVPS Units 1 and 2 Page 8 Revision 2, 4/06 59

BVPS ISTS Conversion I Rev. 2 Change C-10 l 3.7 Plant Systems Enclosure 1 Chanaes to ISTS that action continues to restore the CCW system to operable status such that cooldown to, and maintenance in, Mode 5 is possible. The BVPS RHR design is for a dedicated decay heat removal system. The BVPS RHR System does not support the ECCS System in Modes 1-4 as in a more typical Westinghouse design. In addition, other plant systems can safely remove decay heat in I Mode 4 until adequate RHR heat removal capacity is restored by restoring sufficient CCW capacity. Therefore, the additional time that may be required to reach Mode 5 from Mode 4 in these circumstances does not introduce any undue risk or adversely affect the safe operation of the plant.

3. ISTS SR 3.7.7.1 and associated Bases are edited to delete references to 'safety related" systems in order to clarify the BVPS CCW design by denoting a specific reference to the RHR system. This change is necessary due to the design of the BVPS CCW and RHR.

The primary safety function performed by the CCW System at BVPS is to supply the RHR heat exchangers, with cooling water to cool the unit from RHR entry conditions to Cold Shutdown. The BVPS RHR system does not function as part of the Emergency Core Cooling System (ECCS). Therefore, the BVPS CCW system does not function to support components of the ECCS, as in other Westinghouse plant designs. The surveillance is edited to reflect this plant specific CCW design. BVPS Units 1 and 2 Page 9 Revision 2, 4/06 60

I Rev. 2 Change C-10 I ISTS 3.7.8 Service Water Svstem Inserts

1. New Condition C NOTE NOTE Only applicable in MODE 4 with LCO 3.0.3 and all other inadequate SWS flow to the LCO Actions requiring a MODE Component Cooling Water (CCW) change from MODE 4 to MODE 5 heat exchangers to support the are suspended until adequate required decay heat removal needed SWS flow to the CCW heat to maintain the Unit in MODE 5. exchangers is established to maintain the unit in MODE 5.

C. Two SWS trains inoperable. C.1 Initiate action to restore one Immediately train of SWS to OPERABLE status. 26

Rev. 2 Change 0-10 l3.7 BVPS ISTS Conversion Plant Systems Enclosure I Changes to ISTS ITS 3.7.8 Service Water System JUSTIFICATION FOR DEVIATION (JFD)

1. Brackets have been removed in the ISTS LCO and associated Bases for the inclusion o-plant specific values or details. The ISTS frequency is consistent with the CTS frequency.

2. ISTS 3.7.8 Actions and associated Bases are revised to include a new Condition (Condition C) for two SWS trains inoperable with insufficient SWS flow to the CCW heat exchangers to support the required decay heat removal in Mode 4. The proposed change to the ISTS (and CTS) provides a more appropriate Action than the application of LCO 3.0.3 when two SWS trains are inoperable and can not supply the CCW system with the necessary cooling water to support a cooldown to reach and maintain the plant in Mode 5. The proposed Action Condition is similar to a Condition provided in the AFWA' System specification for three inoperable AFW trains that requires the restoration of at least one AFW train before reducing operating Modes.

LCO 3.0.3, which would otherwise be applicable with two inoperable trains of SWS, simply requires that the plant be placed in Mode 5 within the specified time. However, the SWS System at BVPS functions to supply the CCW heat exchangers with cooling water which in turn provide RHR cooling to cool the unit from RHR entry conditions to Mode 5. Without the cooling capacity of the SWS, the ability of the plant to transition from Mode 4 to Mode 5 and to stay in Mode 5 may be adversely affected. The proposed new Condition for two SWS trains inoperable in Mode 4 with inadequate flow to the CCW heat exchangers provides more appropriate Actions for the specified plant condition than LCO 3.0.3. LCO 3.0.3 would remain applicable for transitioning from Modes I to 4 if two trains of SWS were inoperable. However, once in Mode 4, if the RHR cooling capability is adversely affected, the proposed new Condition would provide an appropriate Action instead of LCO 3.0.3. If the required RHR cooling capacity to place the unit in Mode 5 is not affected, the proposed new Condition would not be applicable. Therefore, LCO 3.0.3 would remain applicable for the condition of two inoperable SWS trains and result in the unit being placed in Mode 5 within the time specified in LCO 3.0.3. The proposed change includes an immediate Completion Times for initiating action to restore on SWS train to operable status. As such, the proposed change assures that action continues to restore the SWS train to operable status such that cooldown to, and maintenance in, Mode 5 is possible. The BVPS RHR design is for a dedicated decay heat removal system. The BVPS RHR System does not support the ECCS System in Modes 1-4 as in a more typical Westinghouse design. In addition, other plant systems can safely remove decay heat in Mode 4 until adequate RHR heat removal capacity is restored. Therefore, the additiona time that may be required to reach Mode 5 from Mode 4 in these circumstances does BVPS Units 1 and 2 Page 10 Revision .2,4/06 61 k4a/id

I Rev. 2 Change C-10 l With two inoperable CCW trains, LCO 3.0.3 would be applicable in MODES 1-3 and result in the plant being placed in MODE 4. However, without adequate RHR decay heat removal capability, transitioning to MODE 5 from MODE 4 in accordance with LCO 3.0.3 may not be possible. In this case, Condition C would be applicable in MODE 4 and would replace LCO 3.0.3 for two inoperable CCW trains. Condition C provides a more appropriate Action than LCO 3.0.3 for reaching MODE 5 when the required RHR cooling capacity is not available. If adequate RHR decay heat removal capability is available to transition from MODE 4 to MODE 5, Condition C would not be applicable and the requirements of LCO 3.0.3 would be applied until the plant reached MODE 5. With two CCW trains inoperable and inadequate CCW flow to the RHR heat exchangers to support the required decay heat removal function, action must be initiated immediately to restore one CCW train to OPERABLE status. The action and Completion Time are reasonable, considering the required decay heat removal capacity to maintain the unit in MODE 5 is not available and the other systems available in MODE 4 to safely remove decay heat until adequate cooling capacity is restored to place and maintain the unit in MODE 5. 124

l Rev. 2 Change C-10 l INSERTS FOR ITS 3.7.8 BASES Service Water System (SWS)

1. The SWS consists of two 100% capacity, safety related, cooling water trains. There are three 100% capacity main SWS pumps capable of taking suction from the Ohio River at the intake structure supplying the two trains. For Unit 1, one SWS pump is normally operated to supply the quantity of water needed for the essential cooling requirements for all operating conditions. For Unit 2, two SWS pumps are normally operated concurrently to supply the quantity of viater needed for the essential cooling requirements for all operating conditions. One SWS pump motor is powered from one cf the two emergency 4,160 V switchgear buses and a second SWS pump motor is powered from the other bus. The third SWS pump motor, which is not normally connected to either of the buses can be manually connected to either. The SWS provides cooling water to such loads as the diesel generator cooling system heat exchangers, the Recirculation Spray System heat exchangers, control room emergency cooling coils, charging pump lube oil coolers, and component cooling water heat exchangers. In addition, the SWS provides a source of emergency makeup water to the Auxiliary Feedwater System. Only one of three SWS pumps is needed to provide the cooling for the minimum number of components required for safe shutdown following a DBA. In the event of a DBA or transient, initiating a containment isolation phase B signal, the SWS is designed to supply sufficient cooling water to safely shutdown the unit, assuming any single active component failure coincident with a LOOP.

2. The design basis of the SWS is for one SWS train to provide cooling to safety related components, required for safe shutdovwn, following a DBA. These components are listed in Reference 1. The SWS is designed to perform its function with a single failure of any active component, assuming a loss of offsite power. The SWS, in conjunction with the CCW System, also cools the unit from residual heat removal (RHR) entry conditions to Cold Shutdown during normal and post accident operations (Reference 2). The time required for this evolution is a function of the number of CCW and RHR System trains that are operating.

3. C.1 and C.2 Condition C applies to two inoperable SWS trains. Condition C is modified by a Note that states the Condition is only applicable in MODE 4 with inadequate SWS flow to the CCW heat exchangers to support the required decay heat removal needed to maintain the unit in MODE 5. In addition, the Actions are modified by a Note that states LCO 3.0.3 and all other LCO Actions requiring a MODE change from MODE 4 to MODE 5 are suspended until adequate SWS flow to the CCW heat exchangers is established to maintain the unit in MODE 5.

With two inoperable SWS trains, LCO 3.0.3 would be applicable in MODES 1-3 and result in the plant being placed in MODE 4. However, without adequate RHR decay heat removal capability, transitioning to MODE 5 from MODE 4 in accordance with LCO 3.0.3 may not be possible. In this case, Condition C would be applicable in MODE 4 and woulc' replace LCO 3.0.3 for two inoperable SWS trains. Condition C provides a more 129

Rev. 2 Change C-10 appropriate Action than LCO 3.0.3 for reaching MODE 5 when the required RHR cooling capacity is not available. If adequate RHR decay heat removal capability is available to transition from MODE 41o MODE 5, Condition C would not be applicable and the requirements of LCO 3.0.3 would be applied until the plant reached MODE 5. With two SWS trains inoperable and inadequate SWS flow to the CCW heat exchangers tb support the required decay heat removal function by the RHR System, action must be initiated immediately to restore one SWS train to OPERABLE status. The action and Completion Times are reasonable, considering the required decay heat removal capacity to maintain the unit in MODE 5 is not available and the other systems available in MODE 4 to safely remove decay heat until adequate cooling capacity is restored to place and maintain the unit in MODE 5. 130

I Rev. 2 Change C-10 I INSERT FOR CTS 3.7.3.1 MARKUP 1. NOTE NOTE LCO 3.0.3 and all other Only applicable in MODE 4 with LCO Actions requiring a inadequate CCW flow to the RHR MODE change From MODE 4 heat exchangers to support the to MODE 5 are suspended required decay heat removal needed until adequate CCW flow to to maintain the Unit in MODE 5. the RHR heat exchangers is established to maintain the unit in MODE 5. C. Two CCW trains inoperable. C.1 Initiate action to restore Immediately one train of CCW to OPERABLE status. %,1J 234

Rev. 2 Change C-10 BVPS ISTS Conversion 3.7 Plant SystEms Enclosure 3 Changes to C TS The affected CTS surveillance verifies the capability of the non-automatic power-operated valves to be cycled. However, remaining ITS SR 3.7.7.1 (CTS 4.7.3.1.1)) verifies each valve is in its correct position to ensure the CCW system can perform its required function. In addition, ASME code class valves will continue to be tested in accordance with the Inservice Testing Program. Compliance with the provisions of the Inservice Testing Program is not optional and is required by the TS (ITS Section 5.0) and Federal regulations (10 CFR 50.55a(f). The required Program specifies industry standard valve test requirements that are adequate to assure valve operability. Together, the remaining ITS surveillance and the Inservice Testing Program provide adequate assurance the required CCW flow path is available and that CCW valve operability is maintained. Therefore, the capability of the CCW system to perform its required function is assured by the remaining surveillance and the Inservice Testing Program. As such, CTS surveillance requirement 4.7.3.1.c is not required to ensure the CCW system is capable of performing its required function and is eliminated from the TS consistent with the ISTS. The proposed change is designated less restrictive because a surveillance required by the CTS will not be required in the ITS. L.3 (Category 4 - Relaxation of Required Action) CTS 3.7.3.1 contains no explicit provision for action when two CCW trains are inoperable. As a result, the unit would require entry into Specification 3.0.3 and the initiation of a unit shutdown to MODE 5 (exiting the Mode of Applicability). However, with two trains of CCW inoperable, sufficient cooling capacity to place and maintain the unit in Mode 5 may not exist. Proposed new Condition C of ITS LCO 3.7.7 would acknowledge this plant condition and provide a more appropriate action in lieu of LCO 3.0.3 for entering Mode 5. The proposed new Action would require an immediate action be initiated to restore one train of CCW to OPERABLE status. The new Condition would only replace LCO 3.0.3 when there is insufficient CCW flow to the RHR heat exchangers such that the unit could not be safely maintained in Mode 5 as required by LCO 3.0.3. The CTS is revised to incorporate the new and more appropriate Action for the condition of two inoperable CCW trains. The addition of the new Action is consistent with the similar ISTS Actions for three inoperable AFW pumps that supercede LCO 3.0.3 until at least one train of AFW is restored to operable status. The purpose of the revised CTS 3.7.3.1 Actions is to ensure that the plant is placed in a safe condition outside of the Mode of Applicability. Entry into Specification 3.0.3 requires a plant shutdown to MODE 5 within 37 hours. The entry into Specification 3.0.3 does not take into account specific actions to restore the means of decay heat removal when no CCW trains are available. The proposed change is acceptable since adequate CCW flow is necessary to transfer heat loads from the reactor coolant via the RHR heat exchangers in order to place and maintain the plant in Mode 5. The proposed change provides an appropriate Action for the specified plant condition and will continue to assure the plant is operated in a safe and orderly manner. LCO 3.0.3 does not provide any guidance regarding this plant condition and would simply continue to force the plant to be Mode 5. The proposed Action to immediately initiate action to restore one train of CCW to operable status addresses the unavailability of adequate RHR cooling in Mode 4 and would require adequate CCW heat removal capability to be restored as soon as BVPS Units 1 & 2 Page 29 Revision :2, 4/06 297

Rev. 2 Change C-10 BVPS ISTS Conversion 3.7 Plant Systems Enclosure 3 Changes to CTS possible. The plant can be safely maintained in Mode 4 with the other systems available. As such, forcing entry into Mode 5 in the time specified in LCO 3.0.3 may not be the best course of action with inadequate cooling capability to safely maintain the plant in Mode 5. Specifying a time in which this action must be met (as LCO 3.0.3 does) would not be appropriate given the plant condition and the need to restore the required cooling capacity prior to meeting the action. This change is designated as less restrictive because less stringent Action requirements are beiig applied in the ITS than were applied in the CTS. L.4 (Category 6- Relaxation Of Surveillance Requirement Acceptance Criteria) CTS 4.7.3.1.b verifies every 31 days that each CCW valve (manual, power operated cr automatic) servicing safety related equipment that is not locked, sealed, or otherwise secured in position is in the correct position. ITS SR 3.7.7.1 requires the same surveillance but clarifies that the acceptance criterion of the CCW System services "the RHR system" rather"safety related equipment." The CTS has been revised to add this clarification to the CCW system surveillance requirement. The BVPS CCW system is not relied on in the safety analysis to perform an accident mitigation function. The primary safety load of the BVPS CCW system is the RHR system. The BVPS RHR system is not part of the Emergency Core Cooling System and performs a dedicated decay heat removal function only. Tha purpose of CTS 4.7.3.1.b provides assurance the proper flow path exists for CCW operation. This change is acceptable because the only required safety function of the CCW System at BVPS is to supply the RHR heat exchangers with cooling water to safely maintain the plant in a shutdown condition. The other functions of the CCW System are related to providing a heat sink for operating heat generated from various components during normal (i.e., not accident mitigation) plant operation. This change is designated as less restrictive because of the greater flexibility of meeting the Surveillance Requirement. More Restrictive Changes (Al) M.1 CTS 3.7.3.1 Action currently contains no requirement to enter applicable Actions of CTS 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. BVPS Units 1 & 2 Page 30 Revision :, 4/06 298

I Rev. 2 Change C-10 INSERTS FOR CTS 3.7.4.1 MARKUP ~iAJ"s

1. SR 3.7.8.2 & SR 3.7.8.3 SR 3.7.8.2 Verify each SWS automatic valve in the flow path that is f181 months not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal.

SR 3.7.8.3 Verify each SWS pump starts automatically on an f181 months actual or simulated actuation signal.

2. New Condition C NOTE NOTE Only applicable in MODE 4 with LCO 3.0.3 and all other inadequate SWS flow to the LCO Actions requiring a Component Cooling Water MODE change from MODE 4 (CCW) heat exchangers to to MODE 5 are suspended support the required decay heat until adequate SWS flow to the removal needed to maintain the CCW heat exchangers is Unit in MODE 5. established to maintain the unit in MODE 5.

C. Two SWS trains inoperable. C.1 Initiate action to restore Immediately one train of SWS to OPERABLE status. 237

Rev. 2 Change C-10 BVPS ISTS Convenion 3.7 Plant Systems Enclosure 3 Changes to GTS confirm the SWS is operable. The CTS surveillance verifies the capability of the non-automatic power-operated valves to be cycled. However, remaining ITS SR 3.7.8.1 requires each manual, power operated, and automatic valve in the flow path that is not locked sealed or other wise secured in position is in the correct position (note that this surveillance includes the position of non-automatic power operated valves). ITS 3.7.8.2 verifies that each 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. In addition, ASME code class valves will continue to be tested in accordance with the Inservice Testing Program. Compliance with the provisions of the Inservice Testing Program is not optional .nd is required by the TS (ITS Section 5.0) and Federal regulations (10 CFR 50.55a(l). Together, the two remaining ITS surveillances and the ASME Inservice Testing Program provide adequate assurance the required SWS flow path is available and that the SWS valves are maintained operable. Therefore, CTS surveillance 4.6.2.1.c.1 is not required to ensure the SWS is capable of performing its required safety function and is deleted consistent with the ISTS. The proposed change is designated less restrictive because a surveillance required by the CTS will not be required in the ITS. L.3 (Category 4 - Relaxation of Required Action) CTS 3.7.4.1 contains no explicit provision for action when two SWS trains are inoperable. As a result, the unit would require entry into Specification 3.0.3 and the initiation of a unit shutdown to MODE 5 (exiting the Mode of Applicability). However, with two trains of SWS inoperable, sufficient cooling capacity to place and maintain the unit in Mode 5 may not exist. Proposed new Condition C of ITS LCO 3.7.7 would acknowledge this plant condition and provide a more appropriate action in lieu of LCO 3.0.3 for entering Mode 5. The proposed new Action would require an immediate action be initiated to restore one train of SWS to operable status. The new Condition would only replace LCO 3.0.3 when there is insufficient SWS flow to the CCW heat exchangers (which provide RHR cooling) such that the unit could not be safely maintained in Mode 5 as required by LCO 3.0.3. The CTS is revised to incorporate the new and more appropriate Action for the condition of two inoperable SWS trains. The addition of the new Action is consistent with the similar ISTS Actions for three inoperable AFW pumps that supercede LCO 3.0.3 until at least one train of AFW is restored to operable status. The purpose of the revised CTS 3.7.4.1 Actions is to ensure that the plant is placed in a safe condition outside of the Mode of Applicability. Entry into Specification 3.0.3 requires a plant shutdown to MODE 5 within 37 hours. The entry into Specification 3.0.3 does not take into account specific actions to restore the means of decay heat removal when no SWS trains are available. The proposed change is acceptable since adequate SWS flow is necessary to transfer heat loads from the reactor coolant via the CCW via the RHR heat exchangers in order to place and maintain the plant in Mode 5. The proposed change provides the appropriate Action for the specified plant condition and will continue to assure the plant is operated in a safe and orderly manner. LCO 3.0.3 does not provide any guidance regarding this plant condition and would simply continue to force the plant to be Mode 5. The proposed Action to immediately initiate action to restore one train of SWS to operable status addresses the unavailability of adequate RHR cooling in Mode 4 BVPS Units I & 2 Page 35 Revision :2, 4/06 303

l I Rev. 2 Change C-10 l BVPS ISTS Conversion 3.7 Plant Systems Enclosure 3 Changes to CTS and would require adequate SWS cooling capacity to be restored as soon as possible. The plant can be safely maintained in Mode 4 with the other systems available. As such, forcing entry into Mode 5 in the time specified in LCO 3.0.3 may not be the best course of action with inadequate cooling capability to safely maintain the plant in Mode 5. Specifying a time in which this action must be met (as LCO 3.0.3 does) would not be appropriate given the plant condition and the need to restore the required cooling capacity prior to meeting the action. This change is designated as less restrictive because less stringent Action requirements are being applied in the ITS than were applied in the CTS. More Restrictive Changes (Al M.1 CTS 3.7.4.1 Action currently contains no requirement to enter applicable Actions of CTS 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. The proposed change is acceptable because LCO 3.4.6 contains appropriate Actions and Conditions to address various combinations of inoperable RCS and RHR loops and requires immediate action be taken. If the RHR loop affected by the inoperable SWS train was required operable to meet LCO 3.4.6, then the note requires the applicable Action Condition of LCO 3.4.6 be entered. If the RHR loop affected by the inoperable SWS train was not used to meet LCO 3.4.6, there is no applicable Condition in LCO 3.4.6 to enter. LCO 3.8.1 contains appropriate Actions and Conditions to address various combinations of inoperable DG(s) and requires immediate action be taken. If the DG affected by the inoperable SWS train was required operable to meet LCO 3.8.1, then the note requires the applicable Action Condition of LCO 3.8.1 be entered. If the DG affected by the inoperable SWS train was not used to meet LCO 3.8.1, there is no applicable Condition in LCO 3.8.1 to enter. The ITS Note provides support/supported system guidance and, due to the immediate actions of the DG LCO, is necessary since the ITS includes LCO 3.0.6 which precludes entering a supported system TS unless specifically directed by the support system LCO. Although consistent with the operability requirements of the DG system, this additional TS requirement was not previously specified in the TS. Therefore, the addition of this Note is considered more restrictive. BVPS Units I &2 Page 36 Revision 2, 4/06 304

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 169 (UNIT 2) REVISION 2 CHANGE C-1l Database # 200601111544 NRC Commenter: R. Clark The NRC reviewer requested that additional concluding statements for ITS 3.3.3 (PAM) JFD # 5 be provided to summarize the justifications originally provided for certain instruments. The affected instruments discussed in JFD # 5 consist of the following Unit 2 instruments:

Containment Sump Level NR,
RCS Subcooling Margin Monitor, and
Secondary System Radiation Monitors.

BVPS agreed to provide the additional text requested. This change only affects the JFD documentation associated with ITS 3.3.3 (PAM Instrumentation) in Section 3.3B of the ITS conversion submittal. Affected Pages: The following Table(s) list the affected pages by type (i.e., ITS markup, CTS markup, etc.). In order to facilitate review by ITS section, a separate table is provided for each ITS section affected by the change. The page numbers listed are the ITS section specific consecutive numbers found in the lower right corner of each page. Note: Because the affected page(s) for each change were extracted from a complete ITS section electronic file, the electronic hyperlinks (created in the complete ITS section file) do not work in the collection of affected pages that follow this cover page. ITS SECTION 3.3B (REMAINDER OF INSTRUMENTATION) INDEX OF AFFECTED PAGES ITS MARKUPS No change ITS JFDS PAGES: 31, 32, 33, 34, 35, 36, 37 & 38 ITS BASES MARKUPS No change ITS BASES JFDS No change CTS MARKUPS No change CTSDOCS No change

Rev. 2 Change C-11 BVPS ISTS Conversion 3.3 B Instrumentation Enclosure 1 Changes to ISTS RWST level reaches the extreme low level setpoint. All actions associated with recirculation spray system however are automatic, and therefore no operator action is required in the design basis analyses based on the containment sump level. The narrow range sump level indication provides information regarding the normal containment sump level and is limited to 0-12 inches of range. The normal containment sump level is not the primary indication for determining the level of water in the containment ECCS sump where the recirculation spray pumps take suction. The wide range sump level indication is located in the ECCS sump and provides the necessary range (0-200") to determine such post accident conditions as the water level in the ECCS sump at the time the recirculation spray system is started. The narrow range sump level indication may be used for RCS leak detection and is addressed in the technical specification for RCS Leakage Detection Instrumentation (BVPS ITS 3.4.15). Therefore, for the purpose of post accident monitoring, the wide range containment sump level indication provides the necessary indication and range to determine the ECCS sump level during accident conditions. The narrow range indication would not provide a direct indication of conditions in the ECCS sump required during post accident conditions and is limited to 12 inches of range. Therefore, the narrow range containment sump level indication is not required in the PAM TS to assure the necessary post accident monitoring information is available in the control room. The Unit 2 wide range sump level indication is included in the proposed PAM ITS. The PAM ITS requires 2 channels of wide range sump level indication operable which is sufficient to assure the capability to monitor sump level after an accident is maintained. The inclusion of the Unit 2 wide range sump level and not the narrow range level in the PAM ITS is consistent with the CTS requirements for both Unit I and 2. In addition, it should be noted that two channels of RWST level are also included in the proposed ITS PAM list. The RWST level also provides information directly related to the amount of water delivered to the RCS and subsequently to the containment during and after safety injection. Two channels of containment sump wide range level and RWST level are included in the proposed PAM ITS. The information provided by these instruments is sufficient to monitor the water level in the ECCS containment sump, even considering a single failure. Therefore, the inclusion of the containment sump narrow range indication in the PAM specification is unnecessary. The proposed PAM instrumentation is adequate to assure the capability to determine the amount of water in containment. Considering that the wide range containment sump level indication provides the necessary indication and range to determine the ECCS sump level during accident conditions and that the narrow range indication does not provide a direct indication of conditions in the ECCS sump required during post accident conditions and is limited to 12 inches of range, the narrow range containment BVPS Units 1 and 2 Page 3 Revision 2, 4/06 31

Rev. 2 Change C-1 1 BVPS ISTS Conversion 3.3 B Instrumentation Enclosure I Changes to ISTS sump indication does not fulfill the necessary PAM Function. Therefore, the narrow range containment sump level indication is not required in the PAM TS to assure the necessary post accident monitoring information is available in the control room. B. Unit 2 RCS Subcoolinq Margin Monitor is not included in the proposed PAM TS. This Unit 2 variable was classified as a Type A and Category 2 variable in the Unit 2 Regulatory Guide 1.97 Report. Unit 1 classified the RCS subcooling monitor as monitoring a Regulatory Guide 1.97 Type B, Category 2 variable. The RCS subcooling indication provides information to the control room operators related to satisfying one of the SI termination criteria following a design basis accident. The inputs to the RCS subcooling monitor are the core exit thermocouples for RCS temperature and the wide range RCS pressure indication for RCS pressure. Since both of these indications are independently available in the control room and are also included in proposed BVPS PAM ITS, the RCS subcooling monitor only provides a verification of these other primary indications. The backup nature of the Unit 2 Subcooling Margin Monitor indication is identified in UFSAR (Table 7.5.4). In addition, the RCS hot leg temperature indication and RCS cold leg temperature indication are included in the BVPS PAM ITS. The RCS hot leg temperature indication can also be used to verify adequate core cooling, RCS subcooling, and in conjunction with the RCS cold leg temperature indication, the effectiveness of RCS heat removal by the secondary system. The RCS pressure and temperature variables were classified as Regulatory Guide 1.97 Type A and Category 1. Considering the variety of RCS temperature indications and the RCS pressure indication included in the proposed BVPS PAM ITS and that the RCS Subcooling Margin Monitor is clearly identified as a backup indication in the Unit 2 UFSAR, the inclusion of the RCS Subcooling Margin Monitor is unnecessary to assure the ability to determine adequate core cooling. The RCS temperature and pressure indications required operable in the proposed BVPS PAM ITS provide sufficient assurance that RCS subcooling can be determined. In addition, since the RCS Subcooling Margin Monitor is specified in the Unit 2 CTS PAM, it will be relocated from the TS to the Licensing Requirements Manual (LRM). The LRM contains other BVPS relocated TS and provides a more appropriate level of control for a backup PAM indication. The relocation of this Unit 2 requirement also serves to make the Unit 1 and Unit 2 PAM ITS requirements the same. Considering the primary inputs to the RCS subcooling monitor are the core exit thermocouples for RCS temperature and the wide range RCS pressure indication for RCS pressure and that both of these indications are included in proposed BVPS PAM ITS, the RCS subcooling monitor is not required to fulfill the necessary PAM Function. Therefore, the RCS subcooling monitor is not required in the PAM TS to assure the necessary post accident monitoring information is available in the control room. C. Unit 2 Secondary System Radiation (Main Steam Discharge Radiation Monitors) BVPS Units 1 and 2 Page 4 Revision 2, 4,'06 32

Rev. 2 Change C41 BVPS ISTS Conversion 3.3 B Instrumentation Enclosure 1 Changes to ISTS is not included in the proposed PAM TS. Secondary system radiation was classified as a Type A and Category 1 variable in the Unit 2 Regulatory Guide 1.97 Report. These effluent radiation monitors may be used to detect a Steam Generator Tube Rupture (SGTR). However, the primary indications used for diagnosis and response to a SGTR accident are RCS inventory losses (i.e., decreasing pressurizer level and pressure) and increasing water level in the affected steam generator. These indications provide the most reliable diagnosis of a SGTR accident to prompt the appropriate operator actions and are included in the proposed BVPS PAM ITS. Although the main steam discharge radiation monitors may provide an indication of steam generator tube leakage, earlier detection of steam generator tube leakage is provided by more sensitive radiation monitors such as the N-16 radiation monitors on each steam line, the steam generator blowdown radiation monitor, and the condenser air ejector radiation monitor. ThE! use of these more sensitive radiation monitors to detect tube leakage is consistent with the EPRI Guidelines for PWR primary-to-secondary leak detection. As such, the Unit 2 secondary system radiation indication is not the primary indication relied on to diagnose or mitigate a steam generator tube rupture accident. The proposed PAM ITS requires pressurizer level, RCS pressure, and SG water level indications operable. The proposed PAM ITS requirements are sufficient to ensure a SGTR is detected. In addition, considering the low levels of fuel leakage in modern fuel assemblies, and the relatively high range of the Unit 2 Main Steam Discharge monitors, these monitors can not be relied on to provide a timely or reliable indication of a SGTR. It should be noted that the Main Steam Discharge Radiation Monitors are required OPERABLE in the CTS (Radiation Monitoring TS), however, the associated Actions permit unlimited continued operation when the monitors are inoperable. As these monitors are effluent monitors they are proposed for relocation to the Offsite Dose Calculation Manual (ODCM) consistent with the location of the corresponding Unit 1 steam discharge radiation monitors. The ODCM contains other effluent monitors relocated from the TS and provides the appropriate level of control for this backup type of PAM indication. The relocation of these Unit 2 radiation monitors to the ODCM makes the location of these monitors the same for both Unit I and Unit 2. Considering the relatively high range of the Unit 2 secondary system radiation monitors, making them unreliable indicators of a SGTR, and the fact that these monitors are not the primary indication relied on to diagnose or mitigate a steam generator tube rupture accident and that the proposed PAM ITS requires pressurizer level, RCS pressure, and SG water level indications to be operable (the prime indications of a SGTR), the Unit 2 Secondary System radiation monitors are not required to fulfill the necessary PAM Function. Therefore, the Unit 2 secondary system radiation monitors are not required in the PAM TS to BVPS Units 1 and 2 Page 5 Revision 2, 4/06 33

l Rev. 2 Change C-11 I BVPS ISTS Conversion 3.3 B Instrumentation Enclosure 1 Changes to ISTS assure the necessary post accident monitoring information is available in the control room. D. Unit 2 neutron flux upper and lower range indication (i.e., the Gamma-Metrics full range neutron flux monitor) is not included in the proposed PAM TS and is not part of the CTS. The upper and lower range neutron flux indication was classified as a Type B and Category 1 variable in the Unit 2 Regulatory Guide 1.97 Report. The Unit 2 Westinghouse Nuclear Instrumentation System (i.e., source, intermediate and power range instrumentation) is proposed to be included in the PAM TS consistent with the corresponding Unit 1 PAM instrumentation. The Unit I response to RG 1.97 identified the Westinghouse Nuclear Instrumentation System source, intermediate, and power range neutron flux variables as the required PAM instrumentation. The Unit I response to RG 1.97 classified the Westinghouse Nuclear Instrumentation System source, intermediate, and power range neutron flux variables as Type B and Category 1 variables. The Unit 2 response to RG 1.97 identified upper and lower range neutron flux variables that utilize the full range Gamma-Metrics instrumentation. The NRC subsequently approved both unit responses to RG 1.97. The Unit 1 SER for the Westinghouse Nuclear Instrumentation System to be used as post accident monitoring instrumentation was transmitted by separate NRC letter dated 11/17/95 (TAC NO. M81201). The NRC found the Westinghouse Nuclear Instrumentation System to be acceptable based on the availability of alternate means of assuring the reactor is in a shutdown condition. The availability of fully qualified core exit temperature and RCS hot and cold leg temperature indications and confirmation of the negative reactivity added by the boron injected into the RCS during accident conditions was considered by the NRC to be sufficient to allow operators to determine that the reactor is in a shutdown condition. The Unit 2 full range Gamma-Metrics instrumentation is not specifically required to fulfill the initial indicating function of the neutron flux variable (i.e., to confirm reactor trip). The Westinghouse Instrumentation can perform this function. In addition, if the Westinghouse Nuclear Instrumentation was not available due to adverse conditions within containment, long term core stability can be verified in the same manner as approved for Unit 1 by core exit temperatures and RCS hot and cold leg temperatures (both of which are included in the proposed PAM TS). Therefore, in order to make the Unit 1 and 2 PAM TS consistent and to provide an accurate indication of neutron flux to satisfy the required PAM function, the Westinghouse Nuclear Instrumentation System (i.e., source, intermediate, and power range indications) are included in the proposed PAM TS for both units. The status of the Unit 2 Gamma-Metrics instrumentation (not included in the CTS or proposed ITS) will remain unchanged. E. Unit 1 Radiation Level in Primary Coolant (RCS letdown Radiation Monitors) is not included in the proposed PAM TS. The radiation level in the primary coolant was classified as a Type C Category 1 variable. The RCS letdown radiation monitors that perform this function are not in the Unit I CTS and Unit 2 does not BVPS Units 1 and 2 Page 6 Revision 2, 4/06 34

Repaginated due to Rev. BVPS ISTS Conversion 2 Change C-11 3.3 B Instrumentation Enclosure I Changes to IST'S list a corresponding RG 1.97 variable. The affected radiation monitors are located in the RCS letdown line, which is isolated upon the receipt of a safety injection signal. Although the RCS letdown radiation monitors may be used as diagnostic indications of fuel leakage, for the purposes of the protection of the health and safety of the offsite general public, the key indicators of the need to implement offsite emergency protective actions at BVPS Units 1 and 2 are high core exit thermocouple indications, high containment radiation levels, failure of complete containment isolation and/or high containment pressures. Other indications, including the RCS letdown line radiation level, are most useful to validate the loss of barriers, but not as primary indications of the potential for, or the loss of the barrier. The Emergency Action Levels in the E-Plan for BVPS Units 1 and 2 utilize the containment high range radiation monitors as an indication of a loss of one or more fission product barriers in the assessment of the declaration of a General Emergency level and the potential need for offsite radiological protection actions. The BVPS Unit 1 and 2 Core Damage Assessment also uses the containment high range radiation monitors as an input to the determination of core damage. Core exit temperature, containment radiation level, containment isolation valve position, and containment pressure instrumentation are all included in the proposed PAM TS and provide adequate assurance that the PAM function can be accomplished. Therefore, in order to make the Unit 1 and 2 PAM TS consistent and to only include the primary indications used to satisfy the PAM functions, the Unit 1 RCS radiation level indication is not included in the proposed PAM TS. The status of the Unit 1 RCS radiation monitors (not included in the TS) will remain unchanged. F. Unit 1 and 2 Containment Pressure (Narrow Range) is not included in the proposed PAM TS. The Containment Pressure Narrow Range indication is currently classified as Regulatory Guide 1.97 Type A, Category I for both BVPS Unit 1 and Unit 2. The narrow range containment pressure instrumentation is no': included in the CTS. The Containment Pressure (Wide Range) instrumentation is proposed for inclusion in the PAM TS. The containment pressure indication is provided for assessing inadequate containment cooling and for determining the potential challenge to containment integrity. The significant post accident use of containment pressure indication is as an indicator of the potential loss of a fission product boundary in the Emergency Action Levels in the E-Plan for BVPS Units 1 and 2. Containment pressure is a key indicator in the declaration of a General Emergency level and the potential need for offsite radiological protection actions. The wide range containment pressure instrumentation provides an adequate range and sensitivity for this purpose. The narrow range containment pressure BVPS Units I and 2 Page 7 Revision 2, 4,'06 35

Repaginated due to Rev. BVPS ISTS Conversion 2 Change C-11 3.3 B Instrumentation Enclosure 1 Changes to ISTS instrumentation is limited in range and does not extend sufficiently beyond the design basis pressure to provide the required indication during all types of post accident conditions. As such, the containment pressure narrow range indication is not required in the PAM TS as it does not provide any additional information pertinent to post accident monitoring that is not provided by the containment wide range pressure indication. The proposed PAM TS include 2 channels of wide range containment pressure indication. The proposed PAM requirements are adequate to assure the capability to monitor containment pressure after an accident (even considering a single failure). In addition, the inclusion of the Containment Pressure (Wide Range) instrumentation in the PAM TS is consistent with the CTS. G. Unit 1 and 2 Containment Hydrogen Monitors are not included in the proposed PAM TS. The Containment Hydrogen Concentration is currently classified as a Regulatory Guide 1.97 Type A, Category I variable for Unit 1 and a Category 1 variable for Unit 2. Although the Hydrogen Monitors are associated with a Category 1 variable (both Units) and Type A (Unit 1 only) they are not included in the BVPS PAM ITS. The Hydrogen Monitors were removed from the ISTS by TSTF-447, Rev. 1 which implemented in the technical specifications the NRC rule change to 10 CFR 50.44 (standards for combustible gas control in light-water-cooled power reactors). In addition, the Hydrogen Monitors were removed from the current BVPS technical specifications by License Amendment numbers 259 (Unit 1) and 149 (Unit 2) issued May 19, 2004. Currently requirements for the BVPS Unit 1 and Unit 2 Hydrogen Monitors are maintained in the BVPS Licensing Requirements Manual (LRM). Non-TyDe A or Cateaorv 1 Variables Added: H. Unit 1 AFW Flow was included in the proposed PAM TS. The Unit I AFW Flow indication is classified as a Regulatory Guide 1.97 Type D, Category 2 variable. This indication is in the CTS requirements for PAM and provides an important indication, similar to the Unit 2 AFW Flow indication, which was classified Regulatory Guide Type A, Category 1. The inclusion of this Unit 1 indication will help to make the PAM requirements for both units consistent. As the Unit I AFW Flow was not designed as a Regulatory Guide 1.97 Type A or Category I instrument, there is only one channel per SG. The AFW Flow indication is included in the proposed PAM ITS in a combined Function with SG Level (Narrow Range) indication. The combined Function is listed as "Secondary Heat Sink Indication" on PAM Table 3.3.3-1. The use of this combined Function allows two channels of indication to be specified for each SG. The required two channels of this Function can be met by any combination of the (3) SG Level (Narrow Range) channels and the single Unit 1 AFW Flow channel for each SG. Any of these channels provide the required post accident indication to assure an available heat sink. BVPS Units I and 2 Page 8 Revision 2, 4106 36

l Repaginated due to Rev. l BVPS ISTS Conversion 2 Change C-11 3.3 B Instrumentation Enclosure 1 Changes to ISTS I. Unit 2 Reactor Vessel Water Level was included in the proposed PAM TS. The Unit 2 Reactor Vessel Water Level indication is classified as a Regulatory Guide 1.97 Type B, Category 2 variable. This indication is in the CTS requirements for PAM and provides an important indication similar to the Unit 1 Reactor Vessel Water Level indication which was classified Regulatory Guide Type B, Category

1. The inclusion of this Unit 2 indication will help to make the PAM requirements for both units consistent.

J. Unit 2 Refueling Water Storage Tank (RWST) Level (Wide Ranae) is added to the proposed PAM TS. The Unit 2 RWST Level (Wide Range) indication is classified as a Regulatory Guide 1.97 Type D, Category 2 variable. However, this Unit 2 indication was determined to provide important information for Unit 2 similar to the Unit 1 RWST Level indication which was classified as a Regulatory Guide 1.97 Type A, Category I variable. The inclusion of this Unit 2 indication will help to make the PAM requirements for both units consistent. The inclusion of this indication in the PAM TS represents a new TS requirement for both units. K. Unit 2 Containment Isolation Valve Position Indication is added to the proposed PAM TS. The Unit 2 Containment Isolation Valve Position indication is classified as a Regulatory Guide 1.97 Type C, Category 2 variable. However, this Unit 2 indication was determined to provide important information for Unit 2 similar to the Unit 1 Containment Isolation Valve Position indication which was classified as a Regulatory Guide 1.97 Type B, Category I variable. The inclusion of this Unit 2 indication will help to make the PAM requirements for both units consistent. The inclusion of this indication in the PAM TS represents a new TS requirement for both units. L. Unit 1 and Unit 2 High Head Safety Iniection (SI) Automatic Iniection Header Flow is added to the proposed PAM TS. The High Head SI Automatic Injection Header Flow indication is classified as a Regulatory Guide 1.97 Type D, Category 2 variable for both units. This indication is not in the CTS. As this variable is not classified as a Type A or Category I variable it was not designed as such. There is only a single channel of indication available for each unit. This variable has been identified as the preferred control room indication for confirming automatic Si initiation. Confirming automatic Si initiation is important in order to determine if manual action is needed to assure high head SI initiation. Although this variable does not meet the criteria for inclusion in the PAM ITS, it is included in the proposed ITS for both units in recognition of its importance in confirming automatic high head SI initiation. As this indication does not meet the Regulatory Guide 1.97 classification requirement for inclusion in the PAM TS and was not designed with redundancy, it is assigned the same Action for a single inoperable channel as the other PAM Functions. The Action to restore the inoperable channel to operable status within 30 days or submit a report to the NRC is sufficient for this instrument Function. The standard Action for a single inoperable channel is acceptable for this BVPS Units 1 and 2 Page 9 Revision 2, 4f06 37

REV. 2 Changes C-9 & BVPS ISTS Conversion Repagination due to C-11 l 3.3 B Instrumentation Enclosure 1 Changes to ISTS Function considering that the Function is not required to be in the PAM ITS and that it does not meet the stringent design requirements of the other Functions that are required to be in the PAM TS. In addition, acceptable alternate indications exist in the control room to confirm automatic high head SI initiation. An alternate method of verifying SI initiation can be provided by the High Head SI pump amperage indication, the High Head SI header pressure indication, and the SI automatic valve position indication. A combination of these indications provides an acceptable long term alternate method to verify automatic SI initiation until the single channel of high head flow indication is restored to operable status.

6. The proposed PAM TS includes Function number 18, " Secondary Heat Sink Indication" and the associated footnote "d" which states " The required channels may be satisfied by using any combination of SG Water Level (Narrow Range) channels and Auxiliary Feedwater Flow channels such that 2 channels are OPERABLE for each SG." The proposed new Function combines the instrument channels for SG level (narrow range) and Auxiliary Feedwater Flow (AFW). The CTS for PAM only includes the AFW Flow indication. The addition of the SG Level (Narrow Range) represents a new TS requirement for the BVPS units. The ability to maintain the SG level within the NR indication also confirms an adequate water volume for decay heat removal as well as confirming the associated AFW system capability to feed the SG. The addition of the SG Water Level NR channels to the PAM TS makes the proposed change possible. The allowance to combine these indications into a single Function is acceptable as these indications serve a similar purpose (i.e., the maintenance of SG level to provide an adequate heat sink). The use of either indicator for this purpose is consistent with the Westinghouse Emergency Response Guidelines as implemented in the BVPS Unit I and Unit 2 Emergency Operating Procedures. In addition, the Unit 1 AFW Flow is not a Regulatory Guide 1.97 Type A or Category 1 instrument, and only one channel is available per SG. As such, the proposed new Function that allows AFW flow and SG level to be combined permits Unit 1 to have 2 channels of indication for each SG and makes both units the same. In addition, the use of the combined "Secondary Heat Sink Indication" Function in the PAM ITS was previously approved by the NRC for the D. C.

Cook plant in their conversion to the ISTS.

7. The proposed PAM Table 3.3.3-1 is revised by the addition of new Note (e) in the table column intended to provide direction when two or more inoperable channels are not restored to operable status in the specified time. The addition of the new note is associated with Function 19 on the table. Function 19 is the only Function with one of required channel. The addition of Note (e) is intended to clarify that Condition B is the correct Condition for Functions with only one required channel and that Conditions E and F (applicable for Functions with 2 or more required channels) do not apply for Functions with only one required channel. This note was added at the request of the NRC.

BVPS Units I and 2 Page 10 Revision 2,4/06 38

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT Z) REVISION 2 CHANGE C-12 Database# 200511171609 & 200601231133 NRC Commenter: P. Hearn/K. Desai BSI 6 Originally, the change proposed in BSI-6 revised the allowance in the note modifying the performance of ITS Surveillance Requirement 3.4.1.4 from 24 hours after reaching 90% RTP to 30 days after reaching 90% RTP. The original BSI-6 change was based on a similar change made by the North Anna Plant in their ITS conversion which was approved by the NRC. However, the BVPS ITS conversion NRC reviewers objected to this change. After discussion with the NRC reviewer, BVPS agreed to change the provisions of the note modifying Surveillance Requirement 3.4.1.4 to 7 days instead of 30 days and to change the specified power level from 90% RTP to 95% RTP. The proposed change to BSI-6 was acceptable to the NRC. This change only affected ITS Surveillance Requirement 3.4.1.4. Affected Pages: The following Table(s) list the affected pages by type (i.e., ITS markup, CTS markup, etc.). In order to facilitate review by ITS section, a separate table is provided for each ITS section affected by the change. The page numbers listed are the ITS section specific consecutive numbers found in the lower right corner of each page. Note: Because the affected page(s) for each change were extracted from a complete ITS section electronic file, the electronic hyperlinks (created in the complete ITS section file) do not work inthe collection of affected pages that follow this cover page. ITS SECTION 3A (RCS) INDEX OF AFFECTED PAGES ITS MARKUPS PAGE: 6 ITS JFDS PAGE: 55 ITS BASES MARKUPS PAGE: 95 ITS BASES JFDS No change CTS MARKUPS PAGE: 223 CTS DOCS PAGES: 295 & 296

l Rev. 2 Change C-12 J RCS Pressure, Temperature, and Flow DNB Limits I 3.4.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.1.1 Verify pressurizer pressure is greater than or equal to 12 hours the limit specified in the COLR. SR 3.4.1.2 Verify RCS average temperature is less than or equal to 12 hours the limit specified in the COLR. SR 3.4.1.3 Verify RCS total flow rate is 2 A }0] gpm and 12 hours greater than or equal o mit specified in the COLR. 7 days SR 3.4.1.4

                                                - NOTE -
         ,00         Not required to be performed until 2-hous after I

FT5 Value ify by precision heat balance that RCS total flow rate 1181 months is 22, gpm and greater than or equal to the limit specified in the COLR. WOG STS 3.4.1 -2 Rev. 2, 04/30/01' 6

Rev. 2 Change C-12 BVPS ISTS Conversion 3.4 Reactor Coolant System Enclosure 1 Changes to ISTS ITS 3.4.1 RCS Pressure, Temperature, and Flow Departurefrom Nuclealte Boiling (DNB) Limits JUSTIFICATION FOR DEVIATION (JFD)

1. The ISTS surveillance note that modifies the precision heat balance requirement is revised to require the surveillance to be performed within 7 days after reaching 95%

RTP instead of 24 hours after reaching 90% RTP. The corresponding BVPS CTS does not contain a time limit in which to perform the heat balance surveillance. Currently the performance of this surveillance is controlled administratively by plant procedures. The time in which the surveillance is performed is not a specific assumption of a safety analysis. However, establishment of the conditions for performance of the precision heat balance is time consuming dependent on other startup testing, and requires stable operating conditions. The ISTS requirement of 24 hours after exceeding the required power does not allow sufficient time to establish stable plant conditions, install required instrumentation, perform the surveillance, and analyze the results. In addition, other required testing at high power levels after a refueling outage, such as physics testing and flux mapping, may interfere with establishing optimum conditions for the performance of the heat balance surveillance. Therefore, BVPS proposes that the note allow 7 days after reaching the specified power to complete the required heat balance surveillance. The 7 day allowance to perform the surveillance after reaching 95% RTP is acceptable considering that the Frequency for performing this surveillance is 18 months. As such the 7 day allowance after reaching 95% RTP provides a sufficient operating restriction to ensure the surveillance is performed in a timely manner while providing time to accommodate any additional required testing, achieve stable operating conditions after startup, install the necessary test equipment, perform the test, and analyze the results. In addition, the NRC has previously approved the 7 day and 95% RTP allowance to perform this testing for other Westinghouse Plants in their conversion to the ISTS. BVPS Units I & 2 Page 1 Revision ,%04/06 55

RCS Pressure, Temperature, and Flow DNB Limits Rev. 2 Change C-12 I I B 3.4.1 BASES SURVEILLANCE RE( DUIREMENTS (continued) 95 )100% This SR is modified by a Note that all ws entry into MODE 1, without having performed the SR, and place ent of the unit in the best condition No for performing til SR.he e Note s the SR is not required t Thsthat performed until °1houF ,fter 2 RTP. This exception is a prpriate since the heat balance req~e the plant to be att iiuv [%RTP to obtai'nthe sa low accuracies. The Surveillance shall be performed witn ing ri}/- RTP. reach REFERENCES 1. VSAR Soction [4,r] dy l195 l UFSAR, Chapter 14 (Unit 1), and UFSAR Chapter 15 (Unit 2). l WOG STS B 3.4.1 -5 Rev. 2, 04/30/01 95

I Rev. 2Change C-12 I POWER DISTRIBUTION LIMITS I I v r DNS-PAIAMETERH ~RCS Pressure. Temperature, NuclateBoiing(DN) LIMITING CONDITION FOR OPERATION UitsITS and Flow Departurefo 3 IT3.13.4.1_] 3.2 .5 The following DNB related parameters shall be maintained within the limits specified below: E --- . Reactor Coolant System Tavg is less than or equal to the limit specified in the COLR, LiV~b. Pressurizer Pressure is greater than or equal to the limit' specified in the COLR, and

c. Reactor Coolant System Total Flow Rate 2 261,6003 and greater than or equal to the limit specified in the COLR.

APPLICABILITY: MODE 14. ACTION: With one or more of the above DNB related parameters not within limits, restore the DNB related parameter(s) to within limit within 2 hours or reduce THERMAL R to less than 5 percent of RATED THERMAL POWER within the next hours. 7 [ ;R 3.4.1.1 LI LJR 3.4.1.3 LLANCE REQUIREMENTS 4-.2 . 5-.1 Each of the above DNB related parameters shall be verified _o be within their limits at least once per 12 hours. The Reactor Coolant System total flow rate shall be

      /determined to be within its                       limits by                               atleast ateasuremqt     once per 18 months                                  Applicability          l                              ion   heat balance lSR 3.4.1.4 l                             1  Aplcbit         oe 1
       -(1        Limit not applicable during either a THERMAL POWER ramp increase in excess of 5 percent RATED THERMAL POWER per minute or a THERMAL POWER step increase in excess of 10% RATED THERMAL POWER.
       -(2)                      ecificati                          on 4.0.4 are nr Reactor Coolant System toL~i                                            o      ow a calorimetric flow measurement                              libration               oactor                     Coolant Sysow                  rate     indicators.
       -(+/- jAnalytical           limit used in             the safety analysis.                           Bases NOTE Not Required to be performed until 7 days after 2 95% RTP.

BEAVER VALLEY - UNIT 2 3/4 2-11 e nt No. 120 223

BVPS ISTS Conversion Rev. 2 Change C-12 3.4 Reactor Coolant System Enclosure 3 Changes to CTS 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 for the measurement of the RCS flow by precision heat balance (calorimetric). The IST'S surveillance 3.4.1.4 note states that the surveillance is "Not required to be performed until 24 hours after 2 [90%] RTP." The ISTS does not use non-specific exeptions to 4.0.4 when required to allow entry into the applicable Mode to perform surveillance testing. Instead, the ISTS provides a more specific exception for a given surveillance with a time limit to more clearly define when the affected surveillance must be performed after Mode entry. 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 i; "not required to be performed until 7 days after - 95% RTP" and is moved into the ITS surveillance 3.4.1.4. Normal TS rules of usage (CTS 4.0.4 and ITS SR 3.0.4) prohibit entry into the Mode of applicability of a TS unless the TS surveillances are met or an exception is provided. The purpose of the subject CTS and ISTS notes is to allow Mode I ent-y to perform the required heat ba'ance (calorimetric) at a power level close to 100%/;. The closer to 100% power the surveillance is performed the more accurate the results of the heat balance. The results of the heat balance are then used (if required) to fine tune the RCS flow instrumentation. The BVPS CTS note that provides the exception to performing the RCS flow verification heat balance does not contain a specific power level at which the surveillance must be performed. Consistent with the instrument uncertainty analysis assumptions made in WCAPs 15264 (Unit 1) and 15265 Unit 2) "Westinghouse Revised Thermal Design Procedure Instrument Uncertainty Methodolgy for FirstEnergy Nuclear Operating Company Beaver Valley Units 1 and 2" BVPS performs the required heat balance near 100% power. The Westinghouse WCAFs were submitted to the NRC as part of the Revised Thermal Design Procedure (RTDP) License Amendment Request. The Westinghouse WCAPS were reviewed by the NRC and found to provide an acceptable methodology for implementation of the RTDP (including the determination of RCS flow) as concluded in the NRC's Safety Evaluation Report for Amendments 239 and 120 issued July 20, 2001. Therefore, adoption of the power level requirement of 2 95% RTP for this surveillance is acceptable and consistent with the current BVPS RTDP licensing basis and implementing procedures. In addition to the power level discussed above, the ISTS note requires that a time limit for perfomring the surveillance be specified. The BVPS CTS note does not contain a time limit in which to perform the heat balance surveillance. Currently the performance of this surveillance is controlled administratively by plant procedures. The time in which the surveillance is performed is not a specific assumption of a safety analysis. However, establishment of the conditions for performance of the precision heat balance is time consuming and requires installation of equipment and achieving stable operating conditions. The ISTS requirement of 24 hours after exceeding the required power does not allow sufficient time to establish stable plant conditions, install required instrumentation, perform the surveillance, and analyze the results. In addition, other required testing at high power levels after a refuelirg outage, such as physics testing and flux mapping, may interfere with establishing optimum conditions for the performance of the heat balance surveillance. Therefore, BVPS proposes that the note allow 7 days after reaching the specified BVPS Units I & 2 Page 2 Revision ,, 4/06 295

Rev. 2 Change C-12l BVPS ISTS Conversion 3.4 Reactor Coolant System Enclosure 3 Changes to C:TS power to complete the required heat balance surveillance. The 7 day allowance to perform the surveillance is acceptable as this time frame provides a sufficient operating restriction to ensure the surveillance is performed in a timely manner while still providing adequate time to accommodate any additional testing required at higher power levels, achieve stable operating conditions after startup, install the necessary test equipment, perform the test, and analyze the results. In addition, the NRC has previously approved the 7 day allowance to perform this testing for other Westinghouse Plants in their conversion to the ISTS. The proposed change imposes additional surveillance restrictions (power level and time constraints) that are not required in the CTS. Therefore, this change is designated more restrictive. Removed Detail Changes (LA) LA.1 (Type I - Removing Details of System Design and System description, Including Design Limits) CTS 3.2.5 LCO requirement c specifies the required RCS flow. Footnote 3 to the required RCS flow states that the specified flow is an analytical limit used in the safety analysis. The corresponding ISTS LCO requirement does, not have any descriptive text associated with it. The CTS is revised to conform to the ISTS and the descriptive information associated with the LCO requirement is moved into the bases. The removal of the descriptive text in the footnote to the LCO requirement is acceptable because this type of information is not necessary to be included in the TS to provide adequate protection of public health and safety. The ITS still retains the requirement that the RCS flow be within the limit. The description of the RCS flow requirement as an analytical limit is not required in order for the LCO requirements to be applicable and enforced. Also, this change is acceptable because this type of descriptive information will be adequately controlled in the ITS Bases consistent with the format and content of the ISTS. Changes to the Bases are controlled by the TS Bases Control Program specified in the Administrative Controls Section of the TS. This program provides for the evaluation of changes to ensure the Bases are properly controlled and that prior NRC review and approval is requested when required. This change is designated as a less restrictive remova of detail change because descriptive text is being removed from the TS. Administrative Changes (A) A.1 In the conversion of the Beaver Valley Power Station current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering or order, etc.) are made to obtain consistency with NUREG-1431, Rev. 2, "Standard Technical Specifications-Westinghouse Plants" (ISTS). Due to the large number of such changes, A.1 changes may not always be marked on each CTS page. Marked or unmarked, all A.1 changes are identified by a single annotation of A.1 at the top of the first page of each CTS. These changes includes all non-technical modifications of requirements to provide consistency with the ISTS, including all significant format changes made to update the older NUREG-0452 BVPS Units 1 & 2 Page 3 Revision ,2, 4/06 296

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 CHANGE C-13 Database# 200601201226 NRC Commenter: C. Hammer BSI 25 The original BSI change was based on TSTF-479. However, the NRC reviewer objected to a portion of TSTF-479 and BVPS agreed to change the affected text. The agreed upon change revises the SR 3.0.2 test interval extension allowance in the Inservice Testing (1ST) Program (ITS 5.5.4.b). This changes the provision in ITS 5.5.4.b such that the test interval extension provided by SR 3.0.2 is limited to IST intervals of less than or equal to 2 years. This change only affects the IST program in Section 5.0 of the ITS. Affected Pages: The following Table(s) list the affected pages by type (i.e., ITS markup, CTS markup, etc.). In order to facilitate review by ITS section, a separate table is provided for each ITS section affected by the change. The page numbers listed are the ITS section specific consecutive numbers found in the lower right corner of each page. Note: Because the affected page(s) for each change were extracted from a complete ITS section electronic file, the electronic hyperlinks (created in the complete ITS section file) do not work in the collection of affected pages that follow this cover page. ITS SECTION 5.0 (ADMINISTRATIVE CHANGES) INDEX OF AFFECTED PAGES ITS MARKUPS PAGE: 14 ITS JFDS PAGES: 62 & 63 ITS BASES MARKUPS No Change ITS BASES JFDS No change CTS MARKUPS PAGE: 90 CTS DOCS PAGES: 126 & 127

I Rev. 2 Change B-1 & C-13 Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.8 Inservice Testing Program (continued ASME Boileo and Pre c~-eRequired Frequencies for I B-1 V eseel Code and applicable performing inservice testing Addenda terminology for activities inservice testing activities Monthly At least once per 31 days

                                              -l      <mnt -rn0-
                                                      -r2r                   A4 I.et  ----        n)   A--
                                 %AUC31twily VI every o 1VIlUIal               leb rVCat         IUll;wpVI U LUdlya

( Semiannually or every 6 months At least once per 184 days 9 - Every 9 months Yearly or annually At least once per 276 days At least once per 366 days and to other normal Biennially or every 2 years At least once per 731 days and accelerated Frequencies specified as 2 years or less in b. The provisions of SR 3.0.2 are applicable to the above required the Inservice Testing Frequenciesor performing inservice testing activities, C-13 P.ogram - c. The provisions of SR 3.0.3 are applicable to inservice testing activities, and I B-1

d. Nothing in the ASME B eri IFCode shall be construed to supersede the requirements of any TS.

5.5. Steam Generator (SG) Tube Surveillance Program REVIEWER'S NOTE The Licensee's current ln s i etor tube surveillance 17 requirements shall be re mthe luded here. An contr p f t The provisions of SR 3.0.2 re applicable to the SG Tube Surveillance Program test frequencies. a 5.5. Secondary Water Chemistrv Program This program provides controls for monitoring secondary water chemistry to inhibit SG tube degradation and low pressure turbine disc stress corrosion GFaGking. The program shall include:

a. Identification of a sampling schedule for the critical variables and control points for these variables,

b. Identification of the procedures used to measure the values of the critical variables, WOG STS 5.5 -6 Rev. 2, 04/30/01 14

Rev. 2 Change C-13 BVPS ISTS Conversion 5.0 Administrative Controls Enclosure 1 Changes to ISTS does not include the installation of pre-stressed concrete containment tendons. As such, there is no requirement for a surveillance program and no requirement for this report in the CTS. Not including this ISTS reporting requirement in the BVPS ITS is consistent with the BVPS Units I and 2 licensing and design bases. Subsequent specifications are renumbered as a result of this change to the ISTS.

30. ISTS 5.6.7 (ITS 5.6.6) provides the requirements for the Steam Generator Tube Inspection Report. Consistent with the associated Reviewer's Notes, the BVPS Units 1 and 2 current licensing basis, reflected in CTS 4.4.5, is included in this reporting section. A separate report subsection (5.6.6.1 & 5.6.6.2) for each BVPS unit is included to maintain each Unit's requirements separate and consistent with the CTS. The corresponding ISTS Reviewer's Notes are deleted. The Reviewer's Notes provide information for the NRC to identify acceptable methods to meet the requirements. The Reviewer's Notes are not meant to be retained in the final version of the plant-specific submittal.

31. ISTS 5.7 provides requirements for High Radiation Areas. ITS 5.5.7 is revised to reflect the BVPS Units 1 and 2 licensing bases and High Radiation Area controls. The change is consistent with the requirements in CTS 6.12.

32. ISTS 5.5.12.b (ITS 5.5.8.b) is revised to reflect the BVPS Units I and 2 whole body exposure limit consistent with the requirements in CTS 6.8.6.c.2.

33. ISTS 5.5.12 (ITS 5.5.8) states "A surveillance program to ensure that the quantity of radioactivity contained... is less than the amount that would result in concentrations less than the limits..." ITS 5.5.8 is revised to replace the word 'less than" with the word 'greater than" consistent with CTS 6.8.6.c.3. The change reflects the BVPS Units 1 and 2 licensing basis as accepted by the NRC in a previous BVPS SER. This change includes no new requirements, but only provides a clarification of the phrase. The intent of the phrase is to ensure that the 10 CFR 20 limits are not exceeded.

34. ISTS 5.5.8.b states "The provisions of SR 3.0.2 are applicable to the above required Frequencies for performing inservice testing activities." ISTS 5.5.8.a contains a list of test intervals referenced in the ASME Inservice Test Requirements. However, the list of test intervals in ISTS 5.5.8.a is not a comprehensive list of inservice testing intervals. In order to make the provisions of SR 3.0.2 applicable to more Inservice test intervals, proposed ITS 5.5.4.b states "The provisions of SR 3.0.2 are applicable to the above required Frequencies and to other normal and accelerated Frequencies specified as 2 years or less in the Inservice Testing Program for performing inservice testing activities." The proposed ITS 5.5.4.b would be applicable to all test intervals s 2 years referenced in the ASME Inservice Testing requirements and not just the test intervals listed in ISTS 5.5.8.a.

The proposed change is based on approved TSTF-479 as modified by agreement with the NRC. The agreed change deviates from the approved TSTF-479 in that it restricts the test interval extension provided by SR 3.0.2 to inservice test intervals of 2 years or less. The change to TSTF-479 is based on the fact that the inservice test intervals > 2 years provide adequate time to schedule the required testing without the additional extension provided by SR 3.0.2. BVPS Units 1 and 2 Page 6 Revision ', 4106 2/05 62

Rev. 2 Change C-13 BVPS ISTS Conversion 5.0 Administrative Controls Enclosure 1 Changes to IST'S l INTENTIONALLY LEFT BLANK BVPS Units 1 and 2 Page 7 Revision :2, 4/06 63

[ ITS5I. CTS Page for ITS 5.5.4 l I Rev. 2 Change B-1 & C-13 I APPLIGABILITY CtJRVEiLLAN;fl REOUIflEMENTS 1.-Survei-ln- interval Testing frequendes applicable to the ASME Code for Operations I and Maintenance of Nuclear Power Plants (ASME OM Code)

                                                         ~-3 fied               in     Seetien        Xi      ef     the 1=

ACGMS B-1 1,wilpr nnr I1rPdC;-:r Andl nnnliaanhli a ddndn fnar t4-h, hrig inspection and aetivitics required by the ASME Astg L isi e~plieab1e as follows inR Boil --- heEo P and applicable Addenda shall -be hnical Apeeifieatiens: ASME Deiler and Preosurc Vzes;2 Required frequencies for lB-1 Code and applicable Addenda performin inservice terminology for inservice linspection and esting inspection andltestinq activities actlvities Weekly At least once per Monthly At least once per Quarterly or every 3 months At least once per Semiannually or every 6 months At least once per Every 9 months At least once per t Yearly or annuallyISR3oA least once per __ ____.:l," _ _C 1S K :_v-: The provisions or Spcificatcin 4.u.2 are applicai , . I above required frequenciesKfor performing inservice and testing activities. Performance ove inservice and test]ng activities shall be ; n ecified Surveillanee I Nothing in the ASMEwi-zoIer and Prcssurc Vcssel Code shall be IBI1

     \        construed to supersede the requirements of any Technieal
        . d Specification.                                                                                                          Ij A14ES
                                         ~             -

JL4 > and to other normal and accelerated Frequencies specified as 2 years or less In the Inservice Testing Program IC.13 C. The provisions of SR 3.0.3 are applicable to inservice testing activities. I _ . . ... _ Biennially or every 2 years At least once per 731 days I Ii BEAVER VALLEY - UNIT 2 3/4 0-4 Amendment No. 144: 90

Rev. 2 Change C-13 BVPS ISTS Conversion IJ I5.0 Administrative Controls Enclosure 3 Changes to C:TS Generic Letter 89-01 provided guidance for relocation of Radiological Effluent Technical Specifications (RETS) from the Technical Specifications to the Offsite Dose Calculation Manual (ODCM), including programmatic controls to be included in the Administrative Controls Chapter of Technical Specifications. Generic Letter 89-01 provided the requirements and wording for the Radiological Effluent Controls Program. These requirements were developed from the RETS. The requirement of CTS 6.8.6.a.5) dealing with projected dose contributions should only be

     'Determination of projected dose contributions from radioactive effluents in accordance with the methodology in the ODCM at least every 31 days" since that was the requirement in the original RETS relocated to the ODCM. There should not be a requirement to project dose contributions for the current calendar quarter and current calendar year. This change makes the requirements of CTS 6.8.6.a.5) consistent with the RETS requirements relocated from the Technical Specification to the Offsite Dose Calculation Manual in accordance with Generic Letter 89-01. This change is acceptable since it is a clarification needed to maintain provisions that were allowed in the RETS and includes no new requirements. This change is designated as less restrictive because less stringent acceptance criteria are being applied in the ITS than were applied in the CTS.

L.4 (Category 7- Relaxation Of Surveillance Frequency) CTS 4.0.5.c states "The provisions of Specification 4.0.2 are applicable to the above required frequencies for performing inservice inspection and testing activities." The above required Frequencies referenced in CTS 4.0.5.c are listed in CTS 4.0.5.b. CTS 4.0.5.b contains a list of test intervals referenced in the ASME Inservice Test Requirements. However, the list of test intervals in CTS 4.0.5.b is not a comprehensive list. As such, proposed ITS 5.5.4.b (which corresponds to CTS 4.0.5.c) states "The provisions of SR 3.0.2 are applicable to the above required Frequencies and to other normal and accelerated Frequencies specified as 2 years or less in the Inservice Testing Program for performing inservice testing activities. This DOC addresses the addition of the words "and to other normal and accelerated Frequencies specified as 2 years or less in the Inservice Testing Program". The proposed BVPS ITS 5.5.4.b would replace CTS 4.0.5.c and be applicable to more test intervals referenced in the ASME Inservice Testing requirements and not just the more common test intervals listed in CTS 4.0.5.b. CTS 4.0.5.b provides a list of the common ASME terminology for inservice testing activities (e.g., monthly, quarterly, etc.) and a corresponding required Frequency (e.g., at least once every 31 days, at least once every 92 days, etc.). Consistent with the explanation in Section 3.1.3 of NUREG 1482, "Guidelines for Inservice Testing at Nuclear Power Plants," the intent of this TS list of ASME surveillance intervals with a corresponding required Frequency is to avoid potential confusion regarding the ASME test intervals. For example, an ASME test interval of monthly could be applied such that the required testing is accomplished at the beginning of one month and the end of the next month effectively yielding a test interval of almost two months. As such, CTS 4.0.5.b specifies "required Frequencies" (e.g., at least once every 31 days) for the common ASME terminology for inservice testing activities. It is not the intent of CTS 4.0.5.b to identify all the potential test intervals that may be utilized in inservice testing activities, nor is the list provided in CTS 4.0.5.b intended to limit the provisions of CTS 4.0.5.c to only those frequencies. However, the ASME inservice test requirements utilizes Surveillance Frequencies BVPS Units 1 & 2 Page 2 Revision 2, 4/06 126

I Rev 2ChangeC-13 BVPS ISTS Conversion 5.0 Administrative Controls Enclosure 3 Changes to CTS not specified in CTS 4.0.5.b. For example, the ASME inservice testing activities may utilize accelerated frequencies (typically some fraction of the common test frequencies listed in CTS 4.0.5.b) and performance based frequencies which may not correspond to a common frequency listed in CTS 4.0.5.b. However, literal compliance with CTS 4.0.5.c would preclude the application of the 25% Surveillance Frequency extension provided by CTS 4.0.2 (ITS SR 3.0.2) from any test interval not specifically listed in CTS 4.0.5.b. The purpose of CTS 4.0.5.c (ITS 5.5.4.b) is to provide the same allowances normally applicable to all other surveillance requirements by the provisions of CTS 4.0.2 (ITS SR 3.0.2). ITS SR 3.0.2 allows a surveillance interval (or in some cases an Action Completion Time) to be extended up to 25% longer than the stated interval. As stated in the ISTS Bases for SR 3.0.2, "This extension facilitates Surveillance scheduling and considers plant operating conditions that may not be suitable for conducting the Surveillance (e.g., transient conditions or other ongoing Surveillance or maintenance activities)". SR 3.0.2 provides this scheduling flexibility to help assure that the required surveillance tests will be performed in a safe and timely manner with proper consideration for existing plant conditions and other ongoing activities. The provisions of SR 3.0.2 are applicable to almost all technical specification surveillance testing (except where regulations, i.e., 10 CFR 50 Appendix J, may require a specific test Frequency). Given that the surveillance interval extensions allowed by SR 3.0.2 are applicable to such safety significant and time sensitive surveillance requirements such as the verification of reactor trip system instrumentation setpoints, there is no reason why the provisions of SR 3.0.2 should not also be applied to more ASME frequencies that may be specified for pump and valve inservice test activities. In addition, the proposed change is consistent with NUREG 1482, "Guidelines for Inservice Testing at Nuclear Power Plants," which acknowledges the applicability of the 25% Frequency extension allowed by the TS. As such, the proposed change is acceptable because it provides the necessary flexibility for scheduling inservice test activities to assure the required testing is performed in both a safe and timely manner with proper consideration for existing plant conditions and other ongoing activities. This change is designated as less restrictive because less stringent frequency requirements are applicable in the ITS than were applicable in the CTS. More Restrictive Changes Mi) M.1 CTS 6.8.1 specifies that written procedures be established, implemented, and maintained covering the activities referenced in CTS 6.8.1.a through 6.8.1.h. IT'S 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. The CTS do not specifically require the current form of EOPs (although BVPS Units 1 and 2 are committed to have them per NUREG-0737 and Generic Letter 82-33). ITS 5.4.1.b requires EOPs which implement the requirements of NUREG-0737, NUREG-0737-Supplement 1, and Generic Letter 82-33. This change is acceptable because it is consistent with current plant practice. The change is designated as BVPS Units 1 & 2 Page 3 Revision :2,4/06 127

EBVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR). Nos. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 CHANGE C-14 Database # 200512191417 & 200512191552 NRC Commenter: R. Clark The NRC reviewer requested that the BVPS ITS Surveillance Requirements 3.8.1.8 and 3.8.1.10 specify a more limiting power factor of 0.89 instead of 0.9 for the required diesel generator loading. BVPS agreed to revise the specified power factor from s0.9 to 50.89. In addition, this change clarifies that the specified power factor is an indicated value (the same as the other DG loading requirements specified in the affected ITS surveillances). This change affects the surveillance requirements of ITS 3.8.1. Affected Pages: The following Table(s) list the affected pages by type (i.e., ITS markup, CTS markup, etc.). In order to facilitate review by ITS section, a separate table is provided for each ITS section affected by the change. The page numbers listed are the ITS section specific consecutive numbers found in the lower right corner of each page. Note: Because the affected page(s) for each change were extracted from a complete ITS section electronic file, the electronic hyperlinks (created in the complete ITS section file) do not work in the collection of affected pages that follow this cover page. ITS SECTION 3.8 (ELECTRICAL POWER SYSTEMS) INDEX OF AFFECTED PAGES ITS MARKUPS PAGES: 10 & 15 ITS JFDS PAGE: 49A ITS BASES MARKUPS PAGES: 77,83,84 & 91 ITS BASES JFDS PAGE: 163 CTS MARKUPS PAGE: 187 & 189 CTS DOCS PAGES: 226 & 227

AC Sources - Operating I Rev. 2 Change D-11 & C-14 I 3.8.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE IFREQUENCY SR 3.8.1 lNUREG-1431, <i7i

                                           - NOTES -

(1. This Surveillance shall not normally be performed _ G8 in MODE 1 or 2. However, this Surveillance may Credit may be be performed to reestablish OPERABILITY taken for provided an assessment determines the safety of unplanned events the plant is maintained or enhanced.<that satisfy this SR.

2. If performed with the DG synchronized with offsite it shall be performed at a power factor k./1jjs{x. However, if grid conditions do not permit, I C-14 the power factor limit is not required to be met. I Under this condition the power factor shall be maintained as close to the limit as practicable. I Verify each DG rejects a load greater than or equal to its associated single largest post-accident load, and:

21 a. Following load rejection, the frequency is i< s [63] Hz, ' 2-4106 Vand s 4368V Un41

b. Within f3J seconds following load rejection, the voltageis [3740] V an - a

                                                                              -                          mg T     D-11

c. Withina seconds following load rejection, the frequency is 2[58.8] lzand 1.21IHz. DA

                                     -*   258.8 HzM and~E 1.2 Hz(Ufi z ae 1              CTSValues]

WOG STS 3.8.1 -7 Rev. 2, 04/30/01 10

I Rev. 2 Change C-14 & C-15 AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.8.1.44

                                                   - NOTES -

10 1. Momentary transients outside the load and power factor ranges do not invalidate this test.

2. This Surveillance shall not normally be performed in MODE 1 or 2. However, this Surveillance may NUREG-1431, be performed to reestablish OPERABILITY provided an assessment determines the safety of Credit may be Li thIIt: podsI1--f II It la 1 KIIIliLtOII-Arl Idl ICUI WI-ICII 1%,UU . -It_-

I 111A1 WI11 taken for

                                                                                          -     unplanned events 22               3. If performed with DG synchronized with offsite                            that satisfy this SF:.l
               \jp      ower, it shall be performed at a power factor
                                                                                                                        - I-i14 0.89              ._ . However, if grid conditions do not permit, the power factor limit is not required to be met.

Under this condition the power factor shall be maintained as close to the limit as practicable. T-l G~-1431, Re3 Verify each DG eperatin* Mat a power factor s IU.9] [181 months operates for 241hours: ( C-15

a. Fer Z42-hours loaded 4[5250]-kW-an 5[5500]*kW- nd\

2 275OkWarid 2850kWUnit 1n)

b. For the remaining hours of the test loaded

                      > rAZAnM tAAI -'nA           g  rr-nnnm IAIA I

WOG STS 3.8.1 - 12 Rev. 2, 04/30/01 15

BVPS ISTS Conversion I Rev. 2 Change D-11 & C-14 I 3.8 Electrical Power Systems Enclosure I Changes to ISTS i4

21. ISTS SR 3.8.1.9 (ITS SR 3.8.1.8) verifies the capability of the DGs to recover from a transient consisting of the loss of the single largest load. The bracketed [ 3 ] second time allowed for the frequency to recover in ITS SR 3.8.1.8.c is revised to 4 seconds.

The Bases for this SR states that: "The time, voltage, and frequency tolerances specified in this SR are derived from Regulatory Guide 1.9 (Ref. 3) recommendations for response during load sequence intervals. The 3 seconds specified is equal to 60% of a typical 5 second load sequence interval associated with sequencing of the largest load." D-11 However, the latest Revision of Regulatory Guide 1.9 (Rev. 3) in Section 1.4 states that

         'Frequency should be restored to within 2 percent of nominal in less than 60 percent of each load-sequence interval for stepload increase and in less than 80 percent of each load-sequence interval for disconnection of the single largest load, and voltage should be restored to within 10 percent of nominal within 60 percent of each load-sequence time interval. The bracketed number (i.e., 3) specifying the frequency limit in ITS SR 3.8.1.8.c is based on 60% of a 5 second load sequence interval. However, ITS SR 3.8.1.8 specifies the disconnection of the DG's single largest load. Consistent with the guidance provided in Regulatory Guide 1.9, for the disconnection of the single largest load, the time allowed for restoration of the frequency is changed from 3 seconds to 4 seconds. The proposed 4 second time limit represents 80 percent of the 5 second load sequence interval and is acceptable as it is consistent with the recommendations of Regulatory Guide 1.9, Rev. 3 for this specific surveillance test.

22. The power factor requirement specified for ITS SRs 3.8.1.8 and 3.8.1.10 is revised to be C-14 more consistent with the BVPS worst case accident loading power factor. This changes the bracketed standard ISTS power factor of 0.9 to 0.89 for the BVPS ITS.

BVPS Units 1 & 2 Page 6 Revision 2, 4/06 49A

AC Sources - Operating Rev. 2 Change C-14 B 3.8.1 BASES ACTIONS (continued) G.1 and G.2 If the inoperable AC electric power sources cannot be restored to OPERABLE status within the required Completion Time, the unit must be brought to a MODE in which the LCO does not apply. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours and to MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging plant systems. H.1 Condition H corresponds to a level of degradation in which all redundancy in the AC electrical power supplies has been lost. At this severely degraded level, any further losses in the AC electrical power system will cause a loss of function. Therefore, no additional time is justified for continued operation. The unit is required by LCO 3.0.3 to commence a controlled shutdown. SURVEILLANCE The AC sources are designed to permit inspection and testing of all discussed in

          -IREMENTS                     important areas and features, especially those that have a standby                                  Reference 8 KITS Values                          function, i aGGcrdaRce-with 10 CFR 50, Appondix A, ODO 18 (Ref. 8.

I Periodic component tests are supplemented by extensive functional tests [ for Unit 1 is 4106 during refueling outages (under simulated accident conditions). The SRs for demonstrating the OPERABILITY of the DGs are in accordance with 6 V and for Unit 2 the recommendations of Regulatory Guide 1.9 (Ref. 3)1egulatory F Reference 3 is 3994 V. Guide 1.108 (Ref. 9), and Regulatory Guide 1.137 (Ref. 10), a addressed in the.FSAR. The SR value bands specified Where the SRs discussed herein specify voltage and frequency fcor voltage and frequency for t etefloigi plcbe h iiu taysaeotu each Unit are analysis values, dy state Output except for the frequency values voltage of58.8Hzto61.2Hzspecified -*value, which is specified in ANSI C81.1 (Ref. 11), allows for voltage drop for Unit 1 in SRs 3.8.1.2 and ____________________________________ 3.8.1.8. These Unit I to the terminals of 1000 V motors whose minimum operating voltage is Frequency tolerances are RG _pecifiedas 90% or 3600 V. It also allows for voltage drops to motors 1.9 recommendations. t hr nau-in mnt down throuwh the 120 Vxlevl welmin uimum, q . r-- ,-. .... .... -Z.. .- . -.- .. .. - . ADAAr .AI__ :ALA y-*A AA;XAW AK canel A; _A-ATAR AR 1OTE: The voltage and opurattig vulufisu g alo; usuly Ispcirdliwu as told o0! plated Uainfig. K;me frequency values specified in The specified maximum steady sltate output voltage of 147561 u each SR need lobe reduced or to the maximum operating voltagee specified for 4000 V motors. It 1 I ircreased, as appropriate, to acount for measurement ensures that for a lightly loaded ddistribution system, the voltage at the uiceainties. terminals of 4000 V motors is no more than the maximum rated operating I CTS Value voltages. fjFhspe cified r nand maximum frequencies of the DG I I W The kW and power factor requirements 8.1 - 13 Rev. 2, 04/30/01 I specified in the SRs are indicated values. 77

Rev. 2 Change C-7 & C-14 BVPS ISTS Conversion 3.8 Electrical Power Systems Enclosure 2 Changes to The ISTS Bases

12. A statement is added to the Surveillance Requirement section of the Bases to indicate the loading requirements for the DGs specified in various SRs are indicated C-14 kW and power factor values. This change is acceptable because these values reflect a range of kW values produced by the DG. The kW values are based on manufacturer limitations (listed in the UFSAR) or the accident analysis assumption for loads of the DG. The power factor value is intended to simulate the accident loading conditions of the DG. Any indication uncertainties associated with these values are not critical to adequately demonstrate the ability of the DG to accept the required loading at the expected power factor.

13 The Bases for ITS SR 3.8.1.8 and ITS SR 3.8.1.10 discuss the conditions under C-7 which the power factor requirement of the SRs may not be met. These discussions are revised to delete the statements that imply the DGs can raise the grid voltage. The changes to these SR Bases were made at the request of the NRC. BVPS Units 1 & 2 Page 2 Revision ,', 4/06 163

AC Sources - Operating B 3.8.1 l Rev. 2 Change C-7, D-11 & C-14 I BASES SURVEILLANCE REQUIREMENTS (contin and 80% res SR 3.8.1.8.a equal to 60% f a typical 5 second load sequence interval associated with I D-11 sequencing of the largest load. The voltage and frequency specified are SR 3.8.1.8.b consistent with the design range of the equipment powered by the DG.

                                   \  .   . Hcorresponds to the maximum frequency excursion, while iR   _.8.. are steady state voltage and frequency SR 3.8.1.8.c        values to which the system must recover following load rejection. The 1i 8 month] Frequency is consistent with the recommendation of Regulatory Guide 1.108 (Ref. 9).

This SR is modified by two Notes. The reason for Note 1 is that during operation with the reactor critical, performance of this SR could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and, as a result, unit safety systems. This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allow the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g. post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system [ NUREEG-1431, Rev 3 l when they are tied together or operated independently for the

               \ '    I    Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or Credit may be        enhanced when the Surveillance is performed in MODE 1 or 2. Risk unplanned events     insights or deterministic methods may be used for this assessment.                  [may Note 2 ensures that the DG is tested under load conditions that are as close to design basis conditions as possible. When s nchroniz d with 2                 offsite power, testing should be performed at a power factor of s ,.              -           IC-14 1      ~K      T~his power factor is representative of the actual inductive loading ao66-W                under design basis accident conditions. Under ce_                        example,
                          \ onditions, h-&eeftoe 2 allows the surveillance ~togcon                     d--at      L power factor other than s-           .. These conditions ccur ven ^gf              IC-14
                \          Volage s high, and the additional field excitation needed to get the power
                   \^                       1. Ifhtrt Fesultso9]

in voltages onthe emergencGy bus6os that aFte too C-7 condiions, tthesethe power factor rhould bo maintained as

                        \ closeups acticable to [0.9] while still maintaining acceptable voltage
                                              \limitergecy e      bDu6es. 'A other c~rcstances, the grid voltage factr of        that the DG excitation levels needed to obtain a power fcoofmmay not Gal:16e unac~ceptable voltages on the emnergenc                  11>14 WOG STS                                        B 3.8.1 - 19                                Rev. 2, 04/30/01 83

AC Sources - Operating B 3.8.1 Rev. 2 Change C-7 & C-14 BASES SURVEILLANCE REQUIREMENTS (continued) such as l any applicable bU6696, but4hep -eitatie are in excess those recommended for C-7 1 the DG. In vurh cases e power factor shall e maintained as close as practicable to MO without exceeding limits. c-14

                              \              - REM1IER'S NOTE -/

TheaowD restrictions may be deleted if it cnbe de tredo the stfo t specific basis, that performing teS hthe reactor in any of the restri MODES can satisfy the follo criteria, as applicable:\/

a. Performance of the SR oareoftny safety system or component inoperable,,

b. Performance of thek o caus ~ations to any of the electrical distribu> sytm hat could resui~ challenge to steady ataeration or to plant safety systems,<

c. Pe ance of the SR, or failure of the SR, will not Iairrsl

                        , n AOO with attendant challenge to plant safety systems.

3.8.1.10 This eillance demonstrates the DG capability to reject a fulla without o speed tripping or exceeding the predetermined v gage limits. The DG full l rejection may occur because of a syste ault or inadvertent brea tripping. This Surveillance ensur proper engine generator load resp e under the simulated test nditions. This test simulates the loss of the tal connected load t the DG experiences following a full load rejectio nd verifies th the DG does not trip upon loss of the load. These accep ce crit a provide for DG damage protection. While the DG is not exted to experience this transient during an event and continues to ailable, f this response ensures that 2 the DG is not degraded for fure applica including reconnection to the bus if the trip initiato n be corrected or lated. The [18 month} Fre ency is consistent with the re mendation of Regulatory Gui 1.108 (Ref. 9) and is intended to be nsistent with expected fu ycle lengths. This ShRas been modified by two Notes. The reason for Note that du g operation with the reactor critical, performance of this SR co ause perturbation to the electrical distribution systems that could WOG STS B 3.8.1 - 20 Rev. 2, 04/30/01 84

AC Sources - Operating B 3.8.1 BASES I Rev. 2 Change C-7 & C-14 I SURVEILLANCE REQUIREMENTS (continued) I oxample, operation with the reactor critical, pe rmance of this Surveill nce could cause perturbations to the electrical di tribution systems that ould challenge continued steady state opera ion and, as a result, unit safety ( systems Note 3 ensures that the DG is sted under load nditions that ar close to design basis conditions as ssible. When ynchronized with offsite power, testing should Pv eVL C-14 er actor is representative o the actu ctive loading a DG would see under design basis acciden ns. Under certain conditions, however, Note 3 allows veilla ce to b conducted as a power factor other than s .hese condition occur hen grd-voltag ls high, and tho additional foIldI ercitation neodod to get the power facto to ; [0.91 recults in voltagos on the emergency busses that are too high. - Under these conditions, the power factor should be maintained as cloeL, I as practicable to [0.9] whits still maintaining acceptable toltage limits OR= lCG7 13 tho emergency busses. in other circumstancos, the grid voltage mayZbV such that the DG excitation levels needed to obtain a power factor of "i may noat cause unccEPtable voltages on the emergency busses, but the excitation levels are in excess of those recommended for the DG. In" A Gases, the power factor shall be maintained close as practicable to f without exceeding the PG*citatiel limits. I his restriction from normally 1\ I performing the urvel nce inMQDE 1 or 2 is further amplified to allow the Surveillance to b rformed fo t o reestablishing cases such L 'IUREG-1431, Rev. 3 1-0. OPERABILITY (e.g., post work testongaolant stcorrectve maintenance, as this corrective modification, deficient or incomplete sLrviance testing, and other unanticipated OPERABILITY concemns) provideda assessment Credit may be determines plant safety is maintained or enhanced. whi U FenIthe taken for -,hall, as a minimumconsider the potential outcomes anid tra--iea'lyli b unplanned events aseted with a failed Surveillance, a successful Surveillance, and a _ that satisfy this SF

1. perturbatiorvof the offsite or onsite system when they are tied together or operated inde ently for the Surveillance; as well as the operator procedures avai abr~,o-cope with these outcomes. These shall be measured against the avid<,risk of a plant shutdown and startup to determine that plant safety is mbnpinedl or enhanced when the Surveillance is performed in MODE 1. Risk insights or deterministic methods may be used for this assessmen.

S . 15 This Surveillance t s that the d i n restart from a 0D- 0 hot condition, such as subseq Surveillances, and achi [10] seconds. utdown from normal requiredv and frequency within 0] second time is derived from uirements of theidet analysis to respond to a design basis large brea WOG STS B 3.8.1 - 27 Rev. 2, 04/30/0'l 91

I Rev. 2 Change C-3 & C-14 I Inserts 3.8.1 (continued) SR 3.8.1.8 surveillance notes SR 3.8.1.8

                                      - NOTES-1   This surveillance shall not normally be performed in MODE 1or 2. However, the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

2 If performed with DG synchronized with offsite power, it shall be performed at a power factor s 0.89. C-14 However, if grid conditions do not permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as practicable. SR 3.8.1.3 surveillance notes SR 3.8.1.3

                                      - NOTES -

I DG loading may include gradual loading as C-3 recommended by the manufacturer. 2 Momentary transients outside the load range do not invalidate this test. 3 This Surveillance shall be conducted on only one DG at a time. 4 This SR shall be preceded by and immediately follow without shutdown a successful performance of SR 3.8.1.2. SR 3.8.1.2 surveillance notes SR 3.8.1.2

                                     - NOTES-1   All DG starts may be preceded by an engine prelube period and followed by a warmup period prior to loading.

2 A modified DG siart involving idling and gradual acceleration to synchronous speed may be used for this SR as recommended by the manufacturer. Cjc-: LCO Sequence Timers I c. Automatic load sequencer timer(s) for each required DG. I 189

Rev. 2 Change C-14 & C-15 Inserts 3.8.1 (continued) Load limits for SR 3.8.1.3 at a load Ž 2340 kW and

2600 kW (Unit 1),

at a load 2 3814 kW and *4238 kW (Unit 2). Time, load, and Note requirements for SR 3.8.1.10 I for 2Ž2 hours loaded 2Ž2750 kW and

2850 kW (Unit 1) I I C-15 I C-15 for Ž 2 hours loaded ; 4238 kW and *4535 kW (Unit 2).

Note 1 Momentary transients outside the load and power factor ranges do not invalidate the test. I Note 2 This surveillance shall not normally be performed in MODE 1or 2. However, the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR. Note 3 If performed with DG synchronized with offsite power, it shall be performed at a power factor

0.89. However, if grid conditions do not permit, the power IC-14 factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as possible.

SR 3.8.1.9 surveillance note SR 38.1.9

                                      - NOTE -

This surveillance shall not normally be performed in MODE 1 or 2. However, portion of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR. 187

l Rev. 2 Change C-14 & C-15 l BVPS ISTS Conversion 3.8 Electrical Power Systems Enclosure 3 Changes to CT'S M.4 CTS surveillance requirement 4.8.1.1.2.b.5 requires each diesel to be tested every 18 months during shutdown to a specific kW load for 2 60 minutes. The loading for Unit 1 is 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 Ž 2 hours at a load of 2 2750 kW and

2850 kW. Unit 2 is C-15 required to run for 2 2 hours at a load of Ž 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
0.89. Additionally, the note states that if grid conditions C-14 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 two run time, a specific loading band, C-15 and specifying a power factor limit for each DG for this test.

This change is acceptable because the test requires the DGs to start and load to C-15 required values and run for an additional hour. The minimum of 2750 kW is the assumed accident loading value for Unit 1. The maximum of 2850 kW is the 2000-hour limit for Unit 1. The 2750 kW value is greater than the continuous duty rating and is specified by the CTS requirement. The Unit 2 range for kW varies from the continuous duty rating to the 2000-hour limit. A load band is provided to avoid routine overloading of the DG during the monthly test requirement, but the 18-month test ensures the capability of the DG to provide an extended capacity. Routine overloading may result in more frequent teardown inspections in accordance with vendor recommendations in order to maintain DG OPERABILITY. The addition of a power factor limit is acceptable because the load on the DG with a loss of offsite power is inductive and creates volt-amp reactive loading of the DG. This is represented in the limit of the power factor requirement. Therefore, the testing of the DG at this rating is only required every 18 months. The ITS requirements are consistent with the ISTS wording for this requirement (i.e. specifying a load band). This change is designated as more restrictive because it adds additional test conditions that the CTS does not require.. M.5 - M.8 Not used. M.9 CTS surveillance requirements for LCO 3.8.1.1 do not require a test of the diesel generator capability to carry emergency loads, transfer those loads to offsite source upon a simulated 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 modify 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. The purpose for the SR is to ensure the DG is capable of performing the required operations. This change is acceptable because the SR ensures that the manual synchronization load transfer from the DG to the offsite source can be made and the DG BVPS Units I & 2 Page 14 Revision 2, 4/06 226

Rev. 2 ChangeC-14 BVPS ISTS Conversion 3.8 Electrical Power Systems Enclosure 3 Changes to CT'; can be returned to a specific status when offsite power is restored. The SR also ensure; that the autostart logic is reset to allow the DG to reload if a subsequent loss of offsite power occurs. The DG is considered to be in ready to load status when the DG is at nominal speed and voltage, the output breaker is open and can receive an autoclose signal on bus undervoltage, and the load sequence timers are reset. This is not the case for Unit 1 DGs. Unit 1's design requires the DGs to proceed through its normal shutdown sequence. The Frequency of 18 months provides adequate assurance of DG OPERABILITY, while minimizing degradation resulting from testing. The ITS requirements are consistent with the ISTS wording for this requirement for Unit 2. The Unit 1 requirements are modified to account for plant design differences. This change is designated as more restrictive because it adds additional surveillance requirement that the CTS does not require. M.1 0 Unit 2 CTS surveillance requirements for LCO 3.8.1.1 do not require a diesel generator, while operating in a test mode and connected to its emergency bus, to override the test 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. The purpose for the SR is to ensure each Unit 2 DG is capable of performing the required operations. This change is acceptable because this demonstration ensures that: the DG availability under accident conditions will not be compromised. As the result of being in the test mode, the DG will automatically reset to ready to load operation if a SI actuation signal is received during this condition. Ready to load operation is defined as the DG running at nominal speed and voltage with the DG output breaker open. In lieu of actual demonstration of connection and loading of loads, testing that adequately shows the capability of the emergency loads to perform these functions is acceptable. The Frequency of 18 months provides adequate assurance of DG OPERABILITY, while minimizing degradation resulting from testing. The ITS requirements are consistent with the ISTS wording for this requirement for Unit 2. The SR is not applicable to Unit I because of plant design does not incorporate this feature. This change is designated as more restrictive because it adds additional surveillance requirement that the CTS does not require. M.11 CTS SR 4.8.1.1.2.b.2 requires the verification of the diesel generator capability to reject a load. This surveillance is required to be performed every 18 months during shutdown. ITS 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 < 0.89. 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 I & 2 Page 15 Revision 2, 4/06 227

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 CHANGE C-15 Database # 200509201353 NRC Commenter: R. Clark The NRC reviewer requested that the current ITS Surveillance Requirement 3.8.1.1 0 be revised to increase the original diesel generator run time of 2 1 hour to > 2 hours to conform more closely to the requirements of the ISTS. The original run time of 2 1 hour was based on the current BVPS technical specification requirements. BVPS agreed to implement the requested change to ITS Surveillance Requirement 3.8.1.10. This change only affects the surveillance requirements of ITS 3.8.1. Affected Pages: The following Table(s) list the affected pages by type (i.e., ITS markup, CTS markup, etc.). In order to facilitate review by ITS section, a separate table is provided for each ITS section affected by the change. The page numbers listed are the ITS section specific consecutive numbers found in the lower right corner of each page. Note: Because the affected page(s) for each change were extracted from a complete ITS section electronic file, the electronic hyperlinks (created in the complete ITS section file) do not work in the collection of affected pages that follow this cover page. ITS SECTION 3.8 (ELECTRICAL POWER SYSTEMS) INDEX OF AFFECTED PAGES ITS MARKUPS PAGES: 15 ITS JFDS PAGE: 47 ITS BASES MARKUPS No change ITS BASES JFDS No change CTS MARKUPS PAGE: 187 CTS DOCS PAGES: 226

I Rev. 2 Change C-14 & C-15 l AC Sources - Operating 3.8.1 iFiji SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY 4. SR 3.8.1.44

                                                  - NOTES -

10 1. Momentary transients outside the load and power 13 tfactor ranges do not invalidate this test.

2. This Surveillance shall not normally be performed in MODE 1 or 2. However, this Surveillance may NUREG-1431,Rv3 be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for

                                                                                            ._ unplanned events 22\              3. If performed with DG synchronized with offsite                       that satisfy this SIR.
                   \D~power, it shall be performed at a power factor                                                  --  I _

0.89 l . . However, if grid conditions do not permit, I -14 the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as practicable. Verify each DG operatig- Hat a power factor s i[.9 months operates for a 24-hours: a-Fe 2421hours loade( 1 -15 14i t 15500] kW and . S 22750 kW and s 2850 kW l nit i1i

                           . -w th-rnn          --mnin-n    hn^rf  nfk   thf-f~     1^-nd ill -vw -

A . M. va i.~ l wi w

                           -FA rnml tAA1 -- A     <
                                                           -ills rrnnm rtw ivi i   _^ivi I2 WOG STS                                    3.8.1 - 12                                   Rev. 2, 04/30/01 15

BVPS ISTS Conversion Rev. 2 Change C-4 & C-15 3.8 Electrical Power Systems Enclosure 1 Changes to ISTS SR that states 'Only applicable to Unit 1." ITS SR 3.8.1.5.2 states 'Check for and remove accumulated water from each day tank." A Note modifies the SR that states

      'Only applicable to Unit 2." These changes to the SRs are acceptable because only the Unit 1 DGs have both day and engine mounted tanks that must be checked for water.                 c-4 For Unit 2, the day tank is the appropriate tank to verify because Unit 2 does not have all engine mounted tank.

11. ISTS SR 3.8.1.7 requires the fast start of each DG to rated voltage and frequency every 184 days. This requirement is not added because the units are licensed in accordance with applicable Safety Guide or Regulatory Guide and does not require the performance of this test and a fast start is performed once every 18 months. The Unit 1 DGs will not field flash on fast start unless an undervoltage signal is present. The Unit I DGs can not be emergency started from the control room. This change will minimize the fast starts for the DGs. The ISTS SRs that follow are re-numbered to reflect this SR deletion.

12. ISTS SR 3.8.1.11 requires the fast start of each DG to rated voltage and frequency on an actual or simulated loss of offsite power every 18 months. This requirement is not added because the units are licensed in accordance with applicable Safety Guide or Regulatory Guide and do not require the performance of this test and a fast start is performed on a loss of offsite power concurrent with an ESF signal once every 18 months. The loss of offsite power concurrent with an ESF signal performs some of the technical requirements listed in this SR. The ISTS SRs that follow are re-numbered to reflect this SR deletion.

13. ISTS SR 3.8.1.12 requires the fast start of each DG to rated voltage and frequency on an actual or simulated ESF actuation (SI) signal every 18 months. This requirement is not added because the units are licensed in accordance with applicable Safety Guide or Regulatory Guide and do not require the performance of this test and a fast start is performed on a loss of offsite power in conjunction with an ESF signal once every 18 months. This is another fast start of the DG with the machine not loading and the emergency buses continued to be powered from the offsite source. The ISTS SRs that follow are re-numbered to reflect this SR deletion.

14. ISTS SR 3.8.1.14 requires the performance of a 24-hour run for each DG every 18 months. This requires a minimum 2-hour run at 105 % to 110 % of rated load and the remaining time of 90 % to 100 % of rated load. ITS SR 3.8.1.10 requires a 2-hour run at c-1s a load of the CTS requirement of 2750 kW for Unit 1 and 4238 kW for Unit 2 to the 2000 hour load limit for each DG (Unit 1 2850 kW and Unit 2 4535 kW). The performance of the two-hour run within the specified load band ensures the capability of the DG to 0-15 sustain the full emergency loading requirements without excessive loading. This is acceptable for Unit 1 because Safety Guide 9, the Unit's current licensing basis, did not require the performance of the 24-hour run. For Unit 2 this is acceptable because it is the current licensing basis described in the UFSAR. As stated in the Unit 2 UFSAR Section 1.8, "Conformance to NRC Regulatory Guides," with regard to the testing requirements of Regulatory Guide 1.108:

              "Paragraph C.2.a(3) suggests a periodic 24-hour, full-load-carrying capability test consisting of 22 hours at the continuous diesel generator rating and 2 hours at the 2-hour rating. Such a test is appropriate only for initial qualification of the diesel BVPS Units 1 & 2                           Page 3                                     Revision 2, 4/06 47

I Rev. 2 Change C-14 & C-15 l Inserts 3.8.1 (continued) Load limits for SR 3.8.1.3 l at a load Ž2340 kWand

2600kW (Unit 1),

Iat a load 2Ž3814 kW and

4238 kW (Unit 2).

Time, load, and Note requirements for SR 3.8.1.10 for 2 2 hours loaded Ž 2750 kW and

2850 kW (Unit 1) I C-15 I C-15 for Ž 2 hours loaded 2 4238 kW and
4535 kW (Unit 2).

Note I Momentary transients outside the load and power factor ranges do not invalidate the test. Note 2 This surveillance shall not normally be performed in MODE 1or 2. However, the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plart is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR. Note 3 If performed with DG synchronized with offsite power, i shall be performed at a power factor

0.89. However, if grid conditions do not permit, the power I C-14 factor limit is not required to be met. Under this condition the power factor shall be maintained as dose to the limit as possible.

SR 3.8.1.9 surveillance note SR 3.8.1.9

                                     - NOTE -

This surveillance shall not normally be performed in MODE 1or 2. However, portion of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR. 187

Rev. 2 Change C-14 & C-15 l BVPS ISTS Conversion 3.8 Electrical Power Systems Enclosure 3 Changes to CTS M.4 CTS surveillance requirement 4.8.1.1.2.b.5 requires each diesel to be tested every 18 months during shutdown to a specific kW load for 2 60 minutes. The loading for Unit I i<; 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 2 2 hours at a load of 2 2750 kW and

2850 kW. Unit 2 is C-15 required to run for 2 2 hours at a load of Ž 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
0.89. Additionally, the note states that if grid conditions Ic-14 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 two run time, a specific loading band, C-15 and specifying a power factor limit for each DG for this test.

This change is acceptable because the test requires the DGs to start and load to C-i5 required values and run for an additional hour. The minimum of 2750 kW is the assumed accident loading value for Unit 1. The maximum of 2850 kW is the 2000-hour limit for Unit 1. The 2750 kW value is greater than the continuous duty rating and is specified by the CTS requirement. The Unit 2 range for kW varies from the continuous duty rating to the 2000-hour limit. A load band is provided to avoid routine overloading of the DG during the monthly test requirement, but the 18-month test ensures the capability of the DG to provide an extended capacity. Routine overloading may result in more frequent teardown inspections in accordance with vendor recommendations in order to maintain DG OPERABILITY. The addition of a power factor limit is acceptable because the load on the DG with a loss of offsite power is inductive and creates volt-amp reactive loading of the DG. This is represented in the limit of the power factor requirement. Therefore, the testing of the DG at this rating is only required every 18 months. The ITS requirements are consistent with the ISTS wording for this requirement (i.e. specifying a load band). This change is designated as more restrictive because it adds additional test conditions that the CTS does not require. M.5 - M.8 Not used. M.9 CTS surveillance requirements for LCO 3.8.1.1 do not require a test of the diesel generator capability to carry emergency loads, transfer those loads to offsite source upon a simulated 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 I DGs would be required to proceed through the shutdown sequence. The surveillance is required to be performed every 18 months. A note modify 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. The purpose for the SR is to ensure the DG is capable of performing the required operations. This change is acceptable because the SR ensures that the manual synchronization load transfer from the DG to the offsite source can be made and the Dc BVPS Units I & 2 Page 14 Revision 2, 4/06 226

BVPS UNITS I & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 CHANGE D-1 Originally, the standard terminology of ISTS 3.7.6 (Condensate Storage Tank or CST) was adopted by BVPS to conform to the ISTS as closely as possible. However, upon further review, the adoption of the standard terminology of CST was determined to be a potential cause of confusion. BVPS has a non-safety related tank that is also called a CST. Therefore, in order to eliminate the potential for confusion, the name of the storage tank in the ITS was changed from CST to the corresponding BVPS specific nomenclature. The BVPS name for this storage tank is the Primary Plant Demineralized Water Storage Tank (PPDWST). Although this is not a technical change and affects only the name of the tank used in the ITS, it also affected references to this tank in many pages of the ITS. Therefore, this change affects pages in Section 3.3B (Remainder of Instrumentation), Section 3.3C (ESFAS), and Section 3.7 (Plant Systems). Affected Pages: The following Table(s) list the affected pages by type (i.e., ITS markup, CTS markup, etc.). In order to facilitate review by ITS section, a separate table is provided for each ITS section affected by the change. The page numbers listed are the ITS section specific consecutive numbers found in the lower right corner of each page. Note: Because the affected page(s) for each change were extracted from a complete ITS section electronic file, the electronic hyperlinks (created in the complete ITS section file) do not work in the collection of affected pages that follow this cover page. ITS SECTION 3.3B (REMAINDER OF INSTRUMENTATION) INDEX OF AFFECTED PAGES ITS MARKUPS PAGE: 8 ITSJFDS No change ITS BASES MARKUPS PAGE: 64 ITS BASES JFDS No change CTS MARKUPS PAGE: 142 CTS DOCS PAGE: 218 (continued)

BVPS UNITS I & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) NOs. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 Change D-1 (continued) ITS SECTION 3.3C (ESFAS) INDEX OF AFFECTED PAGES ITS MARKUPS No change ITS JFDS No change ITS BASES MARKUPS PAGE: 54 ITS BASES JFDS No change CTS MARKUPS No change CTS DOCS No change. ITS SECTION 3.7 (PLANT SYSTEMS) INDEX OF AFFECTED PAGES ITS MARKUPS PAGES: 3,19 & 21 ITS JFDS PAGE: 58 ITS BASES MARKUPS PAGES: 110,111,112,114,115,116 & 118 ITS BASES JFDS PAGE: 202 CTS MARKUPS PAGES: 224 & 226 CTS DOCS PAGES: 278, 282,283,284,285 & 286

BVPS U N ITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 CHANGE D-1 AFFECTEDPAGES FOR ITS SECTION 3.3B (REMAINDER OF INSTRUMENTATION) ITS SECTION 3.3B (REMAINDER OF INSTRUMENTATION) INDEX OF AFFECTED PAGES ITS MARKUPS PAGE: 8 ITS JFDS No change ITS BASES MARKUPS PAGE: 64 ITS BASES JFDS No change CTS MARKUPS PAGE: 142 CTS DOCS PAGE: 218

I Rev. 2 Change C-9, D-1 & D-12 BVPS PAM TABLE (combined Unit I and 2) , CONDITION REFERENCED FROM REQUIRED FUNCTION REQUIRED CHANNELS ACTION D.1

1. Power Range Neutron Flux 2(g) E D-1 2

2. Intermediate Range Neutron Flux 2(g) E

3. Source Range Neutron Flux 2(f) E

4. Reactor Coolant System (RCS) Hot Leg 2 E Temperature (Wide Range)

5. RCS Cold Leg Temperature (Wide Range) 2 E

6. RCS Pressure (Wide Range) 2 E

7. Reactor Vessel Water Level 2 F

8. Containment Sump Water Level (Wide Range) 2 E

9. Containment Pressure (Wide Range) 2 E

10. Containment Area Radiation (High Range) 2 F

11. Pressurizer Water Level 2 E

12. Steam Generator (SG) Water Level (Wide Range) 3 E

13. SG Pressure a) SG'A 2 E b) SG 1B- 2 E c) SG-C' 2 E I D-1

14. Primary Plant Demineralized Water Storage Tank 2 E Level

15. Refueling Water Storage Tank Level (Wide Range) 2 E

16. Penetration Flow Path Containment Isolation Valve 2 per penehttpn flow E Position path

17. Core Exit Temperature a) Quadrant 1 2(c) E b) Quadrant 2 2 (c) E c) Quadrant 3 E 2(c) d) Quadrant 4 E

18. Secondary Heat Sink Indication a) SGA 2 (d) E b) SG B- 2 (d) E c) SG-C' 2 (d) E

19. High Head Si Automatic Iniection Header Flow I B~e).,.. l c9 (d) The required channels may be satisfied by using any combination of SG Water Level (Narrow Range) channels and Auxiliary Feedwater Flow channels such that 2 channels are OPERABLE for each SG.

(e) Condition B contains the appropriate Action for Function(s) with one required channel. nel -- -- _ C-9 (f) Source Range neutron detectors are not required to be energized above the P-6 Intermediate Range Neutron Flux Interlock. (g) Not required in MODE 3. 1 8

I Rev. 2 Ch PAM Instrumentation 3 3.3.3 BASES LCO (continued)

                                          . etermine the nature of the accident in progress (e.g., verify an S         ,and 2   A                         verify uni           ions for termination of SI during se                ary unit -ELBs outside containm At some units, operator action                  sed o        control room indication of SG level. The RCS response during a                      n basis small break LOCA depends on the break size. Fo                   ertain e of break sizes, the boiler condenser mode of heat t                fer is necessary        emove decay heat.

Extended startup ran evel is a Type A variable be se the operator must manually r - and control SG level to establish bo condenser heat transfer. 0rator action is initiated on a loss of subcooled m n. eed r flow is increased until the indicated extended startup ran evel Primary Plant 14 hes the boiler condenser setpoint. Demineralized Water Storage Tank (PPDWST) eandenaate Storaac Tank (CST) Level PPDWST

                                                       --             -  - ---   /-  - -.--

The PPDWST level isIS pro ed to ense wae supply for auxiliary feedwater Tlassihedas a Categy i(AFW). The F- provides tie ensure( d safety grade water supply for the CST _-4,i-e of C.,w on idoMntal tRnkconnAPected by a classified as a Category AF yse. 1 variable for Unit I and AFW't System. -The-a Type A and Category 1 commo outlet e., .Em onitored by a 0 inch to 111 inclevel variable for Unit 2. indication for each faf4 I :clsnlnvad on n control mrim

              /                      /   indicator,         chrtreoder, k-"ti               and unit cnnnmnuer. In nddOinin R contRnl l The PPDWST Level                /        ro annunciator               o low lv.                         (for unit 2) indication is used for the diagnosis of the need to              At some units,       s    Level is consideredcda Type A variabl ecause the                       I rflong term steam generator           control room meter and annunciator arIeconsidered the primary indication heat sink for decay heat              used by the operator[                          T
             <X                         ~~~The DBJ3 th         r        Har         th IO:cS of oeoctric power. steam lino-breqk BDs        lot    N -4         1       1L (GA.

HiThe is e- inital source of water fifor the AFW System. However, as 121 the s epleted, manual operator;.action is necessary to replenish the INSERT 5 _ r align suction to the vVpm e from the hotwell. RWST Level \ WOG STS B 3.3.3 - 9 Rev. 2, 04/30/01 64

I Rev. 2 Change C-9, D-1 & D-12 I INSERTS for ITS 3.3.3 Table 3.3.3-1 NEW PAM FUNCTIONS Ml~ CONDITION REFERENCED FROM REQUIRED FUNCTION REQUIRED CHANNELS ACTION D.1

1. Power Range Neutron Flux 2 (D) E D-12

2. Intermediate Range Neutron Flux 2 (D) E

3. Source Range Neutron Flux 2 () E

4. Reactor Coolant System (RCS) Hot Leg 2 E Temperature (Wide Range)

5. RCS Cold Leg Temperature (Wide Range) 2 E

6. RCS Pressure (Wide Range) 2 E

10. Containment Area Radiation (High Range) 2 F

12. Steam Generator (SG) Water Level (Wide Range) 3 E

13. SG Pressure a) SG"A" 2 E b) SG"B" 2 E c) SG"C" 2 E

14. Primary Plant Demineralized Water Storage Tank 2 E l D-1 Level

15. Refueling Water Storage Tank Level (Wide Range) 2 E

16. Penetration Flow Path Containment Isolation Valve 2 per penetn flow E Position path

18. Secondary Heat Sink Indication a) SG"A- 2 (d) E b) SG "B" 2 (d) E c) SG "C" 2 (d) E

19. HighHeadSIAutomaticinjectionHeaderFlow I B(e) I C-9 (a) Not required for isolation valves whose associated penetration is isolated by at least one dosed and deactivated automatic valve, dosed manual valve, brind flange, or check valve with flow through the valve secured.

(b) Only one position indication channel is required for penetration flow paths with only one installed control room indication channel. (e) Condition B contains the appropriate Action for Function(s) with one required channel. I c-s (1) Source Range neutron detectors are not required to be energized above the P-6 Intermediate Range Neutron Flux Interlock. l D-12 (g) Not required in MODE 3. 142

Rev. 2 Change D-1 BVPS ISTS Conversion 3.3 B Instrumentation Enclosure 3 Changes to CTS acceptable, because it provides a more appropriate surveillance interval for this type of indication that is consistent with the surveillance interval for other PAM instrumentation. In addition, based on the operating experience for the other PAMI instrumentation, the monthly interval for the Channel Check continues to provide adequate assurance that the required indication is maintained operable. As the proposed change continues to provide adequate assurance that the required indication is maintained operable, the change does not adversely affect the safe operation of the plant. The proposed change is designated less restrictive because a less frequent surveillance interval is required in the ITS than in the CTS. More Restrictive Changes (Mi M.1 The CTS PAM instrumentation listed on Table 3.3-11 is revised by the addition of new instrumentation consistent with the proposed list of PAM Functions on ITS Table 3.3.3-1. The following list includes the new PAM Functions introduced by the ITS and the associated Function number from ITS Table 3.3.3-1: Table 3.3.3-1 Function Number Function Title 1 Power Range Neutron Flux 2 Intermediate Range Neutron Flux 3 Source Range Neutron Flux 4 RCS Hot Leg Temperature (Wide Range) 5 RCS Cold Leg Temperature (Wide Range) 6 RCS Pressure (Wide Range) 10 Containment Area Radiation (High Range) (Moved from Radiation Monitoring TS) 12 SG Water Level (Wide Range)

13. a), b), & c) SG Pressure (SGs A, B, &C) 14 Primary Plant Demineralized Water Storage Tank Level 15 Refueling Water Storage Tank Level (Wide Range) 16 Penetration Flow Path Containment Isolation Valve Position

18. a), b), & c) Secondary Heat Sink Indication (For SGs, A, B, & C) 19 High Head Si Automatic Injection Header Flow BVPS Units I & 2 Page 6 Revision '2,4/06 218

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 CHANGE D-1 AFFECTEDPAGES FOR ITS SECTION 3.3C (ESFAS) ITS SECTION 3.3C (ESFAS) INDEX OF AFFECTED PAGES ITS MARKUPS No change ITS JFDS No change ITS BASES MARKUPS PAGE: 54 ITS BASES JFDS No change CTS MARKUPS No change CTS DOCS No change.

ESFAS Instrumentation I Re. 2Chng~e:D:. B 3.3.2 BASES severe environmentlin containh5tLtherefc reflects only steady state instrument uncertai

c. Turbine Trip and Feedwater Isolation - Safety InJection Turbine Trip and Feedwater Isolation is also initiated by all Functions that initiate SI. The Feedwater Isolation Function requirements for these Functions are the same as the requirements for their SI function. Therefore, the requirements are not repeated in Table 3.3.2-1. Instead, Function 1, SI, is except when all Main referenced for all initiating functions and requirements.

Feedwater Lines are isolated by either closed and deactivated MFIVs, or Turbine Trip and Feedwater Isolation Functions must be OPERABLE MFRVs and associated in MODES 1 and-2 land 33 except when all MFIVre, MFRVs, [and bypass valves, or closed assocatcd bypassialvor.] are cloced and [do activated] [or isolated manual valves. In these _}- _ - l_.i_ --V. J-i ...... ini .- .- i._}i..._tRBE"' s. Modes the MFW system and turbine generator may t4olbh~enore.atoi1aybeina-peFation In MODES fag 4,5, be in service. and 6, the MFW System and the turbine generator are not in service and this Function is not required to be OPERABLE.

6. Auxiliary Feedwater The AFW System is designed to provide a secondary side heat sink Primary Plant Demnineralized for the reactor in the event that the MFW System is not available.

Wrater Storage Tank. The system has two motor driven pumps and a turbine driven pump,

                                     \making it available during normal unit operation, during a loss of AC The River Water (Unit 1)and           power, a loss of MFW, and during a Feedwater System pipe break.

Service Water (Unit 2) The normal source pf water for the AFW System is the Gendep~ate Systems provides a backup s)urce of water for the AFW g§Br(qntnknCTL~tnot safety related w i autornaicllyres ee to the Essential I sistem.s~sse The AFWsft System is aligned so that upon a pump start, flow is initiated to the :eSpeGtive [unction 1.b text SGs immediately.

                                       \a. Auxiliary Feedwater - Automatic Actuation Logic and Actuation
           '                      ,                   v (Solid stats Prot"cr-tinn Rvstnm) 7his LCO requires two trains to be OPERABLE. Actuation                        Automa          a        _oc icand actuation relo Ibgic consists of all circuitry               same features and oermnr                                         as described for housed within the actuation subsystems, including the initiating relay contacts ESF_                                                                 E        n lesponsible for actuating the IHSF equipment.

WOG STS B 3.3.2 - 28 Rev. 2, 04/30/01 54

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REWUEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 CHANGE D-1 AFFECTED PAGES FOR ITS SECTION 3.7 (PLANT SYSTEMS) ITS SECTION 3.7 (PLANT SYSTEMS) INDEX OF AFFECTED PAGES ITS MARKUPS PAGES: 3,19 & 21 ITS JFDS PAGE: 58 ITSBASES MARKUPS PAGES: 110,111, 112,114,115,116 & 118 ITS BASES JFDS PAGE: 202 CTS MARKUPS PAGES: 224 & 226 CTS DOCS PAGES: 278, 282, 283, 284, 285 & 286

BVPS ISTS Conversion Rev. 2 Change D-1 3.7 Plant Systems Enclosure 1 Changes to ISTS SECTION 3.7 PLANT SYSTEMS ISTS BVPS ITS CTS Valves (MSIVs) (MSIVs) Isolation Valves 3.7.3 Main Feedwater Isolation 3.7.3 Main Feedwater Isolation N/A Valves (MFIVs) and Main Valves (MFIVs) and Main Feedwater Regulation Valves Feedwater Regulation Valves (MFRVs) and [Associated (MFRVs) and MFRV Bypass Bypass Valves] Valves 3.7.4 Atmospheric Dump Valves 3.7.4 Atmospheric Dump Valves N/A (ADVs) (ADVs) 3.7.5 Auxiliary Feedwater (AFW) 3.7.5 Auxiliary Feedwater (AFW) 3.7.1.2 Auxiliary Feedwater System System System 3.7.6 Condensate Storage Tank 3.7.6 Primary Plant 3.7.1.3 Primary Plant (CST) Demineralized Water Storage Demineralized Water (PPDW) Tank (PPDWST) 3.7.7 Component Cooling Water 3.7.7 Component Cooling Water 3.7.3.1 Component Cooling (CCW) System (CCVV) System Water System (Unit 1); 3.7.3.1 Primary Component Cooling Water System (Unit 2) 3.7.8 Service Water System 3.7.8 Service Water System 3.7.4.1 Reactor Plant River (SWS) (SWS) Water System (RPRWS) (Unit 1); 3.7.4.1 Service Water System (SWS) (Unit 2) 3.7.9 Ultimate Heat Sink (UHS) 3.7.9 Ultimate Heat Sink (UHS) 3.7.5.1 Ultimate Heat Sink - Ohio River 3.7.10 Control Room Emergency 3.7.10 Control Room Emergency 3.7.7 Control Room Emergency Filtration System (CREFS) Ventilation System (CREVS) Ventilation System (CREVS) 3.7.11 Control Room Emergency 3.7.11 Control Room Emergency 3.7.6 Control Room Emergency Air Temperature Control System Air Cooling System (CREACS) Air Cooling System (CREACS) (CREATCS) 3.7.12 Emergency Core Cooling 3.7.12 Supplemental Leak 3.7.8.1 Supplemental Leak System (ECCS) Pump Room Collection and Release System Collection And Release System Exhaust Air Cleanup System (SLCRS) (SLCRS) (PREACS) 3.9.12 Fuel Building Ventilation System 3.7.13 Fuel Building Air Cleanup N/A N/A System (FBACS) 3.7.14 Penetration Room NIA N/A Exhaust Air Cleanup System (PREACS)_ BVPS Units I and 2 Page ii Revision CI 2/05 3

l Rev. 2 Change D-1 I

3. Not required to be met in MODE 4 when steam generator(s) is relied AF1I System upon for heat removal. - -- 3.7.5 Retained from CTS SURVEILLAJPE REQUIREMENTS (continued)

SE iSURVEILLANCE IFREQUENCY SR 3.7.5.4 -

                                          - NOTES -

1. fNot required to be performed for the turbine driven AFW pump until f24 hours] after 2 psigin the steam generator.] T.

2. [AFW train(s) may be considered OPERABLE during alignment and operation for steam generator level control, if it is capable of being manually realigned to the AFW mode of operation.]

Verify each AFW pump starts automatically on an actual f18] months or simulated actuation signal. SR 3.7.5.5 f Verify proper alignment of the required AFW flow Prior to entering paths by verifying flow from the Mte storage MODE 2 ta* to each steam generator. whenever unit has been in MODE 5, MODE 6, or Primary Plant Demineralized Water Storage Tank defueled for a cumulative period 1 of > 30 days) WOG STS 3.7.5 -4 Rev. 2, 04/30/01 19

Rev. 2 Change D-1 I I . 7.T.76 3.7 PLANT SYSTEMS I Primary Plant Demineralized Water Storage Tank (PPDWST) 3.7.6 Condensate Storage Tank (CSTG LCO 3.7.6 The c: shall be OPERABLE. APPLICABILITY: MODES 1, 2, and 3, MODE 4 when steam generator is relied upon for heat removal. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. noperable. A.1 Verify by administrative 4 hours IJ means OPERABILITY of backup water supply. AND

                     \l PPDWST Once per 12 hours thereafter AND            \

A.2 Restore to 7 days I OPERABLE status. B. Required Action and B.1 Be in MODE 3. 6 hours associated Completion Time not met. AND B.2 Be in MODE 4, without f241 hours reliance on steam generator for heat removal. WOG STS 3.7.6 -1 Rev. 2, 04/30/01 21

Rev. 2 Change D-1 BVPS ISTS Conversion 3.7 Plant Systems Enclosure 1 Changes to ISTS ITS 3.7.6 PrimaryPlant Demineralized Water Storage Tank (PPDWST) I JUSTIFICATION FOR DEVIATION (JFD)

1. Plant specific nomenclature (i.e., PPDWST) is retained for this tank to avoid potential confusion with the BVPS non-safety condensate storage tanks.

BVPS Units 1 and 2 Page 7 Revision ,2, 4/06 58

AFW System I Rev. 2 Change D-1 & B-1 I B 3.7.5 BASES Ncte 3 indicates the SR is no: required to be met in MODE 4 when steam REQUIREMENTS (continued) ge ierator(s) are relied upon for heat removal. In MODE used during startup, shutdown, hot standby operations, and hot shutdown 4, T.he heat removal operations for steam generator level control, and these manual requirements are less such operations are an accepted function of the AFW System. OPERABILITY thI t more time is available (i.e., the intended safety function) continues to be maintained. 3. for operator action to n nually initiate AFW if nT e:essary. f SR 3.7.5.5 I cumulative i ( D9 This SR verifies that th FW is properly aligned by verifying the flow PPDWST (WT-TK-10 for Unit 1 and 2FWE-paths from th each steam generator prior to entering MODE 2 after more than 30ays in any combination of MODE 5 or 6 or defueled. OPERABILITY of AFW flow paths must be verified before sufficient core 0DIVD1 TK210 for Unit 2) heat is generated that would require the operation of the AFW System during a subsequent shutdown. The Frequency is reasonable, based on engineering judgement and other administrative controls that ensure that flow paths remain OPERABLE. To further ensure AFW System alignment, flow path OPERABILITY is verified following extended outages to determine no misalignment of valves has occurred. This SR ensures that the flow path from th to the steam generators is properly ID-1 aligned. 3 PPDWi (i :D EVIEWER'S NO 0 This SR is not required by thos and shutdown. e AFW for nomal startup REFERENCES I_ FSAR, Section 1o4.9. 10.3.5.2.2 (Unit 1) and Section 10.4.9 Q bs2 U 2 ASM Edei~ed PFess uro Vescel Gode, Seotien Xi. We vessel 690e. 'beGNOR Ai. (Unit 2) I 1-1111-1 I code for Operation and Maintenance of Nuclear Power Plants I I B-1 WOG STS B 3.7.5 - 9 Rev. 2, 04/30/01 110

I Rev 2. Change D-1 I INSERTS FOR ITS 3.7.5 BASES Auxiliary Feedwater (AFW) System

1. For Unit 1, the turbine-driven AFW pump steam feed lines from each of the three main steam lines combine to form one supply header. The single header then splits into two parallel paths with one Train "A" operated and one Train "B" operated isolation valve on each pathway. The two parallel paths then combine into one header which supplies steam to the turbine driven AFW pump. For Unit 2, the turbine-driven AFW pump steam feed lines from each of the three main steam lines contain two in-line series solenoid operated isolation valves. Downstream of the series isolation valves, the three lines combine to form one main header. The main header then supplies the turbine driven AFW pump. Although the turbine-driven pump in each Unit is capable of receiving the required steam supply from any one of the three main steam lines, only two steam feed lines are required OPERABLE.

The flow path from the Primary Plant Demineralized Water Storage Tank (PPDWST) (WT-TK-10 (Unit 1) and 2FWE-TK210 (Unit 2)) to the steam generators consists of individual supply lines to each of the three AFW pumps. Each motor driven AFW pump is connected to its train related supply header. In addition, for Unit 1, each motor driven AFW pump has the ability to be aligned to the opposite train header. The turbine driven pump can also be aligned to either the Train "A" or "B" supply header. The Train "A" and "B" supply headers branch out to each steam generator feedwater line via three normally open remotely operated valves arranged in parallel flow paths. The individual Train A and B supply header flovi paths are then combined into one common feedwater line injection header for each steamgenerator. The common feedwater injection headers each contain a check valve. Each common feedwater injection header supplies a separate steam generator via the normal feedwater header downstream of the feedwater isolation valves. The steam generators function as a heat sink for core decay heat. The heat load is dissipated by releasing steam to the atmosphere from the steam generators via the main steam safety valves (MSSVs) or atmospheric dump valves (ADVs). If the main condenser is available, steam may be released via the steam dump valves.

2. During a normal plant cooldown, one pump at full flow is sufficient to remove decay heat and cool the unit to residual heat removal (RHR) entry conditions. Thus, the requirement for diversity in motive power sources for the AFW System is met.

3. The limiting Design Basis Accident (DBA) for the AFW System are loss of normal feedwater and feedwater line break.

For the loss of normal feedwater and feedwater line break, the analyses are performed assuming loss of offsite power coincident with reactor trip. The limiting single active failure is the failure of the turbine-driven AFW pump, which requires both remaining motor-driven AFW pumps to be OPERABLE.

4. Sufficient flow would be delivered to the two intact steam generators by the two remaining 111

Rev. 2 Change D-1 AFW pumps. No pump runout occurs due to the cavitating venturis. Two motor driven pumps or one motor driven pump combined with the turbine driven pump can deliver the design bases flows to the intact steam generators during a FWLB. There are two distinct flows that must be delivered during a FWLB. They are prior to fault isolation (i.e., during the first 15 minutes) and subsequent to fault isolation via operator action. Any two of the three AFW pumps are capable of supplying the flows required prior and subsequent to fault isolation. The AFW System design is such that it can perform its function following a total loss of normal feedwater. Any two of the three AFW pumps are capable of supplying the required flows to the three intact steam generators during this event. With one feedwater injection header inoperable, an insufficient number of steam generators are available to meet the feedline break analysis. This analysis assumes AFW flow will be provided to the two remaining intact feedwater lines. Should a feedline break occur on one of the operable feedwater headers with one feedwater injection header already inoperable, the plant could no longer meet its safety analysis.

5. OPERABILITY of the three feedwater trains shall consist of:

a. One motor driven AFW pump with a flow path from the PPDWST to each feedwater line injection header via the train "A" supply header.

b. One motor driven AFW pump with a flow path from the PPDWST to each feedwater line injection header via the train "B" supply header.

c. One turbine driven AFW pump capable of being powered from two steam supplies with a flow path from the PPDWST to each feedwater line injection header via the designated train supply header. Only two out of the three steam supply lines to the turbine driven pump must be operable to provide the required redundancy.

6. With one of the required motor-driven AFW trains (pump or flow path) inoperable in MODE 1, 2 or 3, and the turbine driven AFW train inoperable due to one inoperable steam supply in MODE 1, 2 or 3, action must be taken to restore the affected equipment to OPERABLE status within 24 hours. In this condition, the AFW system may no longer be able to meet the required flow to the SGs assumed in the safety analysis (i.e., from two AFW pumps). Even assuming no further single active failures when in this Condition, the accident (a FLB o' MSLB) could result in the loss of the remaining steam supply to the turbine driven AFW pump. Therefore, only a single OPERABLE AFW pump may be left to mitigate the accident.

The 24-hour Completion Time is reasonable, based on the redundant OPERABLE steam supply to the turbine-driven AFW pump, the availability of the remaining OPERABLE moto:- driven AFW pump, and the low probability of an event occurring that would require the inoperable steam supply to be available for the turbine-driven AFW pump.

7. For the following AFW SRs, constant communications shall be established and maintained between the control room and the auxiliary feed pump room while any normal AFW pump discharge valve is closed during surveillance testing.

112

l Rev. 2 Change D-1 CSl B 3.7 PLANT SYSTEMS A B. Primary Plant Demineralized Water Storage Tank (PPDWST) B 3.7.6 Gendonsate Strg an CT BASES _, BACKGROUND The provides a s ft grad source of water to the steam generators for removing dec ~d sensie heat from the Reactor Coolant System (RCS). The provides a assive flow of water, by gravity, to the Auxiliary Fee 'water (A WSstem (LCO 3.7.5). The steam produced is released to the atmosph e by the main steam safety valves or the atmospheric dump vals. The AFW Dumps operate with a lGtiwus recirculation to the to ensure aminimum D~ump flow ismaintained. Whevrl-tmFakseam isolation valves are open, the prefe ne heat removal is to UilIM l tem to th e sthe nonsafely I grade path of the steam b ondensed steam is returned to the CSTbate transfer pump. T vantage of

              \         9        con~~~densate while minimizing eesst teevraB PPDST      Because the5 is a principal component in removing residual heat from CS, it is designed to withstand earthquakes and other natural henom           luding missiles that might be generated by natural p omena. Th                  is designed to Seismic Category I to ensure              10.3.5.2.2 availa       of the feedwater supply.              dwater is also available from (Unit 1) alternate soS.             I             u     .                                      andi u                                        Se,-.tion description of the          is found in thI        AR, Section           (Ref H      .1 (t0 2)l APPLICABLE             e CST provides cooling water to remove decay heat and to cool d SAFETY              the following all events in the accident analysis as discusse                     the ANALYSES            FSAR, C ters 16] and [151 (Refs. 2 and 3, respectively). r anticipated op0 tional occurrences and accidents tha not affect the OPERABILITY of            team generators, the ana                assumption is generally 30 minutes a           DE 3, steaming tugh the MSSVs, followed by a cooldown to residual he emoval        entry R)              conditions at the Insert           design cooldown rate.

The limiting event for the densate vou is the large feedwater line break coincident withass of offsite power. le failures that also affect this evet ude the following:

a. F eof the diesel generator powering the motor dr FW ump to the unaffected steam generator (requiring additionteam to drive the remaining AFW pump turbine) and WOG STS B 3.7.6 - 1 Rev. 2, 04/30/0-1 114

I Rev. 2 Change D-1 I I PDST> B 3.7.E BASES APPLICABLE SAFETY ANALYSES (continued) Tilure of the steam driven AF W pump (requiring a longert e o act using only one motor driven AFW pump). These a erence limiting failures inthe ste quences for these events.\/ A nonlimiting event considered rientory determinations is a break in either the main feebe or inne near where the two join. This break has the pt ~fr dumping con eae until terminated by operator action ih Emergency Feedae A:uon System would not detect adfencinpressure betwee teseamg tosfrhi break ion. This loss of condensate inventory is partially mpensated for by the retention of steam generator inventory. Crterion _ Ths satisfies ite a 2 an 3 of 10 CFR 50.36(c)(2)(ii). LCO cident analysis assumptions, the CST must contain lent cooling water decay heat for 130 minutes]fow g a reactor trip from 102% RTP, an to cool down tR to RHR entry conditions, assuming a coincide site power and the most r0 adverse single failure. In d it mus *n sufficient water to ensure adequate gstive suction head for the mps during LUTS value cooldow el as account for any losses from the steam AFW C ) l 130,000 galons turbine, or before isolating AFWto a broken line. The level required is equivalent to a usable volume of maintaining the unit inMODE > [which is based on holding the unit in MODE 3 for

                                  .r~ i WA- -r-             &      -IA

_MA S" - -an! Mr n ,................................. X -U r - - 9 3 lor 9 hours with steam -- Vjdj fIt-juib, fun nuweu bt-gj:'4VVJU7H W KF9K FdFiffy f6UHU111UHb

                                                                                      - I -       .          -. - ..

disc-harge to the atmosphere IP11' fllfIR9U IM'T~ilh1'Pflf m Clf'~~' g o.v . . 1~'n~'"~""m~~P~lI

                                                                                          -..-           __         .- ,_           _   . -. _   read and with no reactor coolant       by the accident analysis.                          PD pumps in operation following a l.OOP and subsequent reactor trip from full power. The OPERABILITY of the                     is d           nmed by maintaining the tank                                 I level at or above the minimum re ir d level.

APPLICABILITY In MODES 1, 2, and 3, and i /MmO 4, when steam generator is being relied upon for heat remov, the T is required to be OPERABLE. In MODE 5 or 6, the Tif is not required because the AFW System is not I required. WOG STS B 3.7.6 - 2 Rev. 2, 04/30/0'1 115

l Rev. 2 Change D-1 BASES PPW1 l (ie-., River/Service Water Systems) ACTIONS A.1 and A.2 W/ If the inot OPERAB , the OPERABILITY of the backup supply

should be verified by admiitraiv means within 4 hours and once every 12 hours thereafter. OPR0LIYo the backup Seeawater supply must (2) include verification that th l ah rom the backup water supply to the AFW pumps are OPERBE dta the backup suppl has the Fequired volume of water availablo. The must be restored to OPERABLE status within 7 days, because the backup supply may be performing this function in addition to its normal functions. The 4 hour Completion Time is reasonable, based on operating experience, to verify the OPERABILITY of the backup water supply. Additionally, verifying the backup water supply every 12 hours is adequate to ensure the backup water supply continues to be available. The 7 day Completion Time is reasonable, based on an OPERABLE backup water supply being available, and the low probability of an event occurring during this time period requiring thea .

B.1 and i. ;I A4 If the cannot be restored to OPERABLE status within the associated Completion Time, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours, and in MODE 4, without reliance on the steam generator for heat removal, within [24] hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. SURVEILLANCE SR 3.7.6.1 PW l usable REQUIREMENTS / /o This SR verifies he contains the required olume of cooling water. rvolume may be cinglo-value or a function of RCS-conditions) he 2 hour Frequency is based on operating experience and t e n d for operator awareness of unit evolutions that may affect the i entory between checks. Also, the 12 hour Frequency is considered adequate in view of other indications in the control room, inclu ng alarms, to alert the operator to abnormal deviations in the level. 10.3.5.2.2 (Und 1)

                                                     ,nd Section 10.

4.9 REFERENCES

1 FSAR, Sectionlg-~- (Unit 2) U 2. FSAR, Chapter [61( WOG STS B 3.7.6 - 3 Rev. 2, 04/30/01 116

I Rev. 2 Change D-1 I INSERTS FOR ITS 3.7.6 BASES Primary Plant Demineralized Water Storage Tank (PPDWST) The Auxiliary Feedwater Pumps are normally aligned to take suction from the PPDWST. The PPDWST provides cooling water to remove decay heat and to cool down the unit. Since the Engineered Safety Feature (ESF) design function requires that sufficient feedwater be available during transient and accident conditions to place the unit in a safe shutdown condition, the limiting event for the condensate volume is a loss of offsite power (LOOP) transient. In the event of a LOOP and subsequent reactor trip from full power, the PPDWST inventory must be available to maintain the unit in MODE 3 for 9 hours with steam discharge to the atmosphere and with no reactor coolant pumps in operation. The minimum usable volume conservatively bounds the analysis value. The minimum usable volume may be appropriately increased to account for measurement uncertainties. 118

I Rev. 2 Change D-1 I BVPS ISTS Conversion 3.7 Plant Systems Enclosure 2 Changes to The ISTS Bases ITS 3.7.6 Primary Plant Demineralized Water Storage Tank (PPDWS7) I JUSTIFICATION FOR DEVIATION (JFD)

1. The ISTS Bases text is edited to include editorial enhancements. Changes have been made (additions, deletions, or changes to the NUREG-1431) to reflect the plant specific nomenclature, number, or reference description.

2. The ISTS Bases text is edited to eliminate details not applicable to the BVPS design. The text is also edited to insert BVPS specific information in addition to or in place of the standard bases wording. The Bases description is revised consistent with the corresponding design basis of the plant pertaining to the PPDWST. The changes may I reflect BVPS specific terminology or specific details regarding the safety analyses.

BVPS Units I & 2 Page 7 Revision 2, 4/06 202

I Rev. 2 Change D-1 PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) 4-.7.1.4.1 Verify each AFW manual, power operated, and automatic valve in each water flow path, and in both steam supply flow paths to the steam turbine driven AFW pump, that is

   ,---->                         not locked,.sealed, or otherwise secured in position, is LAdd insertlin the correct position at least once per 31 days.++

of each Service Water Verify, at the frequency specified in the Inservice Testing Program, on a STACCERED TlrT AZIS that the developed head of each AFW pump at the flow test point is greater than or equal to the required developed head as specified in the Inservice Testinq Pro ram l Primary Plant p Peification 4.0 aplicable for 0mineralized Water entry into MODE rbine driven pump Storage Tank _it 4.7.1.2.4 Verify each AFW automatic valve that is not locked, A sealed, or otherwise secured in position, actuates to the 4 SR.7.5. l correct position on an actual or simulated actuation signal at least once per 18 months-++ [erify each AFW pump starts automatically on an actual or lSR 375 simulated actuation signal at least once per 18 Linths.i 4.7.1.2--.-& Cycle rated (excluding au in the flow path that es able during plant ( _f operation, east one c lst X _ er 18 months during shutdown. L4I712-! Verify AFW flow fromITK-2101to the Steam Generators with the AFW valves in their normal alignmen I a Reverify these requirements by a second and independent I

                -'I    operator.

(-5) Not required to be performed for the turbine driven AFW pump until 24 hours after establishing the minimum required secondary [ I side steam pressure of greater than 600 psig. Insert I (No Xl- when wappt=-F steam enerac rlr SR 3.7.5.5 - I This surveillance is required to be performed prior to entry into MODE 2 whenever the plant has been in MODES 5 or 6 for greater than 30 days. cumulative or defueled

         'BEAVE 'R VALLEY - UNIT 2                            3/4 7-5a                  Amendment No.         85 FSR3.7.5.1, SR 3.7.5.3, and SR 3.7.5.4 Notes   lA 224

I Rev. 2 Change D-1 Draft Page from Unit 2 LAR # 173 I (Unit I LAR # 302) I PLANT SYSTEMS [DEMIEStorage Tank (PPDWST)E PRIMARY PLANT DEMINERALIZED WATER I LIMITING CONDITION FOR OPERATION 3.7.1.3 The prmr I OPERABLE with a mini APPLICABILITY: MODES 1, 2 and 4. -J

          -PDWST                                            MODE 4 when steam generator is relied upon for heat removal With the 4 hour     e-her-storage tank water volume not within the limit, aTDW

_ and once per 12 hours thereafter M2 within I e.ctre 'he water v te ihi h limit o oi CITUTDOWN withinsA\_ to n12t~ 'o, tVerify by administrative means Bases

                  . Dmontract heOPERABILITY of thelseLrvice water system a backup supply Ito the auxiliary feedwater pumps and restore the SPWUorg                             anlk water volume Lo withInl its (G CONDB          limit withi 7 days or be in HOT SHUTDOWN within the neXt L  Il           hours. /                  MODE 3 ihin l 3     -     <                I  PPDWST         6 hours and             without reliance on steam generator for hea: remova SURVEILLANCE REQUIREMENTS \                               _t--"_*

I-111\

/0.7.        The PPDW stagea               en shall     1 be demonstrated OPERABLE at least                                       I once per 12 hours by verifying the water level.

BEAVER VALLEY - UNIT 2 3/4 7-6 Amendment No. 226

lRev. 2 Change D-1 BVPS ISTS Conversion 3.7 Plant Systems Enclosure 3 Changes to CTS with one steam supply inoperable. This change is being made so the BVPS ITS is consistent as possible with NUREG-1431. This changes the CTS by moving the Note for following ACTION statement (a) to the Bases. The purpose of the CTS was to provide a clarification of the requirement to enter ACTION statement (a) rather than entering ACTION statement (c). The removal of this detail from the TS is acceptable because this type of information is not necessary to be included in the TS in order to provide adequate protection of the public health and safety. The TS retains the requirement that three AFW trains shall be OPERABLE. As described in the ITS Bases, the condition of one steam supply inoperable does not constitute one AFW train being inoperable, thus Condition C would not be entered. As such the details for meeting the Actions are described in the ITS Bases. Also, this change is acceptable because these types of procedural details will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Bases Control Program specified in the Administrative Controls section of the TS. The Bases control Program assures changes to the Bases are evaluated and prior NRC review and approval is obtained when required by 10 CFR 50.59. This change is designated as a less restrictive removal of detail change because procedural details for meeting requirements are being removed from the! TS. LA.5 (Type I - Removing Details of System Design and System Description, Including, Design Limits) CTS 4.7.1.2.7 requires the verification of AFW flow from WT-TK 1) (Unit 1) and TK-210 (Unit 2) (i.e., the PPDWST) to the steam generators with the AFW valves in their normal alignment. ITS SR 3.7.5.5 requires the verification of AFW flow from the PPDWST to each steam generator. The ITS does not contain a list or description of the PPDWST or the AFW valves that would satisfy the corresponding surveillance. This change is being made so that the BVPS ITS is consistent as possible with NUREG-1431. This changes the CTS by moving specific details regarding performance of the SR (i.e., the PPDWST equipment IC) numbers) to the Bases. The removal of these details, which are related to system design, from the TS is acceptable because this type of information is not necessary to be included in the TS to provide adequate protection of public health and safety. The TS retain the requirement that three AFW trains must be OPERABLE and thus the SR must be met. The retained SR requirement provides adequate assurance that the plant will continue to be operated in a safe manner. The descriptive details regarding performance of the SR are contained in the ITS Bases. As such, this change is also considered acceptable because the removed information will be adequately controlled in the TS Bases. Changes to the TS Bases are controlled by the Bases Control Program. The Bases Control Program is specified in the Administrative Controls section of the TS. The Bases Control Program ensures changes to the bases are evaluated and prior NRC review and approval are obtained when required by 10 CFR 50.59. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the TS. LA.6 (Type 3 - Removing Procedural Details for Meeting TS Requirements) Note (4) of SR 4.7.1.2.1 requires the re-verification of requirements by a second and independent operator. ITS SR 3.7.5.1 does not contain such a requirement. This change is being made so the BVPS ITS is consistent as possible with BVPS Units 1 &2 Page 10 Revision:?, 4/06 278

Rev. 2 Change D-1 BVPS ISTS Conversion 3.7 Plant Systems Enclosure 3 Changes to CTS CTS 3.7.1.3 PRIMARY PLANT DEMINERALIZED WATER (PPDW) ITS 3.7.6 Primary Plant Demineralized Water Storage Tank (PPDWST) DISCUSSION OF CHANGE (DOC) Less Restrictive Changes (L) L.1 (Category 4 - Relaxation of Required Action) CTS 3.7.1.3 Action b allows 4 hour; to demonstrate Operability of the reactor plant river 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 requires the verification by administrative means the Operability of the backup water supply. This changes the CTS by replacing the word 'demonstrate" with 'verify by administrative means" in the Required Action. Eliminating the requirement to

     'demonstrate" and replacing the requirement with "verify by administrative means" prevents a potential misinterpretation of the requirement of what constitutes
     'demonstration" of Operability. This change is being made so the BVPS ITS is consistent as possible with NUREG-1431.

The purpose of the CTS Action b is to ensure the backup water supply system is Operable and capable of providing the required volume of water supply and flow path to the AFW pumps. This change is acceptable since the term "administrative means," as used in the ISTS, is used when the actual performance of testing or other surveillance requirement is not necessary and operability can be confirmed by checking previously performed surveillances, current valve position status, or other administrative controls used to document equipment or component status. The reactor plant river water system (Unit 1) and the service water system (Unit 2) TS Mode of Applicabilities include the Modes the PPDWST is required to be Operab'e. The CTS requirement to "demonstrate" the Operability of the backup water supply takes credit for an Operable Service Water System (as required by CTS 3.7.4) arid SR 4.7.1.2.2. The ITS Required Action to verify the backup water supply system Operability by administrative means (meaning the applicable system LCO requirements are verified to be met including surveillances and valve lineups) accomplishes the same function as the CTS requirement without specifying redundant backup water supply system testing be demonstrasted. This change i;3 designated as less restrictive because the scope of the CTS Action is reduced and more narrowly defined. L.2 (Category 3- Relaxation of Completion Time) CTS 3.7.1.3, Action b. states that if demonstration of the Operability of the backup water 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 hours. 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 hours and MODE 4 without reliance on the steam generators for heat removal within 24 hours. This changes the time to be in MODE 4 without BVPS Units 1 &2 Page 14 Revision 2, 4/06 282

BVPS ISTS Conversion Rev. 2 Cha~ng~eD-1 3.7 Plant Systems Enclosure 3 Changes to C:S reliance on the steam generators for heat removal from 12 hours to 24 hours. The CTS has been revised to incorporate and extend the Completion Time by an additional 12 hours to be in MODE 4. This change is being made so the BVPS ITS are consistent as possible with NUREG-1431. The addition of the condition to be in MODE 4 without reliance on the steam generators for heat removal is discussed in DOC M.1. The addition of the MODE 3 Completion Time is discussed in DOC M.2. The purpose of CTS 3.7.1.3 Action b is to place the unit in a condition outside of the Mode of Applicability. ITS 3.7.3, Condition B, places the unit in a condition outsice of the Mode of Applicability in which it does not rely on the steam generators for heat removal when the PPDWST is inoperable. This change is acceptable because the Completion Time is consistent with safe operation under the specified Condition, considering the Operable status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the allowed Completion Time. Allowing 24 hours to be in MODE 4 without reliance on the steam generators for heat removal is consistent with other Specifications and recognizes that additional time is required from the time MODE 4 is entered until the steam generators are not relied upon for heat removal. This change is designated as less restrictive because additional time is allowed to restore parameters to within the LCO limits than was allowed in the CTS. More Restrictive Changes (M) M.1 CTS 3.7.1.3 specifies requirements for the PPDWST that are applicable in MODES 1, 2, 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 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. This change is being made so the BVPS ITS is consistent as possible with NUREG-1431. The purpose of the CTS is to provide a safety grade source of water to the steam generators via the AFW system for removing decay heat and sensible heat from the RCS. These changes are acceptable because the required steam generators must have a sufficient source of makeup water to be considered Operable for heat removal. The change revises the Mode of Applicability for the PPDWST c6nsistent with the Mode of Applicability for the AFW system (ITS 3.7.5). The change is designated more restrictive because the PPDWST is now required to be Operable in MODE 4. M.2 CTS 3.7.1.3 Action b allows 4 hours to demonstrate Operability of the reactor plant river 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 BVPS Units I & 2 Page 15 Revision :2, 4/06 283

lRev. 2 ChangeD-1 Rev.2 CangeD-13.7 BVPS ISTS Conversion Plant Systems Enclosure 3 Changes to CTS 3.7.6 Required Action A.1 allows 4 hours 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 hours thereafter whenever the PPDWST is inoperable. This changes the CTS by requiring the plant to perform verifications every 12 hours of the backup water supply Operability. The verifications follow the initial 4 hour 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. This change is being made so the BVPS ITS is consistent as possible with NUREG-1431. The revision replacing the word 'demonstrate" with 'verify by administrative means' in the Required Action is discussed in DOC L.2. The purpose of the CTS 3.7.1.3 Action b is to ensure the backup water supply systems are Operable and capable of providing the required volume of water supply and flow to the AFW pumps. This change to add a periodic verification of the Operability of the backup water supply isacceptable because the verification continues to ensure the backup water supply is available over the possible 7 day out of service of the PPDWST. The change is designated as a more restrictive change because the CTS currently does not require a periodic verification of the backup water supply after the initial verification (within 4 hours) is satisfied. M.3 CTS 3.7.1.3 Action b states that if demonstration of the Operability of the backup water 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 hours. IrS 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 hours and MODE 4 without reliance on the steam generators for heat removal within 24 hours. This 4%) 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. This change is being made so the BVPS ITS is consistent as possible with NUREG-1431. The change in the time to reach MODE 4 is discussed in DOC L.1. The purpose of CTS 3.7.1.3 Action b is to place the unit in a condition outside of the Mode of Applicability within a specified completion time. This change to add a intermediate MODE step requirement is acceptable because operating experience has shown that six hours is sufficient to move the plant from full power conditions to MODE 3 without challenging plant systems. The change is designated as a more restrictive change because the CTS currently does not require the plant be placed in MODE 3 within six hours. BVPS Units I & 2 Page 16 Revision :, 4/06 284

BVPS ISTS Conversion Rev. 2 Change D-1 3.7 Plant Systems Enclosure 3 Changes to CTS Removed Detail Changes (LA) LA.1 (Type 1- Removing Details of System Design and System Description, Including Design Limits) CTS 3.7.1.3 LCO defines the required water volume as 'usable" and Action b states the reactor plant river water system (Unit 1) or the service water system (Unit 2) performs a function as a backup supply to the AFW pumps. The corresponding ITS 3.7.6 LCO simply requires the tank to be operable without describing the bases of the specified volume and ITS Required Action A.1 specifies the backup water supply to be Operable when the PPDWST is inoperable without l describing the backup system in detail. The CTS is revised to be more consistent with the ITS. This changes the CTS by relocating specific design details (i.e., the specifics regarding the required water volume and the AFW system backup water supply) to the Bases. The location of these details in the Bases is consistent with the format and presentation conventions of the ISTS. The net effect of this change is to simplify the LCO and Actions consistent with the ISTS. The proposed change is acceptable because the operability requirements for the PPDWST are not changed. The proposed change only moves the system design details to the TS Bases which is necessary to conform to the ISTS presentation and format. The removal of these details, which are related to system design, from the TS, is acceptable because this type of information is not necessary to be included in the TS to provide adequate protection of public health and safety. The ITS still retains the requirement for the required water volume and for the backup water supply to be Operable when the PPDWST is inoperable. The proposed change only moves descriptive detail to the ITS Bases. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the TS Bases Control Program specified in the Administrative Controls Section of the TS. This program provides for the evaluation of changes to ensure the Bases are properly controlled and prior NRC review and approval is requested when required. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the TS. Administrative Changes (A) A.1 In the conversion of the Beaver Valley Power Station current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering or order, etc.) are made to obtain consistency with NUREG-1431, Rev. 2, "Standard Technical Specifications-Westinghouse Plants" (ISTS). Due to the large number of such changes, A.1 changes may not always be marked on each CTS page. Marked or unmarked, all A.1 changes are identified by a single annotation of A.1 at the top of the first page of each CTS. These changes include all non-technical modifications of requirements to provide consistency with the ISTS, including all significant format changes made to update the older NUREG-0452 Technical Specification presentation to the ISTS format. This type of change is also associated with the movement of requirements within the Technical Specifications BVPS Units I & 2 Page 17 Revision ,' 4/06 285

BVPS ISTS Conversion I Rev. 2 Change D-1 I 3.7 Plant Systems Enclosure 3 Changes to CTS and with changes made to the presentation of Technical Specifications requirements to combine the Unit I and 2 Technical Specifications into one document and highlight the differences between the Unit I and 2 requirements. These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS requirements. A.2 CTS 3.7.1.3 Action a provides an option to restore within 4 hours the water volume if the PPDWST is not within limit or be in HOT SHUTDOWN within the next 12 hours. I The corresponding ISTS Action does not include the action to 'restore.' The CTS Action a is revised consistent with the ISTS. This changes the CTS by eliminating the presentation of the restore Action. The revised CTS Action contains only the alternative to the restore Action (CTS 3.7.1.3 Action b). As the action to restore equipment or components to operable status is always ar, option when the LCO is not met, the elimination of this Action from the CTS does not introduce a technical change. The elimination of the restore Action is made to conform to the format and presentation of this information in the ISTS. Therefore.. this change is considered administrative. BVPS Units 1 & 2 Page 18 Revision 2, 4/06 286

BVPS UNITS I & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) NoS. 296 (UNIT 1) & 1 69 (UNIT Z) REVISION 2 CHANGE D-2 This change adds more detail to the Bases for ITS 3.3.2 (ESFAS). The ESFAS Bases description of the Switchover to Recirculation mode Function is revised to include additional BVPS information describing the interlock circuitry. Specifically, information was added to describe that the SI interlock is retained by latching relays until manually reset. Affected Pages: The following Table(s) list the affected pages by type (i.e., ITS markup, CTS markup, etc.). In order to facilitate review by ITS section, a separate table is provided for each ITS section affected by the change. The page numbers listed are the ITS section specific consecutive numbers found in the lower right corner of each page. Note: Because the affected page(s) for each change were extracted from a complete ITS section electronic file, the electronic hyperlinks (created in the complete ITS section file) do not work in the collection of affected pages that follow this cover page. ITS SECTION 3.3C (ESFASJ INDEX OF AFFECTED PAGES ITS MARKUPS No change ITS JFDS No change ITS BASES MARKUPS PAGE: 58 ITS BASES JFDS No change CTS MARKUPS No Change CTS DOCS No Change

ESFAS Instrumentation Rev. 2 Change D-2 B 3.3.2 I BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued) ( 3,Automatic Switchover to Containment Sump In Unit 1, the low head Si rl (LHSI) pumps and containment recirculation spray (RS) pumps draw I I At the end of the injection phase of a LOCA, the RWST will be nearly empty. Continued cooling must be provided by the ECCS to remove water from the containment decay heat. The source of water for the ECCS pumps is sump. The RS pumps pump automatically switched to the containment recirculation sump. The the water through the RS ro-w-bin du~ea~t removal (RHR) pumps and Sotairspray heat exchanger to the pumps draw the wat ai~et-ellcution sump, the recirculation spray headers. The LHSI pumps circulate RHR pumps pump the wa t h anger, hll~ inject-the water back to the reactor the water b h C , and supply thecod a F lh and provide suction to the S Pumps. ISwitchover from the RWST to the containment High Head Si (HHSI) sump must occur before the RWST empties to prevent damage to pumps. In Unit 2, during the recirculation phase, one RS the RHR pumps and a loss of core cooling capability. For similar pump per train provides the reasons, switchover must not occur before there is sufficient water in low head injection function the containment sump to support ESF pump suction. Furthermore, and suction to the HHSI early switchover must not occur to ensure that sufficient borated pump and one RS pump per water is injected from the RWST. This ensures the reactor remains train provides the recirculation spray function. shut down in the recirculation mode. Both the Unit 2 RS pumps on each train draw water a. Automatic Switchover to Containment SumD - Automatic from the containment sump Actuation Logic and Actuation Relays and pump water through an RS heat exchanger. I Ate4 tic actuation Iogic: and actuation rela s same fea and opera esanner as described fo] I E _(Unit 1)and extreme low (Unit 2) ] b, c. Automatic Switchover to ContainmenfSump - Refueling Water

                                               / Storane Tank (RWST) Level - Low VEw Coincident With Safet Function 1.b text                          / niectionnd CninidonW\/th                          Itirt(lo~ zzl~

During the injection phase of a LOCA, the RWST is the source

                                     /           of water for all ECCS pumps. A low             level in the RWST coincident with an Si signal provides rotection against a loss of This LCO requires two trains to be OPERABLE. Actuation                  water for the ECCS pumps and ind' tes the end of the injection logic consists of all circuitry         phase of the LOCA. he RWST i equipped with four level housed within the actuation subsystems, including the                transmitters. T e transmitters rovide no control functions.

initiating relay contacts Therefore, vo-out-of-four logi is adequate to initiate the responsible for actuating the protecti unction actuation. Ithough only three channels ESF equipment. woul e sufficient, a fourth c annel has been added for due to the energize ieased reliability,- to trip design of these

                                                                                          /                           channels.

The SI interlock is maintained The RWST -low Iw All able Value/Tip Setpeint has both by latching relays until reset manually. upper and lower limit T e lower limit is selected to ensure (Unit 1)and extreme lo\v (Unnt 2). WOG STS B 3.3.2 - 32 Rev. 2, 04/30/01 58

iBVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 CHANGE D-3 This change corrects a misplaced DOC hyperlink. The CTS Markup of page 73 in Section 6 (CTS page 6-15) is revised to remove the hyperlink to DOC A.6 for the insert at the top of the page. The correct hyperlink for the insert is DOC L.3 which was originally placed below the inserted text near the insertion point. The affected CTS change on this page (in CTS paragraph

5) was justified by DOC L-3 which now has a hyperlink in two places on the affected page to more clearly identify the applicable changes. This change only removes the misplaced hyperlink to DOC A.6 and clarifies that DOC L.3 applies. DOC A.6 is used on another page in ITS Section 5.0. The change does not affect the text of any CTS changes or DOCs.

Affected Pages: The following Table(s) list the affected pages by type (i.e., ITS markup, CTS markup, etc.). In order to facilitate review by ITS section, a separate table is provided for each ITS section affected by the change. The page numbers listed are the ITS section specific consecutive numbers found in the lower right corner of each page. Note: Because the affected page(s) for each change were extracted from a complete ITS section electronic file, the electronic hyperlinks (created in the complete ITS section file) do not work in the collection of affected pages that follow this cover page. ITS SECTION 5.0 (ADMINISTRATIVE CONTROLS) INDEX OF AFFECTED PAGES ITS MARKUPS No change ITS JFDS No change ITS BASES MARKUPS No change ITS BASES JFDS No change CTS MARKUPS PAGE: 73 CTS DOCS No Change

Rev. 2 Change D-3 ADMINISTRATIVE CONTROLSDeemntoofpjcedos LI contributions from radioactive effluents in god PROCEDURES (Continued) accordance with the methodology inthe I J. ODCM at least every 31 days. Monitoring, sampling, and analysis of radioactive

                      '      liquid and gaseous efflu nts in                                  accordance            w' th 10 CFR 20.1302 and with the methodology and parameters in  the ODCM,      member of the public I d         Limitations o the annual a                      d quarterly doses or dose commitment to a-r                              IE PUBLIG from radioactive Funrestrictedarea] materials in liquid efflue                        s released from each unit I                     to ftIrTRICTED
                                      -AREAS                         con    orming to Appendix I to 10 CFR Part 50,                                                                  (N)

LEI54 Determination contributions of cumulatve from radio ctive effluents for lthe dose current calendar quarter a d current calendar year in accordance with the method loly and parameters in tlhe ODCM at least every 31 day functional capability >i) E Limitations on the and use of the liquid and gaseous ef f luent treatment systems to ensure that the appropriate portions of these systems are used to reduce releases of radioactivity when the projected doses in a 31-day period would exceed 2 percent of tlhe guidelines for the annual dose or dose commitment conforming to Appendix I to 10 CFR Part 50, from thee i 9~ Limitations on the dose rate resulting Xom radioactive material released in gaseous effluents 'to areas beyond the SITE BGUAD4ZY shall be limited to the oerrfollowingt: l\enaordadr site boundary La+ For noble gases: than or equal to 500 mrem/year to the total body and less Lhnn or equal to 3000 mrem/year o the skin and, I whole J [Zb) For Iodine-131, Iodine-133, for tritium, and :-or all radionuclides in particulate form with haLf-lives greater than 8 days: Ad than or equal to 1500 mrem/year to any organ, a dose rate less] E ) Limitations on the annual and quarterly air doses resulting from noble gases released in gaseous soeffluents from each unit to areas beyond the &ITIE sitboundar BOUNDARY conforming to Appendix I to 10 CFR Part 50, Li1 Limitations DdRMl:: O-F THE memberofthepublic l/tritium, and all on the PUBLICG annual from and quarterly Iodine-131, radionuclides in particulate form doses to a Iodine-1:33, with half-lives greater than 8 days in gaseous effluents released from each unit to areas beyond the s bny BOUNDARY conforming to Appendix I to 10 CFR IV Part 50, BEAVER VALLEY - UNIT 2 6-15 Amendment No. 77 73

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION Z CHANGE D-4 ITS 5.5.1 (Offsite Dose Calculation Manual or ODCM), is revised to provide individual paragraph numbering starting with "Licensee initiated changes to the ODCM:" which will become paragraph "c". Appropriate numbers and letters are used to identify each sub-paragraph under paragraph c. This change was made to be more consistent with the paragraph numbering used in other parts of Section 5.0. The CTS markup of the ODCM is also revised to more clearly show the insertion of ODCM paragraphs a and b from the CTS definition of the ODCM. The paragraph renumbering changes provide an enhanced organization of the final paragraphs that is more suitable for referencing in the applicable plant procedures. The CTS markup changes only serve to improve the roadmap of CTS changes which make the disposition of the CTS requirements more clear for future reference. These changes do not introduce any technical changes to the ITS or CTS. Affected Pages: The following Table(s) list the affected pages by type (i.e., ITS markup, CTS markup, etc.). In order to facilitate review by ITS section, a separate table is provided for each ITS section affected by the change. The page numbers listed are the ITS section specific consecutive numbers found in the lower right corner of each page. Note: Because the affected page(s) for each change were extracted from a complete ITS section electronic file, the electronic hyperlinks (created in the complete ITS section file) do not work inthe collection of affected pages that follow this cover page. ITS SECTION 5.0 (ADMINISTRATIVE CONTROLS) INDEX OF AFFECTED PAGES ITS MARKUPS PAGE: 9 ITS JFDS PAGE: 57 ITS BASES MARKUPS No change ITS BASES JFDS No change CTS MARKUPS PAGES: 84 & 88 CTS DOCS No Change

Rev. 2 Change D-4 Programs and Manuals 5.5 5.0 ADMINISTRATIVE CONTROLS 5.5 Programs and Manuals The following programs shall be established, implemented, and maintained. 5.5.1 Offsite Dose Calculation Manual (ODCM)

a. The ODCM shall contain the methodology and parameters used in the calculation of offsite doses resulting from radioactive gaseous and liquid effluents, in the calculation of gaseous and liquid effluent monitoring alarm and trip setpoints, and in the conduct of the radiological environmental monitoring program, and

b. The ODCM shall also contain the radioactive effluent controls and radiological environmental monitoring activities, and descriptions of the 1TSTF-369 information that should be included in the Annual Radiological Environmental Operating, and Radioactive Effluent Release Reports

c. required by Specification [5.6. and Spcification 5 . l Licensee initiated changes to the ODCM: SpJ Hi a- Shall be documented and records of reviews performed shall be retained.

This documentation shall contain: a) i-. Sufficient information to support the change(s) together with the i(, appropriate analyses or evaluations justifying the change(s) and b) 2 A determination that the change(s) maintain the levels of radioactive effluent control required by 10 CFR 20.1302, 40 CFR 190, 10 CFR 50.36a, and 10 CFR 50, Appendix I, and not adversely impact the accuracy or reliability of effluent, dose, or setpoint calculations, b1 Shall become effective after the approval of the plant managW and or Shall be submitted to the NRC in the form of a complete, legible opy of thE~ entire ODCM as a part of or concurrent with the Radioactive Effluet 3 / Release Report for the period of the report in which any change in e ODCM was made. Each change shall be identified by markings in t margin of the affected pages, clearly indicating the area of the page th was changed, and shall indicate the date (i.e., month and year) the cha ge was implemented. manager, pre-designated alternate, or a pre-designated manager to whom the plant manager has assigned in writing OTS _ the responsibility for review and approval of specific subjects, WOG STS 5.5 - 1 Rev. 2, 04/30/01 9

l Rev. 2 Change D-4 & D-5 BVPS ISTS Conversion 5.0 Administrative Controls Enclosure 1 Changes to ISTS; ITS S.OAdministrative Controls JUSTIFICATION FOR DEVIATION (JFD)

1. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis (CTS). ISTS paragraphs are renumbered to provide a letter or number designation for each individual paragraph to be more consistent with other Section 5 programs.

2. The second paragraph of ISTS 5.1.1 states that the plant manager of his designee shall approve, prior to implementation, each proposed test, experiment or modification by system or equipment that affect nuclear safety. The BVPS Units I and 2 CTS do not include this requirement. The requirement for approval of tests, experiment or modifications is adequately controlled by BVPS administrative procedures and need not be included in the BVPS ITS.

3. ISTS 5.1.2 specifies requirements for the control room command function. The BVPS Units 1 and 2 CTS do not include these requirements. The ISTS administrative control requirement was not adopted in the BVPS ITS based on the current licensing basis and due to the sufficient existing federal regulations that address plant staffing and command and control requirements. Specifically 10 CFR 50.54(K)(1) states:

        'The licensee shall designate individuals to be responsible for directing the licensed activities of licensed operators. These individuals shall be licensed as senior operators pursuant to part 55 of this chapter."

In addition, 10 CFR 50.54(m)(2)(iii) states:

        "When a nuclear power unit isinan operational mode other than cold shutdown or refueling, as defined by the unit s technical specifications, each licensee shall have a person holding a senior operator license for the nuclear power unit inthe control room at all times. Inaddition to this senior operator, for each fueled nuclear power unit, a licensed operator or senior operator shall be present at the controls at all times."

And 10 CFR 50.54(K) states:

       "An operator or senior operator licensed pursuant to part 55 of this chapter shall be present at the controls at all times during the operation of the facility'".

The ISTS command and control specification does not add significantly to the requirements of the regulations stated above. The ISTS specification contains a recommended method using specific plant titles for implementing the command and control requirement of 10 CFR 50.54(K)(1). However, it does not affect the regulation requirement that an SRO must be in charge (regardless of job title). In addition, the federal regulations include explicit staffing requirements (i.e., 10 CFR 50.54(K) and 10 CFR 50.54(m)(2)(iii)) which reinforce the requirement to have an SRO in the control room and a licensed operator at the controls. The existing regulations regarding control room staffing and command are sufficiently clear to provide adequate guidance for safe plant operation. The day to day details regarding control room staffing and command are controlled within the appropriate plant procedures. The guidance provided by the federal regulations is adequate to develop appropriate implementing procedures that assure the safe operation of the plant. BVPS Units 1 and 2 Page 1 Revision 2,4/06 2/05 57

I Rev. 2 Change D4 l rITS5.5 _ 44INISTRATIVE CONTROLS I __

    '.5.1 1
     *6.14       OFFSITE DOSE CALCULATION MANUAL (ODCM)                              INSERT Paragraphs a. and b. from (TS c.J       b Changes   to the ODCM:                                      Section 1.0, ODCM definitbn IIa m.           Shall be documented and records of reviews performed shall be retained in accordance with the applicable record retention     provision of the quality assurance                      program (LAB              descript'in inidl        in thp Updatwd Final             Sfety Analys T     Adz.lj:  This documentation shall contain:E r   ODCMr             Sufficient information to support the chang, together with the appropriate analyses or evaluations justifying I

the change(s) and s IY1- -) A determination that the change will maintain the level of radioactive effluent control required by 10 CFR 20.1302, 40 CFR Part 190, 10 CFR 50.36a, and Appendix I to 10 CFR Part 50 and not adversely impact the accuracy or reliability of effluent, dose, or setpoint [<2 OR calculations. S Sall become effective afterf[review and acceptance by t : Il w andlthe approval of the plant manager, precdesignatied Le e or a predesignated manager to whom the plant manager has assigned in writing the responsibility for E review and approval of specific sujcs [ODC Shall be submitted to the in the form of a complete, legible copy of the entire ODCM as a part of or concurrent with the Annual- Radioactive Effluent Release 3 Report for the period of the report in which any change to the ODCM was made. Each change shall be identified by markings in the margin of the affected pages, clearly indicating the area of the page that was changed, and shall indicate the date (e.g., month ear) the change was r 5! z implemented. L I \and 6.16 Meved to the PROCESC CONTROL PROGRAM. CONTAINMENT LEAKAGE RATE TESTING PROGRAM 1512.aI np program shall be established to implement the leakage rate testing of the containment as required by 10 CFR 50.54 (o) and 10 CFR 50, Appendix J, Option B, as modified by approved exemptions+.A_11isr program shall be in accordance with the guidelines contained in Regulatory Guide 1.163, "Performance-Based Containment Leak-Test Program," dated September 1995, except that the next Type A test performed after the November 10, 1993 Type A test shall be performed no later than November 9, 2008. (4) lExemptions to Appendix J of 10 CFR 50, as stated in I~he[- I nnrAtinn 1iopnqpI BEAVER VALLEY - UNIT 2 6-25 Amendment No. 134 84

I Rev. 2 Change D-4 l DEFINITIONSl CTS Page for ITS 5.5.1 (ODCM) part a andb A radiological L 'JFFSI E DOSE CALCULAI MANUAL (ODCM) and 1.30-- The OFFSITE DO E CALCULATION MANU (ODCM) shall con aT the methodology and param ters used in the ca culation of offsite oses resulting from radi ctive gaseous and liquid effluents, i the calculation of gase us and liquid eff ent monitoring Alarm Trip Setpoints, pnd in he conduct of the Radielegiea environmental gonitoring ram. The ODCM shall also contain (1) adioactive Affluent gontrols and XZadiological Anvironmental 'onitoring ts required by-Sczt-icn 6.-.6 and 4 descriptions of the i orration that should be included in the Annual Radiological En ironment:al Operating and Annual Radioactive Effluent Release Reports/required by Specification& in the, A4 inistrative Control section. gatvte l5.6.1 and Specification 5.6.2lII SEOUS RADWASTE TREATMENT SYSTEM 1.3 A GASEOUS RADWASTE TREATMENT SYSTEM is any system des led and i talled to reduce radioactive gaseous effluents by col cting Primary oolant System offgases from the primary system and oviding for dela or holdup for the purpose of reducing he total radioactivi prior to release to the environment. VENTILATION EXHA T TREATMENT SYSTEM 1.32 V, NOTE: These Definitions are contained in the Definition Section signed and instd (1.0) of the Tech Specs consistent with the location of these terial in parti requirements in the ISTS. Changes to this information is r vent exhaust c discussed and documented in Section 1.0 of the Tech Specs. or the purpose d--Xexhaust - stream prior to the release t the en ronment (such a system is not considered to have any effect n le gas effluents). Engineered Safety Feature (ESF) atmospheric eanup systems are not considered to be VENTILATION EXHAUST TREATM T YSTEM components. PURGE-PURGING 1.33 PURGE or PURGIN is the controlled p cess of discharging air or gas from a coninement to maintain mperature, pressure, humidity, concentra ion or other operating co itions, in such a manner that repl cement air or gas is requi d to purify the confinement. VENTING 1.34 ENTING is the controlled process of discharging aK or gas from confinement to maintain temperature, pressure hum dit y, con entration or other operating conditions, in such a manner hat rplacement air or gas is not provided or required during VENTIIq. ent, used in system names, does not imply a VENTING process. \ BEAVER VALLEY - UNIT 2 1-6 Amendment No. 101 88

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 CHANGE D-5 ITS 5.5.11, (Safety Function Determination Program or SFDP) , is revised to provide individual paragraph numbering. Appropriate numbers and letters are used to identify each sub-paragraph. This change was made to be more consistent with the paragraph numbering used in other parts of Section 5.0. The paragraph renumbering changes provide an enhanced organization of the final paragraphs that is more suitable for referencing in the applicable plant procedures. This change does not introduce any technical changes to the ITS or CTS. Affected Pages: The following Table(s) list the affected pages by type (i.e., ITS markup, CTS markup, etc.). In order to facilitate review by ITS section, a separate table is provided for each ITS section affected by the change. The page numbers listed are the ITS section specific consecutive numbers found in the lower right corner of each page. Note: Because the affected page(s) for each change were extracted from a complete ITS section electronic file, the electronic hyperlinks (created in the complete ITS section file) do not work in the collection of affected pages that follow this cover page. ITS SECTION 5.0 (ADMINISTRATIVE CONTROLS) INDEX OF AFFECTED PAGES ITS MARKUPS PAGES: 19 & 20 ITS JFDS PAGE: 57 ITS BASES MARKUPS No change ITS BASES JFDS No change CTS MARKUPS PAGES: 122 & 123 CTS DOCS No Change

I Rev. 2 Change D-5 I Programs and Manuals 5.!5 5.5 Programs and Manuals 5.5. Technical Specifications (TS) Bases Control Program This program provides a means for processing changes to the Bases of these 10 Technical Specifications.

a. Changes to the Bases of the TS shall be made under appropriate administrative controls and reviews.

b. Licensees may make changes to Bases without prior NRC approval provided the changes do not require either of the following:

1. A change in the TS incorporated in the license or

2. A change to the updated FSAR or Bases that requires NRC approval pursuant to 10 CFR 50.59.

c. The Bases Control Program shall contain provisions tpfnsuraihattha Bases are maintained consistent with the FSAR. 5.5.10.b.1 and 5.5.10.b.2,D 4N

d. Proposed changes that meet the criteria of Specification 5.5.14b above shall be reviewed and approved by the NRC prior to implementation.

Changes to the Bases implemented without prior NRC approval shall be provided to the NRC on a frequency consistent with 10 CFR 50.71 (e). Safety Function Determination Pro-ram (SFDP) 5.5.>IJ This program ensures loss of safety function is detected and appropriate actions MI taken. Upon entry into LCO 3.0.6, an evaluation shall be made to determine if loss of safety function exists. Additionally, other appropriate actions may be taken as a result of the support system inoperability and corresponding exception to entering supported system Condition and Required Actions. This program implements the requirements of LCO 3 0 6 The SFDP shall contain the following: IgiI Il Eve la- Provisions for cross train checks to ensure a loss of the capability to perform the safety function assumed in the accident analysis does not go F2. I undetected, LI-Nb- Provisions for ensuring the plant is maintained in a safe condition if a loss of Il I_- I function condition exists, LL+/-\. Provisions to ensure that an inoperable supported system's Completion Time is not inappropriately extended as a result of multiple support system inoperabilities, and WOG STS 5.5 - 11 Rev. 2, 04/30/01 19

Rev. 2 Change D-5 Programs and Manuals I 5.5 [E 5.5 Programs and Manuals (T) \1 Z' 5.5.46 Safety Function Determination Program (SFDP) (continued) 1 Other appropriate limitations and remedial or compensatory actions. E A loss of safety function exists when, assuming no concurrent single failu re, ad k asks n cncuirrent Ils nf nffidtp nDwer nr no rnnci irrent loss of nn-site diesel generator(s), a safety function assumed in the accident analysis cannot be \ Rev. 3 performed. For the purpose of this program, a loss of safety function may exist when a support system is inoperable, and: _ a- A required system redundant to the system(s) supported by the inoperable support system is also inoperable, or 9 b- A required system redundant to the system(s) in turn supported by the inoperable supported system is also inoperable, or A required system redundant to the support system(s) for the supported systems (a) and (b) above is also inoperable. I

    -~               The SFDP identifies where a loss of safety function exists. If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered. When a loss of safety function is caused by the inoperability of a single Technical Specification support system, the appropriate Conditions and Required Actions to enter are those of the support system.

Containment Leakage Rate Testing Proqram 5.5.4t1

                     << ONA]

a. Apr shall establish the leakage rate testing of the cont ent as required b CFR 50.54(o) and 10 CFR 50, Appendixption A, as modified by app d exemptions.

b. The maximum allowab ntainment leaka rate, La, at Pa, shall be [ ]% of containment air weight per da

c. Leakage rate acceptance crit

1. Containment le grate acceptance crt n is

1.0 L.. During the first unit stfollowing testing in accordance h this program, the leaka e acceptance criteria are < 0.60 L. for th pe B and C teHand <0.75 La for Type A tests.

Air lock testing acceptance criteria are: WOG STS 5.5 - 12 Rev. 2, 04/30/01 20

Rev. 2 Change D-4 & D-5 BVPS ISTS Conversion 5.0 Administrative Controls Enclosure I Changes to ISTS, ITS 5.0 Administrative Controls JUSTIFICATION FOR DEVIATION (JFD)

1. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis (CTS). ISTS paragraphs are renumbered to provide a letter or number designation for each individual paragraph to be more consistent with other Section 5 programs.

2. The second paragraph of ISTS 5.1.1 states that the plant manager of his designee shall approve, prior to implementation, each proposed test, experiment or modification by system or equipment that affect nuclear safety. The BVPS Units 1 and 2 CTS do not include this requirement. The requirement for approval of tests, experiment or modifications is adequately controlled by BVPS administrative procedures and need not be included in the BVPS ITS.

3. ISTS 5.1.2 specifies requirements for the control room command function. The BVPS Units I and 2 CTS do not include these requirements. The ISTS administrative control requirement was not adopted in the BVPS ITS based on the current licensing basis and due to the sufficient existing federal regulations that address plant staffing and command and control requirements. Specifically 10 CFR 50.54(K)(1) states:

         "The licensee shall designate individuals to be responsible for directing the licensed activities of licensed operators. These individuals shall be licensed as senior operators pursuant to part 55 of this chapter."

In addition, 10 CFR 50.54(m)(2)(iii) states:

         "When a nuclear power unit is inan operational mode other than cold shutdown or refueling, as defined by the unit's technical specifications, each licensee shall have a person holding a senior operator license for the nuclear power unit inthe control room at all times. Inaddition to this senior operator, for each fueled nuclear power unit, a licensed operator or senior operator shall be present at tie controls at all times."

And 10 CFR 50.54(K) states:

        "An operator or senior operator licensed pursuant to part 55 of this chapter shall be present at the controls at all times during the operation of the facility".

The ISTS command and control specification does not add significantly to the requirements of the regulations stated above. The ISTS specification contains a recommended method using specific plant titles for implementing the command and control requirement of 10 CFR 50.54(K)(1). However, it does not affect the regulation requirement that an SRO must be in charge (regardless of job title). In addition, the federal regulations include explicit staffing requirements (i.e., 10 CFR 50.54(K) and 10 CFR 50.54(m)(2)(iii)) which reinforce the requirement to have an SRO in the control room and a licensed operator at the controls. The existing regulations regarding control room staffing and command are sufficiently clear to provide adequate guidance for safe plant operation. The day to day details regarding control room staffing and command are controlled within the appropriate plant procedures. The guidance provided by the federal regulations is adequate to develop appropriate implementing procedures that assure the safe operation of the plant. BVPS Units 1 and 2 Page 1 Revision 2, 4/06 57

Rev. 2 Change D-5 INSERTS FOR CTS 6.0 MARKUP INSERT 1 5.5.3 Component Cyclic or Transient Limit This program provides controls to track UFSAR Table 4.1-10 (Unit 1) and UFSAR Table 3.9N-1 (Unit 2), cyclic and transient occurrences to ensure that components are maintained within the design limits. INSERT 2 5.5.11 Safety Function Determination Program (SFDP) This program ensures loss of safety function is detected and appropriate actions taken. Upon entry into LCO 3.0.6, an evaluation shall be made to determine if loss of safety function exists. Additionally, other appropriate actions may be taken as a result of the support system inoperability and corresponding exception to entering supported system Condition and Required Actions. This program implements the requirements of LCO 3.0.6.

a. The SFDP shall contain the following:

1. Provisions for cross train checks to ensure a loss of the capability to perform the safety function assumed in the accident analysis does not go undetected,

2. Provisions for ensuring the plant is maintained in a safe condition if a loss of function condition exists,

3. Provisions to ensure that an inoperable supported system's Completion Time is not inappropriately extended as a result of multiple support system inoperabilities, and

4. Other appropriate limitations and remedial or compensatory actions.

b. A loss of safety function exists when, assuming no concurrent single failure, and assuming no concurrent loss of offsite power, or no concurrent loss of onsite diesel generator(s), a safety function assumed in the accident analysis cannot be performed. For the purpose of this program, a loss of safety function may exist when a support system is inoperable, and:

1. A required system redundant to the system(s) supported by the inoperable support system is also inoperable, or

2. A required system redundant to the system(s) in turn supported by the inoperable supported system is also inoperable, or

3. A required system redundant to the support system(s) for the supported systems (a) and (b) above is also inoperable.

122

Rev. 2 Change C-6 & D-5

c. The SFDP identifies where a loss of safety function exists. If a loss of safety 0D-5 function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered. When a loss of safety function is caused by the inoperability of a single Technical Specification support system, the appropriate Conditions and Required Actions to enter are those of the support system.

INSERT 3 5.5.13 Battery Monitoring and Maintenance Program This Program provides for battery restoration and maintenance, based on [the recommendations of IEEE Standard 450-1995, "IEEE Recommended Practice for Maintenance, Testing, and Replacement of Vented Lead-Acid Batteries for Stationary Applications," or of the battery manufacturer} including the following:

a. Actions to restore battery cells with float voltage < 2.13 V, and

b. Actions to equalize and test battery cells that had been discovered with electrolyte level below the minimum established design limit.

INSERT 4 5.5.9 Diesel Fuel Oil Testing Program A diesel fuel oil testing program to implement required testing of both new fuel oil arid stored fuel oil shall be established. The program shall include sampling and testing requirements, and acceptance criteria, all in accordance with applicable ASTM Standards. The purpose of the program is to establish the following: INSERT 5 5.6.5 Post Accident Monitoring Report When a report is required by Condition B or F of LCO 3.3.3, "Post Accident Monitoring (PAM) Instrumentation," a report shall be submitted within the following 14 days. The report shall outline the preplanned alternate method of monitoring, the cause of the inoperabifity, and the plans and schedule for restoring the instrumentation channels of the Function to OPERABLE status. 123

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 169 (UNIT 2) REVISION 2 CHANGE D-6 ITS Table 3.3.7-1, Function 2, Control Room Radiation, Control Room Area Monitors, is simplified to read "Control Room Area Radiation Monitors". This is an editorial change to simplify the title of this instrument function on Table 3.3.7-1. No values specified on Table 3.3.7 are changed and the radiation monitors referred to remain the same. Thus, this change does not introduce a technical change to the ITS or CTS. Affected Panes: The following Table(s) list the affected pages by type (i.e., ITS markup, CTS markup, etc.). In order to facilitate review by ITS section, a separate table is provided for each ITS section affected by the change. The page numbers listed are the ITS section specific consecutive numbers found inthe lower right corner of each page. Note: Because the affected page(s) for each change were extracted from a complete ITS section electronic file, the electronic hyperlinks (created in the complete ITS section file) do not work in the collection of affected pages that follow this cover page. ITS SECTION 3.3B (REMAINDER OF INSTRUMENTATION) INDEX OF AFFECTED PAGES ITS MARKUPS PAGE: 21 ITS JFDS No change ITS BASES MARKUPS No change ITS BASES JFDS No change CTS MARKUPS No change CTS DOCS No Change

Rev. 2 Change D-6 CRE Actuation Instrumentation

                                                                                                       ' 2                  3.3.7 Table 3.3.7-1 (page 1 of 1)

CRElkS Actuation Instrumenta FUNCTION APPLICABLE MODES OR OTHER SPECIFIED REQUIRED SURVEILLANCE CONDITIONS CHANNELS REQUIREMENTS TRIP SETPOINT 1, 2,3,4,fI 2trains SR 34A _ (a) ad _ 1123,4 fJrl \ 21ra~ins Il ( 8 b. Control RoomAirIntaes 6m 3 . Refer to LCO 3.3.2, ESFAS Instrumentation,' Function r all initiation r lContainment Isolation - Phase B functions and requirements. D ( (a) During movement of (recenty) irradiated fuel assemblies, I l and during movement of fuel assemblies over recently irradiated fuel assemblies. k

                                                                                                                   -,U9 WOG STS                                                    3.3.7 - 4                                   Rev. 2, 04/30/01 21

BVPS U1NITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 CHANGE D-7 The ITS Insert 6 for ITS 5.5.12 (Containment Leakage Rate Testing Program) Paragraphs 2.b and 2.c (addressing air lock leakage limits) are revised to replace the 'less than" symbol with the 'less than or equal to" symbol for the La value specified for the air lock leakage criteria . The designation for La is also revised in these paragraphs to use a subscripted "a". These changes make the L. values proposed in the IT'S the same as the CTS values as was originally intended. This change fixes typographical errors in the Enclosure 1 insert page that inadvertently changed the CTS values from 'less than or equal to" to 'less than". The CTS markups of the air lock leakage requirements (CTS 4.6.1.3) associated with ITS 5.5.12 (Containment Leakage Rate Testing Program) are also revised to more clearly label the air lock leakage requirements in CTS 4.6.1.3 as being moved into the containment leakage rate testing program (ITS 5.5.12). These changes correct a typographical error and provide an enhanced CTS markup to better roadmap the CTS changes for future reference. These revisions do not introduce a technical change to the affected CTS requirements being incorporated into the ITS. These changes only affect pages in ITS Section 5.0 (Administrative Controls). Affected Pages: The following Table(s) list the affected pages by type (i.e., ITS markup, CTS markup, etc.). In order to facilitate review by ITS section, a separate table is provided for each ITS section affected by the change. The page numbers listed are the ITS section specific consecutive numbers found in the lower right corner of each page. Note: Because the affected page(s) for each change were extracted from a complete ITS section electronic file, the electronic hyperlinks (created in the complete ITS section file) do not work in the collection of affected pages that follow this cover page. ITS SECTION 5.0 (ADMINISTRATIVE CONTROLS) INDEX OF AFFECTED PAGES ITS MARKUPS PAGE: 50 ITS JFDS No change ITS BASES MARKUPS No change ITS BASES JFDS No change CTS MARKUPS PAGES: Unit 2 86 &110. Unit 1- 111 CTS DOCS No Change

I Rev. 2 Change D-7 S Section 5.0 Inserts Jiktj Insert 6 for Section 5.5.12 b) For each emergency air lock door, no detectable seal leakage when gap between door seals is pressurized to 2 10 psig or door seal leakage quantified to ensure emergency air lock door seal leakage rate is s 0.0005 La when tested at 2 10 psig. Il c) For each personnel air lock door, no detectable seal leakage when gap between door seals is pressurized to 2 Pa or door seal leakage quantified to ensure personnel air lock door seal leakage rate is s 0.0005 La when tested at 2 Pa. Insert 7 for Section 5.6.3 SL 2.1.1, 'Reactor Core Safety Limits" LCO 3.1.1, "SHUTDOWN MARGIN (SDM)" LCO 3.1.3, 'Moderator Temperature Coefficient (MTC)" LCO 3.1.5, 'Shutdown Bank Insertion Limits" LCO 3.1.6, 'Control Bank Insertion Limits" LCO 3.2.1, 'Heat Flux Hot Channel Factor (Fc(Z))" LCO 3.2.2, 'Nuclear Enthalpy Rise Hot Channel Factor (FNOH)' LCO 3.2.3, "Axial Flux Difference (AFD)" LCO 3.3.1, "Reactor Trip System (RTS) Instrumentation - Overtemperature and Overpower AT Allowable Value parameter values LCO 3.4.1, 'RCS Pressure, Temperature, and Flow Departure from Nucleate Boiling (DNB) Limits" LCO 3.9.1, 'Boron Concentration" Section 5.0 Inserts Page 18 50

I --. - I Rev. A fl.._.

                          ^          f   -0 A nange D-I &^lA-O     I                 TS5 lAl ADMINISTRATIVE CONTROLS

[H 1 2 ]ONTAINMENT LEAKAGE RATE TESTING PROGRAM (Continued) The peak calculated containment internal pressure for the design basis loss of coolant accident, P., is 44.9 psig. The maximum allowable containment leakage rate, L., at P., shall be EI3i2.]0.l0% of containment air weight per day. Leakage Rate acceptance criteria are: A25 priortoMODE4entry

a. Containment leakage rate acceptance criterion *s _-.0-4-.

for the overall Type- cacg test-and _ n.O L for It -.-e these' Technican Pfp B and Type C tests en a minimum pathway alrag-Speciicationsshallbe RRIPLR) basis. During the first unit startupT following constnued to modify the testing in accordance with this program, the leakage rate testing Frequencies acceptance criteria are < 0.60 L. on a maxfimum pathway required by 10 CFR50, l5akage rate (MXPLTR) basis for Type B and Type C tests AppenldixJ. _ nd -0.75 for Type A tests. InsertUnit2Airlock Criteri3

                                                                       *0.75 La               From CTS 3.6.1.3_
           \           b         .Air lock testing acceptance criteria and required acti.on                                   I D-7
                         \ are as stated in Specification 3.6.1.3 titled "ContainmentJ{

tA6 lAir Locks." The provi lfrequencies specified ecification in 4.0.2 do Leakage o the Rate Testinl t ( ceroram.

       --.he       provisions of Specificatio n 4.A.                        are     aplicable                to      the Containment Leakage Rate Testing Program.                                       Insert ISR303Unit 1 Air lock Criteria From CTS 3.6.1.3 6.18 TECHNICAL SPECIFICATIONS                   (TS) BASES CONTROL PROGRAM This program provides a means for processing changes to the Bases of these Technical Specifications.

a. Changes to the Bases of the TS shall be made under appropriate administrative controls and reviews.

b. Licensees may make changes to Bases without prior NRC approval provided the changes do not require either of the following:

1. a change in the TS incorporated in the license; or 7

(p ns which are isolated by use of e vves ] blind flange(s), ta IC valve(s), the MXPLRPI of the isolated e n med to be the measured 4k leaka e isolation device(s). BEAVER VALLEY - UNIT 2 6-26 Amendment No. 153 k-6 86

I Rev. 2 Change D-7 & A-6 I Unit 2 CTS page forITS 5.5.12 D-7 CONTAINMENT SYSTEMS IContainment Leakage Rate Testing Program i140>' SURVEILLANCE REQUIREMENTS Li1

           .6.1.3                        tainment air lock shall be demonstr                                                  LE NOTE: These requirements are contained in the Containment Systems section 3.6.2) of the Tech Specs consistent with the location of l these requirements In the ISTS. Changes to this Information Is discussed and documented In Section 3.6 of the Tech Specs.

ting Program: Verify no detectable seal leakaqe when the gap between li5.5.12A.21) & 7 the door seals is pressurized for at least 2 minus i 5.5.12.d.2.c)l to: a) Personnel air lock 2 Pa (44.9 psig). ' A(3 CLRTP/ b) Emergency air lock 2 10.0 psig. or, quantif the air lock door seal leakage t ensure that the leakage rate is

0.0005 La when tested at 2 Pa (44.9 psig) for the personnel air lock and
0.0005 La when tested at 2 10.0 psig for the emergency air lock.

l 5.5.12.d.2.a) l Conduct the overall air lock leakage tests,~Fa ta (44.9 psig), and verify the overall air lock leakag rate is

0.05 La when tested at 2 Pa (44.9 psig):

a) At the frequency specified in the Containp Leakage Rate Testing Program, and / b) Following maintenance performed te o e:er personnel air lock door which result *n a ecrease in closure force on part of the door se ing surface. NOTE: These requirements are contained in the Containment Systems section (3.6.2) of the Tech Specs consistent with the location of these requirements in the ISTS. Changes to this information is discussed and documented in Section 3.6 of the Tech Specs. (7) An inope e air lock door does not inva the previous succe ul performance of the overall air lock leaka test. (8) ults shall be evaluated against the acceptance c :ia applicable to LCO 3.6.1.2. BEAVER VALLEY - UNIT 2 3/4 6-5a Amendment No. 15-. A-6 I 110

Rev. 2 Change D-7 & A-6 lUNIT I CONTAINMENT SYS T Unit I CTSpage forITS 5.5.12 (Z) Containment Leakage Rate Testing Program F E~QUIREMENTS IOTE: These requirements are contained Inthe Containment Systems section (3.6.2) of the Tech Specs consistent with the ocation of these requirements In the ISTS. Changes to this Information Is discussed and documented InSection 3.6 of the 'ech Specs. testing at tne trequency speciriei in tner nt

                            -Leakage Rate Testing Program-i--      Verify no detectable                seal     leakage    when t            tan 5.5.12.d2b)&           between the door seals                    is   pressurized for -

55.12.d.2.c) Ileast 2 minutes to: a) Personnel air lock > Pa (43.3 psig). CL-t i b) Emergency air lock > 10.0 psig. or, quantifyX the air lock door seal leakage to ensure that the leakage rate is < 0.0005 L. when tested at > Pa (43.3 psig) for the personnel air lock and < 0.0005 La when tested at > 10.0 psig for the emergency air lock. G-- Conduct the overall air lock leakage testsJg at 12Fd2) l_> Pa (43-3 psig), and verify the overall air I lock leakage rate is < 0.05 La when tested at 2 Pa (43.3 psig): a) At the trequency specitied in Containment Leakage Rate Testing Pro m, and b) Following maintenance per ed on the outer personnel air lo door which may result in a decreas in closure force on NOTE: These requirements are contained in the Containment Systems section (3.6.2) of the Tech Specs consistent with the location of these requirements in the ISTS. Changes to this information is discussed and documented inSection 3.6 of the Tech Specs. (7) An moper air lock door does not invalid the previous succ 1 performance of the overall air lock leaka est. (8) ults shall be evaluated against the acceptance c iri a applicable to LCO 3.6.1.2. BEAVER VALLEY - UNIT 1 3/4 6-5b Amendment No.271 l A4 111

ERBVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) NoS. 296 (UNIT 1) & 169 (UNIT 2) REVISION Z CHANGE D-8 The Bases for ITS 3.8.3 Required Action E.1 is revised to change the "greater than" symbol associated with the air receiver pressure value to a 'greater than or equal to" symbol consistent with the associated technical specification values used in Condition E for the lower pressure limit specified in that Condition for a single DG start. This change only makes the Bases consistent with the associated ITS requirement. The change does not introduce a technical change to the requirements originally specified in the BVPS ITS. The change only affects the Bases of ITS 3.8.3. Affected Pages: The following Table(s) list the affected pages by type (i.e., ITS markup, CTS markup, etc.). In order to facilitate review by ITS section, a separate table is provided for each ITS section affected by the change. The page numbers listed are the ITS section specific consecutive numbers found in the lower right corner of each page. Note: Because the affected page(s) for each change were extracted from a complete ITS section electronic file, the electronic hyperlinks (created in the complete ITS section file) do not work inthe collection of affected pages that follow this cover page. ITS SECTION 3.8 (ELECTRICAL POWER SYSTEMS) INDEX OF AFFECTED PAGES ITS MARKUPS No change ITS JFDS No change ITS BASES MARKUPS PAGE: 109 ITS BASES JFDS No change CTS MARKUPS No change CTS DOCS No Change

Diesel Fuel Oil, Lube Oil, and Starting Air Rev. 2 Change D-8 B 3.8.3 BASES ACTIONS (continued) performance has been recently demonstrated (within days), it is prudent to allow a brief period prior to declaring the associated DG inoperable. The 7 day Completion Time allows for further evaluation, resampling and re-analysis of the DG fuel oil. (3 D.1 < With the new fuel oil properties defined in the Bases for SR not within the required limits, a period of 30 days is allowed for restoring the stored fuel oil properties. This period provides sufficient time to test the stored fuel oil to determine that the new fuel oil, when mixed with previously stored fuel oil, remains acceptable, or to restore the stored fuel oil properties. This restoration may involve feed and bleed procedures, filtering, or combinations of these procedures. Even if a DG start and load was required during this time interval and the fuel oil properties were outside limits, there is a high likelihood that the DG would still be capable

                    @    of performing its intended function.

With starting air receiver pressure < , sufficient capacity for five successive DG start attempts does not exist. However, as long as the 2 receiver pressu 25] psig, there is adequate capacity for at least psig for Unit 1, hempt, _125 and the DG can be considered OPERABLE while the and > 285 psig for air receiver pressure is restored to the required limit. A period of 48 hours Unit 2 is considered sufficient to complete restoration to the required pressure prior to declaring the DG inoperable. This period is acceptable based on the remaining air start capacity, the fact that most DG starts are accomplished on the first attempt, and the low probability of an event during this brief period. F.1 E With a Required Action and associated Completion Time not et, or one or more DG's fuel oil, lube oil, or starting air subsystem not ithin limits for reasons other than addressed by Conditions A through , the associated DG may be incapable of performing its intended function and must be immediately declared inoperable. WOG STS B 3.8.3 - 4 Rev. 2, 04/30/01 109

BVPS UNITS 1 & 2 1,,INI.lri ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 CHANGE D-9 The ESFAS (ITS 3.3.2) Bases text describing Surveillance Requirement 3.3.2.1 (Channel Check) has a typographical error. In the explanation of this surveillance the section discussing

          'agreement criteria" uses the word 'reliability" instead of 'readability." All other Channel Check surveillance Bases (e.g., SR 3.3.1.1) use the term readability not reliability in this discussion.

BVPS has revised the Bases for this surveillance to be consistent with the other Bases describing the same surveillance. This change will make the ESFAS channel check Bases consistent with other channel check bases (e.g., RTS) in the ITS. This change only affects the Bases of Section 3.3C (ESFAS). Affected Pages: The following Table(s) list the affected pages by type (i.e., ITS markup, CTS markup, etc.). In order to facilitate review by ITS section, a separate table is provided for each ITS section affected by the change. The page numbers listed are the ITS section specific consecutive numbers found inthe lower right corner of each page. Note: Because the affected page(s) for each change were extracted from a complete ITS section electronic file, the electronic hyperlinks (created inthe complete ITS section file) do not work in the collection of affected pages that follow this cover page. ITS SECTION 3.3C (ESFAS) INDEX OF AFFECTED PAGES ITS MARKUPS No change ITS JFDS No change ITS BASES MARKUPS PAGE: 73 ITS BASES JFDS PAGE: 82 CTS MARKUPS No change CTS DOCS No Change

ESFAS Instrumentationi I Rev. 2 Change D-9 B 3.3.2 BASES SURVEILLANCE REQUIREMENTS (continued) similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the two instrument channels could be an indication of excessive instrument drift in one of the channels or of something even more serious. A CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION. readability Agreement criteria are determined by the unit staff, based on a Combination of the channel instrument uncertainties, including indication an& a. If a channel is outside the criteria, it may be an indication I that the sensor or the signal processing equipment has drifted outside its limit. The Frequency is based on operating experience that demonstrates channel failure is rare. The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of the displays associated with the LCO required channels. SR 3.3.2.2 SR 3.3.2.2 is the performance of an ACTUATION LOGIC TEST. The SSPS is tested every 31 days on a STAGGERED TEST BASIS, using the semiautomatic tester. The train being tested is placed in the bypass condition, thus preventing inadvertent actuation. Through the semiautomatic tester, all possible logic combinations, with and without applicable permissives, are tested for each protection function. In addition, the master relay coil is pulse tested for continuity. This verifies that the logic modules are OPERABLE and that there is an intact voltage signal path to the master relay coils. The Frequency of every 31 days on a STAGGERED TEST BASIS is adequate. It is based on industry operating experience, considering instrument reliability and operating 3 history data. N/A to BVPS SR 3.3.2.3 is the p ance of an ACTUATION L EST as described in SR 3.3.2.2, e at the se matic tester is not used and the continuity check does not e performed, as explained in the Note. This SR is ap othe balanc t actuation logic and relays that do no ehe SSPS test circuits instale lize the semiautester ic or perform the continuity check. This te WOG STS B 3.3.2 - 47 Rev. 2, 04/30/01 73

I Rev.2ChangeA-5 &D-9 I BVPS ISTS Conversion 3.3C ESFAS Instrumentation Enclosure 2 Changes to The ISTS Bases ITS 3.3.2 Engineered Safety Feature Actuation System Instrumentation Bases JUSTIFICATION FOR DEVIATION (JFD)

1. This JFD addresses all changes made to the Bases that are editorial in nature or to correct D-9 minor typographical errors that do not affect the technical content of the Bases. The changes addressed by this JFD are made to correct spelling, grammar, and capitalization errors as well as incorporate wording preferences. In some cases, these changes are necessary to make the descriptions of reference content correct (e.g., the content of the BVPS UFSARs may not be exactly the same as described in the ISTS Bases) or to make the actual location of information discussed correct for BVPS (e.g., the location of trip setpoints outside of the TS or the location of the list of the number of required channels for each ESFAS Function). The reasons for the changes addressed by this JFD are considered self-explanatory and a separate more detailed explanation unnecessary. These changes do not significantly impact the technical discussions contained in the Bases and in general improve the clarity or correctness of the affected text or make the text more specific to BVPS. As such, the proposed changes are acceptable.

2. Changes are made to the ISTS Bases to reflect the BVPS specific setpoint methodology and changes introduced by Amendment numbers 270 Unit 1 and 152 (Unit 2). These Amendments introduced Notes to the COT and Channel Calibration SRs that affect the definition of the LSSS for certain ESFAS Functions. The BVPS trip setpoints associated with the ESFAS Functions are nominal values with a calibration tolerance. The nominal trip setpoints are specified in the Licensing Requirements A-5 Manual not the TS. The BVPS Allowable Value is determined by the nominal trip setpoint calibration tolerance. The BVPS ESFAS Function operability is determined by verifying the Function is within the specified Allowable Value (setpoint calibration tolerance). The changes associated with this .JFD are required to maintain consistency with the current BVPS setpoint methodology and the current BVPS licensing basis as modified by Amendment numbers 270 and 152.

3. The standard bases text is deleted or revised to make the generic bases discussion more accurate or complete for BVPS. The proposed revisions include changes resulting from revisions to the corresponding TS requirements that are justified in the associated JFDs for the TS. The proposed changes also include additional or revised references, additional or revised design or safety analysis descriptions that make the standard bases discussion more specific to the corresponding BVPS documentation, design, safety analyses, or licensing basis. In some cases, additional information is added that was moved from the CTS or that is consistent with the existing CTS Bases. The proposed changes enhance the ISTS Bases discussion and help to make the generic bases text more specific to each BVPS Unit.

4. The ISTS Bases text is revised to remove the details of specific instrument locations in the plant. This level of detail is not necessary in the TS bases to understand the purpose of the ESFAS Function or to determine the ESFAS Function operability. As this information was not included in the RTS Bases, the proposed change makes the level of detail in the RTS and ESFAS Bases more consistent. In addition, the TS are not intended to control the details of the plant design and this type of design information is contained in other more BVPS Units I & 2 Page 1 Revision 2,4/06 82

v XBVPS UNITS 1 & 2 k- ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) NOS. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 CHANGE D-10 The ESFAS (ITS 3.3.2) Bases for ITS Action Condition G is revised to include the same discussion as ITS Action Condition C. Both these Actions pertain to inoperable trains of Actuation Logic and actuating relays and have very short Completion Times. The additional text added to Condition G describes the applicable circumstances and ability to declare a single affected component or system inoperable instead of remaining in the relatively short Completion Time for an Action Condition addressing the failure of the actuation logic or relays associated with an entire ESFAS train. The proposed change provides the same Bases clarification for Action Condition G as has been previously incorporated into the Bases for Action Condition C. Affected Pages: The following Table(s) list the affected pages by type (i.e., ITS markup, CTS markup, etc.). In order to facilitate review by ITS section, a separate table is provided for each ITS section affected by the change. The page numbers listed are the ITS section specific consecutive numbers found in the lower right corner of each page. Note: Because the affected page(s) for each change were extracted from a complete ITS section electronic file, the electronic hyperlinks (created in the complete ITS section file) do not work in the collection of affected pages that follow this cover page. ITS SECTION 3.3C (ESFAS) INDEX OF AFFECTED PAGES ITS MARKUPS No change ITS JFDS No change ITS BASES MARKUPS PAGE: 68 ITS BASES JFDS PAGE: 84 CTS MARKUPS No change CTS DOCS No Change

ESFAS Instrumentation B 3.3.2 I Rev. 2 Change D-10 l BASES ACTIONS (continued) a Loss of Offsite Power, D.. O.42 _A..l_.

                                             -A~~      To .....

1-- - AdC..-._ D-_.- _ - iNux0iiar; Peccu~-aWp 1-'umP auctHon I Hni~tUF UH alUCIIOf PrFUb5UF0 Lyw. and

P-4 Interlock.

For the Manual Initiation and the P4 Interlock Functions, this action addresses the train orientation of the SSPS. For the Loss of Offeite D-.-r FCm-C-^ thic -M;-o rea

                                                                              .... oc  th-#k 1-V of            -IWn rr   vEc;n 10                         _"'                 u           I..      lWB 1 W la h a     ---11to-lud 21       vIUVll IO for a failed channel.              the
                                                                        .r AFW System pump suction tranrfer channels, this action r oFGngqiZos that placigi a failed channel in tr;p durin.3 operation is not necessarily a onservative action. Spurious trip of this f.-n.tion cou-Idalin th.. AMAI Sv                n in a n.rc that-is .not im. edii.f.l.

capable of supporting pump sGutien. If a train or channel is inoperable, 48 hours is allowed to return it to OPERABLE status. The specified Completion Time is reasonable considering the nature of these Functions, the available redundancy, and the low probability of an event occurring This Action Condition is intended during this interval. If the Function cannot be returned to OPERABLE to address an inoperability of the status, the unit must be placed in MODE 3 within the next 6 hours and actuation logic or relays MODE 4 within the following 6 hours. The allowed Completion Times are associated with an ESFAS train reasonable, based on operating experience, to reach the required unit that affects the integrated ESFAS response to an actuation conditions from full power in an orderly manner and without challenging signal. The relatively short unit systems. In MODE 4, the unit does not have any analyzed transients Completion Time of this ACTION or conditions that require the explicit use of the protection functions noted (6 hours) is based on the above. assumption that multiple ESF components within a train are G.1. G.2.1. and G.2.2 affected by the failure of the actuation logic or relays. The efore, the short Completion Condition G applies to the automatic actuation logic and actuation relays Time} of this Action is appropriate for the Steam Line Isolation [,Turbine Trip and Feedwater lsolationfand and applicable whenever more AFW actuation Functions. than one ESF system is affected by the inoperable train of logic or I The action addresses the train orientation of the SSPS and the master relays. and slave relays for these functions. If one train is inoperable, 6 hours However, If one or more are allowed to restore the train to OPERABLE status. The Completion inoperable actuation relays In an ESFAS train only affect a Time for restoring a train to OPERABLE status is reasonable considering sinG le ESF component or that there is another train OPERABLE, and the low probability of an event system, the applicable occurring during this interval. If the train cannot be returned to Actions Condition for the OPERABLE status, the unit must be brought to MODE 3 within the next affe :ted ESF component or system should be entered and 6 hours and MODE 4 within the following 6 hours. The allowed the relatively short Completion Times are reasonable, based on operating experience, to Con ipletion Time of this reach the required unit conditions from full power conditions in an orderly Action Condition is not app -opriate or applicable. WOG STS B 3.3.2 - 42 Rev. 2, 04/30/01 68

Rev. 2 Change D-10 BVPS ISTS Conversion 3.3C ESFAS Instrumentation Enclosure 2 Changes to The ISTS Bases setpoint methodology are met provides the required assurance that the ESFAS setpointst are maintained operable and effectively encompasses the requirements of the deleted paragraph.

8. The Bases description of ISTS SR 3.3.2.11 is deleted consistent with the elimination of t'his surveillance from the corresponding ITS 3.3.2 in Enclosure 1. This surveillance is only applicable to the P4 interlock. The BVPS ITS assigns ITS SR 3.3.2.7 (ISTS SR 3.3.2.8) to the P-4 interlock instead of ISTS 3.3.2.11. See the JFD associated with the change to the corresponding surveillance requirement in the Enclosure I markup of ITS 3.3.2.

9. The response time surveillance bases is revised to reflect potential alternative response time testing methods with regard to testing instrument channels with time constants. The use of a step change input signal to verify the response time of a channel eliminates the need to set the time constants to one and results in the same response time whether the time constants are set to nominal values or one. This method may be used in some cases due to the difficulty in resetting certain time constants back to their nominal values following testing.

10. The ISTS Bases text for Action Conditions C and G are revised to incorporate a clarification regarding the applicability of the Action. These Actions address an inoperable train of ESFAS actuation logic or actuation relays. The Completion Time of 6 hours is a relatively short Action time intended to address the loss of a train of actuation logic or relays.

However, there are many actuation relays that must be addressed by this Action and thE' ISTS ESFAS Actions do not include an Action applicable to less than an entire train of actuation relays. In the course of surveillance testing or maintenance, it is likely that a single inoperable relay may be discovered that only affects a single ESF component or system. In this case, the application of the short Completion Time associated with the failure of an entire train of logic and relays would be overly conservative and inappropriate. The proposed clarification addresses this situation and directs the tech spec user to enter the applicable Actions of the affected ESF system or component instead of the Actions fzr an entire train of ESFAS logic and relays. The proposed clarification is reasonable and appropriate considering that if the affected ESF system or component were inoperable for reasons other than the actuating relay, substantially more time may be available in the Action Condition(s) applicable to that ESF component or system. In addition, the proposed clarification is similar to a Bases clarification approved by the NRC in the Farley Nuclear Plant ISTS conversion.

11. The ISTS Bases text describing ESFAS Function 5, Turbine Trip and Feedwater Isolation, is revised to remove redundant and unrelated text. The deleted paragraph seems to primarily describe other Si and P4 interlock functions. The SI function is fully described in the SI portion of the ESFAS bases and the P4 interlock is fully described inthe PA Bases (Function 8.a on ESFAS bases page 34).

The inclusion of this additional text describing Si and P4 Functions in the bases for the Turbine Trip and Feedwater Isolation Function is unnecessary to understand the Turbine Trip and Feedwater Isolation Function and potentially confusing as it gives the impression that the Turbine Trip and Feedwater Isolation Function also starts the AFW pumps. The elimination of this descriptive text does not introduce a technical change to the explanation of the Turbine Trip and Feedwater Isolation Function. BVPS Units 1 & 2 Page 3 Revis'on 2, 4/06 84

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 CHANGE D-1l This change revises ITS Surveillance Requirement 3.8.1.8.c (single largest load rejection test) from 3 seconds to 4 seconds for DG Frequency to stabilize after the load rejection. In the ISTS this time is bracketed allowing for a change. The ISTS Bases states that the requirements of this surveillance are based on Regulatory Guide 1.9. This change is also based on the latest RG 1.9 Rev 3 requirements for frequency during this test. RG 1.9, Rev. 3 Section 1.4 states that "Frequency should be restored to within 2 percent of nominal in less than 60 percent of each load-sequence interval for stepload increase and in less than 80 percent of each load-sequence interval for disconnection of the single largest load..." Thus, the Requlatory Guide allows more time for frequency to stabilize for load rejection tests. The proposed 4 second time limit represents 80 percent of the BVPS 5 second load sequence interval and is consistent with the recommendations of Regulatory Guide 1.9, Rev. 3 for this specific surveillance test. Affected Pages: The following Table(s) list the affected pages by type (i.e., ITS markup, CTS markup, etc.). In order to facilitate review by ITS section, a separate table is provided for each ITS section affected by the change. The page numbers listed are the ITS section specific consecutive numbers found in the lower right corner of each page. Note: Because the affected page(s) for each change were extracted from a complete ITS section electronic file, the electronic hyperlinks (created in the complete ITS section file) do not work in the collection of affected pages that follow this cover page. ITS SECTION 3.8 (ELECTRICAL POWER SYSTEMS) INDEX OF AFFECTED PAGES ITS MARKUPS PAGE: 10 ITS JFDS PAGE: 49A ITS BASES MARKUPS PAGES: 82 & 83 ITS BASES JFDS No change CTS MARKUPS PAGE: 191 CTS DOCS PAGE: 229

AC Sources - Operating I Rev. 2 Change D-11 & C-14 I 3.8.1 lis4;j/ SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE IFREQUENCY SR 3.8.1

                                                  - NOTES -

I NUREG-1431, e. 1 1. This Surveillance shall not normally be performed G8 in MODE 1 or 2. However, this Surveillance may Credit may be be performed to reestablish OPERABILITY taken for provided an assessment determines the safety of unplanned events the plant is maintained or enhanced.<that satisfy this SR.

2. If performed with the DG synchronized with offsite J____power, it shall be performed at a power factor

( O89 J s5 A4. However, if grid conditions do not permit, __l

                                                                                                                           >14 the power factor limit is not required to be met.

Under this condition the power factor shall be A : Hzv A maintained as close to the limit as practicable. 3_6.Hz___ Verify each DG rejects a load greater than or equal to {1 81 month its associated single largest post-accident load, and: / Values

a. Following load rejection, the frequency is

[63] Hz, _ 24106 V and s 4368 V (Unif)

b. Within f3] seconds following load rejection, the AMM voltage is ! [3710] V

c. WithinR seconds following load rejection, the frequency is [58.8]4z 4; and t2 PIz. IJ I H M58.8Hz and 61.2S Hz(Unit 2 CTS ]Values]

WOG STS 3.8.1 -7 Rev. 2, 04/30/01 10

Rev. 2 Change D-11 & C-14 BVPS ISTS Conversion 3.8 Electrical Power Systems Enclosure I Changes to IST',

21. ISTS SR 3.8.1.9 (ITS SR 3.8.1.8) verifies the capability of the DGs to recover from a transient consisting of the loss of the single largest load. The bracketed [ 3 1second time allowed for the frequency to recover in ITS SR 3.8.1 .8.c is revised to 4 seconds.

The Bases for this SR states that: 'The time, voltage, and frequency tolerances specified in this SR are derived from Regulatory Guide 1.9 (Ref. 3) recommendations for response during load sequence intervals. The 3 seconds specified is equal to 60% of a typical 5 second load sequence interval associated with sequencing of the largest load." D1 1 However, the latest Revision of Regulatory Guide 1.9 (Rev. 3) in Section 1.4 states that

         'Frequency should be restored to within 2 percent of nominal in less than 60 percent of each load-sequence interval for stepload increase and in less than 80 percent of each load-sequence interval for disconnection of the single largest load, and voltage should be restored to within 10 percent of nominal within 60 percent of each load-sequence time interval. The bracketed number (i.e., 3) specifying the frequency limit in ITS SR 3.8.1.8.c is based on 60% of a 5 second load sequence interval. However, ITS SR 3.8.1.8 specifies the disconnection of the DG's single largest load. Consistent with the guidance provided in Regulatory Guide 1.9, for the disconnection of the single largest load, the time allowed for restoration of the frequency is changed from 3 seconds to 4 seconds. The proposed 4 second time limit represents 80 percent of the 5 second load sequence interval and is acceptable as it is consistent with the recommendations of Regulatory Guide 1.9, Rev. 3 for this specific surveillance test.

22. The power factor requirement specified for ITS SRs 3.8.1.8 and 3.8.1.1 0 is revised to be C-14 more consistent with the BVPS worst case accident loading power factor. This changes the bracketed standard ISTS power factor of 0.9 to 0.89 for the BVPS ITS.

k4' BVPS Units 1 & 2 Page 6 Revision 2, 04/06 49A

AC Sources - Operating B 3.8.1 Debt Rev. 2 Change D-1 I BASES SURVEILLANCE RE QUIREMENTS (continued) M 1 or 2 is further amplified to allow the Surveillance to be perfoi' for the pOse of reestablishing OPERABILITY (e.g. post work ing following corre e maintenance, corrective modification, cient or incomplete surveil ne testing, and other unanticipa PERABILITY concerns) provided an a ssment determines pkt safety is maintained or enhanced. This assessme as a nimum, consider the Ihal, potential outcomes and transients tated with a failed Surveillance, a NUREG-1431, Rev.3 I successful Surveillance, and a ,urba of the offsite or onsite system *IQ when they are tied togeth operated inde ently for the Surveillance; as well he operator procedures a able to cope with edit may be these outcome ese shall be measured against the ided risk of a take or plant shu n and startup to determine that plant safety is tamed or unplann events enh d when the Surveillance is performed in MODE 1 or 2. Ri that sfy s *ights or deterministic methods may be used for this assessment. 1

                                                                                                                -   \

I,. X' SR 3.8.1-9

                  ~2         8~    EaichDG is provided with an engine overspeed trip to prevent damage to the engine. Recovery from the transient caused by the loss of a large load could cause diesel engine overspeed, which, if excessive, might result in a trip of the engine. This Surveillance demonstrates the DG loaf' response characteristics and capability to reject the largest single load              For Unit 1 without exceeding predetermin                   a. frequency and while                 615 kW with a     speifie~a             ~                          frequency maintaining a specified mgn to theoverspeed trip. [Foiti-unit,,Ie                    limit of 66.2 single load for eac and its horsepower rating is as follows: This                      Hz (993 or tripi                Surveillance          e accomplished by either:                                        RPM). For
                                          )ing                     theUnit                                                    2 825 emerg ency               a      ripping the DG output breake ith the DG carrying greater than o              kW with a feeder breaker               equal to its associated single largest post-accident load while                 frequency Palleled to offsite power, or while solely supplying the bus -or            Hz (552 RPMA).

Reference 12 b. Tripping its associated single largest post-accident load with the DC solely supplying the bus. AeyEq Ed8 (Ref. 12), the load rejection test is acceptable if the increase in diesel speed does not exceed 75% of the difference Consistent, with the between synchronous speed and the overspeed trip setpoint, or 15% recommend aions oL above synchronous speed, whichever is lower. The time, voltage, and frequency tolerances specified in this SR are derived from Regulate s Guide 1.9 (Rf.- recommendations for response during load sequence intervals The 3veconds specified ji I D-11 Reference 3 WOG STS B 3.8.1 - 18 Rev. 2, 04/30/01 82

AC Sources - Operating B 3.8. 1 `tJi l Rev. 2 Change C-7, D-11 & C-14 BASES SURVEILLANCE REQUIREMENTS (ontinued) and80%resl SR 3.8.1.8.a equal to 60%4f a typical 5 second load sequence interval associated with I D-11 sequencing of the largest load. The voltage and frequency specified are SR 3.8.1.8.b consistent with the design range of the equipment powered by the DG. corresponds to the maximum frequency excursion, while are steady state voltage and frequency

                    .1.8.c           es to which the system must recover following load rejection. The f18 month] Frequency is consistent with the recommendation of Regulatory Guide 1.108 (Ref. 9).

This SR is modified by two Notes. The reason for Note I is that during operation with the reactor critical, performance of this SR could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and, as a result, unit safety systems. This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allow the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g. post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite systerrm NUREG-1431, Rev 3 when they are tied together or operated independently for the l Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or Credit may be enhanced when the Surveillance is performed in MODE 1 or 2. Risk unplanned events insights or deterministic methods may be used for this assessment.s mayt that satisfy this SR. Note 2 ensures that the DG is tested under load conditions that are as close to desicn basis conditions as possible. When synchronized with 2e power, testing should be performed at a power factor of f.. . IC-14 ( JIv Thispowerfactorisrepresentativeoftheactualinductiveloading a3 fori w under design basis accident conditions. Under ce eample,l

                                \conditions, hote              2 allows the surveillance to on:x d at a
                                \power factor other than             These conditions ccurven 9fid              IC-14 e i hih,nd headditional field- eXcitation needed to get the powo; r oi resultsin voltages on the emergency busses that are too                       -7 x  LO higs Udor th~ese conditions, the poweF factor shoulid he maintained ars r     fea-~tirableo fao                   .ole :sll mai,.ainingaG^eptable veltage

[0.9 whir eR mergencybusses. In other circumstances, the grid voltage fco that the DG excitation levels needed to obtain a power factor ofpwmay not cause unacceptable voltages on the Wmnrgency IC-14 WOG STS B 3.8.1 - 19 Rev. 2, 04/30/01 83

Rev. 2 Change D-11 Inserts 3.8.1 and 3.8.3 (continued) Condition F for LCO 3.8.3 Condition Required Action Completion Time F. Required Action and F.1 Decare associated DG Immediately Associated Completion inoperable. Time not met. OR One or more DGs with diesel fuel oil, lube oil, or starting air subsystem not within limits for reasons other than Condition A, B,C, D, or E. Actions note for LCO 3.8.3 Limits for SR 3.8.1.8 part b and c Surveillance Requirement

b. Within 3 seconds following load rejection, the voltage is Ž 4106 V and

4368 V for Uniti 1, 94 i tlor Un:2 and

c. Within 4 seconds following load r the freuenc s588 Hz and s 61.2 for Unit 1, 5 a A I

Insert Second Completion Time for LCO 3.8.1 Action A.3 and Action B.4 COMPLETION TIME AND 17 days from discovery of failure to meet LCO Insert Condition A LCO 3.8.3 CONDITION REQUIRED ACTION COMPLETION TIME A. One or more DGs with fuel inventory: Restore fuel oil inventory to 48 hours c 17,500 and Ž15,000 gal (Unit 1) within limits. 191

Rev. 2 Change D-11 I BVPS ISTS Conversion 3.8 Electrical Power Systems Enclosure 3 Changes to CTS M.14 CTS 3.8.1.1 does not require specific limits or requirements for starting air system for DG OPERABILITY. ITS LCO 3.8.3 adds a requirement for starting air system to be OPERABLE when an associated DG is required to be OPERABLE. ITS 3.8.3 Condition E is added. Condition E specifies one or more DGs with starting air receiver pressure

       < 165 psig and 2 125 psig, the receiver pressure must be restored to 2 165 psig within 48 hours. These requirements are for Unit 1. For Unit 2, the Condition specifies one or more DGs with starting air receiver pressure < 394 psig and 2 285 psig restore the receiver pressure to 2 394 within 48 hours. Failure to comply with the specified Actions results in declaring the associated DG inoperable. ITS SR 3.8.3.4 is added and requires the verification that DG air start receiver pressure is 2 165 psig for Unit 1 and 2 394 psig for Unit 2 every 31 days. This changes the CTS by adding the appropriate requirements for starting air system to ensure DG OPERABILITY.

The purpose of the ITS LCO, Action, and surveillance requirements are to ensure the DG air start capacity is maintained within the design requirements for 5 start attempts. The addition of these requirements is acceptable because they provide additional assurance the DG is capable of starting within the time limit assumed by the safety analysis for analyzed events. The proposed ITS requirements are consistent with the ISTS for these requirements. This change is designated as more restrictive because it adds additional technical specification requirements that the CTS does not specify. M.1 5 CTS surveillance requirement 4.8.1.1.2.b.2 requires a verification that the generator (DG) is capable of rejecting a load 2 825 kw without tripping and without exceeding 64.4 Hz for Unit 2. Unit 1 surveillance requirement states; verify the generator capability to reject a load of Ž 615 kw without tripping and without exceeding 66.2 Hz. ITS SR 3.8.1.13 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 Ž 4106 V and 5 4368 V for (Unit 1), or Ž 3994 V and s 4368 V for (Unit 2), and within 4 seconds following load rejection, the frequency is Ž 58.8 Hz and s I 61.2 Hz (Unit 1) or 2 59.9 Hz and s 60.3 Hz (Unit 2). This changes the CTS by adding additional requirements to the surveillance requirement.

The purpose of the ITS SR 3.8.1.8 limitation on voltage and frequency after the transient is to ensure the response of the DG is within a specific band. The addition of these requirements is acceptable because they ensure the DG is capable of responding to a transient within specified limits. The ITS requirements are consistent with the applicable Regulatory Guide 1.9 requirements. This change is designated as more restrictive I because it adds additional surveillance requirement that the CTS does not require. M.16 CTS Action a requires with one offsite circuit inoperable, it must be restored to OPERABLE status within 72 hours. CTS Action b states with one diesel generator inoperable, it must 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 hours and within 17 days from discovery of failure to meet the LCO. Corresponding ITS 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. BVPS Units 1 & 2 Page 17 Revision 2, 04/00 229

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION Z CHANGE D-12 This change proposes some refinements for the Source, Intermediate, and Power Range Instrumentation applicability requirements in ITS 3.3.3 (Post Accident Monitoring or PAM Instrumentation) in Section 3.3B. The addition of Source, Intermediate, and Power Range Instrumentation to the PAM LCO imposes new and different requirements for this instrumentation. Some clarifications for the operability requirements for this instrumentation are! necessary. This change provides a clarification of source range instrumentation operability when neutron detectors are de-energized above P-6 interlock. Footnote (f) added to Table 3.3.3-1 and the associated Bases discussion are incorporated to describe this design feature of the Source Range instrumentation. In addition, the PAM Table 3.3.3-1 requirements for Power and Intermediate Range instrument channels (and associated Bases) are revised to provide a similar exception to the Mode 3 operability requirement for the two required channels of this instrumentation. This change is necessary to make the PAM requirements more consistent with the current Reactor Trip System applicability requirements for Power and Intermediate range channels. These channels are not currently required operable in Mode 3 (per CTS). The power and Intermediate Range instrumentation are not normally used in Mode 3 to monitor reactivity. The Source Range instrumentation is adequate for monitoring reactivity during shutdown conditions and the Intermediate and Power Range instrumentation remain available to confirm a reactor trip from power operation (i.e., Mode I or 2). Affected Pages: The following Table(s) list the affected pages by type (i.e., ITS markup, CTS markup, etc.). In order to facilitate review by ITS section, a separate table is provided for each ITS section affected by the change. The page numbers listed are the ITS section specific consecutive numbers found in the lower right corner of each page. Note: Because the affected page(s) for each change were extracted from a complete ITS section electronic file, the electronic hyperlinks (created in the complete ITS section file) do not work in the collection of affected pages that follow this cover page. ITS SECTION 3.3B (REMAINDER OF INSTRUMENTATION) INDEX OF AFFECTED PAGES ITS MARKUPS PAGE: 8 ITS JFDS No change ITS BASES MARKUPS PAGE: 59 ITS BASES JFDS No change CTS MARKUPS PAGE: 142 CTS DOCS PAGE: 220

I Rev. 2 Change C-9, D-1 & D-12 BVPS PAM TABLE (combined Unit I and 2) CONDITION REFERENCED FROM REQUIRED FUNCTION REQUIRED CHANNELS ACTION DA1

1. Power Range Neutron Flux 2(D) E D-12

2. Intermediate Range Neutron Flux 2'9' E

3. Source Range Neutron Flux 2"') E

4. Reactor Coolant System (RCS) Hot Leg 2 E Temperature (Wide Range)

5. RCS Cold Leg Temperature (Wide Range) 2 E

6. RCS Pressure (Wide Range) 2 E

7. Reactor Vessel Water Level 2 F

8. Containment Sump Water Level (Wide Range) 2 E

9. Containment Pressure (Wide Range) 2 E

10. Containment Area Radiation (High Range) 2 F

11. Pressurizer Water Level 2 E

12. Steam Generator (SG) Water Level (Wide Range) 3 E

13. SG Pressure a) SG'A' 2 E b) SG B- 2 E c) SG C' 2 E l Dr1

14. Primary Plant Demineralized Water Storage Tank 2 E Level

15. Refueling Water Storage Tank Level (Wide Range) 2 E

16. Penetration Flow Path Containment Isolation Valve 2 per penel1 pn flow E Position path

17. Core Exit Temperature a) Quadrant I 2(c) E b) Quadrant 2 2 (c) E c) Quadrant 3 2 (c) E d) Quadrant 4 2(c) E

18. Secondary Heat Sink Indication a) SG'A 2 (d) E b) SG B 2 (d) E c) SG-C 2 (d) E

19. High Head Si Automatic Iniection Header Flow 1 I Ct9 (d) The required channels may be satisfied by using any combination of SG Water Level (Narrow Range channels and Auxiliary Feedwater Flow channels such that 2 channels are OPERABLE for each SG.

(e) Condition B contains the appropriate Action for Function(s) with one required channe_ (e) Source Range neutron detectors are not required to be energized above the P-6 Intermediate Range Q . lt9 Neutron Flux Interlock. D-12 (g) Not required in MODE 3. 1 8

I Rv. Chnge D.12 I PAM Instrumentation B 3.3.3 ii,,,,t or the reliability of ClVs without control room indication (i.e., BASES automatic check valves and relief valves that are not or open under adminitrative dependent on an external power source or closure signal) or provisions of the CIV wechnict 7 provisaions fteCV, ehia LCO (ciontinued) close spcfca\n valve prior knowledge of a passive valve, or v system b cndary status. If a normally active CIV is known to be closed and deactivated, osition indication is not needed to determine status. Therefore, the position indication for valves in this state is not required to be OPERABLE. Type A and Category I variables are equired to meet Regulatory Guide 1.97 Category I (Ref. 2) design and qualification requirements for seismic and environmental qualification, single failure criterion, utilization of emergency standby power, immediately accessible display, continuous readout, and recording of display. The followingI re discussions of the specified instrument Functions listed in Table 3.3.3-1. These-diccssions are intondod as examples of what shookd be

                                                                       ~-.ifilt VfIWV0UtU I.WJi   U.iuil rur UMF        12UH      Wilt brputiiir 11btlbP                                    -ft-o er R e nPower,                              Intermediate, arid Source II4        _oe Raq<              4Gw          al     Neto       Flu Power Range and Source Range Neutron Flux indication is provided to verify reactor shutdown. The " ranges are necessary to cover the full range of flux that may occur po"i                                               <

Neutron flux is classified as a Neutron flux is used for accident diagnosis, verification of subcriticality, and Category 1 variable. diagnosis of positive reactivity insertion." Ad~-Type Aand J Reactor Coolant System (RCS) Hot and Cold e Ternmeratures, 14,5 RCS Hot and Cold Leg Temperatures are ategory I variables rovided for verification of core cooling and long term surveillance. lWde Range) ] RCS hot and cold leg temperatures are used to determine RCS subcooling margin. RCS subcooling margin will allow termination of safety injection (SI), if still in progress, or reinitiation of SI if it has been stopped. RCS subcooling margin is also used for unit stabilization and cooldown control. 1. C .- quu--u

                       - - - - -I- .-     ----
                       ,...-a nme, UI :Lou".cUna iyc
                                                       .- I U,, ,  a    .O.0 ale dC mouJ I    ,uUy    youl

{Is iU. pIuvlUCs an U.IufldUUS cepu maJ flow CIIUWA Q I scurce range neutron detectors to be de-energized above the P-6 Intermediate Range Neutron Flux Interlock. Source Range channel operability, when the associated detector is de-energized, consists of being capable of performing its intended function once power is re ;tored to the associated neutron detector. When the source range dete cors are deenergized. the source range channels are also ccnsidered de-enegized and SR 3.3.3.1 is not applicable. Similarly, the required channels for Intermediate and Power Range indication on Tz ble 3.3.3-1 are modified by footnote (g)which provides an exception to the MODE 3 OPERABILITY requirement for this indication. In MODE 3, the Source Range channels are adequate to provide the required reactivity monitoring function. The Intermediate and Power Range indication channels serve to confirm reactor shutdown in a post reactor trip condition from power operation. WOG STS B 3.3.3 - 4 Rev. 2, 04/30/01 59

I Rev. 2 Change C-9, D-1 & D-12 INSERTS for ITS 3.3.3 Table 3.3.3-1 NEW PAM FUNCTIONS Ml~ CONDITION REFERENCED FROM REQUIRED FUNCTION REQUIRED CHANNELS ACTION D.1

1. Power Range Neutron Flux 2 (E) E D-12

2. Intermediate Range Neutron Flux 2 (g) E

3. Source Range Neutron Flux 2 (f) E

4. Reactor Coolant System (RCS) Hot Leg 2 E Temperature (Wide Range)

5. RCS Cold Leg Temperature (Wide Range) 2 E

6. RCS Pressure (Wide Range) 2 E

10. Containment Area Radiation (High Range) 2 F

12. Steam Generator (SG) Water Level (Wide Range) 3 E

13. SG Pressure a) SG"A" 2 E b) SG "B" 2 E c) SG"C" 2 E

14. Primary Plant Demineralized Water Storage Tank 2 E D-1 Level

15. Refueling Water Storage Tank Level (Wide Range) 2 E

16. Penetration Flow Path Containment Isolation Valve 2 per penetpn flow E Position path

18. Secondary Heat Sink Indication a) SG"A" 2(d) E b) SG "B" 2(d) E c) SG "C" 2(d) E

19. High Head SI Automatic Injection Header Flow I B(e) I C-9 (a) Not required for isolation valves whose associated penetration isisolated by at least one dosed and deactivated automatic valve, dosed manual valve, blind flange, or check valve with flow through the valve secured.

(b) Only one position indication channel is required for penetration flow paths with only one installed control room indication channel. (e) Condition Bcontains the appropriate Action for Function(s) wth one required channel. 0 C-1 (1) Source Range neutron detectors are not required to be energized above the P-6 Intermediate Range Neutron Flux Interlock. l D-12 (g) Not required inMODE 3. 142

BVPS ISTS Conversion Rev. 2 Change D-12 3.3 B Instrumentation Enclosure 3 Changes to CTS conditions. The SGs are designed with a single wide range level channel per SG. Therefore, in order to ensure the continued operability of the SG wide range SG water level indication all three available channels are required operable in the proposed PAM ITS. The single channel of High Head SI Automatic Injection Header Flow specified in the proposed PAM ITS is discussed above. The proposed PAM Function additions listed above include the applicable footnotes (a arid b) necessary to clarify the number of required channels for the Containment Isolation Valve Position Indication Function. The addition of these footnotes is consistent with the corresponding ISTS footnotes and is necessary to define the channel requirements consistent with the containment isolation valve design. Footnote (c) is associated with the Core Exit Temperature Function and is described in DOC A.6. Footnote (d) is associated with Secondary Heat Sink Indication and is discussed in DOC L.4. The proposed neutron flux indication channels (Functions 1, 2, and 3) are modified by notes (f) and (g)to identify appropriate exceptions to the operability requirements for this new PAM instrumentation. The purpose of the PAM TS is to ensure sufficient indication instrumentation is maintained operable to provide the necessary indication in post accident conditions. The proposed change includes the addition of indicating instrumentation that provides information to the operators for use in mitigating the consequences of accidents. The proposed change also includes the appropriate surveillance requirements for each new Function to ensure the Functions are maintained operable in accordance with the PAM technical specification requirements. The proposed change enhances the existing CTS requirements by providing a more complete set of PAM indications in the TS. As such, the proposed change is acceptable because it provides additional assurance that instrumentation necessary to perform PAM functions is maintained operable. The addition of the instrumentation listed above serves to improve the diversity and redundancy of the required PAM instrumentation without adversely affecting equipment availability or the safe operation of the plant. The proposed change is designated more restrictive because new instrumentation is added to the PAM T&. M.2 The 'S/U" frequency for the Channel Check on the Auxiliary Feedwater Flow Rate (i.e., the ITS Secondary Heat Sink Indication) PAM Function is revised to an 'M" frequency. 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. The Channel Check requirement on current TS Table 4.3-7 for the AFW Flow Rate PAM Function specifies that the surveillance is only required during startup (S/U). The Channel Check requirement is further modified by an asterisk footnote which specifies that the Channel Check need only be performed in conjunction with Surveillance Requirement 4.7.1.2.7 following an extended outage. CTS Surveillance 4.7.1.2.7 is contained in AFW Technical Specification 3/4.7.1.2. The surveillance requires that AFW flow to the steam generators be verified after an extended shutdown (i.e., shutdown in Modes 5 or 6 for greater than 30 days). The CTS requirement is intended to specify the performance of a Channel Check only when the AFW system is in service (i.e., in conjunction with Surveillance Requirement 4.7.1.2.7 following an extended outage). The CTS requirement BVPS Units 1 & 2 Page 8 Revision ;, 04/06 220

i p- BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. Z96 (UNIT 1) & 1 69 (UNIT Z) REVISION 2 CHANGE D-13 This change provides clarification of source range instrumentation operability when neutron detectors are de-energized above P-6 interlock (similar to D-1 2 above) for ITS 3.3.4 (Remote Shutdown Instrumentation). This change is necessary to incorporate this design feature of the source range instrumentation into ITS 3.3.4 in the same manner as it is already incorporated into ITS 3.3.1 (RTS). The proposed change adds a Note to Bases Table 3.3.4-1 consistent with the Note for source range instrumentation added to the PAM Table in Change D-12. Affected Pages: The following Table(s) list the affected pages by type (i.e., ITS markup, CTS markup, etc.). In order to facilitate review by ITS section, a separate table is provided for each ITS section affected by the change. The page numbers listed are the ITS section specific consecutive numbers found in the lower right corner of each page. Note: Because the affected page(s) for each change were extracted from a complete ITS section electronic file, the electronic hyperlinks (created in the complete ITS section file) do not work in the collection of affected pages that follow this cover page. ITS SECTION 3.3B (REMAINDER OF INSTRUMENTATION) INDEX OF AFFECTED PAGES ITS MARKUPS No change ITS JFDS No change ITS BASES MARKUPS PAGE: 82 ITS BASES JFDS No change CTS MARKUPS No change CTS DOCS No change

I Rev. 2 Change D-13 I Insert BVPS Specific Table B 3.3.4-1 Table B 3.3.4-1 (page 1 of 1) Remote Shutdown System Indications and Controls Emergency Shutdown Panels PNL-SHUTDN (Unit 1) and PNL-2SHUTDN (Unit 2) REMOTE SHUTDOWN SYSTEM FUNCTION REQUIRED INDICATIONS AND CONTROLS NUMBER OF CHANNELS

1. Reactivity Control Function

a. Source Range Neutron Flux (indication) 1(a)

b. Boric Acid Transfer Pump (control) 1

2. Reactor Coolant System (RCS) Pressure Control Function

a. Pressurizer Pressure (indication) 1 or

b. Pressurizer heater (control) 1

3. Decay Heat Removal via Steam Generators (SGs) Function

a. RCS Hot Leg Temperature (indication) 1

b. RCS Cold Leg Temperature (indication) I

c. SG Pressure (indication) 1SG

d. SG Level (indication) I/SG

e. AFW Flow (indication) 1/SG

f. SG Atmospheric Dump Valve (control) 1 or BiBo YJ9Kf r(lAurAEI~Wai

g. AFW pump (Control) I

h. AFW Flow (Control) 1

4. RCS Inventory Control Function

a. Pressurizer Level (indication) I

b. Charging Pump (Control) 1

c. Charging Flow (Control) 1

d. Letdown Flow (Control) 1

5. Support Systems

a. Component Cooling Water pump (control) 1

b. RiverUt&r ( rol)(trit 1 I

c. 1 (a) Source Range neutron detectors are not required to be energized above the P-6 Intermediate Range Neutron Flux Interlock.

82

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & I 69 (UNIT 2) REVISION Z CHANGE D-14 This change revises Surveillance Requirement 3.1.9.1 Bases. This Surveillance Requirement is for the Mode 2 Physics Test Exception LCO. The change clarifies the relationship between the Test Exception surveillance and the RTS surveillance requirements that are referenced in the Test Exception surveillance. The original text did not provide sufficient guidance to understand the intent of referencing the RTS surveillances in the Test Exception surveillance. This change only affects the Bases of ITS 3.1.9. Affected Pages: The following Table(s) list the affected pages by type (i.e., ITS markup, CTS markup, etc.). In order to facilitate review by ITS section, a separate table is provided for each ITS section affected by the change. The page numbers listed are the ITS section specific consecutive numbers found in the lower right corner of each page. Note: Because the affected page(s) for each change were extracted from a complete ITS section electronic file, the electronic hyperlinks (created in the complete ITS section file) do not work in the collection of affected pages that follow this covei page. ITS SECTION 3.3B (REMAINDER OF INSTRUMENTATION) INDEX OF AFFECTED PAGES ITS MARKUPS No change ITS JFDS No change ITS BASES MARKUPS PAGES: 111 & 112 ITS BASES JFDS PAGE: 132 CTS MARKUPS No change CTS DOCS No change

I Rev. 2 Change D-14 l PHYSICS TESTS Exceptions - MODE :2 Big3 BASES ACTIONS A.1 and A.2 If the SDM requirement is not met, boration must be initiated promptly. A Completion Time of 15 minutes is adequate for an operator to correctly align and start the required systems and components. The operator should begin boration with the best source available for the plant conditions. Boration will be continued until SDM is within limit. Suspension of PHYSICS TESTS exceptions requires restoration of each of the applicable LCOs to within specification. B.1 When THERMAL POWER is > 5% RTP, the only acceptable action is to open the reactor trip breakers (RTBs) to prevent operation of the reactor beyond its design limits. Immediately opening the RTBs will shut down the reactor and prevent operation of the reactor outside of its design limits. C.1 When the RCS lowest T.,, is < 531OF, the appropriate action is to restore Tats to within its specified limit. The allowed Completion Time of 15 minutes provides time for restoring T,,, to within limits without allowing the plant to remain in an unacceptable condition for an extended period of yJ) time. Operation with the reactor critical and with temperature below 531OF could violate the assumptions for accidents analyzed in the safety analyses. D.1 If the Required Actions cannot be completed within the associated Completion Time, the plant must be brought to a MODE in which the requirement does not apply. To achieve this status, the plant must be brought to at least MODE 3 within an additional 15 minutes. The Completion Time of 15 additional minutes is reasonable, based on operating experience, for reaching MODE 3 in an orderly manner and without challenging plant systems. SURVEILLANCE SR 3 .1.ti inaccordance with a require REQUIREMENTS ' The power range and intermediate rage neutron detectorsinust-be veified to be OPERABLE in MODE 2 LCO 3.3.1, "Reactor Trip I System (RTS) Instrumentation." A CHANNEL OPERATIONAL TEST is WOG STS B 3.1 - 6 Rev. 2, 04/30/01 111

Rev. 2 Change D-14 PHYSICS TESTS Exceptions - MODE :2 9B 3 The performance of the RTS CHANNEL OPERATION/ BASES TEST requirements referenced in this SR r- IL tiaccordance with the frequency requirement of SURVILLNCEEQUREMNTS coninu the referenced RTS surveillances which ensures SURVILLACE EQUIEMENS (ontiuedeach channel is tested performed on each power ran d intermediate range channenrior tort initiation of the-PHYSICS TESTS. proerlalgne reuird will th toproid dgreensure that potetio o coe the RTS isduin- thF I properly aligned to provide the required degree of core protection during---, the performance of the PHYSICS TESTS. SR 3.1.X72 i Verification that the RCS lowest loop Tavg is 2 531OF will ensure that the unit is not operating in a condition that could invalidate the safety analyses. Verification of the RCS temperature at a Frequency of 30 minutes during the performance of the PHYSICS TESTS will ensure that the initial conditions of the safety analyses are not violated. SR 3.1.3 R Verification that the THERMAL POWER is < 5% RTP will ensure that the plant is not operating in a condition that could invalidate the safety analyses. Verification of the THERMAL POWER at a Frequency of 30 minutes during the performance of the PHYSICS TESTS will ensure that the initial conditions of the safety analyses are not violated. SR 3.1.s. The SDM is verified by performing a reactivity balance calculation, considering the following reactivity effects:

a. RCS boron concentration,

b. Control bank posiftionr4Ii:1

c. RCS average tempera ture{

Fuel burnup based on gross thermal energy generation/

e. Xen etation,/

4 f. Samarium conent

g. Isothermal temp er c when below the point of adding H),\

h. derate Defect, when above the POAH, and WOG STS B 3.1 - 7 Rev. 2, 04/30/01 112

Rev. 2 Change D-14. BVPS ISTS Conversion 3.1 Reactivity Control Systems Enclosure 2 Changes to The ISTS Bases

 'imwi       The proposed change to the ISTS bases is acceptable because the proposed change references the industry standard for a description of the testing performed at BVPS. It is not necessary to repeat or summarize the standard test descriptions in the TS bases. The reference standard is readily available and contains sufficient:

detail to confirm the methods and adequacy of the BVPS Physics Test program.

7. The Neutron Flux Symmetry test is deleted from the list of Mode 2 Physics Tests.

Consistent with the explanation that follows the list of tests in the ISTS bases, this test is performed in Mode 1 and is not part of the BVPS Mode 2 Physics Tests addressed by this Test ExceptiDn.

8. The critical boron test is revised to reference the "Reference Bank" instead of control rods. The Reference Bank is the specific 'control rods" used at BVPS for this test.

9. The Bases for ITS SR 3.1.9.1 is revised to more clearly describe the relationship with ITS LCO 3.3.1, Reactor Trip System (RTS) Instrumentation and the RTS SF:s referenced by SR 3.1.9.1. ITS SR 3.1.9.1 requires the performance of RTS SRs that are part of ITS 3.3.1 which is also applicable in Mode 2.

91 u1 BVPS Units 1 & 2 Page 14 Revision :', 04/06 132

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Ncis. 296 (UNIT 1) & 169 (UNIT 2) REVISION 2 CHANGE D-15 This change revises the markup of ITS 3.7.10 (Control Room Emergency Ventilation System or CREVS) Action Condition F to be consistent with the corresponding CTS requirement. The change will add the word 'required" before "CREVS Train" in the Action Condition. As only 2 of the 3 BVPS CREVS trains are required operable by the LCO the word required is needed to clearly identify that the two inoperable trains referred to in the Actions are the two trains required by the LCO and not the spare train and one required train. This change will make the proposed ITS 3.7.10 Action Condition F consistent with the corresponding CTS Action as was originally intended. Affected Paqes: The following Table(s) list the affected pages by type (i.e., ITS markup, CTS markup, etc.). In order to facilitate review by ITS section, a separate table is provided for each ITS section affected by the change. The page numbers listed are the ITS section specific consecutive numbers found in the lower right corner of each page. Note: Because the affected page(s) for each change were extracted from a complete ITS section electronic file, the electronic hyperlinks (created in the complete ITS section file) do not work in the collection of affected pages that follow this cover page. ITS SECTION 3.3B (REMAINDER OF INSTRUMENTATION) INDEX OF AFFECTED PAGES ITS MARKUPS PAGE: 30 ITS JFDS No change ITS BASES MARKUPS PAGE: 148 ITS BASES JFDS No change CTS MARKUPS No change CTS DOCS No change

Rev. 2 Change D-15 3.7.10 ACTIONS (continued) CONDITION I REQUIRED ACTION COMPLETION TIME D. Required Action and associated Completion \ -NOTE-Time of Condition A not I Pac ~oic K (i met [in MODE 5 or 6, or protectionH if during movement of automati anr totoxic [recently] irradiated fuel gas pc tcin mo ig assemblie erable. l CREVS Place OPERABLE GRE Immediately train in emergency o or during movement of fuel assemblies over OR recently irradiated fueL. lpressurization mode of operation. JQC D.2 Suspend movement of I Immediately required CREVS [recently] irradiated fuel I and movement of fuel assemblies over assemblies, recently irradiated fuel.

        .                    ,                -4
      /    E. Two CRt6S trains inoperable [in MODE 5 of 6-3eiq during movement of E.1       Suspend movement of frecently] irradiated fue assemblies.                /

Immediately 0D [recently] irradiated fuele Al14tn ! 4mbr r e ,RV ( 1' _ _ F. Two CREFS trains F.1 Enter LCO 3.0.3 Immediately inoperable in MODE 1, 2, 3, or 4 for reasons other than Condition B. SURVEILLANCE REQUIREMENTS URVEILLANCE FREQUENCY SR 3.7.10.1 Operate each train for [3 10 continuou hour s 1 days with the heaters operating or {for enywihout heatrs6) Ž 15 minute heaters operating. SR 3.7.10.2 Perform required filter testing in accordance In accordance with the{Ventilati Filter Testing Program (VFTP)I. with [VFTPI WOG STS 3.7.10 -2 Rev. 2, 04/30/01 30

I Rev. 2 Change D-15 INSERTS FOR ITS 3.7.10 BASES Control Room Emergency Ventilation System (CREVS) D.1 and D.2 During fuel movement involving recently irradiated fuel assemblies, if an inoperable CREVS train cannot be restored to OPERABLE status within the required Completion Time, the OPERABLE CREVS train must immediately be placed in the emergency pressurization mode od operation. This action requires the control room ventilation isolation dampers to be closed and the control room to be pressurized by the operating CREVS train. This action ensures that the remaining train is OPERABLE, that no failures preventing automatic actuation will occur, and that any active failure would be readily detected. An alternative action is to immediately suspend activities that could result in a release of radioactivity that might require isolation of the control room. This involves suspending movement of recently irradiated fuel assemblies and suspending movement of fuel assemblies over recently irradiated fuel assemblies. This places the unit in a condition that minimizes risk. This does not preclude the movement of fuel to a safe position. E.1 During fuel movement involving recently irradiated fuel assemblies, if two required CREVS trains are inoperable, action must be taken immediately to suspend activities that could result in a release of radioactivity that might require the CREVS function. Two inoperable trains also include the conditions of one or more inoperable series isolation dampers in both trains or one or more inoperable series isolation dampers in one train and the opposite CREVS train inoperable. This Action involves suspending movement of recently irradiated fuel assemblies and suspending movement of fuel assemblies over recently irradiated fuel assemblies. This places the unit in a condition that minimizes accident risk. This Action does not preclude the movement of fuel to a safe position. F.1 If both required CREVS trains are inoperable in MODES 1, 2, 3, or 4 for reasons other than an inoperable control room boundary (i.e., Condition B) the CREVS may not be capable of performing the intended function and the unit is in a condition outside the accident analyses. Two inoperable trains also include the conditions of one or more inoperable series isolation dampers in both trains or one or more inoperable series isolation dampers in one train and the opposite CREVS train inoperable. In this condition, Specification 3.0.3 must be entered immediately. INSERT 6 - BVPS SPECIFIC SURVEILLANCE SECTION SR 3.7.1 0.1 Standby systems should be checked periodically to ensure that they function properly. As the environment and normal operating conditions on this system are not severe, testing each train once every month provides an adequate check of this system. The CREVS fan and filter flow path is operated for 2 15 minutes by initiating flow through the HEPA filter and charcoal adsorber train with heaters operating to ensure that they function properly. This Surveillance does not require that the control room be isolated in order to verify fan and filter flow path 3.7.10 Bases Insert Page 81 148

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 CHANGE D-16 This change makes editorial changes (in presentation and format) to the ITS 5.5.7 Ventilation Filter Testing Program (VFTP) insert page. The proposed changes only serve to clarify the BVPS specific text describing the surveillance frequencies specified in the program. The changes provide a more orderly presentation of this information to enhance the readability for users. This change only affects the VFTP text in ITS 5.5.7. Affected Panes: The following Table(s) list the affected pages by type (i.e., ITS markup, CTS markup, etc.). In order to facilitate review by ITS section, a separate table is provided for each ITS section affected by the change. The page numbers listed are the ITS section specific consecutive numbers found in the lower right corner of each page. Note: Because the affected page(s) for each change were extracted from a complete ITS section electronic file, the electronic hyperlinks (created in the complete ITS section file) do not work in the collection of affected pages that follow this cover page. ITS SECTION 5.0 (ADMINISTRATIVE CONTROLS) INDEX OF AFFECTED PAGES ITS MARKUPS PAGE: 47 ITS JFDS No change ITS BASES MARKUPS No change ITS BASES JFDS No change CTS MARKUPS No change CTS DOCS No change

Rev. 2 Change D-16 Section 5.0 Inserts Insert 3 - Not Used. Insert 4 for Section 5.5.7 Ventilation Filter Testing Program (VFTP) A program shall be established to implement the following required testing of Engineered Safety Feature (ESF) filter ventilation systems for the Control Room Emergency Ventilation System (CREVS) and the Supplemental Leak Collection and Release System (SLCRS). Tests described in Specifications 5.5.7.a and 5.5.7.b shall be performed at least once per 18 months and after the following:

Each complete or partial replacement of the high efficiency particulate air (HEPA) filter or charcoal adsorber bank;
Any structural maintenance on the HEPA filter or charcoal adsorber housing;
Significant painting, fire, or chemical release (for the Unit 1 and Unit 2 SLCRS) in any ventilation zone communicating with the system while the filtration system is operating; and
Significant painting, fire, or chemical release (for the Unit 1 and Unit 2 CREVS) in the vicinity of control room outside air intakes while the system is operating.

Tests described in Specification 5.5.7.c shall be performed at least once per 18 months and after the following:

720 hours of adsorber operation (for the Unit 1 and 2 CREVS and the Unit 1 SLCRS) or after 4 months of adsorber operation (for the Unit 2 SLCRS);
Any structural maintenance on the charcoal adsorber bank housing;
Significant painting, fire, or chemical release (for the Unit I and Unit 2 SLCRS) in any ventilation zone communicating with the system while the filtration system is operating; and
Significant painting, fire, or chemical release (for the Unit 1 and Unit 2 CREVS) in the vicinity of control room outside air intakes while the system is operating.

Tests described in Specifications 5.5.7.d and 5.5.7.e shall be performed at least once per 18 months. The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the VFTP test frequencies.

a. Demonstrate for each of the required ESF systems that an inplace test of the HEPA filters shows a penetration and system bypass specified below when tested in accordance with ANSI N510-1980 (for the Unit 1 and 2 CREVS) and the Unit 2 SLCRS and in accordance with ANSI N51 0-1975 (for the Unit I SLCRS) at the system flowrate specified below:

ESF Ventilation System Penetration Flowrate SLCRS < 1.0% (Unit 1) 2 32,400 cfm and *39,600 cfm (Unit 1)

                                 < 0.05% (Unit 2)      2 51,300 cfm and < 62,700 cfm (Unit 2)

CREVS < 0.05% 2 800 cfm and

1000 cfm Section 5.0 Inserts Page 15 47

EIVPS UNITS I & 2 ITS CONVERSION LICENSE AMENDMENT REQ~UEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 CHANGE D-17 This change makes an editorial change to the title of ITS 3.4.12 (OPPS). The title of ITS 3.4.12 is revised from 'Overpressure Protection Systems" to 'Overpressure Protection Systemn." Affected Pages: The following Table(s) list the affected pages by type (i.e., ITS markup, CTS markup, etc.). In order to facilitate review by ITS section, a separate table is provided for each ITS section affected by the change. The page numbers listed are the ITS section specific consecutive numbers found in the lower right corner of each page. Note: Because the affected page(s) for each change were extracted from a complete ITS section electronic file, the electronic hyperlinks (created in the complete ITS section file) do not work in the collection of affected pages that follow this cover page. ITS SECTION 3.3C (ESFAS) INDEX OF AFFECTED PAGES ITS MARKUPS No change ITS JFDS No change ITS BASES MARKUPS PAGE: 33 ITS BASES JFDS No change CTS MARKUPS No change CTS DOCSNo change ITS SECTION 3A4 (RCS) INDEX OF AFFECTED PAGES ITS MARKUPS PAGE: 29 ITS JFDS PAGE: 75 ITS BASES MARKUPS PAGES: 135, 139 & 149 ITS BASES JFDS PAGE: 210 CTS MARKUPS No change CTS DOCS No change (continued)

BVPS U N ITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 Change D-17 (continued) ITS SECTION 3.5 (ECCS) INDEX OF AFFECTED PAGES ITS MARKUPS PAGE: 6 ITS JFDS No change ITS BASES MARKUPS PAGES: 37 &45 ITS BASES JFDS No change CTS MARKUPS No change CTS DOCS No change

EVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 169 (UNIT 2) REVISION 2 CHANGE D-17 AFFECTED PAGES FOR ITS SECTION 3.3C (ESFAS) ITS SECTION 3.3C (ESFAS) INDEX OF AFFECTED PAGES ITS MARKUPS No change ITS JFDS No change ITS BASES MARKUPS PAGE: 33 ITS BASES JFDS No change CTS MARKUPS No change CTS DOCS No change.

r s I Rev. 2 Change D-17 ESFAS Instrumentation I B 3.3.2 t41) BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)

                                                  .      Reactor Trip,

Turbine Trip, W Feedwater Isolation,
Start of metOFdFiven auxiliary feedwater (AFlN) pumps,
Control room ventilation isolabieand
Enabling automatic switchover of Emergency Core Cooling Systems (ECCS) suction to containment sump.

These other functions ensure:

Isolation of nonessential systems through containment penetrations,
Trip of the turbine and reactor to limit power generation,
Isolation of main feedwater (MFW) to limit secondary side mass losses, Start of AFW to ensure secondary side cooling capability,

                                      -         -       *~on*-,in  oEnfBu .nn-rn ronm
                                                                                  -to,        ra-  h;t-h;I;h.   --

Inns 1440WJ

Enabling ECCS suction from the refueling water storage tank (Unit 1) and extreme low (Unit 2) I (RWST) switchover on lolew RWST level to ensure continued J cooling via use of the containment sump.

except for the Unit 1 automatic high Safety Injection - Manual Initiation head safety injection (HHSI) flow path isolation valves when LCO The LCO requires one channel per train to be OPERABLE. The 3.4.12, "Overpressure Protection operator can initiate SI at any time by using either of two I System," is applicable. Consistent l switches in the control room. This action will cause actuation of with the requirements of LCO all components in the same manner as any of the automatic 3.4.12, in MODE 4 when any RCS cold leg temperature is

the enable actuation signals!-._

temperature specified in the PTLR, the Unit I automatic HHSI flow path The LCO for the Manual Initiation Function ensures the proper must be isolated with power amount of redundancy is maintained in the manual ESFAS removed from the isolation valves. actuation circuitry to ensure the operator has manual ESFAS Therefore, when operating in the initiation capability. MODE 4 Applicability of LCO 3.4.12, the manual initiation of Unit 1 SI will require additional manual valve operation to establish an SI injection flow path. WOG STS B 3.3.2 - 7 Rev. 2, 04/30/01 33

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 CHANGE D-17 AFFECTED PAGES FOR ITS SECTION 3.4 ('RCS) ITS SECTION 3.4 (RCS) INDEX OF AFFECTED PAGES ITS MARKUPS PAGE: 29 ITS JFDS PAGE: 75 ITS BASES MARKUPS PAGES: 135,139 & 149 ITS BASES JFDS PAGE: 210 CTS MARKUPS No change CTS DOCS No change

Rev. 2 Change D-17 1~ 3.4.12 3.4 REACTOR COOLANT SYSTEM (RCS) l 3.4.12 LowyTempei~alure Overpressure Protection (LTOP) System LCO 3.4.12 TOP System shall be OPERABLE with a maximum of [one] [hi pressw injection (HPI)] pump [and one charging pump] capabof IINSERT 1 injecting Ithe RCS and the accumulators isolated and a of the lfollowina oresre relief capabilities:

a. Two power oper relief valves (POR with lift settings within the limits specified in eTLR,

[b. Two residual heat removal suction relief valves with setpoints Ž 1436.5] psid s [46 .psig, I [c. One PORV wi lift setting within the limi ecified in the PTLR and one suction relief valve with a setpoin 436.5] psig and < 3.51 psig, ] or dThe ROS depressurized and an RCS vent of 2 [2.07] square S. MODE 4 whe RCS cold leg temperature is * [275OF1 [LTOPRaniKg temperature specified in the PTLR], may be MODE 5, unisolated the en MODE 6 when the reactor vessel head is o Approved _ __ TSTF-243

Rev. 2 Change D-17 BVPS ISTS Conversion 3.4 Reactor Coolant System Enclosure I Changes to ISTS ITS 3.4.12 OverpressureProtectionSystem JUSTIFICATION FOR DEVIATION (JFD)

1. The ISTS LCO requirements for low temperature overpressure protection are revised to conform to the corresponding CTS requirements and the BVPS design.

This includes the following revisions: a) The name of the over pressure protection system used in the IST'S is changed to the current BVPS nomenclature for this system (i.e., Overpressure Protection System (OPPS)), b) The BVPS design does not include high pressure RCS injection pumps other than the charging pumps. Therefore, the ISTS reference to other high pressure injection pumps is deleted, c) The BVPS specific safety analysis for low temperature overpressure protection does not include the RHR valves. The only valves modeled in the analysis are the PORVs. Therefore, the RHR valves can not currently be credited for this protection and references to the RHR valves are deleted from the LCO, d) Due to design differences between the BVPS units the RCS vent size assumed in the safety analysis for low temperature overpressure protection is different for each unit. Therefore, two different RCS vent sizes (one for each unit) are included in the BVPS specific LC O, e) The additional Unit I specific requirement to isolate the ECCS high head SI (HHSI) flow path is included in the BVPS version of this LCO. The requirement to isolate the HHSI flow path is consistent with Unit I CTS 3/4.5.4, "HHSI Flow Path". Unit 2 does not have a corresponding requirement. This requirement is necessary as the Unit 1 low temperature over pressure protection safety analysis does not consider this flow path (SI high head injection) when evaluating mass injection events. Therefore, the Unit I TS require that this potential mass injection flow path be isolated such that an inadvertent SI signal would not cause an over pressure condition in the RCS. This Unit I requirement was previously in the ECCS section of the TS but is only applicable when operating with an RCS temperature less than or equal to the over pressure protection system enable temperature. Therefore, the requirement is moved into ITS 3.4.12: to consolidate all the low temperature over pressure protection system requirements in the same TS. The changes to the ISTS listed above are consistent with the CTS and the BVPS design.

2. The ISTS Applicability is revised consistent with the corresponding CTS Applicability. This includes changing the bracketed options for the specific temperature to "the enable temperature" consistent with the BVPS nomenclature for this term.

BVPS Units 1 & 2 Page 21 Revision :2, 4/06 75

Pressurizer Safety Valves Rev. 2 Change D-17 B 3.4.10 B 3.4 REACTOR COOLANT SYSTEM (RCS) B 3.4.10 Pressurizer Safety Valves The Unit 1 pressurizer safety valves. are totally enclosed, pilot-actuated, _ self-actuated valves. The Unit 2 BASES

                                  =                                                                       I

(\2 BACKGROUN[ D The pressurizer safety valves provide, in conjunction with he Reactor Protection System, overpressure protection for the RCS. pressurizer is 345,000 Ibm/hr safety valves are totally enclosed pop type, spring loaded, self actuated (Unit 1) and 378.200 valves with backpressure compensation. The safety valves are designed Ibm/hr (Unit 2). The to prevent the system pressure from exceeding the system Safety Limit capacity of the pressurizer safety (SL), f2735-psig, which is 110% of the design pressure. valves is based on the valve geometry. Because the safety valves are totally enclosed and self actuating, they The pressurizer are car idered independent components. The relief capacity for each safely valve capacity is used in the analysis valvet [ 3 based on postulated overpre sa s of the complete loss conditions resulting frt to the turbine. of steam flow to the This event results' um sut the presic turbine event, to demonstrate that the relief capaci r esa discharge capacity is sufficient flow from the pressurizer safety valves is directed to the pressurizer relief to maintain RCS pressure below 110% tank. This discharge flow is indicated by an increase in temperature of the design downstream of the pressurizer safety valves or increase in the pressurizer pressure. relief tank temperature or level. Overpressure protection is required in MODES 1, 2, 3, 4, and 5; however, the enable in MODE 4, with one or more RCS cold leg temperatures * [27FJ-50[Low FneatF Q uro Protection (LTOP) arming temperature specified in the PTLRJ, and MODE 5 and MODE 6 with the reactor vessel IJ head on, overpressure protection is provided by operating procedures and by meeting the requirements of LCO 3.4.12, "Iow TeperaturweG Overpressure Protection (I.OP) Syste stemF

                                                                                         .. 4           )     74        -    .)

Thee 1% ASME tolerance I req tuirement is met by The upper and lower pressure limits are based on the +/- 1% tolerance asssiring the as left lift setting requirement (Ref. 1) for lifting pressures above 1000 psig.AThe lift setting isuv:thin 1% of 2485 psig. is for the ambient conditions associated with MODES 1, 2, and 3. This requires either that the valves be set hot or that a correlation between hot. and cold settings be established.

               %A)                     The pressurizer safety valves are part of the primary success path and mitigate the effects of postulated accidents. OPERABILITY of the safety valves ensures that the RCS pressure will be limited to 110% of design pressure. The consequences of exceeding the American Society of Mechanical Engineers (ASME) pressure limit (Ref. 1) could include damage to RCS components, increased leakage, or a requirement to perform additional stress analyses prior to resumption of reactor operation.

WOG STS B 3.4.10- 1 Rev. 2, 04/30/01 135

IRev. 2 Change D-17 Pressurizer PORVs B 3.4.11 KR)' B 3.4 REACTOR COOLANT SYSTEM (RCS) B 3.4.11 Pressurizer Power Operated Relief Valves (PORVs) BASES BACKGROUND The pressurizer is equipped with two types of devices for pressure relief: pressurizer safety valves and PORVs. The PORVs aroe air opeatod_ valves-that are controlled to open at a specific set pressure when the A @ pressurizer pressure increases and close when the pressurizer pressure decreases. The PORVs may also be manually operated from the control room. Block valves, which are normally open, are located between the pressurizer and the PORVs. The block valves are used to isolate the PORVs in case of excessive leakage or a stuck open PORV. Block valve closure is accomplished manually using controls in the control room. A stuck open PORV is, in effect, a small break loss of coolant accident (LOCA). As such, block valve closure terminates the RCS depressurization and coolant inventory loss. The PORVs and their associated block valves may be used by plant operators to depressurize the RCS to recover from certain transients if normal pressurizer spray is not available. Additionally, the series arrangement of the PORVs and their block valves permit performance of surveillances on the valves during power operation. The PORVs may also be used for feed and bleed core cooling in the case of multiple equipment failure events that are not within the design basis, such as a total loss of feedwater. v~heP rblok valves, and their controls are po INSERT1 vital buses that norma ece power froer sources, but are also capable of being p yew ncy power source in the!K event of a Sos 0 w er. Two 0O~ a ;theirsoated block _yie-r owered from two separate safety trains (Ref. 1). Each PORV has a relief capacity of _ V6, each having a relief capacity of 210,000 lb/hr 210,000 Ibmrhrat at 2335 peig. The functional design of the PORVs is based on 2500 psia for Unit maintaining pressure below the Pressurizer Pressure - High reactor trip ant2350 psia 1brnr setpoint following a step reduction of 50% of full load with steam dump. for Unit 2. In addition, the PORVs minimize challenges to the pressurizer safety valves and also may be used for low temperature overpressure protection (LTOP). See LCO 3.4.12, "Low Temporaturo Overpressure Protection WTB3.System , 0 I WOG STS B 3.4.11 - 1 Rev. 2, 04/30/01 139

I Rev. 2 Change D-17 I r---------I LT!! .4.12 'Iwi B 3.4 REACTOR COOLANT SYSTEM (RCS) B 3.4.12 Loww4RpeFatue Overpressure Protection ( P) Syste BASES O ) BACKGROUND The &4O>ystem controls RCS pressure at low temperatures so the integrity of the reactor coolant pressure boundary (RCPB) is not compromised by violating the pressure and temperature (PIT) limits of 10 CFR 50, Appendix G (Ref. 1). The reactor vessel is the limiting RCPB component for demonstrating such protection. The PTLR provides the maximum allowable actuation logic setpoints for the power operated relief valves (PORVs) and the maximum RCS pressure for the existing RCS eemperature during cooldown, shutdown, and heatup to meet the Referencemets during the bQP MODES The reactor vessel m ater at low temperatures than at c normal operating temperature. As the vessel neutron exposure F accumulates, the material toughness decreases and becomes lees resistant to pressure Mtrss at low temperatres (Ref 2). RCS pressure, therefore, is maintained low at low temperatures and is increased only as temperature is increased. The potential for vessel overpressurization is most acute when the RCS is water solid, occurring only while shutdown; a pressure fluctuation can A ' occur more quickly than an operator can react to relieve the condition. Exceeding the RCS PIT limits by a significant amount could cause brittle cracking of the reactor vessel. LCO 3.4.3, "RCS Pressure and Temperature (P/T) Limits," requires administrative control of RCS In addition, the Unit I pressure and temperature during heatup and cooldown to prevent headsafetymainjcthion exceeding the PTLR limits. (HHSI) flow path must be isolated. This LCO provides RCS overpressure prote tion by having a minimum coolant input capability and having adequa pressure relief capacity. Limiting coolant input capability requires a but Ult injection (HPI)] pump arId one charging mpj incapable of injection into the RCS and isolating the accumulators. The pressure relief capacity requires either two redundant RCS relief valves or a depressurized RCS limited to and an RCS vent of sufficient size. One RCS relief valve or the open one RCS vent is the overpressure protection device that acts to terminate an charging increasing pressure event. additional

                                       \With Fime coolant input capability the ability to providePore coolant' when low temperaturedDutoWi                is    restricted. suhe ICO ndhesnoPt Mequi         nthe makeup cGtrl0 overpressure protection is       sw~tem-deactiva ted or the safety iniection (SIl) actuation c-irc~uits Werocl-d_

required Due to the lower pressures in the LTOP1 MODES~nd the i WOG STS B 3.4.12 - 1 Rev. 2, 04/30/01 149

Rev. 2 Change D-17 BVPS ISTS Conversion 3.4 Reactor Coolant Sysl:em Enclosure 2 Changes to The ISTS Bases ITS 3.4.12 Overpressure Protection System (OPPS) Bases JUSTIFICATION FOR DEVIATION (JFD)

1. The ISTS bases text is revised to reflect the corresponding changes made to the ISTS LCO. The changes were justified in the JFDs associated with changes to ISTS 3.4.12. This includes changes in terminology as well as technical changes and reference changes due to BVPS design or licensing differences from the ISTS.

This includes the incorporation of CTS provisions (e.g., CTS specific methods for rendering pumps incapable of injecting into the RCS) that were relocated from the CTS to the ITS Bases.

2. The ISTS bases text is revised to incorporate minor editorial changes or clarifications regarding new ISTS requirements. The proposed changes are not intended to introduce technical changes to the ISTS bases and are made to enhance the clarity or further explain new requirements to help the end user.

In addition, it is unnecessary to repeatedly reference numeric values that may change in bases that are not associated with the Technical Specification containing those values. Therefore, some values are deleted and a reference to the applicable Technical Specification(s) containing the specific value is made. This reduces the potential for introducing errors in the bases when values change that are not specifically associated with that bases.

3. The ISTS Bases text is revised to incorporate BVPS specific design description information. This is done to replace the generic text that is not applicable to BVPS.

4. The ISTS bases description is revised consistent with the corresponding CTS bases description. This incorporates clarifications previously utilized in the CTS bases for OPPS.

5. The generic ISTS bases text for the low temperature overpressure protection safety analysis is revised to be specific to the BVPS OPPS analysis and corresponding CTS and ITS requirements. This includes reference changes where applicable.

6. Local verification of valve position provides an adequate alternative to remote verification and may be used to assure the valve remains in the required position.

7. The ISTS reference to engineering evaluations is replaced with the explanation that the occurrence of a design basis low temperature overpressure event during the completion time allowed by the action is unlikely. The proposed change is more consistent with the applicable BVPS licensing basis and does not diminish the validity of the bases for the Action or the fact that the Action places the plant in a safe condition.

8. The standard Bases text describing the acceptable test of required relay contacts in the bases for a Channel Operational Test is revised to refer to "any" required contacts and to delete references to non-TS testing and specific surveillance intervals. By replacing "the" with "any", the proposed change removes the implication that the applicable instrument channel always has required relay contact(s). If the instrument channel for which the bases description applies has any required relay contacts, the discussion will still apply. In addition, the references to non-TS testing and a specific surveillance interval are removed.

BVPS Units I & 2 Page 13 Revision :2, 04/06 210

BVPS UNITS I & 2 ~I4J#) ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 CHANGE D-17 AFFECTEDPAGES FOR ITS SECTION 3.5 (ECCS) ITS SECTION 3.5 (ECCS) INDEX OF AFFECTED PAGES ITS MARKUPS PAGE: 6 ITS JFDS No change ITS BASES MARKUPS PAGES: 37 & 45 ITS BASES JFDS No change CTS MARKUPS No change QJ CTS DOCS No change

I Rev. 2 Change D-17 I ECCS - Operating 3.5.2 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) 3.5.2 ECCS - Operating LCO 3.5.2 Two ECCS trains shall be OPERABLE.

                                                                   - NOTES -

f1. In MODE 3, both safety injection (Sf pump flow paths may be isolated by closing the isolation valves for up to 2 hours to perform L one of the required Icharging 2. pressure isolation valve testing per SR 3.4.14.1. In MODE 3, EGGS pumps may be made incapable of injecting to

                                        > . supor trasiton nto r fom he Apliabiityof LCO 3.4.12, I \    LowTemoraureOverresureProectonfTOPl) System~," for up to 4 hours or until the temperature of all RCS cold legs exceeds r375em     [Low Temper~turo Gyerroecuro Protection
! the OPPS enableI                      &(LTOP)a~rningfemperature specified in the PTLR plus425]0 FI,                       I whichever comes first.-

3. For Unit I onlj In MODE 3, the ECCS automatic HHS I flow path may be isolated to support transition into or from the Applicability of LCO 3.4.12, Overpressure Protection APPLICABILIT Y: MODES 1, 2, and 3.

System (OPPS)' for up to 4 hours or until the temperature of all RCS cold legs exceeds the OPPS enable temperature I specified in the PTLR plus 251F, whichever comes first. E1Ut1 CTS ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more trains A.A Restore train(s) to 72 hours inoperable. OPERABLE status. B. Required Action and B.1 Be in MODE 3. 6 hours associated Completion Time not met. AND B.2 Be in MODE 4. 12 hours C. Less than 100% of the C.1 Enter LCO 3.0.3. Immediately ECCS flow equivalent to a single OPERABLE ECCS train available. WOG STS 3.5.2- 1 Rev. 2, 04/30/01 6

ECCS - Operating I Rev. 2 Change D-17 l B 3.5.2 BASES LCO (continued) Iduring the recirculation phase of ora includes the piping, instruments, and controls to ensure an OPERABLE flow path capable of taking suction from the RWST upon awSI signal and aMatiGall transferring suction to the containment sumF During an event requiring ECCS actuation, a flow path is required to simultaneously to both the provide an abundant supply of water from the RWST to the RCS via e RCS hot or cold legs for Unit 1. The flow path from ECCS pumps and their respective supply headers to each of the Or cold the containment sump is leg injection nozzles. In the long term, this flow path may be switched to cycled alternatively take its supplV from the containment sump and to supplV its flovA994he between the RCS cold RCS hot and cold logs. legs or hot legs for Unit 2. The flow path for each train must maintain its designed independence to ensure that no single failure can disable both ECCS trains. The LCO is modified by th ee Notes. Note I As indicated in Noto 1, the Si flow paths may I;Pisolated'for 2 hours in provides an exception MODE 3, under controlled conditions, to perform pressure isolation valve allowing the LHSI flow paths testing per SR flow n ath r is ily restorable from the to be control room. one required charging pump As indicated in Note 2, oaeration in MODE 3 with made incanable of iniectina in oder to facilitate entrv into or exit from the System (OPPS), is Applicability of LCO 34.1 i "Low emperate Overpressure Protection ne cessary when OPPS GP arming erable temperature is at or near the MODE 3 boundary temperature of 3500 F. LCO 3.4.12 requires that Gertain-p~umps be rendered incapable of injecting at and beiw e IOP almiing temperature. When this enable l ire- at or near the MODE 3 boundary temperature, time is needed to mak pumps incapable of injecting prior to entering the I-IOP required charging provide time to restore the inoperable pumps to L. OPERABLE status on exiting the Applicability. yl APPLICABILI In MODES 1, 2, and 3, the ECCS OPERABILITY requirements for the limiting Design Basis Accident, a large break LOCA, are based on full l INSERT 6 power operation. Although reduced power would not require the same level of performance, the accident analysis does not provide for reduce cooling requirements in the lower MODES.l The centrifubqaLchafgin p peu the pump I num erf MODE 2 and MODE 3 requirements are bounded by the MODE 1 analysis. WOG STS B 3.5.2 - 5 Rev. 2, 04/30/01 37

Rev. 2 Change D-17 MOP curve is contained in the IST Program and was developed using the required developed head at a specific flow point as a reference point. From the reference point, a curve was drawn which is a constant percentage below the current pump performance curve. Based on the MOP curve, a verification is performed to ensure that the pump's developed head at the flow test point is greater than or equal to the required developed head.

6. Note 3 is only applicable to Unit 1. As indicated in Note 3, operation in MODE 3 with the Unit 1 ECCS automatic high head safety injection (HHSI) flow path isolated in order to facilitate entry into or exit from the Applicability of LCO 3.4.12, " Overpressure Protection System (OPPS)," is necessary when the OPPS enable temperature is at or near the MODE 3 boundary temperature of 350 0F. LCO 3.4.12 requires that the Unit 1 ECCS automatic HHSI flow path be isolated when any RCS cold leg temperature is

the enable temperature specified in the PTLR. When this temperature is near the MODE 3 boundary temperature, Note 3 provides time to isolate the ECCS automatic HHSI flow path prior to entering the OPPS Applicability, and to restore the flow path on exiting the OPPS Applicability.

45

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 169 (UNIT 2) REVISION 2 CHANGE D-18 This change adds a clarification to the Bases for ITS Surveillance Requirements 3.5.2.5 and 3.5.2.6. The proposed addition provides a more detailed explanation of the required scope of testing and is consistent with current BVPS practice. Note that the Bases for these two ITS surveillances are combined in a single Bases discussion. Affected Pages: The following Table(s) list the affected pages by type (i.e., ITS markup, CTS markup, etc.). In order to facilitate review by ITS section, a separate table is provided for each ITS section affected by the change. The page numbers listed are the ITS section specific consecutive numbers found in the lower right corner of each page. Note: Because the affected page(s) for each change were extracted from a complete ITS section electronic file, the electronic hyperlinks (created in the complete ITS section file) do not work in the collection of affected pages that follow this covet, page. ITS SECTION 3.5 (ECCS) INDEX OF AFFECTED PAGES ITS MARKUPS No change ITS JFDS No change ITS BASES MARKUPS PAGE: 41 ITS BASES JFDS PAGE: 69 CTS MARKUPS No change CTS DOCS No change

ECCS - Operating The Unit 2 recirculation spray pumps 2RSS-P21C and 2RSS-P21D start on a receipt of an B 3.5.2

                                 .<-1or simulated Containment Pressure -

I9CRAU01

                                    - High signal following a time delay.                     l Rev. 2 Change D-188 BASES            High-I'~

I xA For the Automatic Switchover E REQUIRE ENTS (continued) ,except 2RSS-P21Cand2RSS-P21D, to tie Containment Sump fun tion of the ECCS, these Surveillances include a that 4ch ECCS pump starts on receipt of an actual or simulated Si verfication of the associated signa ~This Surveillance is not required for valves that are locked, I req jired slave relay operation. The Automatc Switchover to sealed, or otherwise secured in the required position under administrative the Containment Sump, controls. The 18 month Frequency is based on the need to perform these Fur ction 7 in LCO 3.3.2, Surveillances under the conditions that apply during a plant outage and Engiineered Safety Feature Actuation System (ESFAS) the potential for unplanned plant transients if the Surveillances were Insirumentation, does not performed with the reactor at power. {he 18 month Frequency is also indjde a requirement to per om a SLAVE RELAY acceptable based on consideration of the design reliability (and TEST due to equipment safety confirming operating experience) of the equipment. The actuation logic is corcems if such a test was tested as part of ESF Actuation System testing, and equipment perbomed at power. The refore, verification of the performance is monitored as part of the Inservice Testing Program. req iired slave relay OP ERABILITY for the Autlmatic Switchover to the Containment Sump ESFAS fun tion is included in these Relin ens heflwpath on an SI neressary for 18-inonth ECCS prpe prfrEC ne se valvestops to allow proper Suiveillances. positioning for restricted flow to ac d cold leg, ensuring that the other cold legs receive a e requ urn flow. This Surveillance is noe o lnts wit flow lith oifices. The 18 monthE nyi based on the same reasons as tot di S,.5andSR 3.5.2.6.' However, this does not preclude performance of this SR 3.5.2. and nurveillance at power when it can be accomplished in a Periodic inspections of the containment sm suction inlet ensure that it safe manner. is unrestricted and stays in proper operati g condition. The 18 month Frequency is based on the need to perfo this Surveillance under the conditions that apply during a plant outage' on the need to have access to the location, and beGause of the potential for- an unplanned tranrcint if the Surveillance were performed with the reactor at power ,,This Frequency has been found to be sufficient to detect abnormal degradation and is K confirmed by operating experience. REFERENCES 1 *0 G 50, Appendix A, GDC 35.

2. 10 CFR 50.46. ection 14.3 (Unit and UFSAR, Section 15l 2)

3. Section UFSAR, 14.3.4 (Unit 1)and UFSAR, Section 6.2.1 (Unit 2).l l 4. FSAR, Chapter 115], "Accident Analysis."

UFSAR, Appendix 1A, '1971 AEC General Design Criteria Conformance,' (Unit 1)and UFSAR, Section 3.1, 'Conformance with ::J U.S. Nudear Regulatory Commission General Design Criteria,- (Unit 2). WOG STS B 3.5.2-9 Rev. 2, 04/30/01 41

Rev. 2 Change D-18 BVPS ISTS Conversion 3.5 ECCS Enclosure 2 Changes to The ISTS Bases

7. Bases changes are made to clarify that the large break LOCA analysis assumptions that form the basis for the ECCS requirements includes the assumption that offsite power is available. The Best Estimate LOCA analysis for BVPS confirms that the availability of offsite power is the limiting condition for this transient.

8. The ISTS surveillance bases discussion regarding "the need to perform the surveillance under conditions that apply during a plant outage and the potential for an unplanned transient if the surveillance were performed with the reactor at power" is revised to clarify the intent of the ISTS. The purpose of the ISTS bases discussion is to assure the surveillance is performed consistent with safe plant operation. However, the ISTS bases text could be interpreted to require all performances of the surveillance be conducted during shutdown conditions. The proposed change to the ISTS bases text is consistent with the NRC conclusions regarding shutdown restrictions on TS surveillances stated in Generic Letter 91-04. In Generic Letter 91-04, the NRC stated, "This restriction

[performance only during shutdown] ensures that a surveillance would only be performed when it is consistent with safe plant operation." The Generic Letter further stated that "The staff concludes that the TS need not restrict surveillances as only being performed during shutdown. Nevertheless, safety dictates that when refueling interval surveillances are performed during power operation, licensees give proper regard for their effect on the safe operation of the plant." As such, the proposed change to the ISTS bases incorporates a clarification to the bases that reflects the NRC guidance stated in Generic letter 91-04.

9. A clarification regarding the scope of ITS SRs 3.5.2.5 & 6 is added to the SR Bases discussion. The proposed addition to the ISTS bases reflects the current BVPS practice for testing the Automatic Switchover to Containment Sump function of the ECCS. To ensure the safe verification of this ECCS function, the testing is performed during shutdown conditions. Therefore it is performed on an 18 month interval as part of the ECCS automatic pump and valve actuation surveillances (ITS SR 3.5.2.5 & 6).

BVPS Units 1 & 2 Page 3 Revision 2, 04/06 69

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 CHANGE D-19 This change updates Volume 1, Review Information, of the original BVPS ITS Conversion submittal. The review information inthis volume of the submittal was revised to account for changes such as recently approved TSTFs, new BVPS License Amendment Requests (LARs) submitted to the NRC, LARs recently approved by the NRC, and Revision 2 changes. These changes result in complete new sections to replace the following Volume I sections:

TSTF Status,
LAR Status,
CTS Roadmap, and
ISTS Roadmap.

The new sections are labeled Revision 1 or 2 as applicable replace each corresponding current Volume 1 section (in its entirety . Note that this change does not affect any ITS or CTS pages. Volume 1 only provides information to assist inthe review of the BVPS ITS Conversion submittal. Affected Pages: A complete copy of each revised Volume 1 section follows. Each new Volume 1 section is labeled as Revision 1 or 2 to appropriately supersede the corresponding current section. As each current Volume 1 section is completely replaced by a later revision, a separate list of affected pages is not necessary.

TSTF STATUS Approved Changes I Rev. 2 Change D-19l Revision 'I Page l STATUS OF APPROVED NUREG-1431 TSTFs NOT INCORPORATED INTO REVISION 2 OF NUREG-1431 As of March 2006 (Copy of all listed TSTFs available separately on CD) APPROVED TSTF STATUS TSTF # DESCRIPTION DISPOSITION 21-A, Incorporated a Bases change to the LCO section Incorporated with changes. BVPS Rev. 0 of ITS 3.9.5, "RHR and Coolant Circulation - Low has proposed changes that are

Water Level" Bases that provides an exception to consistent with the recommendations the requirement for the RHR loops to be in NRC letter (W. D. Beckner to J.

circulating reactor coolant. The Bases exception Davis (NEI) dated 4129199). In this allows both required RHR pumps to be aligned to letter, the NRC recommended TSTF-the RWST to support filling or draining the 21, Rev.0 be revised to include a refueling cavity or for performance of required corresponding LCO exception Note testing. inthe Specification. In addition, BVPS has expanded the issue addressed by TSTF-21 to include ITS 3.9.4, "RHR and Coolant Circulation - High Water Level." These changes are listed aith the beyond scope items. 337-A, Revise LCO 3.5.5 for RCP seal injection to add a Incorporated applicable portions. Rev. 1 flow resistance option.

The BVPS CTS and proposed ITS do not use the flow resistarce option presented in this TSTF. Therefore, the flow resistance portion of this TSTF was not incorporated in the NUREG-1431 markup.

343-A Containment Structural Integrity. Affects Not Applicable. requirements for Pre-stressed Containment ev. Tendon Surveillances. Not applicable to the BVPS containment design which is not pre-stressed and does not include tendons. 347-A, P-7 Surveillance. Provides correct surveillance Incorporated. Rev. 1 for the P-7 interlock.

Incorporated in Revision 3 of NUREG-1431

TSTF STATUS Approved Changes Revision 'I KimLY Page 2 APPROVED TSTF STATUS TSTF # DESCRIPTION DISPOSITION 358-A, Missed Surveillance Requirements. Allows for Incorporated. Rev. 6 extended operation with a missed surveillance.

Already implemented in CTS.

359-A, Increase Flexibility in MODE Restraints. Incorporated. Rev. 9

Already implemented in CTS.

369-A, Removal of Monthly Operating Report and Incorporated. Rev.1 Occupational Radiation Exposure Report.

Implemented in CTS.

370-A, Increase accumulator Ccmpletion Time from I Incorporated. Rev. 0 hour to 24 hours (WvCAP-1 5049)

Already implemented in CTS.

371-A, NIS Power Range Channel Daily SR TS Change Incorporated. Rev. 1 to Address Low Power Decalibration. 372-A Addition of LCO 3.0.8, Inoperability of Snubbers Not Incorporated. Rev. 4 374-A, Revision to TS 5.5.13 and associated TS Bases Incorporated applicable portions. Rev. 0 for Diesel Fuel Oil. Added fuel oil standards to

Bases and clarified "clear and bright" fuel oil BVPS specific ITS bases includes requirement. the applicable standards for BVPS.

BVPS replaced ITS clear and bright requirement with corresponding CTS requirement. 400-A Clarify Bases for SR that verifies DG trip bypass. Incorporated Bases dlarification Rev. I portion of this TSTF. Did not

incorporate the portion of T;STF that relocates the list of trips from ITS SR 3.8.1.9 to the Bases.

401-A, Revise Incorrect Bases f r Containment Air Incorporated. Rev. 0 Temperature.

Incorporated in Revision 3 of NUREG-1431

TSTF STATUS' Approved Changes Revision 1 Page 3 APPROVED TSTF STATUS TSTF # DESCRIPTION DISPOSITION 411-A, Relaxation of Surveillance Test Intervals for the Not Incorporated. Rev. 1 Reactor Protection System (WCAP-15376-P).

Due to the complexity of this change it is planned to be implemented by a separate LAR.

41 8-A, Relaxation of RPS and ESFAS Test Times and Not Incorporated. Rev. 2 Completion Times (WCAP-14333).

Due to the complexity of this change it is planned to be implemented by a separate LAR.

419-A, Revise PTLR Definition and References in ISTS Incorporated. Rev. 0 5.6.6, RCS PTLR 420-A, Relocate Boron Injection Tank Technical Not Applicable. Rev. 0 Specification SDM value to COLR

Note: After approval of the Uprate LAR Unit 1 no longer has this Technical Specification. Unit 2 never had this Technical Specification.

Therefore, this Technical Q Specification is not included in the BVPS ITS. 421-A, Revises RCP Flywheel Inspection Program. Not Incorporated. Rev. 0

BVPS does not have the RCP Flywheel Inspection Program requirement in the CTS or proposed ITS.

429-A, Ice mass determination surveillance Not Applicable. Rev. 3 requirements.

Not applicable to the BVPS containment design. (For Ice Condenser Plants only).

433-A Eliminate SR 3.8.2.1, Note 2 from the PWR ITS Incorporated with changes A Rev. 0 NUREGs. BVPS specific Note replaces the deleted ISTS note.

Incorporated in Revision 3 of NUREG-1431

TSTF STATUS Approved Changes Revision 1 Page 4 APPROVED TSTF STATUS TSTF # DESCRIPTION DISPOSITION 434-A, Clarifying SR 3.0.1 Bases to state that Incorporated. Rev. 0 Surveillance can be performed in steps 438-A, Clarify Exception Notes to be Consistent with the Incorporated. Rev. 0 Requirement Being Excepted. 439-A Eliminates the second Completion Time in Not Incorporated. Rev. 2 certain Actions that limit the time the LCO is not

met. That is the Complelion Times that State

                'From Discovery of Failure to meet the LCO.'

440-A, Eliminate Bases Requirement for Performing a Incorporated. Rev. 0 System Walkdown. 447-A, Elimination of Hydrogen Recombiners and Incorporated. Rev. 1 Change to Hydrogen and Oxygen Monitors.

Already implemented in CTS.

449-A Steam Generator Tube Integrity Program. Not Incorporated. This TSTF is Rev. 4 Revises (simplifies) Section 5.0 requirements for being implemented into the BVPS

SG Tube Inspections, revises Section 3.4 ITS for CTS (LAR #s 3241196) submitted by operational leakage and creates new Section 3.4 letter dated 1117/05. These LARs specification for SG Tube Integrity. are expected to be approved prior to ITS approval. The BVPS ITS must be updated to reflect the proposed CTS changes.

470-A Corrects Titles and References in PAM Incorporated. Rev. 0 Instrumentation (ITS 3.3.3) Bases. 472-A Corrects a Bases change made by TSTF-283. Incorporated. Note this TSTF was Rev. 0 moved from the BVPS 'incorporated

pending list" to the approved TSTF list.

479-A Changes to reflect revision of 10 CFR 50.55a. Incorporated. Rev. 0 Affects references to ASME Section IX. The

      *        'ASME OM Code' replaces references to "ASME Section IX. Also revises the ASME Inservice Testing Requirements in Section 5.0 of the ITS.

Incorporated in Revision 3 of NUREG-1431

TSTF STATUS Approved Changes Revision I Page 5 APPROVED TSTF STATUS TSTF # DESCRIPTION DISPOSITION 482-A Corrects text in LCO 3.0.6 Bases. Incorporated. Note this TSTF was Rev. 0 moved from the BVPS 'incorporated

pending list' to the approved TSTF list.

485-A Corrects text of example 1.4-1 in Section 1.0 of Incorporated. Rev. 0 the ITS.

Incorporated in Revision 3 of NUREG-1431

TSTF STATUS Pending Changes I Rev. 2 Change D-1 9 Revision i Page 1, STATUS OF PENDING NUREG-1431 TSTFs INCORPORATED INTO THE BVPS ISTS CONVERSION SUBMITTAL (Copy of all listed TSTFs available separately on CD) TSTF # DESCRIPTION DISPOSITION 412, Rev. 0 Provides Actions for One Steam Supply to Incorporated latest version (1204). Turbine Driven AFW/EFW Pump Inoperable This TSTF provides appropriate (Section 3.7). actions for the affected condition, consistent with the BVPS safety analyses assumptions. The TSTF also clarifies the operability status of the turbine-driven AFW when a single steam supply is inoperable. 451-T, Provides corrections to Battery Monitoring and Incorporated portion addressing Rev. 0 Maintenance Program (Section 5.0) and the Bases of SR 3.8.4.2. Portion of Bases of SR 3.8.4.2 (Section 3.8). TSTF affecting the Battery Monitoring Program in Section 5.0 of ITS was withdrawn from BVPS ITS submittal. 453 -T, Provides a new Technical Specification (in Incorporated latest version of this Rev. 2 Section 3.1) and revises existing requirements TSTF (12104) in cooperation with (in Section 3.3) necessary to more completely Westinghouse and consistent with address a rod withdrawal from subcritical the applicable BVPS safety conditions (RWFS) event. The TSTF adds new analyses. operating restrictions (boron concentration requirements) during conditions when the power range nuclear instrumentation may not be able to provide the necessary trip function protection from an RWFS event. 472-T, Corrects a bases error introduced by Update. Moved to Approved TSTF Rev. 0 implementation of Approved TSTF-283 List. Incorporated in Rev. '. of (approved by the NRC in 11/2000). Affects NUREG-1431. Section 3.8. (Status: Incorporatad)

TSTF STATUS Pending Changes Revision I1 Page 2 STATUS OF PENDING NUREG-1431 TSTFs INCORPORATED INTO THE BVPS ISTS CONVERSION SUBMITTAL (Copy of all listed TSTFs available separately on CD) TSTF # DESCRIPTION DISPOSITION 482, Rev. 0 Provides editorial enhancements to the Bases for Update. Moved to Approved TSTF LCO 3.0.6. Minor changes that help clarify List. Incorporated in Rev. a-;of (WOG-176) support and supported systems. Includes other NUREG-1431. less significant editorial changes to the Bases for LCO 3.0.6 as well. (Status: Incorporated) 491, Rev. 0 Relocates Main Steam and Feedwater Isolation Incorporated. Valve closure times to document outside of the Technical Specifications that is controlled by 10 CFR 50.59.

LAR STATUS Rev. 2 Change D-19 Page ) Revision 2 YJuy BVPS ITS CONVERSION PROJECT OUTSTANDING LICENSE AMENDMENT REQUEST (LAR) STATUS The approval for all of the following outstanding LARs has been requested prior to the approval of the BVPS Improved Technical Specification (ITS) conversion LAR. Therefore, the changes proposed in each of the following LARs have been incorporated into the BVPS Current Technical Specifications (CTS) used in the ITS conversion documentation. The proposed changes from the LARs are incorporated directly into the affected CTS (i.e., not marked-up on the CTS). The ITS conversion documentation assumes approval of each outstanding LAR as submitted. Each CTS page inthe ITS conversion documentation affected by one or more of the following LARs is clearly marked (in the upper right hand corner) as a "Draft Page" from the applicable LAR(s). Following NRC approval of the outstanding LARs, the ITS conversion LAR will be supplemented by letter. In the supplemental letter(s), the "Draft" CTS pages used in the ITS LAR will either be confirmed as approved or replaced by CTS pages with the required changes to make the ITS conversion LAR documentation conform to the final NRC approved BVPS license amendments. An electronic copy of each LAR listed below is available (separately on CD). In Attachment A to each outstanding LAR (A-1 for Unit I and A-2 for Unit 2) a list of affected pages and detailed markups of those pages are provided. The following list of LARs is only intended to provide an overview and brief description of the outstanding LARs.

LAR STATUS Page 2 Revision 2 Unit I Unit 2 LAR Description and Status ISTS Conversion LAR # LAR # Documentation Status 184 Unit 2 Response Time Testing. Allows response Approved changes time to be verified by other means than performing incorporated aid a test. Includes a bases change. LAR is consistent pages updated with with the guidance provided in WCAP-13632-P-A new amendment and WCAP-14036-P-A number in Revision 1. Submitted by letter dated July 23, 2004. LAR No.1 84 was approved by the NRC in Unit 2 license amendment No. 147 issued March 24, 2005 (TAC No. MC3894). 306 176 Emergency Diesel Generator Allowed Outage Time Approved changes extension to 14 days. A risk informed LAR. incorporated and pages updated with Submitted by letter dated May 26, 2004. new amendment number in Revision 1. LAR Nos. 306 and 176 were approved by the NRC in license amendment Nos. 268 (Unit 1) and 150 (Unit 2) issued September 29, 2005 (TAC Nos. MC3331 and MC3332). 309 181 Channel Functional Test Surveillance interval Approved changes extension for undervoltage relays and RWST level. incorporated and Based on the NRC approved methodology in pages updated with WCAP-10271. new amendme nt number in Revision 1. Submitted by letter dated June 2, 2004. LAR Nos. 309 and 181 were approved by the NRC in license amendment Nos. 267 (Unit 1) and 149 (Unit 2) issued September 19, 2005 (TAC Nos. MC3404 and MC3405).

LAR STATUS Page :3 Revision 2 Unit I Unit 2 LAR Description and Status ISTS Conversion LAR# LAR # Documentation Status 326 177 Unit 2 Capsule W &Overpressure Protection Approved changes System changes. Also improves consistency of TS incorporated aid requirements for low temperature overpressure pages updated with protection between units and with the ISTS. new amendment number in Revision 1. Submitted by letter dated June 1, 2004. LAR Nos. 326 and 177 were approved by the NRC in license amendment Nos. 265 (Unit 1) and 146 (Unit 2) issued March 11, 2005 (TAC Nos. MC3375 and MC3376). 329 198 Deletion of Monthly Operating Report & Approved changes Occupational Radiation Exposure Report (TST-369 incorporated a nd CLIIP) pages updatec with new amendment Submitted by letter dated February 22, 2005. number in Revision 1. LAR Nos. 329 and 198 were approved by the NRC in license amendment Nos. 266 (Unit 1) and 148 (Unit 2) issued July 28, 2005 (TAC Nos. MC6176 and MC 6177). 314 187 Post Accident Monitoring Instrumentation (PAM) Affected ITS Revision. Update PAM instrumentation conversion requirements consistent with guidance of WCAP- documentation revised 15981, Post Accident Monitoring Instrumentation to reflect withdrawal of Re-Definition for Westinghouse NSSS Plants." The LARs 314 and 187 in WCAP was submitted to the NRC 9/17104. Revision 1. Submitted by letter dated February 22, 2005. LARs 314 and 187 were withdrawn by FENOC letter dated May 11, 2005.

LAR STATU'; Page ' Revision 2 Unit I Unit 2 LAR Description and Status ISTS Conversion LAR# LAR # Documentation Status 302 173 Extended Power Uprate. 2689 MWt to 2900 MWt Draft pages rated Thermal Power. incorporated. Note: Some Unit 1 changes from this LAR were incorporated into a separate Unit 1 LAR (#320) to support the Unit 1 Replacement SG effort. See separate listing for Unit 1 LAR # 320. This LAR includes the elimination of the Unit 1 TS (3.5.4.1.1) that addresses Boron Injection Tank (BIT) volume and boron concentration requirements applicable in Modes 1-3. Therefore, this Unit 1 TS is not shown in the BVPS conversion documentation for Section 3.5. Unit 2 does not have a corresponding BIT TS. Submitted by letter dated October 4, 2004. 310 182 Constant Axial Offset Control (CAOC) to Relaxed Approved changes Axial Offset Control (RAOC). Also incorporates incorporated and changes to conform more closely to corresponding pages updated with ISTS requirements. new amendment number in Revision 2. J Submitted by letter dated February 11, 2005. LAR Nos. 310 and 182 were approved by the

                 ,NRC in license amendment Nos. 274 (Unit 1) and 155 (Unit 2) issued February 27, 2006 (TAC Nos. MC5904 and MC5905).

317 190 Containment Atmospheric Conversion. Approved changes incorporated and Proposes changes to convert the subatmospheric pages updated with containment TS requirements to more closely new amendment conform to atmospheric containment TS number in Revision 2. requirements. Submitted by letter dated June 2, 2004. LAR Nos. 317 and 190 were approved by the NRC in license amendment Nos. 271 (Unit 1) and 153 (Unit 2) issued February 6, 2006 (TAC Nos. MC3394 and MC3395).

LAR STATUS' Page 5 Revision 2 Unit 1 Unit 2 LAR Description and Status ISTS Conversion LAR# LAR # Documentation Status 318 191 Best Estimate Loss of Coolant Accident Approved changes (BELOCA). Consistent with WCAP-12945-P-A. incorporated and pages updated with Submitted by letter dated October 4, 2004. new amendment number in Revision 2. LAR Nos. 318 and 191 were approved by the NRC in license amendment Nos. 272 (Unit 1) and 154 (Unit 2) issued February 6, 2006 (TAC Nos. MC4647 and MC4648). 325 195 Control Room Emergency Ventilation System Draft pages (CREVS) incorporated. Revision of current requirements to make the BVPS requirements consistent between Units and to conform more closely to the corresponding ISTS (Rev. 3) requirements. Adds new TS 3.7.6 to address Control Room Emergency Air Cooling System (CREACS). Revises U1 Applicability for control room radiation monitors to be consistent with U2 (i.e., required for recently irradiated fuel movement instead of any 5w irradiated fuel movement). Submitted by letter dated February 17, 2005. 327 197 Revise Unit 1 & 2 SG Low Level Reactor Trip and Approved changes ESFAS Allowable values and Unit 2 ESFAS SG incorporated and level high allowable value. pages updated with new amendment The pages containing the Unit 1 SG Low Level number in Revision 2. value changed by this LAR are superceded by value used in the Replacement SG LAR (#320). Submitted by letter dated October 5, 2004. LAR Nos. 327 and 197 were approved by the NRC in license amendment Nos. 270 (Unit 1) and 152 (Unit 2) issued January 11, 2006 (TAC Nos. MC4649 and MC4650).

LAR STATU.S Page 6 Revision 2 <4j) Unit I Unit 2 LAR Description and Status ISTS Conversion LAR# LAR # Documentation Status 202 This change eliminates the Technical Specification Draft pages references to the Unit 2 rectifiers. The resulting incorporated. Technical Specifications will only refer to battery chargers instead of both rectifiers and chargers. Submitted by letter dated October 14, 2005 and approval has been requested prior to the implementation of the BVPS ITS conversion License Amendment. 320 The BVPS Unit I LAR # 320 proposed changes to Approved changes support the replacement Steam Generators (RSG). incorporated and LAR # 320 contains changes previously submitted pages updated with in Unit 1 LAR # 302 for the extended power uprate new amendment (EPU). number in Revision 2. Submitted by letter dated April 13, 2005. Unit I LAR No. 320 was approved by the NRC in Unit I license amendment No. 273 issued February 9, 2006 (TAC No. MC6725. This Amendment includes Unit 1 changes that were previously identified as part of the Extended Power Uprate LAR (LAR # 302) in the ITS conversion submittal documentation. 173 Supplement to Unit 2 Extended Power Uprate Draft pages LAR (# 173). incorporated. The revisions in this supplement raise the minimum Accumulator nitrogen cover pressure to 611 psig, delete the percent indicated level from the accumulator volume requirements, and insert

                   .usable" in the LCO statement for accumulator volume (to match the existing SR text). The corresponding Unit 1 change was approved in the Replacement SG Amendment # 273 issued 2/9/06 (see Unit 1 LAR # 320).

Submitted by FENOC letter L-05-168 dated 10/28/05.

LAR STATUS Page 7 Revision 2 Unit I Unit 2 LAR Description and Status ISTS Conversion LAR# LAR # Documentation Status 173 Supplement to Unit 2 Extended Power Uprate Draft pages LAR (# 173). incorporated. Although this supplement does not revise any technical specifications it does include a technical specification Bases change for the AFW System. The Bases addition justifies the 72 hour time allowed for one inoperable AFW pump (i.e., how the AFW System flow requirements are met with a single inoperable AFW pump. The corresponding Unit 1 bases change was approved in the RSG Amendment # 273 (see Unit 1 LAR # 320). Submitted by FENOC letter L-05-198 dated 12/16/05. 324 196 This LAR Implements TSTF-449. TSTF 449 Not incorporated. revises the definition of Leakage, introduces a new Final draft pages from ITS LCO (3.4.20) in Section 3.4 titled Steam this LAR were not Generator Tube Integrity, revises ITS 3.4.13, available for inclusion Operational Leakage, revises Specification 5.5.5, in Revision 2. The ITS SG Tube Surveillance Program, and Revises 5.6.6, conversion SG Tube Inspection Report. This LAR is expected documentation will be to be approved prior to the approval of the BVPS updated to include the ITS. changes in this LAR in a future revision. Submitted by FENOC Letter L-05-144 dated 117/05. Note F* requirements from U2 LAR No. 183 must be incorporated into new 5.5.5, SG Tube Inspection Program.

LAR STATUS Page B Revision 2 Unit I Unit 2 LAR Description and Status ISTS Conversion LAR# LAR # Documentation Status 183 Implements F* Tube plugging criteria for U2 SG Not incorporated. tubes with degradation in the tubesheet roll Final draft pages from expansion region (WCAP-16385-NP, Rev. 1). The this LAR were not changes affect the SG Tube Inspection Program available for inclusion requirements in Section 5.0 of the BVPS ITS. in Revision 2. The ITS conversion Submitted by FENOC Letter L-05-061 dated documentation will be 4/11/05. updated to include the NOTE: This LAR must be incorporated into the changes in this LAR in changes resulting from U2 LAR 196 (new SG Tube a future revision. Inspection Program in Section 5.0 of the ITS).

t1 _ v* E7 CTS ROADMAP I Rev. 2 Change D-19 l Page 1 Revision 2 BVPS UNIT I AND UNIT 2 CURRENT TECHNICAL SPECIFICATIONS (CTS) ROADMAP LISTED IN CTS ORDER NOTES:

1. Each CTS and BVPS Improved Technical Specification (ITS) listed below is common to both units unless identified as unit specific.

2. Unit 1 CTS pages are only included in the CTS markups when a technical difference exists between the Unit 1 page and the Unit 2 page.

3. Each marked-up CTS page In the submittal affected by an outstanding License Amendment Request (LAR) is clearly identified as a draft page with the applicable LAR number(s) referenced.

CTS SECTION 1.0 DEFINITIONS CT S (1.0) BVPS ITS (1.1) NOTES APPLICABLE LICENSE AMENDMENT REQUESTS Defined Terms Section 1.1 Note Retained in ITS Section 1.1 as a Note. Thermal Power Thermal Power Rated Thermal Power Rated Thermal Power Draft pages utilized from LAR #s 302 (Unit 1)and 173 (Unit 2). Operational Mode Mode Action Actions Operable - Operability Operable - Operability Reportable Event N/A Not used in ITS. Containment Integrity N/A Not used in ITS. Channel Calibration Channel Calibration Channel Check Channel Check Channel Functional Test Channel Operational Test &Trip Actuating Device Operational Test Core Alteration Core Alteration

Ar-t

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  ,-Z-CTS ROADMAP Page 2 Revision 2 CTS SECTION 1.0 DEFINITIONS CTS (1.0)                    BVPS ITS (1.1)                                   NOTES   APPLICABLE LICENSE AMENDMENT REQUESTS Shutdown Margin               Shutdown Margin Leakage                       Leakage Quadrant Power Tilt Ratio     Quadrant Power Tilt Ratio Dose Equivalent 1-131         Dose Equivalent 1-131 Staggered Test Basis          Staggered Test Basis Frequency Notation            N/A                                  Not used in ITS.

Reactor Trip System Response Reactor Trip System Response Time Time Engineered Safety Feature Engineered Safety Feature Response Time Response Time Axial Flux Difference Axial Flux Difference Physics Tests Physics Tests E - Average Disintegration E - Average Disintegration Energy Energy Source Check N/A Not used in ITS. Process Control Program N/A Not used in ITS. Offsite Dose Calculation 5.5.1 Offsite Dose Calculation Moved to Section 5.0 of ITS. Manual (ODCM) Manual (ODCM) Gaseous Radwaste Treatment N/A Not used in ITS. System Ventilation Exhaust Treatment N/A Not used in ITS. System . Purge-Purging N/A Not used in ITS.

OF k II CTS ROADMAP Page 3 Revision 2 CTS SECTION 1.0 DEFINITIONS CTS (1.0) BVPS ITS (1.1) NOTES APPLICABLE LICENSE

                                             .                                                 AMENDMENT REQUESTS Venting                      N/A                                 Not used in ITS.

Major Changes NIA Not used in ITS. Member(s) Of The Public NMA Not used in ITS. Core Operating Limits Report Core Operating Limits Report Pressure And Temperature Pressure And Temperature Limits Limits Report (PTLR) Report (PTLR) . Table 1.1 Operational Modes Table 1.1 Modes Table 1.2 Frequency Notation NIA Not used in ITS. CTS SECTION 2.1 SAFETY LIMITS CTS BVPS ITS NOTES APPLICABLE LICENSE AMENDMENT REQUESTS 2.1.1 Reactor Core 2.1.1 Reactor Core SLs Draft page utilized from LAR 173 (Unit 2). 2.1.2 Reactor Coolant System 2.1.2 Reactor Coolant System Pressure Pressure SL CTS SECTION 3/4.0 APPLICABILITY CTSBVPS ITS NOTES APPLICABLE LICENSE AMENDMENT REQUESTS 3/4.0 Applicability 3.0 Limiting Condition For Operation (LCO) Applicability 3.0 Surveillance Requirement (SR) Appricability

r L CTS ROADMAP Page 4 Revision 2 CTS SECTION 3/4.1 REACTIVITY CONTROL SYSTEMS CTS BVPS ITS NOTES APPLICABLE LICENSE AMENDMENT REQUESTS 3/4.1.1.1 SHUTDOWN 3.1.1 Shutdown Margin CTS Surveillance 4.1.1.1.2 was expanded into a MARGIN -Tg > 200-F separate specification for core reactivity (3.1.2) in the 3.1.2 Core Reactivity ITS. 3/4.1.1.2 SHUTDOWN 3.1.1 Shutdown Margin Both CTS Shutdown Margin specifications are MARGIN - Tvg s 2001F combined in a single ITS 3.1.1. 3/4.1.1.3 Boron Dilution N/A Relocated to the Licensing Requirements Manual (LRM). 3/4.1.1.4 Moderator 3.1.3 Moderator Temperature Temperature Coefficient (MTC) Coefficient (MTC) 314.1.1.5 Minimum 3.4.2 RCS Minimum Temperature CTS moved to Section 3.4 (RCS) in the ITS. Temperature for Criticality for Criticality Changes to the CTS are shown in Section 3.4. 3/4.1.2.8 Refueling Water 3.5.4 Refueling Water Storage CTS moved to Section 3.5 (ECCS) in the ITS. Draft page utilized from LAR #8 Storage Tank Tank (RWST) Changes to the CTS are shown in Section 3.5. 302 (Unit 1) and 173 (Unit 2). 3/4.1.2.9 Isolation of 3.1.8 Unborated Water Source BVPS specific CTS applicable in Modes 4, 5 and 6. Unborated Water Sources - Isolation Valves The proposed ITS is based on ISTS 3.9.2, Unborated Shutdown Water Source Isolation Valves but retained in Section 3.1 consistent with the CTS since it is applicable in Modes other than Mode 6. 3/4.1.3.1 Group Height 3.1.4 Rod Group Alignment Limits 314.1.3.2 Position Indication 3.1.7.1 Unit 1 Rod Position Due to design differences (Unit 1 Analog System and Systems - Operating Indication Unit 2 Digital System) and other CTS differences, 3.1.7.2 Unit 2 Rod Position separate unit specific specifications are proposed. Indication 3/4.1.3.4 Rod Drop Time 3.1.4 Rod Group Alignment Limits CTS requirements incorporated into ITS 3.1.4 as SR 3.1.4.3.

C e CTS ROADMAP Page 5 Revision 2 CTS SECTION 3/4.1 REACTIVITY CONTROL SYSTEMS CTS BVPS ITS NOTES APPLICABLE LICENSE AMENDMENT REQUESTS 314.1.3.5 Shutdown Rod 3.1.5 Shutdown Bank Insertion Insertion Limit Limits 3/4.1.3.6 Control Rod Insertion 3.1.6 Control Bank Insertion Limits Limit CTS SECTION 314.2 POWER DISTRIBUTION LIMITS CTS BVPS ITS NOTES APPLICABLE LICENSE AMENDMENT REQUESTS 3/4.2.1 Axial Flux Difference 3.2.3 Axial Flux Difference (AFD) (AFD) 3/4.2.2 Heat Flux Hot Channel 3.2.1 Heat Flux Hot Channel Factor Factor FQ (Z) (Fo(Z)) 3/4.2.3 Nuclear Enthalpy ( N )N Hot 3.2.2 Nuclear Enthalpy Rise Hot Channel Factor (FAH) Channel Factor (FAH) 3/4.2.4 Quadrant Power Tilt 3.2.4 Quadrant Power Tilt Ratio Ratio (QPTR) 3/4.2.5 DNB Parameters 3.4.1 RCS Pressure, Temperature, CTS moved to Section 3.4 (RCS) in the ITS. and Flow Departure from Nucleate Changes to the CTS are shown in Section 3.4. Boiling (DNB) Limits

.0-C., 147 CTS ROADMAP Page 6 Revision 2 CTS SECTION 3/4.3 INSTRUMENTATION CTS BVPS ITS NOTES APPLICABLE LICENSE AMENDMENT REQUESTS 314.3.1 Reactor Trip System 3.3.1 RTS Instrumentation The RTS requirements are in Section 3.3A of the Draft pages utilized from LAR Instrumentation 3.3.8 Boron Dilution Detection BVPS conversion documentation. #s 302 (Unit 1) ana 173 (Unit 2). Instrumentation Source Range Indication only requirements moved to ITS 3.3.8 in Section 3.3B of BVPS conversion documentation. Changes to the Source Range Indication requirements are shown in Section 3.3B. 314.3.2 Engineered Safety 3.3.2 ESFAS Instrumentation Section 3.3C of BVPS conversion documentation. Draft pages utilized from LAR # Feature Actuation System 3.3.5 Loss of Power LOP DG Start ESF bus undervoltage relays moved to ITS 3.3.5 in 302 (Unit 1) nstrumentation and Bus Separation Section 3.3B of the conversion documentation. Instrumentation 3/4.3.3.1 Radiation Monitoring 3.3.6 Unit 2 ITS 3.3.6 Containment Section 3.3B of BVPS conversion documentation. Draft pages utilized from LAR # Purge and Exhaust Isolation Unit I requirements for the Containment Purge and 325 (Unit 1). Instrumentation Exhaust Isolation Radiation Monitors are Relocated ITS 3.3.7, Control Room to the Unit 1 LRM. Emergency Ventilation System (CREVS) Instrumentation ITS 3.4.15, RCS Leakage Detection Instrumentation 3/4.3.3.5 Remote Shutdown 3.3.4 Remote Shutdown Section 3.3B of BVPS conversion documentation. Instrumentation Instrumentation 3/4.3.3.8 Post Accident 3.3.3 Post Accident Monitoring Section 3.3B of BVPS conversion documentation. Monitoring (PAM) (PAM) Instrumentation Instrumentation CTS SECTION 3/4.4 REACTOR COOLANT SYSTEM (RCS) CTS BVPS ITS NOTES APPLICABLE LICENSE AMENDMENT REQUESTS

C' L CTS ROADMAP Page 7 Revision 2 CTS SECTION 314.4 REACTOR COOLANT SYSTEM (RCS) CTS BVPS ITS NOTES APPLICABLE LICENSE AMENDMENT REQUESTS 3/4.4.1.1 RCS Loops - Normal 3.4.4 RCS Loops - Modes 1 and 2 Operation 314.4.1.2 RCS Loops - Hot 3.4.5 RCS Loops - Mode 3 Standby 3/4.4.1.3 RCS Loops - 3.4.6 RCS Loops - Mode 4 Shutdown 3.4.7 RCS Loops Mode 5, Loops Filled 3.4.8 RCS Loops Mode 5, Loops Not Filled 3/4.4.1.4.1 Loop Isolation 3.4.17 RCS Loop Isolation Valves Valves - Operating 3/4.4.1.5 Isolated Loop Startup 3.4.18 RCS Isolated Loop Startup 3/4.4.3 Safety Valves 3.4.10 Pressurizer Safety Valves Draft pages utilized from Unit 2 LAR # 173. Draft page utilized from Unit I LAR # 302. 3/4.4.4 Pressurizer 3.4.9 Pressurizer 3/4.4.5 Steam Generators 5.5.5 Steam Generator (SG) Tube CTS surveillance requirements moved to ITS Section Draft pages utilized from LAR # Surveillance Program 5.5.5.1 (Unit 1) and 5.5.5.2 (Unit 2). Detailed markup 173 (Unit 2). See Section 5.0 SR 3.4.13.2 of both Units requirements in Section 5.0. markups for affected pages. Requirement to meet the Section 5 Program retained LAR #s 324 (Unit 1) & 196 (Unit in ITS 3.4.13 as SR 3.4.13.2. 2) & 183 (Unit 2) for SG Tube Inspection Program. Draft pages not incorporated yet. 3/4.4.6.1 Leakage Detection 3.4.15 RCS Leakage Detection Applicable pages from 3/4.3.3.1 Radiation Monitoring Instrumentation Instrumentation (as modified by Unit 2 LAR 187) are included in Section 3.4 to show addition of Rad Monitors. A ,A, 2 Cpe tion! LeakIge , 41 RCS OperatinnI LonkIn" I AR #e 324 (Unit 1) & 196 (Unit I

C r E-CTS ROADMAP Page 8 Revision 2 CTS SECTION 3/4.4 REACTOR COOLANT SYSTEM (RCS) CTS BVPS ITS NOTES APPLICABLE LICENSE AMENDMENT REQUESTS

2) for SG Tube Inspection Program. Draft pages no incorporated yet.

314.4.6.3 Pressure Isolation 3.4.14 RCS Pressure Isolation Valves Valve (PM Leakage 3/4.4.8 Specific Activity 3.4.16 RCS Specific Activity Unit I LAR # 302 makes the Unit 1 specific activity Unit 1 LAR #302. limit the same as Unit 2. Therefore, with no other difference, the Unit 1 pages are not included in the BVPS conversion documentation. 3/4.4.9.1 RCS Pressure 3.4.3 RCS Pressure and Temperature Limits Temperature (P/T) Limits 3/4.4.9.3 Overpressure 3.4.12 Overpressure Protection Protection Systems System (OPPS) I 3/4.4.11 Relief Valves 3.4.11 Pressurizer Power Operated Relief Valves (PORVs) CTS SECTION 3/4.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) CTS BVPS ITS NOTES APPLICABLE LICENSE AMENDMENT REQUESTS 3/4.5.1 Accumulators 3.5.1 Accumulators Draft pages utilized from LAR # 173 (Unit 2). 3/4.5.2 ECCS Subsystems - 3.5.2 ECCS - Operating Draft pages from Unit 1 LAR # T.g Ž 3500 F 302.

CTS ROADMAP Page 9 Revision 2 CTS SECTION 314.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) CTS BVPS ITS NOTES APPLICABLE LICENSE AMENDMENT REQUESTS 3/4.5.3 ECCS Subsystems - 3.5.3 ECCS - Shutdown Draft pages from Unit I LAR # T.as < 3500 F 302. 314.5.4 Seal Injection Flow 3.5.5 Seal Injection Flow Draft pages from Unit 2 LAR # (Unit 2) 173. 3/4.5.4.1.1 Boron Injection N/A This Unit 1CTS is deleted in uprate LAR # 302. Unit 1 LAR # 302. Tank Ž 3500 F (Unit 1) Therefore, this CTS is not included in the BVPS conversion documentation. 3/4.5.1.2 Boron Injection Tank 3.4.12 Overpressure Protection Unit 1 LAR # 302 revises and renames the CTS to Draft pages from Unit 1 LAR # < 3500F (Unit 1) System (OPPS) "3/4.5.4 HHSI Flow Path." As the requirements of 302. this Unit 1 CTS are for low temperature overpressure protection, the requirements are moved to ITS 3.4.12. Changes to the CTS are shown in Section 3.4. 3/4.5.5 Seal Injection Flow 3.5.5 Seal Injection Flow Uprate LAR #s 302 (Unit 1) and 173 (Unit 2) make (Unit 1) the Unit 1 and Unit 2 CTS requirements for Seal Injection Flow the same. Therefore, this Unit 1 CTS is not included in the BVPS conversion documentation. CTS SECTION 314.6 CONTAINMENT SYSTEMS CTS BVPS ITS NOTES APPLICABLE LICENSE AMENDMENT REQUESTS 3/4.6.1.1 Containment Integrity 3.6.1 Containment CTS valve surveillance moved to ITS 3.6.3. 3/4.6.1.2 Containment N/A CTS replaced by requirements in ITS 3.6.1 and the Leakage containment leakage rate testing program. 314.6.1.3 Containment Air 3.6.2 Containment Air Locks CTS requirements for air lock door leakage moved Locks into ITS 5.5.12, "Containment Leakage Rate Testing Program." Changes to these requirements are __

CTS ROADMAP Page 10 Revision 2 CTS SECTION 314.6 CONTAINMENT SYSTEMS CTS BVPS ITS NOTES APPLICABLE LICENSE AMENDMENT REQUESTS shown in Section 5.0 of the conversion documentation. 3/4.6.1.4 Internal Pressure 3.6.4 Containment Pressure Although BVPS was originally designed with a subatmospheric containment, LAR #s 317/190 make the temperature and pressure requirements close to an atmospheric containment. Therefore, the ISTS atmospheric temperature and pressure requirements were selected for the BVPS specific ITS. 314.6.1.5 Air Temperature 3.6.5 Containment Air Temperature Although BVPS was originally designed with a subatmospheric containment, LAR #s 317/190 make the temperature and pressure requirements close to an atmospheric containment. Therefore, the ISTS atmospheric temperature and pressure requirements were selected for the BVPS specific ITS. 314.6.1.6 Containment N/A CTS replaced by requirements in ITS 3.6.1 and the Structural Integrity containment leakage rate testing program. 3/4.6.2.1 Containment Quench 3.6.6 Quench Spray System Spray System 3/4.6.2.2 Containment 3.6.7 Recirculation Spray System Recirculation Spray System 3/4.6.2.3 Chemical Addition 3.6.8 Spray Additive System System 3/4.6.3 Containment Isolation 3.6.3 Containment Isolation Valves Valves

I- - r CTS ROADMAP Page 11 Revision 2 CTS SECTION 3/4.7 PLANT SYSTEMS CTS BVPS ITS NOTES APPLICABLE LICENSE AMENDMENT REQUESTS 3/4.7.1.1 Main Steam Safety 3.7.1 Main Steam Safety Valves Draft pages utilized from LAR #s Valves (MSSVs) (MSSVs) 302 (Unit 1) and 173 (Unit 2). 3/4.7.1.2 Auxiliary Feedwater 3.7.5 Auxiliary Feedwater (AFW) System System 3/4.7.1.3 Primary Plant 3.7.6 Primary Plant Demineralized Draft pages utilized from LAR #s Demineralized Water (PPDVW) Water Storage Tank (PPDWST) 302 (Unit 1) and 173 (Unit 2). 3/4.7.1.4 Activity 3.7.13 Secondary Specific Activity Unit 1 LAR # 302 makes the Unit 1 specific activity Unit 1 LAR #302. limit the same as Unit 2. Therefore, with no other difference, the Unit 1 pages are not included in the BVPS conversion documentation. 3/4.7.1.5 Main Steam Isolation 3.7.2 Main Steam Isolation Valves Valves (MSIVs) 3/4.7.3 Component Cooling 3.7.7 Component Cooling Water Water System (Unit 1) (CCW) System 3/4.7.3 Primary Component Cooling Water System (Unit 2) 3/4.7.4 Reactor Plant River 3.7.8 Service Water System (SWS) Water System (Unit 1) - 3/4.7.4 Service Water System (Unit 2) 3/4.7.5 Ultimate Heat Sink - 3.7.9 Ultimate Heat Sink (UHS) Ohio River 3/4.7.6 Control Room 3.7.11 Control Room Emergency Draft pages utilized from LAR #s Emergency Air Cooling System Air Cooling System (CREACS) 325 (Unit 1) and 195 (Unit 2). (CREACS)

L I-- CTS ROADMAP Page 12 Revision 2 CTS SECTION 314.7 PLANT SYSTEMS CTS BVPS ITS NOTES APPLICABLE LICENSE AMENDMENT REQUESTS 3/4.7.7 Control Room 3.7.10 Control Room Emergency Draft pages utilized from LAR #s Emergency Ventilation System Ventilation System (CREVS) 325 (Unit 1) and 195 (Unit 2). (CREVS) 3/4.7.8 Supplemental Leak N/A This CTS is applicable in Modes 1-4 and is Collection and Release System Relocated to the Licensing Requirements Manual (SLCRS) (LRM). SLCRS requirements for fuel movement involving recently irradiated fuel are retained in ITS 3.7.12, "SLCRS" consistent with CTS 3.9.12. CTS SECTION 314.8 ELECTRICAL POWER SYSTEMS CTS BVPS ITS NOTES APPLICABLE LICENSE AMENDMENT REQUESTS 3/4.8.1.1 AC Sources 3.8.1 AC Sources Operating Operating 3.8.3 Diesel Fuel Oil, Lube Oil, and Starting Air 5.5.9 Diesel Fuel Oil Testing Program 3/4.8.1.2 AC Sources 3.8.2 AC Sources Shutdown Shutdown 3/4.8.2.1 AC Distribution 3.8.7 Inverters Operating Operating 3.8.9 Distribution Systems Operating 3/4.8.2.2 AC Distribution 3.8.8 Inverters Shutdown Shutdown 3.8.10 Distribution Systems Shutdown 3/4.8.2.3 DC Distribution 3.8.4 DC Sources Operating Draft pages utilized from Unit Ooeratino 2 LAR #202

A-U CTS ROADMAP Page 13 Revision 2 CTS SECTION 314.8 ELECTRICAL POWER SYSTEMS CTS BVPS ITS NOTES APPLICABLE LICENSE AMENDMENT REQUESTS 3.8.6 Battery Cell Parameters 3.8.9 Distribution Systems Operating 3/4.8.2.4 DC Distribution 3.8.5 DC Sources Shutdown Draft pages utilized from Unit Shutdown 3.8.10 Distribution Systems 2 LAR # 202 Shutdown CTS SECTION 3/4.9 REFUELING OPERATIONS CTS BVPS ITS NOTES APPLICABLE LICENSE AMENDMENT REQUESTS 3/4.9.1 Boron Concentration 3.9.1 Boron Concentration 3/4.9.2 Instrumentation 3.9.2 Nuclear Instrumentation 3/4.9.3 Decay Time N/A Moved from the CTS to the LRM by an LA DOC. 3/4.9.4 Containment Building 3.9.3 Containment Penetrations Penetrations 3/4.9.8.1 RHR and Coolant 3.9.4 RHR and Coolant Circulation Circulation - High Water Level 3/4.9.8.2 RHR and Coolant 3.9.5 RHR and Coolant Circulation Circulation Low Water Level - Low Water Level 3/4.9.9 Containment Purge 3.3.6 Unit 2 Purge and Exhaust Unit 2 valve actuation surveillance requirements and Exhaust Isolation System Isolation Instrumentation, retained in ITS 3.9.3, 'Containment Penetrations." 3.9.3 Containment Penetrations Remainder of CTS 3/4.9.9 moved to Instrumentation 3 C a n t Sectin 3.3_ ._n'he _s cn_..e-i. d-c.--..i-...-

CTS ROADMAP Page 14 Revision 2 CTS SECTION 314.9 REFUELING OPERATIONS CTS BVPS ITS NOTES APPLICABLE LICENSE AMENDMENT REQUESTS (for Unit 2 valve actuation All Unit I CTS 3/4.9.9 requirements Relocated to the surveillances) LRM. All changes to CTS 3/4.9.9 except for the Unit 2 Valve actuation requirements moving to ITS 3.9.3 are shown in Section 3.3B. 314.9.10 Water Level Reactor 3.9.6 Refueling Cavity Water Level Vessel 3/4.9.11 Storage Pool Water 3.7.15 Fuel Storage Pool Water Moved to Section 3.7 of the conversion Level Level documentation. All changes to CTS shown in Section 3.7. 3/4.9.12 Fuel Building 3.7.12 Supplemental Leak Moved to Section 3.7 of the conversion Ventilation Fuel Movement Collection and Release System documentation. All changes to CTS shown in Section __ __ __ _ _ _ _ _ _ (SLCRS) 3.7. 3/4.9.14 Spent Fuel Storage 3.7.14 Spent Fuel Pool Storage Moved to Section 3.7 of the conversion Pool (Unit 1) documentation. All changes to CTS shown in Section 3/4.9.14 Spent Fuel Pool 3.7. Storage (Unit 2) Requirements of Unit I CTS 3/4.9.14 are divided between ITS 3.7.14 and ITS 3.7.16. 3/4.9.14 Spent Fuel Storage 3.7.16 Fuel Storage Pool Boron Moved to Section 3.7 of the conversion Pool (Unit 1) Concentration documentation. All changes to CTS shown in Section 3/4.9.15 Fuel Storage Pool 3.7. Boron Concentration (Unit 2) Requirements of Unit I CTS 3/4.9.14 are divided between ITS 3.7.14 and ITS 3.7.16.

C z-CTS ROADMAP Page 15 Revision 2 CTS SECTION 314.10 SPECIAL TEST EXCEPTIONS CTS BVPS ITS NOTES APPLICABLE LICENSE AMENDMENT REQUESTS 3/4.10.1 Shutdown Margin N/A Not in ISTS. Deleted From CTS. Addressed in Section 3.1 of BVPS conversion documentation. 3/4.10.2 Group Height, N/A Not in ISTS. Deleted From CTS. Addressed in Insertion and Power Section 3.1 of BVPS conversion documentation. Distribution Limits 3/4.10.3 Pressure/Temperature N/A Not in ISTS. Deleted From CTS. Addressed in Limitation Reactor Criticality Section 3.1 of BVPS conversion documentation. (Unit 1) 314.10.3 Physics Tests (Unit 2) 3.1.9 PHYSICS TESTS Exceptions Addressed in Section 3.1 of BVPS conversion 3/4.10.4 Physics Tests (Unit 1) - Mode 2 documentation. 3/4.10.4 Reactor Coolant 3.4.19 RCS Loops -Test Addressed in Section 3.4 of BVPS conversion Loops (Unit 2) Exceptions documentation. 3/4.10.5 No Flow Tests (Unit CTS SECTION 5.0 DESIGN FEATURES CTS BVPS ITS NOTES APPLICABLE LICENSE AMENDMENT REQUESTS 5.1 Site Location 4.1 Site Location 5.2 Reactor Core 4.2 Reactor Core 5.3 Fuel Storage 4.3 Fuel Storage

CTS ROADMAP Page 16 Revision 2 ITS SECTION 6.0 ADMINISTRATIVE CONTROLS CTS BVPS ITS NOTES APPLICABLE LICENSE AMENDMENT REQUESTS 6.1 Responsibility 5.1 Responsibility 6.2.1 Onsite and Offsite 5.2.1 Onsite and Offsite Organizations Organizations 6.2.2 Unit Staff 5.2.2 Unit Staff 6.3 Facility Staff Qualifications 5.3.1 Facility Staff Qualifications 6.4 & 6.5 Deleted N/A 6.6 Reportable Event Action N/A Deleted 6.7 Deleted NA 6.8 Procedures 5.4 Procedures Many subsections of CTS 6.8 are moved into new Draft pages utilized from LAR # I 5.5 Programs and Manuals ITS Section 5.5 for Programs. 173 (Unit 2). CTS requirements moved into ITS Section 5.5 from Draft pages utilized from LAR #s Sections 3.4 and 3.7 for new programs are affected 325 (Unit 1) and 195 (Unit 2). by LARs. LAR #s 324 (Unit 1)& 196 (Unit

2) & 183 (Unit 2) for SG Tube Inspection Program. Draft pages not incorporated yet.

6.9.1 Deleted N/A 6.9.2 Annual Radiological 5.6.1 Annual Radiological Environmental Operating Environmental Operating Report Report 6.9.3 Annual Radioactive 5.6.2 Radioactive Effluent Release Effluent Release Report Report 6.9.4 Deleted N/A 6.9.5 Core Operating Limits 5.6.3 Core Operating Limits Report Draft pages utilized from LAR # Report (COLR) (COLR) 173 (Unit 2)

I - U-CTS ROADMAP Page 17 Revision 2 ITS SECTION 6.0 ADMINISTRATIVE CONTROLS CTS BVPS ITS NOTES APPLICABLE LICENSE AMENDMENT REQUESTS 6.9.6 Pressure Temperature 5.6.4 Reactor Coolant System Limits Report (PTLR) (RCS) Pressure Temperature Limits Report (PTLR) 6.10 Deleted N/A 6.11 Radiation Protection NIA CTS requirements moved to UFSAR. Program 6.12 High Radiation Area 5.7 High Radiation Area 6.13 Process Control Program N/A CTS requirements moved to UFSAR. (PCP) 6.14 Offsite Dose Calculation 5.5.1 Offsite Dose Calculation Manual (ODCM) Manual (ODCM) 6.15 &6.16 N/A CTS # 6.15 is not used and CTS 6.16 only refers to being moved to the PCP (CTS 6.13) 6.17 Containment Leakage 5.5.12 Containment Leakage Rate Rate Testing Program Testing Program 6.18 Technical Specifications 5.5.10 Technical Specifications (TS) Bases Control Program (TS) Bases Control Program

C r f ISTS ROADMAP l Rev. 2 Change D-19 l Revision 1 Page 1 ROADMAP OF IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) AND CROSS-REFERENCE TO PROPOSED BVPS SPECIFIC UNIT I AND 2 ITS AND CURRENT TECHNICAL SPECIFICATIONS (CTS) LISTED IN ISTS ORDER Each BVPS Improved Technical Specification (ITS) and CTS listed below is common to both units unless identified as unit specific. SECTION 1.0 USE & APPLICATION ISTS BVPS ITS CTS NOTES 1.0 Use and Application 1.0 Use and Application NIA New Section added to CTS. 1.1 Definitions 1.1 Definitions 1.0 Definitions 1.2 Logical Connectors 1.2 Logical Connectors NIA New Section added to CTS. 1.3 Completion Time 1.3 Completion lime N/A New Section added to CTS. 1.4 Frequency 1.4 Frequency NIA New Section added to CTS. SECTION 2.0 SAFETY LIMITS ISTS BVPS ITS CTS NOTES 2.1 Safety Limits 2.1 Safety Limits 2.1 Safety Limits 2.2 SL Violations 2.2 SL Violations 2.1 Safety Limits SECTION 3.0 LCO & SR APPLICABILITY ISTS BVPS ITS CTS NOTES 3.0 LCO & SR Applicability 3.0 LCO & SR Applicability 314.0 LCO & SR Applicability .-

A0-ISTS ROADMAP Revision 1 Page 2 SECTION 3.1 REACTIVITY CONTROL SYSTEMS ISTS BVPS ITS CTS NOTES 3.1.1 SHUTDOWN MARGIN 3.1.1 SHUTDOWN MARGIN 3.1.1.1 SHUTDOWN MARGIN -Tavg > 2000 F 3.1.1.2 SHUTDOWN MARGIN -Tavg s 2000 F 3.1.2 Core Reactivity 3.1.2 Core Reactivity N/A New ITS 3.1.2 "Core Reactivity" is created from CTS surveillance 4.1.1.1.2 which verifies core reactivity. 3.1.3 Moderator Temperature 3.1.3 Moderator Temperature 3.1.1.4 Moderator Coefficient Coefficient Temperature Coefficient 3.1.4 Rod Group Alignment 3.1.4 Rod Group Alignment Limits 3.1.3.1 Movable Control Limits Assemblies Group Height 3.1.5 Shutdown Bank Insertion 3.1.5 Shutdown Bank Insertion Limits 3.1.3.5 Shutdown Rod Limits Insertion Limit 3.1.6 Control Bank Insertion 3.1.6 Control Bank Insertion Limits 3.1.3.6 Control Rod Limits Insertion Limits 3.1.7 Rod Position Indication 3.1.7.1 Unit 1 Rod Position Indication 3.1.3.2 Position Indication Separate Rod Position Indication Specifications are 3.1.7.2 Unit 2 Rod Position Indication Systems - Operating proposed for Unit l and Unit 2. Unit I has an Analog Position Indication System and Unit 2 has a Digital Position Indication System. The CTS Specification requirements for each system are substantially different. The proposed ITS requirements for each unit, although more similar than the CTS, are still different enough to warrant separate Specifications for improved clarity. N/A 3.1.8 Unborated Water Source 3.1.2.9 Isolation of BVPS Specific 3.1 Specification. ISTS Section 3.1 Isolation Valves Unborated Water Sources does not have a Specification that corresponds to CTS

                                                                        -Shutdown                   3.1.2.9 "Isolation of Unborated Water Sources -

Shutdown". The proposed BVPS ITS 3.1.8 is based on the similar Mode 6 ISTS Specification 3.9.2. Since the BVPS version of this TS is aDDlicable in more than iust

ISTS ROADMAP Revision 1 Page 3 SECTION 3.1 REACTIVITY CONTROL SYSTEMS ISTS BVPS ITS CTS NOTES Mode 6 it is retained in Section 3.1 consistent with the CTS instead of Section 3.9 like the ISTS. 3.1.8 PHYSICS TESTS 3.1.9 PHYSICS TESTS Exceptions - 3.10.4 Physics Tests (Unit Exceptions - Mode 2 Mode 2 1) 3.10.3 Physics Tests (Unit 2) N/A 3.1.10 RCS Boron Limitations < 500°F N/A The BVPS ITS Section 3.1 is revised by the addition of a new Technical Specification (3.1.10, RCS Boron Limitations < 500 OF). 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. NSAL-00-016 discussed the reactor trip functions associated with the mitigation of an Uncontrolled Rod Cluster Control Assembly (RCCA) Bank Withdrawal from a Low Power or Subcritical Condition event (RWFS). The proposed specification provides additional protection at low RCS temperatures when the power range instrumentation may not be operable. SECTION 3.2 POWER DISTRIBUTION LIMITS ISTS BVPS ITS CTS 3.2.1.A Heat Flux Hot Channel N/A N/A The ISTS contains specifications for different Factor (Fa(Z)) (CAOC-Fxy) methodologies. The BVPS ITS utilizes the RAOC methodology specifications contained in the ISTS. Therefore, the CAOC methodology specifications are deleted from the BVPS specific implementation of Section 3.2.

ISTS ROADMAP Revision 1 Paae 4 SECTION 3.2 POWER DISTRIBUTION LIMITS ISTS BVPS ITS CTS 3.2.1.B Heat Flux Hot Channel 3.2.1 Heat Flux Hot Channel Factor 3.2.2 Heat Flux Hot Factor (Fo(Z)) (RAOC-W(Z)) (Fo(Z)) Channel Factor (Fo(Z)) 3.2.1.C Heat Flux Hot Channel N/A N/A The ISTS contains specifications for different Factor (Fo(Z)) (CAOC-W(Z)) methodologies. The BVPS ITS utilizes the RAOC methodology specifications contained In the ISTS. Therefore, the CAOC methodology specifications are deleted from the BVPS specific implementation of Section 3.2. 3.2.2 Nuclear Enthalpx Rise 3.2.2 Nuclear Enthalpy Rise Hot 3.2.3 Nuclear Enthalpy Hot Channel Factor (FEH) Channel Factor (Fal) Hot Channel Factor (FNH) 3.2.3.A Axial Flux Difference N/A NIA The ISTS contains specifications for different (AFD) (CAOC) methodologies. The BVPS ITS utilizes the RAOC methodology specifications contained in the ISTS. Therefore, the CAOC methodology specifications are deleted from the BVPS specific implementation of Section 3.2. 3.2.3.B Axial Flux Difference 3.2.3 Axial Flux Difference (AFD) 3.2.1 Axial Flux Difference (AFD) (RAOC) (AFD) 3.2.4 Quadrant Power Tilt 3.2.4 Quadrant Power Tilt Ratio 3.2.4 Quadrant Power Tilt Ratio (QPTR) (QPTR) Ratio (QPTR) SECTION 3.3 INSTRUMENTATION ISTS BVPS ITS CTS NOTES 3.3.1 RTS Instrumentation 3.3.1 RTS Instrumentation 3.3.1.1 RTS In Section 3.3A of Conversion documentation. Due to Instrumentation the size of the Instrumentation Section, it was divided into 3 separate subsections (A, B, & C). 3.3.2 ESFAS Instrumentation 3.3.2 ESFAS Instrumentation 3.3.2.1 ESFAS In Section 3.3C of Conversion Documentation. Instrumentation

r &e-ISTS ROADMAP Revision 1 Paae 5 SECTION 3.3 INSTRUMENTATION ISTS BVPS ITS CTS NOTES 3.3.3 Post Accident Monitoring 3.3.3 PAM Instrumentation 3.3.3.8 Accident In Section 3.3B of Conversion Documentation. (PAM) Instrumentation Monitoring Instrumentation 3.3.4 Remote Shutdown 3.3.4 Remote Shutdown 3.3.3.5 Remote Shutdown In Section 3.3B of Conversion Documentation. Instrumentation Instrumentation Instrumentation 3.3.5 Loss of Power (LOP) 3.3.5 Loss of Power LOP DG Start and 3.3.2.1 Engineered In Section 3.38 of Conversion Documentation. Diesel Generator (DG) Start Bus Separation Instrumentation Safety Feature System Instrumentation Instrumentation Function 6, Loss of Power 3.3.6 Containment Purge and 3.3.6 Unit 2 Containment Purge and 3.9.9 Containment Purge In Section 3.3B of Conversion Documentation. Exhaust Isolation Exhaust Isolation Instrumentation and Exhaust Isolation Intrmetaio nstnumentaion 3.3.3.1 Radiation Due applicable to Unit design differences, proposed ITS 3.3.6 is only to Unit 2. Monitoring Instrumentation Process Monitor 2.cii 3.3.7 Control Room 3.3.7 Control Room Emergency 3.3.3.1 Radiation In Section 3.3B of Conversion Documentation Emergency Filtration System Ventilation System (CREVS) Monitoring (CREFS) Instrumentation Instrumentation Instrumentation Area Monitor 1.c 3.3.8 Fuel Building Air Cleanup N/A N/A In Section 3.3B of Conversion Documentation. System (FBACS) Actuation ISTS 3.3.8, FBACS, is not used in the BVPS specific Instrumentation implementation of the ISTS. BVPS does not have CTS requirements, or a system design that corresponds to FBACS, or safety analyses assumptions that would require this type of instrumentation to be operable.

R-ISTS ROADMAP Revision 1 Paae 6 SECTION 3.3 INSTRUMENTATION ISTS BVPS ITS CTS NOTES 3.3.9 Boron Dilution Protection 3.3.8 Boron Dilution Detection 3.3.1.1 Reactor Trip In Section 3.3B of Conversion Documentation. System (BDPS) Instrumentation System Instrumentation Instrumentation Function 6.b (Source ISTS 3.3.9 applies to a plant design that has an acive Range Instrumentation system using source range instrument channels to Indictiononlyinitiate automatic action that re-positions valves inorder Requirements) to mitigate a boron dilution event. The BVPS design does not include this type of automatic mitigation system. The proposed BVPS version of this ISTS contains the source range indication requirements moved from the Reactor Trip System Instrumentation TS. The affected BVPS source range indication requirements provide monitoring capability only. Consistent with the ISTS, the source range indication only requirements were removed from the Reactor Trip System Technical Specification. The proposed ITS 3.3.8 was developed to house the BVPS specific source range indication requirements. SECTION 3.4 REACTOR COOLANT SYSTEM ISTS BVPS ITS CTS NOTES 3.4.1 RCS Pressure, Temperature, 3.4.1 RCS Pressure, Temperature, 3.2.5 DNB Parameters and Flow Departure from Nucleate and Flow Departure from Nucleate Boiling (DNB) Limits Boiling (DNB) Limits 3.4.2 RCS Minimum Temperature 3.4.2 RCS Minimum Temperature 3.1.1.5 Minimum for Criticality for Criticality Temperature for Criticality 3.4.3 RCS Pressure and 3.4.3 RCS Pressure and 3.4.9.1 Temperature (PIT) Limits Temperature (PIT) Limits Pressure/Temperature Limits 3.4.4 RCS Loops - Modes 1 and 2 3.4.4 RCS Loops - Modes 1 and 2 3.4.1.1 RCS Loops-Normal Operation

r ISTS ROADMAP Revision 1 Paae 7 SECTION 3.4 REACTOR COOLANT SYSTEM ISTS BVPS ITS CTSNOTES 3.4.5 RCS Loops - Mode 3 3.4.5 RC$ Loops - Mode 3 3,4.1.2 RCS Loops -Hot Standby 3.4.6 RCS Loops - Mode 4 3.4.6 RCS Loops - Mode 4 3.4.1.3 RCS Loops - 3.4.7 RCS Loops Mode 5, Loops 3.4.7 RCS Loops Mode 5, Loops Sudw Filled Filled 3.4.8 RCS Loops Mode 5, Loops 3.4.8 RCS Loops Mode 5, Loops Not Filled Not Filled 3.4.9 Pressurizer 3.4.9 Pressurizer 3.4.4 Pressurizer 3.4.10 Pressurizer Safety Valves 3.4.10 Pressurizer Safety Valves 3.4.3 Safety Valves 3.4.11 Pressurizer Power Operated 3.4.11 Pressurizer Power Operated 3.4.11 Relief Valves Relief Valves (PORVs) Relief Valves (PORVs) 3.4.12 Low Temperature 3.4.12 Overpressure Protection 3.4.9.3 Overpressure Overpressure Protection (LTOP) System (OPPS) Protection Systems System 3.5.4.1 Boron Injection Tank < 350 OF (Unit 1 only) 3.4.13 RCS Operational Leakage 3.4.13 RCS Operational Leakage 3.4.6.2 Operational Leakage 3.4.14 RCS Pressure Isolation 3.4.14 RCS Pressure Isolation 3.4.6.3 Pressure Isolation Valve (PlV) Leakage Valve (PIV) Leakage Valves 3.4.15 RCS Leakage Detection 3.4.15 RCS Leakage Detection 3.4.6.1 Leakage Detection Instrumentation Instrumentation Instrumentation 3.4.16 RCS Specific Activity 3.4.16 RCS Specific Activity 3.4.8 Specific Activity 3.4.17 RCS Loop Isolation Valves 3.4.17 RCS Loop Isolation Valves 3.4.1.4.1 Loop Isolation Valves - Operating

ISTS ROADMAP Revision 1 Paae 8 SECTION 3.4 REACTOR COOLANT SYSTEM ISTS BVPS ITS CTS NOTES 3.4.18 RCS Isolated Loop Startup 3.4.18 RCS Isolated Loop Startup 3.4.1.5 Isolated Loop Startup 3.4.19 RCS Loops -Test 3.4.19 RCS Loops -Test 3.10.5 No FlowTest (Unit Exceptions Exceptions 1) 3.10.4 RCS Loops (Unit 2) SECTION 3.5 ECCS ISTS BVPS ITS CTS NOTES 3.5.1 Accumulators 3.5.1 Accumulators 3.5.1 Accumulators 3.5.2 ECCS - Operating 3.5.2 ECCS - Operating 3.5.2 ECCS Subsystems - T., 350'F 3.5.3 ECCS - Shutdown 3.5.3 ECCS - Shutdown 3.5.3 ECCS Subsystems - Tov < 350 0F 3.5.4 Refueling Water Storage Tank 3.5.4 Refueling Water Storage 3.1.2.8 Refueling Water (RWST) Tank (RWST) Storage Tank (RWST) 3.5.5 Seal Injection Flow 3.5.5 Seal Injection Flow 3.5.5 Seal Injection Flow (Unit 1) 3.5.4 Seal Injection Flow (Unit 2) 3.5.6 Boron Injection Tank N/A 3.5.4.1.1 Boron Injection Never a part of the Unit 2 TS and eliminated from Unit 1 System - Boron Injection TS in the pending Extended Power Uprate License Tank 2 350'F (Unit 1 only) Amendment Request # 302. The BVPS ISTS conversion is based on the post uprate TS so this Unit 1 TS is not shown in the Section 3.5 conversion documentation.

I e.- ISTS ROADMAP Revision 1 Page 9 SECTION 3.6 CONTAINMENT SYSTEMS ISTS BVPS ITS CTS NOTES 3.6.1 Containment (Atmospheric, 3.6.1 Containment 3.6.1.1 Containment Subatmospheric, Ice Condenser, Integrity and Dual) 3.6.1.2 Containment Leakage 3.6.1.6 Containment Structural Integrity 3.6.2 Containment Air Locks 3.6.2 Containment Air Locks 3.6.1.3 Containment Air (Atmospheric, Subatmospheric, Ice Locks Condenser, and Du-!) 3.6.3 Containment Isolation 3.6.3 Containment Isolation 3.6.3.1 Containment Valves (Atmospheric, Valves Isolation Valves Subatmospheric, Ice Condenser, and Dual) 3.6.4A Containment Pressure 3.6.4 Containment Pressure 3.6.1.4 Intemal Pressure (Atmospheric, Dual, and Ice Condenser) 3.6.4B Containment Pressure N/A N/A Although this is a subatmospheric type LCO, it is not (Subatmospheric) selected for BVPS due to the changes resulting from approved License Amendment Request (LAR) numbers 317 (Unit 1) and 190 (Unit 2), License Amendments 271 (Unit 1) and 153 (Unit 2) Incorporate changes that revise pressure and temperature requirements to be more consistent with an atmospheric containment design than a subatmospheric design. Therefore, the atmospheric type LCO is selected for BVPS. 3.6.5A Containment Air 3.6.5 Containment Air 3.6.1.5 Air Temperature Temperature (Atmospheric and Temperature I

r ISTS ROADMAP Revision 1 Page 10 SECTION 3.6 CONTAINMENT SYSTEMS ISTS BVPS ITS CTS NOTES Dual) _ 3.6.5B Containment Air N/A N/A Not applicable to the BVPS containment design. Temperature (Ice Condenser) 3.6,5C Containment Air NMA N/A Although this is a subatmospheric type LCO, it is not Temperature (Subatmospheric) selected for BVPS due to the changes resulting from approved License Amendment Request (LAR) numbers 317 (Unit 1)and 190 (Unit 2), License Amendments 271 (Unit 1)and 153 (Unit 2) incorporate changes that revise pressure and temperature requirements to be more consistent with an atmospheric containment design than a subatmospheric design. Therefore, the atmospheric type LCO is selected for BVPS. 3.6.6A Containment Spray and N/A N/A Not applicable to the BVPS containment design. Cooling Systems (Atmospheric and Dual) (Credit taken for iodine removal by the Containment Spray System) 3.6.6B Containment Spray and N/A N/A Not applicable to the BVPS containment design. Cooling Systems (Atmospheric and Dual) (Credit not taken for iodine removal by the Containment Spray System) 3.6.6C Containment Spray System N/A N/A Not applicable to the BVPS containment design. (Ice Condenser) 3.6.6D Quench Spray (QS) System 3.6.6 Quench Spray System 3.6.2.1 Containment (Subatmospheric) Quench Spray System 3.6.6E Recirculation Spray (RS) 3.6.7 Recirculation Spray System 3.6.2.2 Containment System (Subatmospheric) Recirculation Spray System 3.6.7 Spray Additive System 3.6.8 Spray Additive System 3.6.2.3 Chemical Addition

ISTS ROADMAP Revision I Pacie 11 SECTION 3.6 CONTAINMENT SYSTEMS ISTS BVPS ITS CTS - NOTES (Atmospheric, Subatmospheric, Ice System Condenser, and Dual) 3.6.8 Hydrogen Recombiners N/A N/A Deleted in Revision 3 (by TSTF-447). (Atmospheric, Subatmospheric, Ice Removed from the BVPS CTS by a prior approved Condenser, and Dual) (if license amendment. permanently installed) 3.6.9 Hydrogen Mixing System N/A N/A Not applicable to the BVPS containment design. (HMS) (Atmospheric, Ice Condenser, and Dual) 3.6.10 Hydrogen Ignition System N/A N/A Not applicable to the BVPS containment design. (HIS) (Ice Condenser) 3.6.11 Iodine Cleanup System N/A N/A Not applicable to the BVPS containment design. (ICS) (Atmospheric and Subatmospheric) 3.6.12 Vacuum Relief Valves N/A N/A Not applicable to the BVPS containment design. (Atmospheric and Ice Condenser) 3.6.13 Shield Building Air Cleanup N/A N/A Not applicable to the BVPS containment design. System (SBACS) (Dual and Ice Condenser) 3.6.14 Air Retum System (ARS) N/A N/A Not applicable to the BVPS containment design. (Ice Condenser) 3.6.15 Ice Bed (Ice Condenser) N/A N/A Not applicable to the BVPS containment design. 3.6.16 Ice Condenser Doors (Ice N/A N/A Not applicable to the BVPS containment design. Condenser) 3.6.17 Divider Barrier Integrity (Ice N/A NMA Not applicable to the BVPS containment design. Condenser) II_ I 13.6.1 8 Containment Recirculation INMA NMA INot applicable to the BVPS containment design.

2Z-f ILu ISTS ROADMAP Revision 1 Page 12 SECTION 3.6 CONTAINMENT SYSTEMS ISTS BVPS ITS CTS NOTES Drains (Ice Condenser) 3.6.19 Shield Building (Dual and N/A N/A Not applicable to the BVPS containment design. Ice Condenser) Moved to 3.6.8 in NUREG-1431 Revision 3 to replace the Hydrogen Recombiner LCO. SECTION 3.7 PLANT SYSTEMS ISTS BVPS ITS CTSNOTES 3.7.1 Main Steam Safety Valves 3.7.1 Main Steam Safety Valves 3.7.1.1 Main Steam Safety (MSsvs) (MSSVs) Valves (MSSVs) 3.7.2 Main Steam Isolation Valves 3.7.2 Main Steam Isolation Valves 3.7.1.5 Main Steam Line (MSIVs) (MSIVs) Isolation Valves 3.7.3 Main Feedwater Isolation 3.7.3 Main Feedwater Isolation N/A New TS added to CTS. Valves (MFIVs) and Main Feedwater Valves (MFIVs) and Main Regulation Valves (MFRVs) and Feedwater Regulation Valves [Associated Bypass Valves] (MFRVs) and MFRV Bypass Valves 3.7.4 Atmospheric Dump Valves 3.7.4 Atmospheric Dump Valves N/A New TS added to CTS. (ADVs) (ADVs) 3.7.5 Auxiliary Feedwater (AFW) 3.7.5 Auxiliary Feedwater (AFW) 3.7.1.2 Auxiliary System System Feedwater System 3.7.6 Condensate Storage Tank 3.7.6 Primary Plant Demineralized 3.7.1.3 Primary Plant (CST) Water Storage Tank (PPDWST) Demineralized Water (PPDW) 3.7.7 Component Cooling Water 3.7.7 Component Cooling Water 3.7.3.1 Component (CCW) System (CCW) System Cooling Water System (Unit 1); 3.7.3.1 Primary

.e-                                                              0-r-

P. T-ISTS ROADMAP Revision 1 PaNe 13 SECTION 3.7 PLANT SYSTEMS ISTS BVPS ITS CTS NOTES Component Cooling Water System (Unit 2) 3.7.8 Service Water System (SWS) 3.7.8 Service Water System 3.7.4.1 Reactor Plant (SWS) River Water System (RPRWS) (Unit 1); 3.7.4.1 Service Water System (SWS) (Unit 2) 3.7.9 Ultimate Heat Sink (UHS) 3.7.9 Ultimate Heat Sink (UHS) 3.7.5.1 Ultimate Heat Sink

                                                                         - Ohio River 3.7.10 Control Room Emergency     3.7.10 Control Room Emergency      3.7.7 Control Room Filtration System (CREFS)         Ventilation System (CREVS)         Emergency Ventilation System (CREVS) 3.7.11 Control Room Emergency Air 3.7.11 Control Room Emergency      3.7.6 Control Room Temperature Control System        Air Cooling System (CREACS)        Emergency Air Cooling (CREATCS)                                                            System (CREACS) 3.7.12 Emergency Core Cooling     3.7.12 Supplemental Leak           3.7.8.1 Supplemental       Mode 1-4 requirements of CTS 3.7.8.1 are relocated.

System (ECCS) Pump Room Collection and Release System Leak Collection And The fuel movement requirements of CTS 3.9.12 are Exhaust Air Cleanup System (SLCRS) Release System (SLCRS) retained in ITS 3.7.12. (PREACS) 3.9.12 Fuel Building Ventilation System 3.7.13 Fuel Building Air Cleanup N/A N/A Not applicable to BVPS design. System (FBACS) 3.7.14 Penetration Room Exhaust N/A N/A Not applicable to BVPS design. Air Cleanup System (PREACS) 3.7.15 Fuel Storage Pool Water 3.7.15 Fuel Storage Pool Water 3.9.11 Storage Pool Water Level Level Level 3.7.16 Fuel Storage Pool Boron 3.7.16 Fuel Storage Pool Boron 3.9.15 Fuel Storage Pool Boron concentration requirements from Unit I CTS Concentration Concentration Boron Concentration (Unit 3.9.14 moved into ITS 3.7.16 and fuel storage

r t ISTS ROADMAP Revision 1 Paae 14 SECTION 3.7 PLANT SYSTEMS ISTS BVPS ITS CTS NOTES

2) requirements retained in ITS 3.7.14.

3.9.14 Spent Fuel Storage Pool (Unit 1) 3.7.17 Spent Fuel Pool Storage 3.7.14 Spent Fuel Pool Storage 3.9.14 Spent Fuel Storage Boron concentration requirements from Unit I CTS Pool (Unit 1) 3.9.14 moved into ITS 3.7.16 and fuel storage 3.9.14 Spent Fuel Pool requirements retained in ITS 3.7.14. Storage (Unit 2) 3.7.18 Secondary Specific Activity 3.7.13 Secondary Specific Activity 3.7.1.4 Activity SECTION 3.8 ELECTRICAL POWER SYSTEMS ISTS BVPS ITS CTS NOTES 3.8.1 AC Sources Operating 3.8.1 AC Sources Operating 3.8.1.1 AC Sources Operating 3.8.2 AC Sources Shutdown 3.8.2 AC Sources Shutdown 3.8.1.2 AC Sources Shutdown 3.8.3 Diesel Fuel Oil, Lube Oil, and 3.8.3 Diesel Fuel Oil, Lube Oil, and 3.8.1.1 AC Sources Starting Air Starting Air Operating 3.8.4 DC Sources Operating 3.8.4 DC Sources Operating 3.8.2.3 DC Distribution Operating 3.8.5 DC Sources Shutdown 3.8.5 DC Sources Shutdown 3.8.2.4 DC Distribution Shutdown 3.8.6 Battery Cell Parameters 3.8.6 Battery Cell Parameters 3.8.2.3 DC Distribution Operating 3.8.7 Inverters Operating 3.8.7 Inverters Operating 3.8.2.1 AC Distribution Operating 3.8.8 Inverters Shutdown 3.8.8 Inverters Shutdown 3.8.2.2 AC Distribution

UI-C - ISTS ROADMAP Revision 1 Pane 15 SECTION 3.8 ELECTRICAL POWER SYSTEMS ISTS BVPS ITS CTS NOTES Shutdown 3.8.9 Distribution Systems 3.8.9 Distribution Systems 3.8.2.1 AC Distribution Operating Operating Operating 3.8.2.3 DC Distribution Operating 3.8.10 Distribution Systems 3.8.10 Distribution Systems 3.8.2.2 AC Distribution Shutdown Shutdown Shutdown 3.8.2.4 DC Distribution Shutdown SECTION 3.9 REFUELING OPERATIONS ISTS BVPS ITS CTS NOTES 3.9.1 Boron Concentration 3.9.1 Boron Concentration 3.9.1 Boron Concentration 3.9.2 Unborated Water Source 3.1.8 Unborated Water Source 3.1.2.9 Isolation of ISTS 3.9.2 "Unborated Water Source Isolation Valves" Isolation Valves Isolation Valves Unborated Water Sources is applicable solely in Mode 6. The corresponding

                                                                    - Shutdown                   BVPS CTS is applicable in Modes 4, 5, and 6 and is located in Section 3.1 "Reactivity Control Systems".

Consistent with the CTS, the BVPS ITS version of this TS will continue to be located in Section 3.1. 3.9.3 Nuclear Instrumentation 3.9.2 Nuclear Instrumentation 3.9.2 Instrumentation 3.9.4 Containment Penetrations 3.9.3 Containment Penetrations 3.9.4 Containment Building Penetrations 3.9.5 RHR and Coolant Circulation 3.9.4 RHR and Coolant Circulation 3.9.8.1 RHR and Coolant - High Water Level - High Water Level Circulation 3.9.6 RHR and Coolant Circulation 3.9.5 RHR and Coolant Circulation 3.9.8.2 RHR and Coolant - Low Water Level - Low Water Level Circulation - Low Water

it VF ISTS ROADMAP Revision 1 Page 16 SECTION 3.9 REFUELING OPERATIONS ISTS BVPS ITS CTS NOTES Level 3.9.7 Refueling Cavity Water Level 3.9.6 Refueling Cavity Water Level 3.9.10 Water Level SECTION 4.0 DESIGN FEATURES ISTS BVPS ITS CTS NOTES 4.1 Site Location 4.1 Site Location 5.1 Site Location 4.2 Reactor Core 4.2 Reactor Core 5.2 Reactor Core 4.3 Fuel Storage 4.3 Fuel Storage 5.3 Fuel Storage SECTION 5.0 ADMINISTRATIVE CONTROLS ISTS BVPS ITS CTS NOTES 5.1 Responsibility 5.1 Responsibility 6.1 Responsibility 5.2 Organization 5.2 Organization 6.2 Organization 5.3 Unit Staff Qualification 5.3 Unit Staff Qualification 6.3 Unit Staff Qualification 5.4 Procedures 5.4 Procedures 6.8 Procedures 5.5 Programs and Manuals 5.5 Programs and Manuals 6.8 Procedures 5.6 Reporting Requirements 5.6 Reporting Requirements 6.9 Reporting Requirements 5.7 High Radiation Area 5.7 High Radiation Area 6.12 High Radiation Area

                                           - -          -m          m-BEAVER VALLEY POWER STATION UNITS 1 & 2 IMPROVED TECHNICAL SPECIFICATION CONVERSION LICENSE AMENDMENT REQUEST REVISION 2 REPLACEMENT PAGES Organized By ITS Sections In Numerical Order Complete Set Of Revision 2 Replacement Pages For The BVPS ITS Conversion Submittal Volumes 1-10.

Replace The Current Volume 1-10 Pages With The Corresponding Enclosed Revision 2 Pages. l- = -- -

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REIIUEST (LAR) NOs. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 REPLACEMENT PAGES This volume contains the pages affected by Revision 2 organized by ITS Section and presented in numerical order for each section. Volumes 2 through 10 of the original BVPS ITS conversion submittal were organized by ITS sections and the pages of each section were numbered consecutively in the lower right hand corner. The pages in this Revision 2 volume are organized similar to the original submittal volumes to facilitate replacing pages inVolumes 2 through 10 of the BVPS ITS conversion submittal. In addition, this volume contains the replacement pages necessary to update the Review Information provided in the original Volume I of the BVPS ITS conversion submittal. In most cases the pages in this volume are a one for one replacement of the original corresponding page. For some changes, however, it was necessary to add new pages to the submittal. When new Revision 2 pages are added, the page number is followed with an Alpha designation indicating the order to insert the new page. For example, if irn this volume, page number 80 for a certain ITS Section isfollowed by pages 80A through 80E, the Alpha labeled pages are new pages and should be inserted in Alpha order following page 80 and before page 81.

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQ UEST (LAR) NOS. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 REPLACEMENT PAGES ITS SECTION 1.0 USE AND APPLICATION NO REVISED PAGES IN THIS SECTION Km#

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQ UEST (LAR) NOS. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 REPLACEMENT PAGES ITS SECTION 2.0 SAFETY LIMITS LIST OF AFFECTED PAGES 17

2.0 Safety Limits (Ss)DRAFT lRo17' PAGE 2.0 SAFETY LIMITS UA. LR#I1j 2.1 SAFETY LIMIS S Reator Coolant System (RCS) highest loop average temperaturean

   -*REACTOR CORE                     In MODES I and72,                                                                      S]

he combination of THERMAL POWER, pressurizer pressure-,--,td e--iighezt operating ioop coolant temperaturo (T -I shall not exceed the limits specified in the COLR; and the following Sa-fe. Limits- shall not be exceeded: 2.1.1.1 The departure from nucleate boiling ratio (DNBR) shall be maintained 2 1.17 for WRB-1 DNB correlation for Vantage 5H (V5H) fuel assemblies, and 2 1.14 for WRB-2M DNB correlation for Robust Fuel Assemblies (RFA). 2.1.1.2 The peak fuel centerline temperature shall be maintained

     < 4700 0 F.

APPLIGABILITY: MODES 1 and 2. 2.2.flA

                *~I-G                              l 2.2 Safety Limit Violations                                 MODE E2. I A GT-
   \1f Safety Limit 2.1.1 is                        violated,         restore compliance              and     be   in   HGI SGTANDBY within 1 hour.

_l _ _ _ A be maintained <

   -REACTOR COOLANT SYSTEM PRESSURE dhe     Reactor            Coolant          System       pressure       shall       /nt       e-eeeed 2735     psi APPLIO.S..              M            1,    2, 3,      1, a      S--

ATO2.2Sat Limit Violations 2.2.2.1 In MODE I or 2, resItoe 2 is violated: compliance and be in MODE 3 PIODIE: 1 and 9 .. fS212siltd Whenever thoc Reactor Coolant System prooourc has emcee led 2735 psig, be in HOT STAND3Y with the Reactor Coolant Syst.-em proesure within its limit within 1 hour. MODES 3, 4, and 5 Whonoor--tho Reactor Coolant System pressure has emeoeeed 2735 paig, reduce the reaeter Coolant System pressure to wit}-n

              /t-s-limit within 5 minutes.

2.2.2.2 In MODE 3,4, or 5, restore complianceI (i) BEAVER VALLEY - UNIT 2 2-1 Amendment No. 17

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQ UEST (LAR) NOS. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 REPLACEMENT PAGES ITS SECTION 3.0 LCO & SR APPLICABILITY NO REVISED PAGES IN THIS SECTION

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQ UEST (LAR) NOS. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 REPLACEMENT PAGES ITS SECTION 3.1 REACTIVITY CONTROL SYSTEMS LIST OF AFFECTED PAGES 111 112 132

Rev. 2 Change D-14 PHYSICS TESTS Exceptions - MODE 2 B. 3lk1 BASES ACTIONS A.1 and A.2 If the SDM requirement is not met, boration must be initiated promptly. A Completion Time of 15 minutes is adequate for an operator to correctly align and start the required systems and components. The operator should begin boration with the best source available for the plant conditions. Boration will be continued until SDM is within limit. Suspension of PHYSICS TESTS exceptions requires restoration of each of the applicable LCOs to within specification. B.1 When THERMAL POWER is > 5% RTP, the only acceptable action is to open the reactor trip breakers (RTBs) to prevent operation of the reactor beyond its design limits. Immediately opening the RTBs will shut down the reactor and prevent operation of the reactor outside of its design limits. C.1 When the RCS lowest Tavg is < 531 'F, the appropriate action is to restore Tavg to within its specified limit. The allowed Completion Time of 15 minutes provides time for restoring Tavg to within limits without allowing the plant to remain in an unacceptable condition for an extended period of time. Operation with the reactor critical and with temperature below 531 OF could violate the assumptions for accidents analyzed in the safety analyses. D.1 If the Required Actions cannot be completed within the associated Completion Time, the plant must be brought to a MODE in which the requirement does not apply. To achieve this status, the plant must be brought to at least MODE 3 within an additional 15 minutes. The Completion Time of 15 additional minutes is reasonable, based on operating experience, for reaching MODE 3 in an orderly manner and without challenging plant systems. SURVEILLANCE SR 3.1. 'l inaccordance with are required REQUIREMENTS The power range and intermediate rage neutron detectors ve ileIto be OPERABLE in MODE 2 LCO 3.3.1, "Reactor Trip I System (RTS) Instrumentation." A CHANNEL OPERATIONAL TEST is WOG STS B3. 1-6 Rev. 2, 04/30/01 111

I Rev. 2 Change D-14 PHYSICS TESTS Exceptions - MODE 2 B 13, y 4 Jv The performance of the RTS CHANNEL OPERATIONA IB3.I BASES TEST requirements referenced inthis SR i-I

                                                    . -         in accordance with the frequency requirement of the referenced RTS surveillances which ensures SURVEILLANCE REQUIREMENTS (continued                    !each channel is tested performed on each power rang Hnd intermediate range channeiprior to, 9               initiation of the-PHYSICS TESTS. M-hi6 will ensure that the RTS is                  .2 th properly aligned to provide the required degree of core protection durind the performance of the PHYSICS TESTS.

SR 3.1.92 Verification that the RCS lowest loop Tang is 2 531 'F will ensure that the unit is not operating in a condition that could invalidate the safety analyses. Verification of the RCS temperature at a Frequency of 30 minutes during the performance of the PHYSICS TESTS will ensure that the initial conditions of the safety analyses are not violated. SR 3.1.8"3 T Verification that the THERMAL POWER is t 5% RTP will ensure that the plant is not operating in a condition that could invalidate the safety analyses. Verification of the THERMAL POWER at a Frequency of 30 minutes during the performance of the PHYSICS TESTS will ensure that the initial conditions of the safety analyses are not violated. SR 3.1.*4--'E The SDM is verified by performing a reactivity balance calculation, considering the following reactivity effects:

a. RCS boron concentration,

b. Control bank positionio-n,~T1 WOG STS B3.1; -7 Rev. 2, 04/30/01 112

I Rev. 2 Change D-14 BVPS ISTS Conversion 3.1 Reactivity Control Systems Enclosure 2 Changes to The ISTS Bases The proposed change to the ISTS bases is acceptable because the proposed change references the industry standard for a description of the testing performed at BVPS. It is not necessary to repeat or summarize the standard test descriptions in the TS bases. The reference standard is readily available and contains sufficient detail to confirm the methods and adequacy of the BVPS Physics Test program.

7. The Neutron Flux Symmetry test is deleted from the list of Mode 2 Physics Tests.

Consistent with the explanation that follows the list of tests in the ISTS bases, this test is performed in Mode 1 and is not part of the BVPS Mode 2 Physics Tests addressed by this Test Exception.

8. The critical boron test is revised to reference the "Reference Bank" instead of control rods. The Reference Bank is the specific "control rods" used at BVPS for this test.

9. The Bases for ITS SR 3.1.9.1 is revised to more clearly describe the relationship with ITS LCO 3.3.1, Reactor Trip System (RTS) Instrumentation and the RTS SRs referenced by SR 3.1.9.1. ITS SR 3.1.9.1 requires the performance of RTS SRs that are part of ITS 3.3.1 which is also applicable in Mode 2.

BVPS Units 1 & 2 Page 14 Revision ( 2/051 132

Y4mi.*. BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQ UEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 REPLACEMENT PAGES ITS SECTION 3.2 POWER DISTRIBUTION LIMITS LIST OF AFFECTED PAGES 96 97 98 99 100 102 y24p

a ] 4.2 POWER DISTRIBUTION LIMITS Rev 2. ChangeAjJ

    *4-.2-. 1     AXIAL FLUX DIFFERENCE  (AFD)    ITS 3.2.3 3   LIMITING CONDITION FOR OPERATION 3.2.4    The AFD in % flux difference units shall be maintained within the limits(l) specified in the COLR.

APPLICABILITY: MODE 1 with THERMAL POWER 2 50% RTJ d ACTION: lCKIl With AFD not within the limits, reduce THERMAL POWER to < 50% of RTP within 30 minutes. SURVEILLANCE REQUIREMENTS Verify AFD within limits for each OPERABLE excore channel at least once per 7 days. I Moved to Note In LCO 3.2.3 44+/- The AFD shall be considered outside limits when two or more I OPERABLE excore channels indicate AFD to be outside limits. (2) Sce Special Test Exeeptien 3-.10 A2 BEAVER VALLEY - UNIT 2 3/4 2-1 Amendment No. 155 (Next page is 3/4 2-4) I 96

POWER DISTRIBUTION LIMITS I ITS 3.2.1 Rev. 2 Change H i HEAT J FLUX HOT CHANNEL FACTOR-F0L (Z) < g] LIMITING CONDITION FOR OPERATION

              - FQ(Z), as approximated by Fg(Z) and FQ(Z),          shall be within the limits specified in the COLR.

APPLICABILITY: MODE 1 ACTION: C (1) i <fl e-. With FQ(Z) not within limit C, FA.1 ] 1_ Reduce THERMAL POWER 2 1% RTP for each 1% F&,(Z) exceeds the limit within 15 minutes after each FC,(Z) determination; and Reduce the Power Range Neutron Flux-High Trip Setpoints 2 1% for each 1% F6(Z) exceeds the limit C within 72 hours after each F6(Z) determination; and lA.3 l Reduce the Overpower AT Trip Setpoints 2 1% for each C 1% F6(Z) exceeds the limit within 72 hours after each F6(Z) determination; and l .1.1and3.2.1.2l lA.4 4- Perform Surveillance Requirements 4.2.2.2.2. I prior to increasing THERMAL POWER above the limit of Action a.l. Cond.C l :- Otherwise, be in MODE 2 within the following 6 hours. 3 b- With F6(Z) not within limits(2): EBA G-- Reduce AFD limits 2 1% for each 1% Fw(Z) exceeds limit within 4 hours, and Note InCond. A

      -(4-- Action a.4 shall be completed whenever Action a. is entered.

42-) Action b.4 shall be completed whenever Action b. is entered. A Note in Cond. 155 BEAVER VALLEY - UNIT 2 3/4 2-4 Amendment No. 155 97

POWER DISTRIBUTION LIMITS Rev. 2 Change A--9 I LIMITING CONDITION FOR OPERATION (Continued) B 2- Reduce the Power Range Neutron Flux-High Trip Setpoints 2 1% for each 1% that the maximum allowable power of the AFD limits is reduced within 72 hours; and l 3.2.1.1 and 3.2.1.2 ] E. -3 Reduce the Overpower AT Trip Setpoints 2 1% for each 1% that the maximum allowable power of the FD limits is reduced within 72 hours; and 4-X Perform Surveillance Requirements 4.2.2.2 and 4.2.2=3 prior to increasing THERMAL POWER above the maximum allowable power of the AFD limits.

            . Otherwise, be in MODE 2 within the following 6 hours.
                                                     /m)

SURVEILLANCE REQUIREMENTS / \ 4.2.2.l The provisions of Speeifiea* o -.0.4 are net applieable.. F6(Z) shall be verified to be within the limit according to 2F2s the following schedule(3):

a. Once after each refueling prior to THERMAL POWER exceeding 75% RTP; and i b. Once within 12 hours after achieving equilibrium conditions after exceeding, by 2 10% RTP, the THERMAL POWER at which F6(Z) was last verified; and

c. At least once per 31 Effective Full Power Days thereafter.

I Moved to Surveillance Requirement Note I (3) During power escalation at the beginning of each cycle, THERMAL POWER may be increased until an equilibrium power level has been achieved, at which a power distribution map is obtained. BEAVER VALLEY - UNIT 2 3/4 2-5 Amendment No. 155 I 98

POWER DISTRIBUTION LIMITS Rev. 2 Change A-9 SURVEILLANCE REQUIREMENTS (Continued) F6(Z) shall be verified to be within limit(4) according to the following schedule(3):

a. Once after each refueling prior to THERMAL POWER exceeding 75% RTP; and

b. Once within 12 hours after achieving equilibrium conditions after exceeding, by 2 10% RTP, the THERMAL POWER at which F6(Z) was last verified; and

c. At least once per 31 Effective Full Power Days, thereafter.

Moved to Surveillance Requirement Note (3) During power escalation at the beginning of each cycle, THERMAL POWER may be increased until an equilibrium power level has been achieved at which a power distribution map is obtained. ij1W (4) If measurements indicate that the maximum over z of [F6(Z)/K(Z)] has increased since the previous evaluation F6(Z): C

a. Increase F6(Z) by the greater of a factor of 1.02 or by an appropriate factor specified in the COLR and reverify F6(Z) is within limits, or SR3212

b. Repeat Surveillanzo Rcquircmcnt 4.2.2.3 once per 7 Effective Full Power Days until Note (4)a above is met or two successive flux maps indicate that the maximum over z of [F6(Z)/K(Z)] has not increased.

Note in SR 3.2.1.2 BEAVER VALLEY - UNIT 2 3/4 2-6 Amendment No. 155 I 99

Rev. 2 Change A-9 POWER DISTRIBUTION LIMITS I I

~,Uuy within the limits specified In the COLR.

APPLICABILITY: MODE 1 L ACTION: A.1.1 Restore to within limit or Li] With FH exce ing its limit: ~~4.4i a meduce THERMAL t ess than 50% of RATED THERMAL

        --               lPOWER      within         hours and re uce the Power Range Neutron L      2-1&  2 -2      Flux-High Trip Setpoints to < 55% of RATED THERMAL POWER within the next 4 hours.                   72            PedonnSR3.2.2.1 rugh in-core mapping to be wEittii                        t_1njtj 50 percent of RATED THERMAL POWER prior-tbe geneeed-ng thisi THIRMAL power, at a nominal 75 percent of RATED THERMAL POWER prier to e                   e'ding thi-         TIIERMAL power and within 24 hours after attaining 95 perce t or greater RATED THERMAL POWER.

100

POWER DISTRIBUTION LIMITS Rev. 2 Change A-9 ] OUADRANT POWER TILT RATIO (OPTR) LIMITING CONDITION FOR OPERATION 3.2.4 The QUADRANT POWER TILT RATIO shall be less than or equal to 1.02. APPLICABILITY: MODE 1 greater than 50 percent of RATED THERM4AL POWER. ACTION: With the QPTR not within the limit: A [7 a-- Within 2 hours, reduce THERMAL POWER greater t n or equal to 3 percent from RATED THERMAL POW each 1 percent of QPTR greater than 1.00, and determine QPTR 2AiliI b-- Within 12 hours and once per 12 hours Survzillanec Requiramema t 4.2.4 and reduce THERMAL POWER thereafter, r-m greater than or equal to 3 percent from RTP for each. 1 Lpercent of QPTR greater than 1.00, and e Within 24 hours and once per 7 days thereafter, perform gLI LA. JiSurveillance Requirementska.2.2.2, 4.2.2.3, and 42.34, and A.1 SR 3.2.1.1, SR 3.2.1.2, and SR 3.2.2.1l d- Pri r to increasing THERMAL POWER above the limit of ACTION l~1 aeorb above, re-evaluate the safety analyses and confirm e the results remain valid for the duration of e n under this con lticn resntor lw.1ithin the imi A.4 restore A. ovin!eiI e-E After ACTION above is completed and/prior to inc eas:ing THERMAL POWER above the limit of A TION above, ITS Action normalize the excore detectors to 6 a QPTR n e loesqual te 1.02, an Afi f- A.- l[After ACTION<<above is completed nd within 24 hours after reaching RTP or within 48 hours fter increasing THERMAL POWER abo e the limit of ACTION a-er-b above, perform Surveillan e Requirements 4.2.2.3, and 4.2.3.1. Ed.B g-A Otherwise, r uce THERMAL POWER to less than or equal to 50 F percent RTP hin 4 hours. SR 3.2.1.1, SR 3.2.1.2, and SR 3.2.2.1

/-

m equillib~rium conditions at RTP not to exceedl GDt bITS n . Action A.5 NOTE Required Action A.6.shall be (1) See Speeial Toet - aptien 3.a0.2. _ completed whenever Required Action A2 A.5 is performed. BEAVER VALLEY - UNIT 2 3/4 2-9 Amendment No. 15' 102

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REIIUEST (LAR) NOS. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 REPLACEMENT PAGES ITS SEC'TION 3.3A REACTOR TRIP SYSTEM INSTRUMENTATION LIST OF AFFECTED PAGES 17 129A 36 164 37 165 40 166 43 167 82 168 84 169 90A 170 <AS 90B 171 90C 172 90D 173 92 174 103 175 114 176 116 177 116A 178 118 179 121 180 122 181 123 182 127 183 129 184 185 186 187

I Rev. 2 Change A-5 I RTS Instrumentation 3.3.1 Table 3.3.1-1 (page 3 of 6) \ Reactor Trip System Instrumentation

12. Undervollage 1i >7 per bus K RCPs X~ 13 SR 3.3.1

13. Underfrequency 1M A per bus K RCPs

14. Steam 12 per SG] E Generator (SG) SR 3.3.1..

Water Level - 3 Low Low E SR 3.3.1.

46. Turbine Trip

a. Low Fluid Oil 3 SR 3.3.1.10

             >    Pressure                                                                       SR 3.3.1.45

b. Turbine Stop 4 SR 3.3.I.10 3 2 [1J% open Valve SR 3.3.1.45

[ZG Closure

4. Safety 1.2 2 trains SR 3.3 ' ' NA Injection (SI)

Input from Engineered Safety Feature Actuation [ ystem

     +*         Above the P-7 (Low Power Reactor Trips Block) interlock.

{h). Above he P-9 (Power Range Neutron Flux) interlock. 3() If the as-found hannel set point is conservative with respect to the AlloNable

                                                                          ~Value but outside its predelfined as-found acceptance criteria band, then the      I   A-5

_ r hannel shall be evaluated to verify that it is functioning as required be bre Unit 1-Auto Stop _ returning the c hannel to setrvice. If the as-found instrument channel setpoint is riot conservative with resp(ect to the Allowable Value, the channel shall be lUnit 2-Emergency Trip Header ldeclared inoperable.

       *\ WOG STS                                                        3.3.1 -15                                               Rev. 2. 04/30/01 (I) The instrument channel selpoint shall be reset to a value that is within the as-left tolerance of the Nominal trip           A-5 18          Setpoint or a value that is more conservative than the Nominal Trip Setpoint; otherwise, the channel shall be declared inoperable. The Nominal Tdip Setpoint and the methodology used to determine the Nominal Trip: etpoiit the predefined as-found acceptance criteria band, and the as-left selpoint tolerance band are specified in a document incorporated by reference into the Updated Final Safety Analysis Report.                                                  1 7

RTS Instrumentation B 3.3.1 Q44w l Rev. 2 Change A-5 I BASES BACKGROUND (continued) defined in Technical Specifications as "...being capable of performing its safety functions(s)." Fer automatic protective devices, the required safety fuIto is to ensuro th t a SL is not emceoded and therefore the LSSS se I -n-l -. In t If

                                                    -U           on -! as age I]: Ht]

U~O1t U(IIflU I ~rr¶

                                                                                 ~d[1O   JE.1 IB I~HU NDDDA Dl rDILII
                                                                                                              -    T-          - - Bar r are Tlilili1(1 lit]LI correcivie      ac     se             the rule whtoicnhae tefinecessry t eInr d byF                                                     in Text deleted because the eychnical Specifications andUs corresponding designation as the LSa BVPS CTS Bases                   requhseeby 10 CFR 50.36 would be an overly restrictive require                                if it discussions that identify         were apping as an OPERABILITY limit for the "as found" val                                a and cescribe the BVPS             protective aevct se ting during a surveillance. This wousult in specific LSSS are used in         Technical Sw dsilln compliance problemit a wol                      h eports and place of this generic text.

Therefore, this text is corrective actions requi byth rue h red- ssary to ensure unne essary detail that safety. For example, an~a tsatic protectie evice with a setting that explains something which has been found to be drifferent t p setpoint due to some drift of is not applicable to BVPS. the setting may still be OPErce drift is to be expected. This expected drift would have bee pcific3H accounted for in the setpoint methodology for calculatwe trip setpointw thus the automatic protective action wo J§I have esured that thy would not be exceeded with t as found" setting of the protectiv x~ice. Therefore, the device wa tl be OPERABLE since it woul hve ormed its safety funcin and the only corrective action reqie woudb~ reset themter e to the trip selpoint to account for further drift durigth t

                                      ,%tfveillance interval.\

2~ oint to define "as found" OF designation as thecumstances described above woul re oth the rule and Technical { je _s l at are c early not warrantee there is al6o The __ seome point beyond which the device would have-not been able to rfonr its function due, for example, to greater than expected drift. TFhvalue. of this _eedest-be specified in the Technical Specifications in order to define setting is OPERABILITY of the devices and is designated as the Allowable Value,< I PERABILITY limit Which, PsMated above, w.... thevvzz is same asvvw . .v v.,ea .. .. the LSSS. The Allowable Value specified in Table 3.3.1-1 serves as theL&Sm such that a channel is OPERABLE if the trip setpoint is found not to exceed the TeAt deleted because it is Allowable Value d-rin tho CHANtNEL OPERATIONAL TERST (COT). As either redundant to sR ,t~ able Value differs from the trip setpoint by an subsequent discussions in primarily equal toerd instrument loo es, such as Trip SetpointlAllowable Val ie section of Bases or drift, during the surveillance in ner, the actual setting of is unnecessary detail that the device will sti SSS definition an a Safety 20 does not significantly add Li exceeded at any given point of time as long as the to the understanding of the n-t AM-frld 1-u-nd that ,k-M~AH e1-0-n the- --lrv01-nr int-rl MNnfo RTS TS that, although the channel is "OPERABLE" under these circumstances, WOG STS B 3.3.1 - 2 Rev. 2, 04/30/01 36

I Rev. 2 Change A-5 I RTS Instrumentation B 3.3.1 BASES the BVPS Unit 1and Unit 2 setpoint _ methodology for protection systems (Ref. 1). BACKGROUND (coni tinued) the trip setpoint should be lIft adjusted to a value within the established the trip setpoint calibration toleance band, in accordance with uwedaio[W-E assumptions stated in the. oforoncod setpoint methodology (as left ok ger _ l ++_ Ot -A'tt_+ GFRIFIal-u

                      -a  -\

aRna GORiiirR9

                                  -ar  -A-A-Iar Ng DOH19DUiiiliR9
                                                         -   -t Wmllnm  -t uiu~        iiwrc~

the uncertainty terms atsig~ed. If the actual setting of the device is found to have exceeded the Allowable Value the device would be considered inoperable from a Technical Specification perspective. This requires corrective action including those actions required by 10 CFR 50.36 when automatic protective devices do not function as required. natively, a TS format incorporating an Allowable Valu column may oposed by a licensee. In this case th tpoint value of Table 3.3. - cated in the TS Base a licensee-controlled document outside S. C to the trip setpoint value would be controlled by 10 CFRministratively as appropriate, and adjusted per the se methodology licable surveillance requirements. option, the licensee may inclu e trip setpoint in Table 3 s shown, or as suggested by the licensees' dology or license. ] During A0Os, which are those events expected to occur one or more times during the unit life, the acceptable limits are:

1. The Departure from Nucleate Boiling Ratio (DNBR) shall be maintained above the Safety Limit (SL) value le prevent departim from nucleato boiling (DNB),

2. Fuel centerline melt shall not occur, an

3. The RCS pressure 4% of psia sharI not be exceeded.

Operation within the SLs of Specification 2.0, "Safety Limits (SLs)," also maintains the above values and assures that offsite dose will be within the10CFR50,and10CFR40O d ng-A s. Ilimits l Accidents are events that are analyzed e\ lrthixuyug they are not expected to occur during the unit life. The acceptable limit during U t accidents is that offsite dose shall be maintained within a d fractionef 10 CFR 4 imits. Different accident categories are allowed a fitterent traction ot these limits, based on probability of occurrence. Meeting the acceptable dose limit for an accident category is considered having acceptable consequences for that event. WOG STS B 3.3.1 - 3 Rev. 2, 04/30/01 37

RTS Instrumentation B 3.3.1 l Rev. 2 Change A-5 BASES BACKGROUND intinued) ,and LSSS Allowable Values RTS Set~oint t e Th trip setpoints used in U p are based on the analytical limits stated in Reference 1. The selection of these ip setpoints is such that nominal adequate protection is provided when all sensor and processing time delays are taken into account. To allow for calibration tolerances, tunertainties, instrument drift, and severe environment errors for those H I 6 channels that must function in harsh n'vFironments ae defined by 10 CFR 50.1 0 (Ref. 5), tho Allowable Values IpecIified in Tbe3.3. I1 in the accor~mpanvinn I CO a;re coAvaiv sith rprsnect to the analytical limits. A detailed description of the methodology used to calculate the Allowable Values andkrip setpoints, including their explicit nominal uncertainties, is provided in the "RTSIESFAS Setpoint Methodology xSttdy! (R46) which incorporates all of the known uncertainties applicable to each channel. The magnitudes of these uncertainties are Reference I factored into the determination of each'irip setpoint and corresondingr d I Allowable Value. The trip setpoint entered into the b ismore Ltrip evice conservative than thatlspecified by the Allowable Value (LSSS)-to naccount for measurement errors detectable by the COT. The Allowable Value serves as the Technical Specification OPERABILITY limit fo.-the purpose of the COT. One example of such a change in measurement INSERT 6 ror is drift during the surveillance interval. If the measured setpoipt does ceed the Allowable Value, the is`consiere I char3n 1 nominal OPERABL t Th trip setpoint is the value at which the is set and is the

                                  .expected value to be achieved during calibration.                                               v trip device with a       ensures the LSSS and the safety analysis limits are met for surveillance to be within nominal trip setpoint       interval selected whya channel is adjusted based on stated channoli                                     the ble   s cnsidredcalibration u-roetaintie6. Any ble is considered to be properly adjusted when                                        tolerance the "as left" setpoint value is within the band for CHANNE GALIBRATION un~ertainity allowance (ige., ++/-rack calibration +                                       clibration cfoparator setting UnGraintiesh). Tho trip setpoint value is                                  therefore oerance.

ZI INSET Tr conElaeroa a -nominal - ;aluoeie., exprcfesa as a value without inequalities) for the purposes of COT and CHANNEL CALIBRATION. ai p q setpIItbidl ibicn.. M G - I Woiu ea R 1 - BAS-l 1let Mquirtmn:11[i U 1 - I-O raf - .6A A,-1 .1 I - I KA

                                                                                                               .tu;:iUi.        dUlUu
                                                                                                                             '.W.D0i ho Operable RTS Functions        c     ensure that SLs are not violated during AOOs (and that the with setpoints maintained         consequences of DBAs will be acceptable, providing the unit is operated spwcifed in the Technical         from within the LCOs at the onset of the AOO or DBA and the equipment Specifications                    functions as designed).

WOG STS B 3.3.1 - 6 Rev. 2, 04/30/01 40

RTS Instrumentation B 3.3.1 K), I Rev. 2 Change A-5 I BASES i;Bases a

D

                        § IT         APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued) provido d that the +/-

calibration tolerance band nominal trip setpoint. A trip setpoint may be set more conservative tha n remairs the same and 2 the nominal trip setpoint as necessary in response to plant condition the All 3wable Value is Failure of any instrument enders the affected channel(s) inoperable and administratively controlled reduces the reliability pL£hA affected Functions. accorcingly in the conseivative dir meet tie assumptions of INSERT 9 I t aa The LCO generally reqiresPERABILITY of four or three channels in I the setpoint methodology. each instrumentation Function, two channels of Manual Reactor Trip in The conservative each logic Function, and two trains in each Automatic Trip Logic Function. direction is established by Four OPERABLE instrumentation channels in a two-out-of-four the dirtaction of the configuration required when one RTS channel is also used as a Allowable Value. system input. This configuration accounts for the possibility of the may be ~shared channel failing in such a manner that it creates a transient that requires RTS action. In this case, the RTS will still provide protection, However, exceptions to even with random failure of one of the other three protection channels. these requirements are Three OPERABLE instrumentation channels in a two-out-of-three part of the current configuration are generally required when there is no potential for control Iizensing and designcofgrtoargeealreurdwethrisnponilfrcnrl tasis (e.g., inthe steam system and protection system interaction that could simultaneously create cenerator level a need for RTS trip and disable one RTS channel. The two-out-of-three instrumentation a median and two-out-of-four configurations allow one channel to Pe tripped during selector switch is utilized maintenance or testing without causing a reactor trip. vvnecific exceptions separa tion between the to the above general philosophy exist and are discussed below. Frotection and control systems instead of a Reactor Trip System Functions fourth level instrument channel). The The safety analyses and OPERABILITY requirements applicable to each RTS Function are discussed below: The Manual Reactor Trip feature is not ( 1. Manual Reactor Trip (D)~ credited by any safety analyses. The Manual Reactor Trip ensures that the control room Operator can initiate a reactor trip at any time by using either of two reator trip switches in the control room. A Manual Reactor Trip accoNplishes the same results as any one of the automatic trip Functions It is used by the reactor operator toshut down the reactor whenever any Imnully I ~ -;th,;4_ PO IMM 1rM"1Pt1 ____ tMVMMUl me ___________ 0-4 _ V!g MWOU _-__rd Myt mmMPl0DtgUjjlMMt. The LCO requires two Manual Reactor Trip channels to be OPERABLE. Each channel is controlled by a manual reactor trip switch. Each channel activates the reactor trip breaker in both trains. Two independent channels are required to be OPERABLE so that no single random failure will disable the Manual Reactor Trip Function. WOG STS B 3.3.1 - 9 Rev. 2, 04/30/01 43

RTS Instrumentation l B3.3.1 Rev. 2 Change A-5 J BASES J ,,A;, . As, ,.;, SURVEILLANCE REQUIREMENTS (continued) 2 OH~ relay are verified by other Technical Specificationand non Technical Specifications teste at least onre per FefU*ling interval with aPPlicable ee/~icn Setpoints must be within the Allowable Values specified in Table 3.3.1-11 The difference between the current "as found" values and the previous INSERT 10 test "as left" values must be consistent with the drift allowance used in the setpoint methodology. The setpoint shall be left set consistent with the assumptions of the current unit specific setpoint methodology. I 21 lThe "as found" and "as left" values must also be recorded and reviewed

                 \/E\n~tcncy with the assumptions of Roeoc SR 3.3.1 .: is modified by a Note that provides a                        delay in the 5-requirement to perform this Surveillance for source range instrumentation when entering MODE 3 from MODE 2. This Note allows a normal                             6

( shutdown to proceed without a delay for testing in MODE 2 d a short time in MODE 3 until the RTBs are open and S 31 is no A b b performed. If the unit is to be inIMODE3with-he-RTBsclosedf ors this Surveillance must be performed prior to hours after entry introMODE 3. decreasing power below the P-6 setpoint. The Frequency of 1921 clays isjustified in Reference 7. A(,u SR 3.3.1. f fJi SR 3.3. isthe performance of a COT as described in SR 3.3.1.7, except it is modified by a Note that this test shall include verification that the P-6 and P-10 interlocks are in their required state for the existing unit condition. I A ful test of the required contact(s) of a chalosti may be performed byT~e-edfiation of the change 55aeina igle contact of the relay. This clarifie ieas~ia able COT of a relay.

                      ,This is acceptable because alls     _g eoCntacts                             of the relay are verified by               ote              pcfcations and non Specifi at, o atlatoce per rt-fu-ling intervl wt                              p l e~tions. IThe Frequency is modified by aNote that allows this surveillance to be satisfied if it has been performed within f921 days of the Frequencies prior to reactor startup and fGH1iours after reducing power below P-1 0 and P 6. The Frequency of "prior to startup" ensures this surveillance is performed prior to critical operations and applies to the
                         ~ourGeo, intermediate and power range low instrument channels. The Frequency of 11 2}hours after reducing power WOG STS                                 B 3.3.1 - 48                                       Rev. 2, 04/30/01 82

RTS Instrumentation B 3.3.1 ,I'} Rev. 2 Change A-5 BASES SURVEILLANCE REQUIREMENTS (continued) verifies that the channel responds to a measured parameter within the

         \       J\                     necessary range and accuracy.

Insert description of CHANNEL CALIBRATIONS must be performed consistent with the RTD calibration assumptions of the unit specific setpoint methodology. The difference from next page. between the current "as found" values and the previous test "as left" values must be consistent with the drift allowance used in the setpoint (\Ei methodology. CR The Frequency of 18 months is based on the assumption of an 18 monith calibration interval in the determination of the magnitude of equipment E1 drift in the setpoint methodology. SR 3.3.1.1 0 is modified by a Notstating that this test shall include verification that the time constants are adjusted to the prescribed values where applicable. S-R3.3A.1.11 n dton ths SR 3-11 1 is the nArform;ncn of ; CHANANEL AMIRATION. Rs SR is modified by a 2 Notetating that neutron detectors are excluded from the CHANNEL CALIBRATION. The CHANNEL CALIBRATION for the power range calibration data neutron detectors consists of a normalization of the detectors based on a and establishing power calorimetric and flux map performed above 15% RTP. The detector CHANNEL CALIBRATION for the source range and intermediate range operating neutron detectors consists of obtaining the detector plateau or preamp conditions in Sicriminator cure evaluating those GruAve, and comparing the curves accordance with Ao-B-i approved plant to the manufacturer's d:at This Surveillance is not required for the NIS procedures. power range detectors for entry into MODE 2 or 1, and is not required for the NIS intermediate range detectors for entry into MODE 2, because the unit must be in at least MODE 2 to perform the test for the intermediate range detectors and MODE I for the power range detectors. T4he V10 - ,based on the need to perform this Surf unaer the conumu inalatpply uurirng a plant oua ine poienual ror an unplanned transient i e I erformed with the reactor at power. Operati en w n these components usually pass i ance when performed o nth I\I:) WOG STS B 3.3.1 - 50 Rev. 2, 04/30/01 84

I Rev. 2 Change A-5 l 3.3.1 Bases Inserts

5. In addition to the channel OPERABILITY guidance discussed above, the CHANNEL OPERATIONAL TEST (COT) and CHANNEL CALIBRATION Surveillance Requirements (SRs) specified on Table 3.3.1-1 for certain RTS Functions are modified by Notes (k) and (I) that specify additional Technical Specification requirements. The applicable Notes are specified directly on Table 3.3.1-1 next to the numerical SR designations for the affected RTS Functions.

The additional Technical Specification requirements for these RTS Functions include OPERABILITY evaluations for setpoints found outside the as-found acceptance criteria band and the requirement to reset the setpoint to within the as-left tolerance of the nominal trip setpoint or a value that is more conservative than the nominal trip setpoint or declare the affected channel inoperable. These additional Technical Specification requirements are only applicable to the RTS Functions with the Notes modifying their COT and CHANNEL CALIBRATION SR numbers on Table 3.3.1-1.

6. As discussed earlier, for certain RTS Functions, the COT and CHANNEL CALIBRATION SR numbers specified on Table 3.3.1-1 are modified by Notes that impose additional Technical Specification requirements for channel OPERABILITY.

7. The nominal trip setpoint is based on the calculated total loop uncertainty per the plant specific methodology documented in the Licensing Requirements Manual. The setpoint methodology, used to derive the nominal trip setpoints, is based upon combining all of the uncertainties in the channels. Inherent in the determination of the nominal trip setpoints are the magnitudes of these channel uncertainties. Sensors and other instrumentation utilized in these channels should be capable of operating within the allowances of these uncertainty magnitudes.

Occasional drift in excess of the allowance may be determined to be acceptable based on the other device performance characteristics. Device drift in excess of the allowance that is more than occasional, may be indicative of more serious problems and would warrant further investigation.

8. For most RTS Functions the Allowable Value specified on Table 3.3.1-1 is the LSSS required by 10 CFR 50.36. However, for certain RTS Functions, the COT and CHANNEL CALIBRATION SR numbers specified on Table 3.3.1-1 are modified by Notes (k) and (I) that impose additional Technical Specification Requirements for channel OPERABILITY and change the LSSS for the affected Functions. For each RTS Function in Table 3.3.1-1 with Notes modifying the required COT and CHANNEL CALIBRATION SR numbers, the nominal trip setpoint specified in the Licensing Requirements Manual is the LSSS.

This definition of the LSSS is consistent with the guidance issued to the industry through correspondence with Nuclear Energy Institute (NEI) (Reference NRC-NEI Letter dated September 7, 2005). The definition of LSSS values continues to be discussed between the industry and the NRC, and further modifications to these Bases will be implemented as guidance is provided. Table 3.3.1-1 Notes (k) and (I) are applicable to the COT and CHANNEL CALIBRATION SRs for specific instrument functions since changes to Allowable Values associated with these instrument functions were already under review by the NRC at the time the revised NRC setpoint criteria were documented and made available to the industry in an NRC letter to NEI. Changes to the remaining instrument functions may be pursued after guidance endorsed by both the NRC and NEI is issued. 90A

I Rev. 2 Change A-5 l 3.3.1 Bases Inserts

9. In addition to the channel OPERABILITY guidance discussed above, the CHANNEL OPERATIONAL TEST (COT) and CHANNEL CALIBRATION Surveillance Requirements ('SRs) specified on Table 3.3.3-1 for certain RTS Functions are modified by Notes (k) and (I) that specify additional Technical Specification requirements. The applicable Notes are specified directly on Table 3.3.1-1 next to the numerical SR designations for the affected RTS Functibns.

The additional Technical Specification requirements for these RTS Functions include OPERABILITY evaluations for setpoints found outside the as-found acceptance criteria band and the requirement to reset the setpoint to within the as-left tolerance of the nominal trip setpoint or a value that is more conservative than the nominal trip setpoint or declare the affected channel inoperable. These additional Technical Specification requirements are only applicable to the RTS Functions with the Notes modifying their COT and CHANNEL CALIBRATION SR numbers on Table 3.3.1-1.

10. For certain RTS Functions the required COT (SR 3.3.1.6 specified in Table 3.3.1-1) is mod fied by Notes (k) and (I). These Notes specify additional requirements for the affected instrument channels.

Note (k) specifies the following:

If the as-found channel setpoint is conservative with respect to the Allowable Value but outside its predefined as-found acceptance criteria band, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service, and
If the "as-found" instrument channel setpoint is not conservative with respect to the Allowable Value, the channel shall be declared inoperable.

The evaluation of channel performance required by Note (k) involves an assessment to verify the channel will continue to behave in accordance with design basis assumptions, and to ensure confidence in the channel performance prior to returning the channel to service. In addition, if the 'as found" trip setpoint value is non-conservative with respect to the Allowable Value, or is found to be outside of the two sided predefined acceptance criteria band on either side of the nominal trip setpoint, the affected channel will be evaluated under the corrective action program. Note (I) specifies the following:

The instrument channel setpoint shall be reset to a value that is within the as-left tolerance of the nominal trip setpoint, or a value that is more conservative than the nominal trip setpoint; otherwise, the channel shall be declared inoperable, and
The nominal trip setpoint and the methodology used to determine the nominal trip setpoint, the predefined as-found acceptance criteria band, and the as-left setpoint tolerance band are specified in a document incorporated by reference into the Updated Final Safety Analysis Report.

For BVPS, the document containing the nominal trip setpoint, the methodology used to determine the nominal trip setpoint, the predefined as-found acceptance criteria band, and th as-left setpoint tolerance band is the LRM. 90B

I Rev. 2 Change A-5 l 3.3.1 Bases Inserts (Insert 10 continued) For the RTS Functions with a COT modified by Note (I), the Note requires that the instrument channel setpoint be reset to a value within the 'as left" setpoint tolerance band on either side of the nominal trip setpoint or to a value that is more conservative than the nominal trip setpoint. The conservative direction is established by the direction of the inequality sign applied to the associated Allowable Value. Setpoint restoration and post-test verification assure that the assumptions in the plant setpoint methodology are satisfied in order to protect the safety analysis limits. If the channel can not be reset to a value within the required "as left" setpoint tolerance band on either side of the nominal trip setpoint, or to a value that is more conservative than the nominal trip setpoint (if required based on plant conditions) the channel is declared inoperable and the applicable ACTION is entered. For the RTS Functions with a COT modified by Notes (k) and (I), the 'as found" and "as left' setpoint data obtained during COTs or CHANNEL CALIBRATIONS are programmatically trended to demonstrate that the rack drift assumptions used in the plant setpoint methodology are valid. If the trending evaluation determines that a channel is performing inconsistent with the uncertainty allowances applicable to the periodic surveillance test being performed, the channel is evaluated under the corrective action program. If the channel is not capable of performing its specified safety function, it is declared inoperable.

11. For certain RTS Functions the required CHANNEL CALIBRATION (SR 3.3.1.10 specified in Table 3.3.1-1) is modified by Notes (k) and (I). These Notes specify additional requirements for the affected instrument channels.

Note (k) specifies the following: YJ)' . If the as-found channel setpoint is conservative with respect to the Allowable Value but outside its predefined as-found acceptance criteria band, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service, and a If the "as-found" instrument channel setpoint is not conservative with respect to the Allowable Value, the channel shall be declared inoperable. The evaluation of channel performance required by Note (k) involves an assessment to verify the channel will continue to behave in accordance with design basis assumptions, and to ensure confidence in the channel performance prior to returning the channel to service. In addition, if the 'as found" trip setpoint value is non-conservative with respect to the Allowable Value, or is found to be outside of the two sided predefined acceptance criteria band on either side of the nominal trip setpoint, the affected channel will be evaluated under the corrective action program. Note (I) specifies the following:

The instrument channel setpoint shall be reset to a value that is within the as-left tolerance of the nominal trip setpoint, or a value that is more conservative than the nominal trip setpoint; otherwise, the channel shall be declared inoperable, and
The nominal trip setpoint and the methodology used to determine the nominal trip 90C

I Rev. 2 Change A-5 I 3.3.1 Bases Inserts (Insert 11 continued) setpoint, the predefined as-found acceptance criteria band, and the as-left setpoint tolerance band are specified in a document incorporated by reference into the Updated Final Safety Analysis Report. For BVPS, the document containing the nominal trip setpoint, the methodology used to determine the nominal trip setpoint, the predefined as-found acceptance criteria band, and the as-left setpoint tolerance band is the LRM. For the RTS Functions with a CHANNEL CALIBRATION modified by Note (I), the Note requires that the instrument channel setpoint be reset to a value within the "as left" setpoint tolerance band on either side of the nominal trip setpoint or to a value that is more conservative than the nominal trip setpoint. The conservative direction is established by the direction of the inequality sign applied to the associated Allowable Value. Setpoint restoration and post-test verification assure that the assumptions in the plant setpoint methodology are satisfied in order to protect the safety analysis limits. If the channel can not be reset to a value within the required 'as left' setpoint tolerance band on either side of the nominal trip setpoint, or to a value that is more conservative than the nominal trip setpoint (if required based on plant conditions) the channel is declared inoperable and the applicable ACTION is entered. For the RTS Functions with a CHANNEL CALIBRATION modified by Notes (k) and (I), the "as found" and "as left" setpoint data obtained during COTs or CHANNEL CALIBRATIONS are programmatically trended to demonstrate that the rack drift assumptions used in the plant setpoint methodology are valid. If the trending evaluation determines that a channel is performing inconsistent with the uncertainty allowances applicable to the periodic surveillance test being performed, the channel is evaluated under the corrective action program. If the channel is not capable of performing its specified safety function, it is declared inoperable. 90D

Rev. 2 Change A-5 BVPS ISTS Conversion 3.3A RTS Instrumentation Enclosure 2 Changes to The ISTS Bases ITS 3.3.1 Reactor Trip System InstrumentationBases JUSTIFICATION FOR DEVIATION (JFD)

1. This JFD addresses all changes made to the Bases that are editorial in nature and that (1o not affect the technical content of the Bases. The changes addressed by this JFD are made to correct spelling, grammar, and capitalization errors as well as incorporate wording preferences. In some cases, these changes are necessary to make the descriptions of reference content correct (e.g., the content of the BVPS UFSARs may not be exactly the same as described in the ISTS Bases) or to make the actual location of information discussed correct for BVPS (e.g., the location of trip setpoints outside of the TS or the location of the list of the number of required channels for each RTS Function). The reasons for the changes addressed by this JFD are considered self-explanatory and a separate more detailed explanation unnecessary. These changes do not significantly impact the technical discussions contained in the Bases and in general improve the clarity or correctness of the affected text or make the text more specific to BVPS. As such, the proposed changes are acceptable.

2. Changes are made to the ISTS Bases to reflect the BVPS specific setpoint methodology and changes introduced by Amendment numbers 270 Unit 1 and 152 (Unit 2). These Amendments introduced Notes to the COT and Channel Calibration SRs that affect the definition of the LSSS for certain RTS Functions. The BVPS trip setpoints associated with the RTS Functions are typically nominal values with a calibration tolerance. The nominal trip setpoints are specified in the Licensing Requirements Manual not the TS. The BVPS Allowable Value is determined by the nominal trip setpoint calibration tolerance. The BVPS RTS Function operability is determined by verifying the Function is within the specified Allowable Value (setpoint calibration tolerance). The changes associated with this JFD are required to maintain consistency with the current BVPS setpoint methodology and the current BVPS licensing basis as modified by Amendment numbers 270 and 152.

3. Consistent with the BVPS safety analyses performed by Westinghouse, maintaining the minimum DNBR above the safety limit does not prevent DNB from occurring. By definition, maintaining the DNBR above the safety limit demonstrates that there is a 95% probability at a 95% confidence level that the lead rod will not experience DNB. As such, the generic ISTS bases text is revised to delete the reference to preventing DNB. In addition, the mare conservative BVPS specific analytical acceptance criteria for RCS pressure (2748.5 psia) is referenced in the Bases instead of the Safety Limit (SL) value used in the standard Bases.

4. The ISTS discussion of offsite dose limits is revised to include the limits of 10 CFR 50.67.

The BVPS design basis accident analysis utilize the Alternate Source Term and offsite dose limits associated with 10 CFR 50.67 instead of 10 CFR 100 for the dose calculations. This change makes the ISTS Bases more consistent with the current BVPS licensing Basis.

5. The standard bases text is deleted or revised to make the generic bases discussion more BVPS Units 1 &2 Page 1 Revision 2, 4/06 92

Rev. 2 Change A-5 FUNCTION A A -- ed UNIT2 OR OTHERSPECI IED CONDITION l REQCTOITRUMENTED ICONDITIONS

                                      \                 \                             _\~~MINIU                                    ,//

6TGTA3 NO. CHANNELS CHANNELS ALLOWAELE APPLIC LE F________ __;_ GPF CHANNELS TO TRIP OPERABLE VALUE MODES AG4GN J .Overtemperature AT 3 2 See Table t io 1, 2 Overpoe 3 2 See Table 1, 2 Notation (h/)\ gPrcesle-ToW 3 2 2 Ž 1941 psig** 1, G K

            ~(bov      P-74 ~        Applicablilty (A4)>E ressrurizer-        zuze High             3               2                2                S 2379 psig                   , 2     L\
     **4. Preconrstant        uwati   L e     in t                    2                2P              < P9                          2 s           fo lea     and High       on f                     a                                          BASES        t                span oinstrument         d
                             -ISingle        Loop            ll2/loop            in      2    /  op in
                 /operating                                                              op  rat~n n Aloop Atilabllv                                                    170                                     \                                        21 A      AVERf VARLE  - UT         2                        3/loop 2/loop in        2A                  89.6                              L  d mn         15 Y    T      (Above    P-71andbew             8)                        two                             rac
                                                                                                   \lniaed             loop   nI                  =_     _>
                   >   \                                               ~~~operating      tpratn          fo                         AE 1.Reactor Coolant Flow Low                                      loops            goop,       \t-

14. Steam Generator Water 3/loop 2/loop /2/loop n ro 1, 2 -7 ;

Level-Low-Low range instrument \

                                -hane8Clbrtin                                                     R    Not     cate                                                   1
                                                     ,_-_<                             o                 span-each     steam                                        f

( LA2 BAES r~ (L2 > . enerator ._

                                                    \/            ~8             (h)Above                      the P-7 (Low Power Reactor Trips Block) Interlock.l
        ** Time constants utilized in the lead-lag controller for Prsuier                                   Pressure-Low are 2! 2 seconds for lead and

S I second for lag, l Channe~lcalibration shall ensure that these time constants are adjusted to those Ivalues.

                                                                    'l  Channel Calibration SR Nt BEAVER VALLEY - UNIT 2                                               3/4 3-3                                                      Amendment No. 152           lA-6 0

_C C L I-- ___ A28CHANNEL OPERATIONAL I ___________A29 TEST (COT) OR TRIP Rev. 2 Change A-5 i < ACTUATING DEVICE ITS SR 3.3.1.14 Verity RTS OPERATIONAL TEST (TADOT) A28 Response Time Is within limits. OR ACTUATION LOGIC TEST J-^ Changes to Modes are _F REACTOR MIIU4frZ,~ ~ INS`TRUME~NTAIKI U SUKVh;11J1 R EMENTSl addressed In markup of Changes to Functions REA R R _N Table 3.3-1 are addressed Inmarkup of Table 3.3.1 Functional Unit Channel Check Channel Funcr

                                                                                                                 -nn e nal   I M
                                                                                                                                    ? edes in     Whieh I
      -     12. Loss of Flow - Sn                    e   o                                                                          1

3. Loss of Flow - Two Loop

      -4 (Above P-7 and clew                 r 8) 14.\team/Generator Water L                     el-L w-Low

15. DEL TED.

16. Under ltage-Reac r Coolant NA Pumps ove P-7)

17. Underfre ency eactor N.A.

_ _ Coolant Pu s (Above P-7)

18. Turbine Tr'(Above P-9)

A. Emerg ncy ip Header N.A. Low ressur B. Tu me Stop alve N.A. C osure\

19. Saf ty Injection Inp t from N.A.

ES

20. eactor Coolant Pump Br aker N.A.

Position Trip (Above P-7

1. Reactor Trip Breaker N.A.

                                                                                                         --   A. Q / _14)
                                                                                                            -_T ,

BEAVER VALLEY - UNIT 2 3 /4 3 -11 Amendment No. 152 I A-6 (9)

Ad, ust power range channel If calorimetric heat balance cal ulatlon results exceed power range channel output by more than + 2% RTP. Not required to be performed until 24 hours Rev. 2 Change A-9 aftnr THERMAL POWER is 215% RTP. Not required to be performed until 7 days after THERMAL POWER is I 2 50% RTP. 42+ -NHea~-b lanee only, above 15 pereent cof RATED THIERMAL POWEI X 1

         -        r          At least once every 31 Effective Full Power Days (EFPD)
                         , compare incore to excore axial imbalance above 50 percent Notes                     of RATED THERMAL POWER.                  Ralibratif                      te difference greater than or equal to 3 percent.                            Adjust (4)                (Net U~sed)l. Frequency of SR 3.3.1.4 & SR 3.3.1.5               '  A35 45-          -     jEach train            tested      every   other month        on a      STAGGERED       TEST IBASIS.                                                                                            I 46(                 Neutron detectors may be excluded from CHANNEL CALIBRATION.                                     I 4-7                         l                                                -     Note i!.R13.1.10 ]

4(-8+/- - Below 2-6, not required to be performed for source range - instrumentation prior to entering MODE 3 from MODE 2 until LF Applicability

              ~              12husIfe icblt 12 hours after entr                 inte   _GD    3;      powe~rhas been reduced belowP..S
          ,-{9)
             ,8                   . , ,._
                              ,{Befit  1-  H      I __        . _     I        -.

1-1 (10) - The CHANNEL FUNCTIONAL TEST shall independently verify the OPERABILITY of the undervoltage and shunt trip circuits for the Manual Reactor Trip Function. The test shall also verify the OPERABILITY of the Bypass Breaker trip circuit(s). BEAVER VALLEY - UNIT 2 3/4 3-13 Amendment No. 15E I 116

I Rev. 2 Change A-5 I TABDLT 4..3 1 (Continued) NOTATION (Continued) (16) - If the as-found channel setpoint is conservative with respect to the Allowable Value but outside its predefined as-found acceptance criteria band, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service. If the as-found instrument channel setpoint is not conservative with respect to the Allowable Value, the channel shall be declared inoperable. (17) - The instrument channel setpoint shall be reset to a value A-5 that is within the as-left tolerance of the Nominal Trip Setpoint, or a value that is more conservative than t:he Nominal Trip Setpoint; otherwise, the channel shall be declared inoperable. The Nominal Trip Setpoint and the methodology used to determine the Nominal Trip Setpoint, the predefined as-found acceptance criteria band, and the as-left setpoint tolerance band are specified in a document incorporated by reference into the Updated Final Safety Analysis Report. l ITS Table 3.3.1-1 Notes (k) 8 (I) BEAVER VALLEY - UNIT 2 3/4 3-13a Amendment No. 152 116A

BEAVER 'vALLEYi - 'uNIT 1 3;4 3 -3 AtrmleincdLLLrLI .vo. 273 I 0,

TABLE 3.3-1 (Continued) l Rev. 2ChangeA- J TABLE NOTATION ction may be manually bypassed in this Mode above P-1 (2) Trip functio nually bypassed in thi ve P-S. (3) W Changes to this Unit 1 material are addressed in the Unit 2 markup. and the control rod drive s capable of rod wi (8) In t ondition, source range Function does not provi r ip ut does provide indication. I:Ovrtmprture A Note I (Unit 1)l The Overtemperature AT Function Allowable Value shall not exceed the following nominal trip setpoint by more than 0.5% AT span for the AT channel, 0.5t AT span for the Tavg channel, 0.5% AT span for the Pressurizer Pressure channel and 0.5% AT span for the f(AI) channel. AT (I<: S) ATo [KI -K2 (+rIS)[T (1 +r 5 ) T1] + K3 (P -P')-f(AI)] where: AT is measured RCS AT, 'F. D /FA POWE ATO is loop specific indicated AT at UTE W, OF. T is measured RCS average temperature, OF. T' is Tavg at PATED T-IIEPJ{AL ecified in the COLR. P is measured pressurizer pressure, psia. PI is nominal pressurizer pressure specified in the COLR. _+rS is the function generated by the lead-lag compensator

             +Tr2 S   for Tavg.

11 & T2 are the time constants utilized in the lead-lag compensator for Tavg specified in the COLR. I_ is the function generated by the lag compensator for (I+r 4 S) measured AT. I is the function generated by the lag compensator for (I+T5 S) measured Tavg. 4 & T5 are the time constants utilized in the lag compensators for the AT and Tavg, respectively, specified in the COLR. BEAVER VALLEY - UNIT 1 3/4 3-5 Amendment No.273, 121

TABLE 3.3-1 (Continued) I Rev. 2 Change A41E I TABLE NOTATION (Continued) 3 I

                                                 -1 S is the Laplace transform operator, sec .

K1 is specified in the COLR. K2 is specified in the COLR. K3 is specified in the COLR. f(AI) is a function of the indicated difference between top and bottom detectors of the power-range nuclear ion chambers as specified in the COLR. BEAVER VALLEY - UNIT 1 3/4 3-5a Amendment No.273 122

I Rev. 2 Change A8 I TABLE 3.3-1 (Continued) TABLE NOTATION (Continued) Note 2 (Unit 1) 4 : Overpower AT The Overpower AT Function Allowable Value shall not exceed the following nominal trip setpoint by more than 0.5% AT span for the AT channel and 0.5% AT span for the Tavg channel. AT (I+rS) < ATO [K 4 -K 5 (1 +TS)T 1 - K6 [T 1 -T")) (I+ T5 S) (I+r 5 S) where: AT is measured RCS AT, OF. ATo is loop specific indicated AT at PFAL PGW R, OF. T is measured RCS average temperaure, F. T" is Tavg at specified in the COLR. K4 is specified in the COLR. K5 is specified in the COLR. K6 is specified in the COLR. T3S is the function generated by the rate lag compensator 1+r 3 S for Tavg. T3 is the time constant utilized in the rate lag compensator for Tavg specified in the COLR. I is the function generated by the lag compensator for (I+r 4 S) measured AT. I is the function generated by the lag compensator for (I + r 5 S) measured Tavg. r4 8&rs are the time constants utilized in the lag compensators for the AT and Tavg, respectively, specified in the COLR. 1 S is the Laplace transform operator, sec , BEAVER VALLEY - UNIT 1 3/4 3-5b Amendment No. 273 I 123

I,- N

-4

I Rev. 2 Change A-<- TABLE 4.3-1 (Continued) Changes to this Unit I material are addressed in the Unit 2 markup. (1) - If no ormed in previous 31 days. (2) - Heat balance on e 15 RATED THERMAL POWER. (3) - At least once ev 1 E Full Power Days (EFPD) compare inc o excore axial i nce above 50 percent of RAT ERMAL POWER. Recalibra tet difference er than or equal to 3 percent.

      -     (Not Used)

(5) - Each train tested every other mont

      -    Neutron detectors may be excluded from CHANNEL CALIBRATION.

(7) - Below P-10. (8) - elow P-6, not required to be performed for sou e range i trumentation prior to entering MODE 3 from E 2 until 12 h rs after entry into MODE 3. (9) - (Not Use (10) - The CHANNEL CTIONAL TEST shall i ependently verify the OPERABILITY of e undervoltage a shunt trip circuits for the Manual React Trip Functin. The test shall also verify the OPERAB ITY of the Bypass Breaker trip circuit(s)s (11) - The CHANNEL FUNCTIONAL ES shall independently verify the OPERABILITY of the adervolt e and shunt trip attachments of the Reactor Tri Breakers. (12) - Local manual hunt trip prior X placing breaker in service. (13) - Autom

undervoltage trip.

(14) - W the reactor trip system breakers c s and the ontrol rod drive system capable of rod withdrawal. (15) - Surveillance Requirements need not be performe on alternate detectors until connected and required OPERABILITY. Changes to this Unit I material are addressed in the Unit 2 markup. BEAVER VALLEY - UNIT 1 3/4 3-13 Amendment No. 274 I 129

I Rev. 2 Change A-5 ] TABLE 4.3-1 (Continued) NOTATIol Changes to this Unit I material are addressed in the Unit 2 markup. (16) - if t as-found channel setpoint is nservative with respect the Allowable Value but o side its predefined as-found ac tance criteria band, en the channel shall be evaluated t verify that it functioning as required before returning e channel service. If the as-found instrument channel etpo is not conservative with respect to the Allowh Value, the channel shall be declared inoperable. A-5 (17) - The instrument nnel setpoiK shall be reset to a value that is with 'the as-left toler ce of the Nominal Trip Setpoint, a value that is more onservative than the Nominal rip Setpoint; otherwise, th channel shall be decla d inoperable. The Nominal Trip tpoint and the me odology used to determine the Nominal ip Setpoint, e predefined as-found acceptance criteria ba , and the as-left setpoint tolerance band are specified in a ocument incorporated by reference into the Updated Final fety Analysis Report. X BEAVER VALLEY - UNIT 1 3/4 3-13a Amendment No. 27C0 129A

Rev.2 ChangeC.1 BVPS ISTS Conversion _l l 3.3A RTS Instrumentation Enclosure 3 Changes to CTS measures for inoperable Power Range Neutron Flux- Low Trip Function channel(s) that address the potential for an RWFS in the new Applicable Modes. The proposed changes are acceptable because they provide additional protection in the TS for an RWFS event. The proposed changes provide additional assurance that the plant will be operated in a safe manner when the potential for an RWFS event exists. Together with the new ITS LCO 3.1.10, "RCS Boron Limitations < 500 OF," the proposed changes provide a more complete set of TS requirements (for both above and below an RCS temperature of 500 OF) that address the potential for an RWFS event. As such, the proposed changes do not adversely affect the safe operation of the plant. As the proposed changes include new operating restrictions (TS requirements) the changes are designated as more restrictive. Removed Detail Changes (LA) LA.1 (Type 3 - Removing Procedural Details for Meeting Tech Spec Requirements) CTS Surveillance 4.3.1.1.3 specifies that response time testing be performed for the RTS instrument Functions. The CTS surveillance includes details for performing the testing that specify "Each test shall include at least one logic train such that both logic trains are tested at least once per 36 months". The corresponding ISTS surveillance requirement specifies the same test be performed on a Staggered Test Basis. The CTS is revised to conform to the ISTS and the CTS details for performing response time testing on logic trains (replaced by the ISTS defined test term Staggered Test Basis) is moved into the bases for the response time test surveillance. This change also includes the editorial revisions made to the corresponding Unit 1 response time testing surveillance (not shown) to change the Unit 1 CTS wording from "test" and 'tested" to the more common ISTS descriptive terms of 'verify" and 'verified' which is also consistent with the corresponding Unit 2 surveillance. The replacement of the procedural detail in the CTS surveillance requirement with the defined term (Staggered Test Basis) used in the ISTS is acceptable because the detailed CTS description of the required testing is not necessary to be included in the TS to provide adequate protection of public health and safety. The defined test term used in the ITS is adequate to describe the required testing. The editorial changes (test to verify) made to the Unit I information being removed are acceptable because they do not affect the technical intent of the surveillance. The proposed ITS surveillance requirement continues to assure that response time testing be performed for the required instrument Functions in the same manner as before. The procedural details for implementing staggered testing on logic trains specified in the CTS is not required in order for the LCO operability requirements to be applicable and enforced. The ISTS defined test term used in place of the CTS requirement (i.e., Staggered Test Basis) provides a more complete and standardized method for implementing the required testing. The editorial changes to the Unit I material being removed are made solely to conform to the ISTS presentation of this information and with the current Unit 2 terminology. Also, the removal of the procedural detail is acceptable because this type of procedural detail will be adequately controlled in the ITS Bases consistent with the format and content of the ISTS. Changes to the Bases are controlled by the TS Bases Control Program BVPS Units 1 & 2 Page 34 Revision 2. 4/06 164

REMAINING DOC PAGES INCLUDED BVPS ISTS Conversion ONLY DUE TO REPAGINATION FROM 3.3A RTS Instrumentation CHANGE C-1 Enclosure 3 Changes to CTS specified in the Administrative Controls Section of the TS. This program provides for the evaluation of changes to ensure the Bases are properly controlled and that prior NRC review and approval is requested when required. This change is designated as a less restrictive removal of detail change because procedural detail is being removed from the TS. LA.2 (Type I - Removing Details of System Design and System Description, Including Design Limits) The Channels To Trip column in CTS Table 3.3-1 is deleted consistent with the ISTS. The corresponding ISTS RTS Table 3.3.1-1 does not include this information. The channels required to initiate an RTS function trip is described in the ITS Bases for each RTS Function. The proposed change is acceptable because the Channels To Trip column in CTS Table 3.3-1 contains information describing the design of the RTS which is not required to ensure the RTS system is maintained operable. The ISTS "Required Channels" specifies the necessary channels to maintain the RTS operable and the ISTS Actions provide the appropriate measures when the Required Channels are not met. RTS design features are also described in the UFSAR. Changes to the plant design as described in the FSAR are subject to the review requirements of 10 CFR 50.59. In addition, the requirements for the RTS design are also controlled by the required industry standards (IEEE 279, etc.), federal regulations (General Design Criteria), and specific NRC requirements and guidelines pertaining to the RTS. Changes to these plant design requirements are in turn controlled in accordance with the Quality Control Programs that are required by federal regulations (10 CFR 50.54). Also, this change is acceptable because the design description information will be retained within the ITS bases for each RTS Function and changes to the ITS Bases are controlled by the TS Bases Control Program specified in the Administrative Controls Section of the TS. This program provides for the evaluation of changes to ensure the Bases are properly controlled and that prior NRC review and approval is requested when required. This change is designated as a less restrictive removal of detail change because design detail is being removed from the TS. LA.3 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) The CTS RTS Functions 12 and 13 (Loss of Flow) contain operational descriptions of how these Functions work. CTS Function 12, is effective above the P-8 interlock and provides a reactor trip with low flow in a single RCS loop. CTS Function 13 is effective above the P-7 interlock and below the P-8 interlock and provides a reactor trip with low flow in two RCS loops. However, these CTS Functions utilize the same instrumentation and setpoints. In the ISTS, the operation of this RTS Function above and below the P-8 interlock is described in the RTS bases and the ISTS only specifies a single low flow Function that requires the affected instrument channels operable above the P-7 interlock. The CTS is revised consistent with the ISTS. This changes the CTS by moving the description of the Function design and operation into the associated RTS bases. The proposed change is acceptable because the information removed from the CTS Table 3.3-1 is not required in the TS to ensure the affected RTS instrumentation is maintained operable. The TS still requires the affected instrumentation to be operable in the applicable modes or specifies the appropriate Action to be taken in a similar manner as before. The description of how this function is designed to operate above or below the P-8 interlock is not required in the TS to ensure the BVPS Units 1 &2 Page 35 Revision 2, 4/06 165

l REMAINING DOC PAGES INCLUDED ONLY BVPS ISTS Conversion DUE TO REPAGINATION FROM CFIANGE C-1 3.3A RTS Instrumental ion Enclosure 3 Changes to C TS appropriate RTS instrumentation is maintained operable. Also, this change is acceptable since changes to the ITS Bases are controlled by the TS Bases Control Program specified in the Administrative Controls Section of the TS. This program provides for the evaluation of changes to ensure the Bases are properly controlled and that prior NRC review and approval is requested when required. This change is designated as a less restrictive removal of detail change because design detail is being removed from the TS. LA.4 (Type I - Removing Details of System Design and System Description, Including Design Limits) The allowable values specified for CTS Functions 11, 13, 14, 23d, and 23e on Table 3.3-1 contain design related descriptions that help to describe the allowable values (e.g., % of instrument span, % of indicated flow, or whether the setpoint is applied going up or down in power). The corresponding ISTS allowable values specified on Table 3.3.1-1 do not contain this additional descriptive information and simply present the allowable values as numerical values denoted as a percent. The CTS allowable values are revised to conform more closely to the corresponding ISTS allowable values. This changes the CTS by moving the design details associated with each allowable value listed above into the Bases description of the associated RTS Function. The proposed change is acceptable because it is necessary to conform more closely to the ISTS and because the design description associated with each affected allowable value is not required in the TS to ensure the operability of the associated RTS Function. The ITS continues to specify the setpoint in a simplified format and require that the associated RTS instrumentation be maintained operable. In addition, the design information associated with allowable values is documented in the RTS setpoint methodology referenced in the RTS bases. 'The setpoint methodology documents the design basis of the RTS Function allowable values, not the TS. In addition, the design information being moved from the affected allowable values specified in CTS Table 3.3-1 will be retained in the RTS bases for each of the associated RTS Functions. As such, this change is also acceptable because changes to the ITS Bases are controlled by the TS Bases Control Program specified in the Administrative Controls Section of the TS. This program provides for the evaluation of changes to ensure the Bases are properly controlled and that prior NRC review and approval is requested when required. This change is designated as a less restrictive removal of detail change because design detail is being removed from the TS. LA.5 (Type 3 - Removing Procedural Details for Meeting Tech Spec Requirements) CTS Action Note 6 modifying CTS Action 7 (applicable to the OverTemperature (OT) and OverPower (OP) RTS Functions) states; "An OPERABLE hot leg channel consists of: 1) three RTDs per hot leg, or 2) two RTDs per hot leg with the failed RTD disconnected and the required bias applied." The corresponding ISTS Action Condition E does not contain this level of detail describing the system operability requirements. The CTS is revised to conform to the ISTS. This changes the CTS by removing the descriptive detail contained in Note 6 and placing it in the ISTS bases for the OT and OP RTS Functions. The proposed change is acceptable because the information removed from the CTS Actions is not required in the TS to ensure the affected RTS instrumentation is maintained operable. The TS still requires the affected instrumentation to be operable in the applicable modes or specifies the appropriate Action to be taken in a BVPS Units 1 & 2 Page 36 Revision 2, 4/06 166

BVPS ISTS Conversion 3.3A RTS Instrumentation Enclosure 3 Changes to CTS similar manner as before. The detailed operability description of this RTS Function is more appropriately contained in the bases description of the RTS Function. The ISTS typically contains this type of information in the bases. Also, this change is acceptable because changes to the ITS Bases are controlled by the TS Bases Control Program specified in the Administrative Controls Section of the TS. This program provides for the evaluation of changes to ensure the Bases are properly controlled and that prior NRC review and approval is requested when required. This change is designated as a less restrictive removal of detail change because operability details are being removed from the TS. LA.6 (Type 3 - Removing Procedural Details for meeting Tech Spec Requirements) Unit 2 only (Unit 1 does not have Action 44). Action 44 is applicable to the Unit 2 RTS Interlock Functions (i.e., P-6, P-8, P-9, etc.). CTS Action 44 specifies the following for an affected interlock; "determine by observation of the associated permissive annunciator window(s) that the interlock is in its required state for the existing plant condition." The corresponding ITS Action Conditions 0 and P require the following; "verify interlock is in required state for existing unit conditions." The CTS Action is revised to conform to the ISTS. This changes the CTS by removing the specific procedural guidance explaining how to verify the interlock status (by observation of the associated permissive annunciator window(s)) from the TS and placing this guidance in the associated TS Bases. The proposed change is acceptable because the information removed from the CTS Actions is not required in the TS to ensure the affected RTS instrumentation is maintained operable. The TS still requires the affected instrumentation to be operable in the applicable Modes or specifies the appropriate Action to be taken in a similar manner as before. The procedural detail for completing the required actions is more appropriately contained in the bases description of the Action. The ISTS typically contains this type of information in the bases. Also, this change is acceptable because changes to the ITS Bases are controlled by the TS Bases Control Program specified in the Administrative Controls Section of the TS. This program provides for the evaluation of changes to ensure the Bases are properly controlled and that prior NRC review and approval is requested when required. This change is designated as a less restrictive removal of detail change because procedural details are being removed from the TS. LA.7 (Type 3 - Removing Procedural Details for meeting Tech Spec Requirements) The refueling surveillance requirement on CTS Table 4.3-1 for the Manual Reactor Trip Function is modified by Note 10. CTS Note 10 states "The CHANNEL FUNCTIONAL TEST shall independently verify the OPERABILITY of the undervoltage and shunt trip circuits for the Manual Reactor Trip Function. The test shall also verify the OPERABILITY of the Bypass Breaker trip circuit(s)". The corresponding ISTS surveillance requirement does not contain this procedural detail for testing the Manual Reactor Trip Function. The CTS is revised to conform to the ISTS. This changes the CTS by moving the procedural instructions in CTS Note 10) to the bases for the affected surveillance requirement. The proposed change is acceptable because the information removed from the CTS Surveillance Requirement is not required in the TS to ensure the affected RTS instrumentation is maintained operable. The TS still requires the surveillance testing to be performed on the affected RTS Function. The procedural detail for completing the surveillance testing is more appropriately contained in the bases description of the Surveillance Requirement. The ISTS typically contains this type BVPS Units 1 & 2 Page 37 Revision ,2,4106 167

BVPS ISTS Conversion 3.3A RTS Instrumentation Enclosure 3 Changes to CTS of information in the bases. Also, this change is acceptable because changes to the ITS Bases are controlled by the TS Bases Control Program specified in the Administrative Controls Section of the TS. This program provides for the evaluation of changes to ensure the Bases are properly controlled and that prior NRC review and approval is requested when required. This change is designated as a less restrictive removal of detail change because procedural details are being removed from the TS. LA.8 (Type 3 - Removing Procedural Details for meeting Tech Spec Requirements) The CTS surveillance requirements for the Reactor Trip Breakers (RTBs) specified on Table 4.3-1 require a Channel Functional Test (CFT). The CTS CFT is modified by a note (#11) that states "The CHANNEL FUNCTIONAL TEST shall independently verify the OPERABILITY of the undervoltage and shunt trip attachments of the Reactor Trip Breakers." The corresponding ISTS surveillance (SR 3.3.1.4) specifies a Trip Actuating Device Operational Test (TADOT) be performed on the RTBs. The ISTS surveillance does not contain the same note as the CTS CFT. The CTS is revised to conform to the ISTS. This changes the CTS by moving the CTS surveillance note into the ITS Bases associated with the surveillance. The change in defined test terms from CFT to TADOT was addressed in TS Section 1.0, Definitions. This DOC is only intended to address moving the CTS note into the TS Bases. The proposed change is acceptable because the information removed from the CTS Surveillance Requirement is not required in the TS to ensure the affected RTS instrumentation is maintained operable. The TS still requires the surveillance testing to be performed on the affected RTS Function. The procedural detail for completing the surveillance testing is more appropriately contained in the bases description of the Surveillance Requirement. The ISTS typically contains this type of information in the bases. Also, this change is acceptable because changes to the ITS Bases are controlled by the TS Bases Control Program specified in the Administrative Controls Section of the TS. This program provides for the evaluation of changes to ensure the Bases are properly controlled and that prior NRC reviewy and approval is requested when required. This change is designated as a less restrictive removal of detail change because procedural details are being removed from the TS. LA.9 (Type 3 - Removing Procedural Details for meeting Tech Spec Requirements) The CTS monthly CFT surveillance for the RTB Bypass Breakers specified in Table 4.3-1 is modified by a note (#12) that states "Local manual shunt trip prior to placing breaker in service." The CTS Note provides a test Frequency "prior to placing the breaker in service" and procedural detail for performing the test "local manual shunt trip." The corresponding ISTS surveillance (SR 3.3.1.4) contains a note that specifies the surveillance must be perforned on the RTB Bypass Breakers prior to placing the Bypass Breakers in service. The CTS surveillance requirement is revised to conform to the ISTS. This changes the CTS requirement by moving the procedural guidance for performing the surveillance (the inclusion of the local manual shunt trip) to the TS Bases associated with the surveillance. The proposed change is acceptable because the information removed from the CTS Surveillance Requirement is not required in the TS to ensure the affected RTS instrumentation is maintained operable. The TS still requires the surveillance testing to be performed on the affected RTS Function. The procedural detail for completing the surveillance testing is more appropriately contained in the bases description of the Surveillance Requirement. The ISTS typically contains this type BVPS Units I & 2 Page 38 Revision 2, 4/06 168

BVPS ISTS Conversion 3.3A RTS Instrumentation Enclosure 3 Changes to CTS of information in the bases. Also, this change is acceptable because changes to the ITS Bases are controlled by the TS Bases Control Program specified in the Administrative Controls Section of the TS. This program provides for the evaluation of changes to ensure the Bases are properly controlled and that prior NRC review and approval is requested when required. This change is designated as a less restrictive removal of detail change because procedural details are being removed from the TS. LA.10 (Type 3 - Removing Procedural Details for meeting Tech Spec Requirements) The CTS refueling CFT surveillance for the RTB Bypass Breakers specified in Table 4.3-1 is modified by a note (#13) that states "Automatic undervoltage trip." The CTS Note provides procedural guidance for performing the required test. The corresponding ISTS surveillance requirement does not contain a similar note. The CTS surveillance is revised to conform to the ISTS surveillance. This changes the CTS by moving the procedural guidance for performing the surveillance into the TS Bases associated with the surveillance. The proposed change is acceptable because the information removed from the CTS Surveillance Requirement is not required in the TS to ensure the affected RTS instrumentation is maintained operable. The TS still requires the surveillance testing to be performed on the affected RTS Function. The procedural detail for completing the surveillance testing is more appropriately contained in the bases description of the Surveillance Requirement. The ISTS typically contains this type of information in the bases. Also, this change is acceptable because changes to the ITS Bases are controlled by the TS Bases Control Program specified in the Administrative Controls Section of the TS. This program provides for the evaluation of changes to ensure the Bases are properly controlled and that prior NRC review and approval is requested when required. This change is designated as a less restrictive removal of detail change because procedural details are being removed from the TS. Administrative Changes (A) A.1 In the conversion of the Beaver Valley Power Station current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering or order, etc.) are made to obtain consistency with NUREG-1431, Rev. 2, "Standard Technical Specifications-Westinghouse Plants" (ISTS). Due to the large number of such changes, A.1 changes may not always be marked on each CTS page. Marked or unmarked, all A.1 changes are identified by a single annotation of A.1 at the top of the first page of each CTS. These changes include all non-technical modifications of requirements to provide consistency with the ISTS, including all significant format changes made to update the older NUREG-0452 Technical Specification presentation to the ISTS format. This type of change is a'so associated with the movement of requirements within the Technical Specifications and with changes made to the presentation of Technical Specifications requirements to combine the Unit 1 and 2 Technical Specifications into one document and highlight the differences between the Unit I and 2 requirements. BVPS Units I & 2 Page 39 Revision 2, 4/06 169

BVPS ISTS Conversion 3.3A RTS Instrumentation Enclosure 3 Changes to CTS These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS requirements. A.2 The CTS 3/4.3.1 LCO statement, Applicability, and Actions are revised consistent with the ISTS format and presentation of this information. The CTS LCO statement is revised to eliminate the phrase 'as a minimum". The LCO requirements for a system or component are the minimum requirements by definition of the term

     'Limiting Condition for Operation" (LCO) in 10 CFR 50.36. Therefore, the CTS term "as a minimum" is not necessary to describe the LCO requirement and has been deleted. The CTS LCO statement is revised to address the instrument Functions in ISTS Table 3.3.1-1 instead of the channels and interlocks in CTS Table 3.3-1. The Functions listed in ISTS Table 3.3.1-1 include the channels and interlocks referenced in the CTS LCO. The Applicability of CTS 3/4.3.1 is revised to refer to the ISTS Table 3.3.1-1 instead of the corresponding CTS Table. In addition, the CTS 3/4.3.1 Actions are revised consistent with the ISTS. In addition, the CTS 3/4.3.1 Action reference to Tab'e 3.3-1 is replaced with the ISTS Condition A which states the condition of one or more Functions (on Table 3.3.1-1) with one or more inoperable channels or trains. The ISTS Condition A Action provides the reference to the applicable Action Condition for each instrument Function listed on ISTS Table 3.3.1-1. The ISTS Condition A, effectively accomplishes the same thing as the CTS Action it replaces by referencing the Table containing the applicable Actions for each Function.

The proposed changes are acceptable because they are format and presentation changes necessary to conform to the LCO, Applicability, and Action requirements in the ISTS. The proposed changes to the format and presentation of the CTS do not represent technical changes. Therefore, the proposed changes are designated administrative. A.3 The CTS surveillance requirements 4.3.1.1.1, 4.3.1.1.2, and 4.3.1.1.3 contain the overall surveillance requirements for the RTS instrument functions. CTS 4.3 1.1.1 specifies Channel Checks, Channel calibrations and channel functional tests for the RTS Functions. CTS 4.3.1.1.2 describes the required testing for the RTS interlock functions and CTS 4.3.1.1.3 specifies response time testing be performed on the RTS Functions. In addition to the general requirements specified above, CTS Table 4.3-1 contains the specific surveillance tests associated with each RTS instrument function. CTS Table 4.3-1 is a separate Table for surveillance requirements that duplicates much of the information already presented for each RTS function in CTS Table 3.3-1. The ISTS does not include general instrument surveillance requirements that correspond to CTS 4.3.1.1.1, 4.3.1.1.2, and 4.3.1.1.3. The ISTS contains a list of all the surveillance requirements associated with each of the RTS instrument Functions. Each ISTS RTS surveillance is numbered and states a specific surveillance test requirement and performance frequency. The ISTS lists the surveillance requirements by number that are applicable to each RTS instrument function on one master Table (ISTS 3.3.1-1). The single ISTS Table 3.3.1-1 contains all the requirements for each RTS function. The list of surveillance requirements applicable to each RTS instrument function on ISTS Table 3.3.1-1 is different in presentation and format from the CTS general surveillances (4.3.1.1.1, 4.3.1.1.2, and 4.3.1.1.3) and CTS surveillance Table 4.3-1, but contains similar information regarding the surveillance requirements associated with each RTS instrument Function. The CTS surveillance requirement presentation is revised to conform to the ISTS. This changes the CTS by eliminating the general surveillance BVPS Units 1 & 2 Page 40 Revision 2, 4/06 170

BVPS ISTS Conversion 3.3A RTS Instrumentation Enclosure 3 Changes to CTS requirements 4.3.1.1.1, 4.3.1.1.2, and 4.3.1.1.3 and the separate Surveillance Table (4.3-1). This change also includes the editorial revisions made to the corresponding Unit I response time testing surveillance (not shown) to change the Unit I CTS wording from "demonstrated" to the more common ISTS descriptive term 'verified" which is also consistent with the corresponding Unit 2 surveillance. The proposed change is acceptable because it represents a change in the format and presentation of the RTS surveillance requirements that is necessary to conform to the ISTS. The proposed changes consolidate the RTS surveillances associated with each instrument function and eliminate the repetition of requirements. Specifically, the elimination of the general surveillance requirements 4.3.1.1.1, 4.3.1.1.2, and 4.3.1.1.3 is acceptable because the technical requirements of the CTS surveillances are retained in the corresponding ISTS requirements listed in ISTS Table 3.3.1-1. The ISTS list of surveillances for each RTS Function includes a specific response time surveillance requirement assigned to each RTS Function that has response time limits associated with it. The assignment of individual response time verification requirements to each RTS Function that has response time limits associated with it assures the general response time requirement in CTS 4.3.1.1.3 is preserved without technical changes. In addition, any technical changes to the detailed surveillance requirements listed on CTS Table 4.3-1 are identified and discussed in the markup of that CTS Table. Therefore, the elimination of the general surveillances described in 4.3.1.1.1, 4.3.1.1.2, and 4.3.1.1.3 and re-organization of the CTS surveillance requirements is designated an administrative change. A.4 CTS surveillance 4.3.1.1.3 requires that response time testing be performed on the RTS functions and specifies that the testing be performed on "one channel per function such that all channels are verified at least once every N times 18 months where N is the total number of redundant channels in a specific reactor trip function as shown in the "Total No. of Channels" column of Table 3.3-1". The corresponding ISTS surveillance for response time testing requires that the testing be performed on a "Staggered Test Basis". The CTS is revised to conform to the ISTS. This changes the CTS by replacing the explanation of how each channel must be tested with a simple reference to the TS defined term of "Staggered Test Basis". The change to the Total Number of Channels column referenced in the CTS is discussed in another DOC that addresses the change from Total Number to Required channels. This change also includes the editorial revisions made to the corresponding Unit I response time testing surveillance (not shown) to change the Unit 1 CTS wording from 'tested' to the more common ISTS descriptive term

    .verified" which is also consistent with the corresponding Unit 2 surveillance.

The proposed change is acceptable because the CTS requirement explaining how the response time of each channel should be verified is the same as verifying the channel response time on a staggered basis as defined in the ISTS. The proposed change is consistent with the format and presentation of this requirement in the ISTS. The ISTS requirements reference defined terms instead of repeating this information in each surveillance. The proposed change does not introduce a technical change to the CTS requirements. The specified interval remains the same. The proposed change simplifies the presentation of the surveillance BVPS Units I & 2 Page 41 Revision 2, 4/06 171

BVPS ISTS Conversion 3.3A RTS Instrumentation Enclosure 3 Changes to CTS requirement without changing the intent. Therefore, the proposed change is designated administrative. A.5 Unit 2 only. Unit 1 does not have footnote 1. CTS Surveillance 4.3.1.1.1 requires that the RTS instrument functions be demonstrated operable in accordance with the requirements of Table 4.3-1. The CTS surveillance is modified by footnote 1. Footnote 1 states "For the automatic trip logic, the surveillance requirements shall be the application of various simulated input combinations in conjunction with each possible interlock logic state and verification of the required logic output including, as a minimum, a continuity check of output devices." The corresponding ISTS RTS surveillance requirements do not include a similar footnote. In the ISTS, the corresponding surveillance test requirements are identified in the defined terms of Section 1.0 of the TS. Individual ISTS surveillance requirements reference the defined terms of TS Section 1.0 as necessary. The CTS is revised to conform to the ISTS. This changes the CTS by moving the description of the test requirements 'or automatic trip logic to the definition section of the TS. The specific definition that defines this type of testing is the ISTS ACTUATION LOGIC TEST. Additionally, the CTS surveillance for automatic trip logic is revised to reference the performance of an ACTUATION LOGIC TEST (as defined in Section 1.0 of the TS). The proposed change is acceptable because the change only re-organizes the existing CTS requirements to conform to the ISTS. The placement of the affected test requirements in a defined term in Section 1.0 of the TS does not introduce a technical change to the CTS and retains the required testing within the TS. Therefore, the proposed change is designated administrative. A.6 The column headings for Functional Unit, Applicable Mode, and Action in CTS Table 3.3-1 are revised to conform to the corresponding column headings in ISTS Table 3.3.1-1. In the ISTS, the corresponding column headings are Function, Applicable Mode or Other Specified Condition, and Condition. The proposed change is acceptable because the change in column headings on the RTS table represents a change in presentation only that is necessary to conform to the ISTS. Changing Functional Unit to Function is a change in title only that does not introduce a technical change to the CTS requirements. Adding "or other specified condition" to the CTS column heading for Applicable Mode provides a clarification that encompasses the CTS use of footnotes to modify the applicable Modes with additional conditions. For example, the Applicable Mode for CTS Functional Unit 1 is modified by Footnote 3 which places the following condition on certain Modes; "with the reactor trip system breakers in the closed position and the control rod drive system capable of rod withdrawal." As such, the addition of "or other specified condition" to the CTS Applicable Mode column is consistent with the CTS use of notes to modify the applicability with additional conditions and does not represent a technical change to the CTS. Changing the CTS Table 3.3-1 column heading "Action" to "Condition" is necessary due to the format of ISTS Actions. The ISTS Actions are expressed in three separate parts i.e., a specific Condition (e.g., one channel inoperable) with an associated Required Action (e.g., place the channel in trip) and a Completion Time for that Action (e.g., 6 hours). Although the CTS Actions contain the separate components used in the ISTS example above, in the CTS, the components are combined together in a paragraph or two and simply labeled "Action". These components are physically separated in the ISTS presentation of Actions. The separation of these components provides better BVPS Units I & 2 Page 42 Revision 2, 4/06 172

BVPS ISTS Conversion 3.3A RTS Instrumental-ion Enclosure 3 Changes to CTS human factoring of the TS and allows the user to quickly identify the applicable condition and determine the requirements associated with it. As such, the change from "Action" heading" to "Condition" heading is purely one of format and presentation of the same information. The proposed changes do not involve technical changes to the CTS and are designated administrative changes. A.7 The CTS Table 3.3-1 table heading titled 'Total Number of Channels" is revised to be "Required Channels" consistent with the corresponding ISTS Table 3.3.1-1 Table headings. In addition, the Minimum Channels Operable column of CTS Table 3.3-1 is deleted consistent with the content of the corresponding ISTS Table 3.3.1-1. The proposed change is acceptable because the revisions described above do not result in technical changes to the number of instrument channels required operable or the applicable Actions when the required channels are not met. All Actions for an inoperable instrument channel in the ISTS key off the Required Channels specified for the affected function. The new ISTS Conditions assigned to each Instrument Function will specify the appropriate action when one or more "Required" instrun-ent channels are inoperable. The minimum channels column used in the CTS to identify the number of operable channels for which continued operation is permissible is no longer used or required in the TS. The ISTS Actions encompass the concept of the minimum required channels, i.e., the plant would be required to be placed in a Mode or Condition outside the Applicable Mode when the minimum number of channels for continued operation is not met. The ISTS Actions accomplish this without a specific reference to the minimum required channels. As such the proposed changes described above do not introduce a technical change to the CTS requirements. In addition, any technical changes to the CTS Actions associated with the RTS instrument functions are identified in the markup of those Actions and addressed in the DOCs associated with the changes to the CTS Actions. This DOC is intended to address the reformat of the CTS Table 3.3-1 to conform to the corresponding ISTS Table 3.3.1-1. Therefore, this change is designated administrative. A.8 The CTS Table 3.3-1 Allowable Value column title is revised by the addition of UWit specific designations. The corresponding ISTS Table does not include Unit specific designations. However, the BVPS specific implementation of the ISTS includes both Unit 1 and Unit 2 requirements in one set of TS. As each BVPS Unit may have different setpoints, the resulting BVPS ITS Table 3.3.1-1 is proposed with separate Unit 1 and Unit 2 Allowable Value columns for each RTS function. The proposed change is acceptable because the CTS Allowable Values are not changed. The proposed change merely combines the Unit 1 and Unit 2 Allowable Values into the same ITS RTS Instrument Function Table. As such, the proposed change is designated administrative. A.9 CTS Functional Unit 6b (Source Range Neutron Flux without rod withdrawal capability) on CTS Table 3.3-1 is modified by two footnotes (8 and 9). CTS footnote 8 states that "Alternate detectors may only be used for monitoring purposes Without Rod Withdrawal Capability until detector functions are modified to permit equivalent alarm and trip functions." Footnote 8 applies to Unit 2 only. CTS Unit 2 footnote 9 (footnote 8 for Unit 1) states "In this condition, source range Function does not provide reactor trip but does provide indication." In addition, CTS Table 4.3-1 contains BVPS Units 1 & 2 Page 43 Revision 2, 4/06 173

BVPS ISTS Conversion 3.3A RTS Instrumentation Enclosure 3 Changes to CTS Note 15 which modifies the surveillance requirements associated with "Alternate" neutron flux detectors used for indication purposes. CTS Functional Unit 6b specifies requirements for source range indication only and contains no reactor trip requirements. This CTS Function is assigned a specific Action (5) that is associated only with this RTS Function. The Action is modified by footnote 7 which is also specific to this RTS Function. The ISTS RTS requirements do not address indication only functions. The corresponding ISTS RTS TS contains requirements for reactor trip instrumentation only. The CTS is revised consistent with the ISTS. This changes tle CTS by moving the source range neutron flux instrument indication requirements (including all associated notes form Tables 3.3-1 and 4.3-1 and Action 5) out of the RTS TS and into a separate source range indication TS (ITS 3.3.8). The proposed change is acceptable because the CTS requirements are moved within the TS without introducing a technical change to the requirements. The affected CTS requirements do not address an RTS function and do not belong in the RTS TS. The ISTS contains a generic Boron Dilution Protection System (BDPS) LCO, ISTS 3.3.9. Although the BDPS system addressed by ISTS 3.3.9 is not part of the BVPS design, it contains some requirements that are similar to the BVPS CTS source range indication requirements. As such, ISTS 3.3.9 (BVPS ITS 3.3.8) will be revised to address the CTS source range indication requirements so that they may continue to be specified in the TS separate from the reactor trip system requirements. The proposed change makes the CTS more closely conform to the ISTS presentation of these requirements. The proposed change only moves requirements within the TS and is therefore, designated administrative. A.10 Unit 2 only. The

footnote in CTS Table 3.3-1 provides an explanation of the acroymn RTP ( Rated Thermal Power) used in some of the Allowable Values specified in the Table. The corresponding ISTS Table 3.3.1-1 does not include this footnote to explain RTP. The CTS is revised to conform to the ISTS. This changes the CTS by eliminating the footnote explanation of the acroymn RTP from CTS Table 3.3-1. In addition, this change addresses the removal of the
from each place it is used in CTS Table 3.3-1 to reference the RTP footnote.

The proposed change is acceptable because the change is necessary to conform to the ISTS format and presentation conventions. In the ISTS, the term Rated Thermal Power (including the acoynm RTP) is a defined term in Section 1.0 of the TS. The defined term, including acroynnm, is explained once in the front matter of the ISTS. The ISTS then utilizes the acroynms of defined terms throughout the TS without explaining the acroynms each time they are used. The proposed change does not introduce a technical change to the CTS and is made to conform to the ISTS format and presentation conventions for defined acroynms. Therefore, the proposed change is designated administrative. A.11 The CTS Table 3.3-1 Source Range Neutron Flux Function title "With Rod Withdrawal Capability" is deleted. The corresponding ISTS Function does not use this Function title to identify the source range instrumentation. In the ISTS, this information is contained in the plant condition specified in the Applicability for the Source Range RTS Function. The CTS is revised consistent with the ISTS. This changes the CTS by eliminating a separate reference to the specified plant condition of the Applicability for this RTS Function. The plant condition of "with rod withdrawal capability" continues to be specified in the Applicability for Modes 3, 4, and 5 (CTS Note 3). BVPS Units I & 2 Page 44 Revision ;, 4/06 174

BVPS ISTS Conversion 3.3A RTS Instrumentation Enclosure 3 Changes to CTS The proposed change is acceptable because it is necessary to conform to the ISTS presentation of this information and because it does not introduce a technical change to the CTS requirements. The requirement for the source range instrumentation to be operable with rod withdrawal capability is retained in the Applicability requirements for the source range instrumentation consistent with the location of this information in the ISTS. The affected CTS Function title is a specific plant condition for which the RTS function must be applicable and therefore, is part of the Applicability for the Function. As such, the proposed change only affects the presentation of the RTS requirements and conforms to the ISTS. The proposed change is designated administrative as it does not introduce a technical change to the CTS requirements. A.12 Unit 2 only. The Allowable Value for CTS Functional Unit 9 (Pressurizer Pressure-Low) on Table 3.3-1 is modified by a ** footnote that specifies the time constants associated with the Allowable Value. In addition to the time constants (which are part of the Allowable Value) the footnote also specifies that "Channel calibration shall ensure that these time constants are adjusted to those values." The corresponding ISTS Functions in CTS Table 3.3.1-1 do not include footnotes with requirements for the channel calibration of the function. The ISTS includes the requirement to verify the time constants associated with a Function in the Channel Calibration Surveillance Requirement for that Function. The ISTS includes notes in the channel calibration surveillance that clarify or modify the requirements for that surveillance. The CTS is revised to conform to the ISTS. This changes the CTS by moving the note affecting channel calibration from the list of functions on CTS Table 3.3-1 into the RTS channel calibration surveillance requirement. The proposed change is acceptable because the change is necessary to conform to the ISTS presentation of this information, the change does not result in a technical change to the CTS requirement, and because the CTS requirement is retained within the TS. The proposed change simply re-organizes the CTS requirement consistent with the ISTS. As the proposed change does not introduce a technical change to the CTS, it is designated administrative. A.13 The CTS Loss of Flow Functions 12 and 13 on CTS Table 3.3-1 have been combined into one Function, ITS Function 10, Reactor Coolant Flow - Low, consistent with the ISTS. CTS Function 12, is effective above the P-8 interlock (30% RTP) and provides a reactor trip with low flow in a single RCS loop. CTS Function 13 is effective above the P-7 interlock (10% RTP) and below the P-8 interlock (30% RTP) and provides a reactor trip with low flow in two RCS loops. However, these CTS Functions utilize the same instrumentation that is required operable from 10% to 100% RTP. As such, the corresponding ISTS Function is presented as a single RTS Function, that requires the affected instrument channels to be operable above the P-7 interlock (10% RTP). The CTS is revised to be consistent with the ISTS. This changes the CTS by combining Functions 12 and 13 and eliminating essentially redundant information from CTS Table 3.3-1. The proposed change is acceptable because it is necessary to conform to the presentation of this information in the ISTS and because it does not introduce a technical change to the CTS requirements. The combination of the two separate RTS functions into one Function is possible because the instrumentation used for each of the affected CTS functions is the same. In addition, the applicable Action and setpoints are also the same. In the CTS, this instrumentation was divided into BVPS Units I & 2 Page 45 Revision 2, 4/06 175

BVPS ISTS Conversion 3.3A RTS Instrumentation Enclosure 3 Changes to CTS two separate functions to better describe the operation of the function above and below the P-8 permissive (one or two loop trip). In the ISTS, this description of channel operation is retained in the bases description for this RTS Function (see associated LA DOC). The ISTS simplifies the presentation of this RTS function and retains the essential requirement that the instrument channels be operable above P-7 or the appropriate Action must be taken. Regardless of the one or two RCS loop trip operation of the Function, all channels are required operable above the P-7 interlock. The affected channels, including Allowable Values, are not changed and continue to be required operable above P-7 the same as the CTS. The proposed change only simplifies the presentation of these requirements. The proposed change is designated administrative because it does not introduce a technical change to the CTS requirements. A.14 The CTS Table 3.3-1 contains Function 21 for the Reactor Trip Breakers (RTBs). This CTS function includes Actions specifically for the undervoltage and shunt trip mechanisms associated with the RTBs as well as Actions for an RTB inoperable for other reasons. The corresponding ISTS Table 3.3.1-1 contains separate line item Functions for the RTBs and the RTB undervoltage and shunt trip mechanisms. The ISTS assigns the specific Actions for the undervoltage and shunt trip mechanisms to that Function line item and the Actions applicable to the RTB Function to the RTE3 Function line item. The CTS is revised to conform to the ISTS. This changes the CTS by creating a new separate Function line item for undervoltage and shunt trip mechanisms in CTS Table 3.3-1. This Doc addresses the change that creates a separate line item function for the RTB undervoltage and shunt trip mechanisms. Other changes to the RTS RTB Functions are addressed in other DOCs. The proposed change is acceptable because it is necessary to conform to the ISTS presentation of this information and because the separation of these items into two RTS Functions does not introduce a technical change to the CTS requirements. The new RTB undervoltage and shunt trip mechanism Function is required operable in the same Modes as before and if inoperable requires the same Actions as before. The separation of these RTB Functions serves to clarify the different Action Condition and Completion Time applicable for the RTB undervoltage and shunt trip mechanisms. The proposed change only represents a change in the presentation of this information. As such, the proposed change is designated administrative. A.15 The CTS allowable value for the RTS P-13 Function is expressed as "% RTP turbine first stage pressure equivalent". The corresponding ISTS P-13 Function is simply expressed as "% turbine power". The CTS is revised to conform to the ISTS. This changes the CTS by expressing the P-13 function allowable value as % turbine power instead of % RTP turbine first stage pressure equivalent. The proposed change is acceptable because the ISTS allowable value is a simplified form of the CTS allowable value and does not represent a technical change to the CTS. In addition, the CTS explanation that the turbine power is "RTP turbine first stage pressure equivalent" is being retained in the corresponding bases discussion of this Function to further explain the measured parameter. The P-1 3 Function is a measure of turbine power used together with a measure of reactor power (P-10) to provide the P-7 interlock function (low power permissive). At approximately 10% RTP or turbine power the P-7 interlock enables several RTS Functions. As such, the ISTS naming convention for the P-13 interlock allowable value is acceptable and more clearly labels the parameter as related to turbine BVPS Units 1 & 2 Page 46 Revision 2, 4/06 176

BVPS ISTS Conversion 3.3A RTS Instrumentation Enclosure 3 Changes to CTS power. The proposed change is designated administrative as the change is not intended to introduce a technical change to the CTS. A.16 CTS Note 3 in Table 3.3-1 states the following; " With the reactor trip system breakers in the closed position and the control rod drive system capable of rod withdrawal." This CTS Note is 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 removing the reactor trip breakers (RTBs) from the applicability requirement and adding the requirement to the applicability of whenever one or more rods are not fully inserted. This DOC is intended to address the elimination of the RTBs from the CTS note. The CTS Applicability requires the associated RTS Functions to be operable when the possibility of an inadvertent or uncontrolled rod withdrawal accident exists. The associated RTS Functions provide reactor trip actuations to mitigate the consequences of a rod withdrawal event. In order to assure the availability of the required protection Functions the CTS Applicability requires the associated RTS Functions to be operable whenever the RTBs are closed and when the rod control system is capable of rod withdrawal. However, the possibility of rod withdrawal may be precluded if the rod control system is not capable of rod withdrawal (the RTBs must be closed for the rod control system to be capable of rod withdrawal). The note need only specify that the rod control system is capable of rod withdrawal to adequately address the condition where the RTS Functions are required operable. A specific reference to the RTBs in the note is not required as the capability of the rod control system to withdraw rods is dependent on the RTB breaker position. As such, this portion of the proposed change to CTS Note 3 is acceptable as it simplifies the CTS note and does not introduce a technical change to the intent of the CTS note. As the proposed change does not introduce a technical change to the CTS, it is designated administrative. A.17 The CTS Actions specify "With the number of channels OPERABLE one less thar required by the Minimum Channels OPERABLE requirement...." or 'With the number of channels OPERABLE one less than required by the Total Channels OPERABLE requirement...." These CTS Actions are based on the minimum channels operable or total channels specified in CTS Table 3.3-1 for each RTS Function. The ISTS does not contain a "minimum channels operable" or "total channels" requirement. The ISTS uses the single term "Required" channels or trains for all RTS Functions. In the ISTS, all Actions are based on one or more "Required" channels or trains inoperable. The ISTS Required Channels is equivalent to the CTS Total Channels requirement. The CTS is revised to conform to the ISTS. This changes the CTS by eliminating the Action references to the Minimum or Total channels operable and simply specifying "one channel inoperable". In some cases, the ITS Action Conditions are specific to a single RTS Function and may contain the Function name (e.g., one Turbine Trip channel inoperable). In addition, the ISTS Action Conditions may identify the RTS Function by "train" instead of by "channel" where applicable (e.g., the automatic trip logic RTS Function is not a channel and is referred to by trains of automatic trip logic). The proposed change is acceptable because the number of channels (or trains) on which the CTS Actions are based is not changed. The ISTS Required Channels is equivalent to the CTS Total Channels requirement. In cases where the CTS Action is based on the Minimum Channels requirement, the Minimum Channels requirement is BVPS Units I & 2 Page 47 Revision 2, 4/06 177

BVPS ISTS Conversion 3.3A RTS Instrumentation Enclosure 3 Changes to CTS equivalent to the CTS Total Channels Requirement. Therefore, the ISTS use of Required Channels simplifies the CTS presentation of this information without introducing a technical change to the number of channels used for initiating an Action requirement. The use of the term trains in the ISTS for certain Functions is also acceptable as it more accurate identifies the associated RTS Functions that are designed with train A and train B systems and that are technical not instrumentation channels (e.g., automatic actuation logic). The CTS Minimum Channels requirement is also used within an Action statement where the continued operation of the plant is permitted "providing the Minimum Channels operable requirement is met". The ISTS does not use this convention to indicate where continued operation is permitted. If an Action exists in the ISTS for a specific Condition, operation may continue in accordance with that Action. However, if an Action is not included in the ISTS for a specific condition (e.g., an RTS Function with two required channels inoperable), LCO 3.0.3 must be entered and the plant placed in a condition where the RTS Function is no longer required. Therefore, the proposed change to eliminate the phrase "operation may continue" from the CTS Actions is also acceptable. The ISTS format, presentation and conventions of use have eliminated the need for the CTS Action references to "Total Channels" or "Minimum Channels" and such phrases as "operation may continue" without introducing technical changes to the number of channels required to be operable by the RTS TS or the conditions under which continued operation is permitted. As the proposed changes involve revisions to the format and presentation of the CTS Action requirements without introducing technical changes to those requirements, the changes are designated administrative. A.18 CTS Action 2, assigned to the Power Range Neutron Flux RTS Functions 2, 3, and 4 in CTS Table 3.3-1, is comprised of two parts (a and b). CTS Action 2a addresses. the Power Range High Neutron Flux channels and CTS Action 2b addresses all the other Power Range Neutron Flux channels. CTS Action 2 is modified by footnote 4, applicable to both parts of the Action and footnote 5 which is applicable only to CTS Action 2a. The corresponding ISTS Actions are contained in Conditions D and E. The ISTS Conditions contain the same notes as the CTS but in the ISTS Note format with the Actions not as footnotes. ISTS Condition D corresponds to CTS Action 2a for the Power Range Neutron Flux High channels and ISTS Condition E corresponds to CTS Action 2b for the other Power Range Neutron Flux channels. The CTS is revised to conform to the ISTS presentation of these Action requirements. This changes the CTS by dividing CTS Action 2 into separate ISTS Action Conditions (13 and E) and reformatting the CTS Actions into the ISTS format. The technical changes made to CTS Action 2 are addressed in the DOCs associated with that CTS Action. This DOC addresses the presentation changes to CTS Action 2. The proposed change is acceptable because no technical changes are being made to CTS Action 2. The CTS Action is simply reformatted into the separate ISTS Action conditions described above. As such, the proposed change is designated administrative. A.19 The Source Range RTS Function in CTS Table 3.3-1 is assigned Action Statement

4. CTS Action statement 4 is comprised of parts a, b, and c. CTS Action 4a is identified as applicable to Mode 2 below P-6, CTS Action 4b is identified as applicable to Modes 3,4, and 5, and CTS Action 4c is identified as applicable to Mode 2 below P-6 and Modes 3, 4, and 5. The Corresponding ISTS Action BVPS Units 1 & 2 Page 48 Revision 2, 4/06 178

BVPS ISTS Conversion 3.3A RTS Instrumentation Enclosure 3 Changes to CTS Conditions are H, I, and J. ISTS Condition H is identified as applicable to Mode 2: below P-6, ISTS Condition I is identified as applicable to Mode 2 below P-6 and Modes 3,4, and 5, and ISTS Condition J is identified as applicable to Modes 3, 4, and 5. The CTS Actions are revised to conform to the ISTS Action Conditions. This changes the CTS by reformating the single CTS Action statement 4 into 3 separate ISTS Action Conditions. This DOC is only intended to address the reformat of the CTS Action into separate ISTS Conditions. Any technical changes to the CTS Action are addressed in other DOCs. The proposed change is acceptable because the separate ISTS Action Conditions correspond directly to parts a, b, and c of CTS Action 4 and the proposed change! only represents a change in format and presentation of the CTS Action. The Actions associated with the Source Range RTS Function remain essentially the same. The ISTS Table 3.3.1-1 format assigns the Action Conditions by Applicab'e Mode such that ISTS Conditions H and I are assigned to Mode 2 below P-6 and ISTS Conditions I and J are assigned to Modes 3, 4, and 5. The assignment of these Conditions in the ISTS Table 3.3.1-1 effectively corresponds to the CTS assignment of Action Statement 4 parts a, b, and c. As the proposed change only involves the format and presentation of the CTS requirements it is designated administrative. A.20 CTS Action 7b provides the allowance that "the inoperable channel may be bypassed for up to 4 hours for surveillance testing of other channels per Specification 4.3.1.1.1." The corresponding ISTS Action Condition Note (in Conditions E, L, and K) states that "the inoperable channel may be bypassed for up to 4 hours for surveillance testing of other channels." The CTS is revised to conform to the ISTS. This changes the CTS by eliminating the reference to Specification 4.3.1.1.1 from the CTS Action 7b. CTS Specification 4.3.1.1.1 states the surveillance requirements applicable to the RTS Functions. The surveillance requirements of 4.3.1.1.1 are such that they may have to be performed on the affected RTS instrumentation while operating in the applicable Mode where the RTS Function is required operable. Surveillance testing of instrument channels requires that the channel be placed in the trip condition at some point during testing to verify correct channel operation. If the affected RTS Function already has an inoperable channel in the trip condition, placing a second channel in trip for verification during testing may result in a reactor trip. Failure to perform the required surveillances within the specified interval plus any applicable extensions would require that the affected RTS channel be declared inoperable (per the rules of TS). Declaring a channel inoperable due to a missed surveillance will also result in a plant shutdown if another RTS channel in that Function was already inoperable (LCO 3.0.3 applies to two inoperable channels in the same RTS Function). Therefore, the CTS contains the allowance to bypass inoperable channels for a limited time to allow the required surveillance testing to proceed on the remaining operable channels in an RTS Function and thus to allow for continued operation of the plant. The proposed change is acceptable because it accomplishes the same thing as the CTS requirement. The inclusion of a reference to the specific surveillance (4.3.1.1.1) is not required to ensure the remaining channels of an RTS Function are properly tested with the inoperable channel bypassed. The ISTS Action Note accomplishes this task with a simpler presentation and without introducing a technical change to the BVPS Units I & 2 Page 49 Revision .', 4/06 179

BVPS ISTS Conversion 3.3A RTS Instrumentation Enclosure 3 Changes to CTS CTS requirements. The proposed change is designated administrative because no technical change is made to the CTS requirements. A.21 CTS Action 7 requires that the affected RTS channel be placed in the trip condition in 6 hours. CTS Action 7 is common to several RTS Functions. The corresponding ITS Action Conditions (E, K, and L) contain the same Action to place the channel in trip in 6 hours plus an additional default Action that is applicable if the Action to place the channel in trip can not be met. The ISTS default Action requirement is based on the applicable Mode of the RTS Function and serves to remove the plant from the applicable Mode of the affected RTS Function if the Action to place a channel in trip is not met. As such, the corresponding RTS Functions in the ISTS have different Action Conditions assigned to them depending on the applicable Mode of the RTS Function. The default Action of ISTS Condition E requires that the plant be placed in Mode 3 and is applicable to RTS Functions that are required operable in Modes I and 2. The default Action of ISTS Condition K requires that the power be reduced to < P-7 and is applicable to RTS Functions that are required operable at power levels 2 P-7. The default Action associated with ITS Condition L requires that the power be reduced to < P-9 and is applicable to the Turbine Trip RTS Functions that are required operable at power levels 2 P-9. The CTS action 7 is split to conform to ISTS Actions E, K, and L. This changes the CTS by assigning different Actions to the RTS Functions depending on the applicable Mode of the Function. The specific technical changes to CTS Action 7 to convert to ISTS Conditions E and K are discussed in the DOCs associated with Action 7. This DOC is only intended to address the presentation difference that results from the technical changes introduced by the new ISTS Conditions. The proposed change assigns specific Actions to each RTS Function that are tailored to better fit the Mode of applicability for each of the Functions. The proposed change is acceptable because the change is necessary to conform to the ISTS format and presentation of Action Conditions and because the change addressed in this DOC does not include a technical change to the CTS Actions. As this change addresses the format and presentation of the Actions it is designated administrative. A.22 CTS Action 1 provides the allowance that "one channel may be bypassed for up to 4 hours for surveillance testing per Specification 4.3.1.1.1 provided the other channel is operable." The corresponding ITS Action Condition M Note states that "one train may be bypassed for up to 4 hours for surveillance testing provided the other train is operable." The CTS is revised to conform to the ITS Condition Note. This changes the CTS by eliminating the reference to Specification 4.3.1.1.1 from the CTS Action 1. The change in terminology from channel to train is addressed in another DOC. CTS Specification 4.3.1.1.1 states the surveillance requirements applicable to the RTS Functions. The surveillance requirements of 4.3.1.1.1 may have to be performed on the RTS instrumentation while operating in the applicable Mode where the RTS Function is required operable. Surveillance testing of instrument channels or trains requires that the channel or train be placed in the trip condition at some point during testing to verify correct channel operation. In the case of RTS inputs such as the SI input, the input is a train A and train B function such that a trip from either train would actuate a reactor trip. Therefore, the CTS contains the allowance to bypass a channel for a limited time to allow the required surveillance testing to be performed without causing a reactor trip. BVPS Units I & 2 Page 50 Revision 2, 4/06 180

BVPS ISTS Conversion 3.3A RTS Instrumentalion Enclosure 3 Changes to CTS The proposed change is acceptable because it accomplishes the same thing as the CTS requirement. The inclusion of a reference to the specific surveillance (4.3.1.1.1) is not required to ensure the RTS Function is properly tested without causing a reactor trip. The ISTS Action Note accomplishes this task with a simpler presentation and without introducing a technical change to the CTS requirements. The proposed change is designated administrative because no technical change is made to the CTS requirements. A.23 CTS Action 40b provides the allowance that "one channel may be bypassed for up to 2 hours for surveillance testing per Specification 4.3.1.1.1, provided the other channel is operable." The corresponding ITS Action Condition N Note 1 states that "one train may be bypassed for up to 2 hours for surveillance testing provided the other train is operable." The CTS is revised to conform to the ITS Condition Note. This changes the CTS by eliminating the reference to Specification 4.3.1.1.1 from the CTS Action 40b. The change in terminology from channel to train is addressed in another DOC. CTS Specification 4.3.1.1.1 states the surveillance requirements applicable to the RTS Functions. The surveillance requirements of 4.3.1.1.1 may have to be performed on the RTS instrumentation while operating in the applicable Mode where the RTS Function is required operable. Surveillance testing of instrument channels or trains requires that the channel or train be placed in the trip condition at some point during testing to verify correct channel operation. The CTS and ITS Actions are applicable to the reactor trip breakers (RTBs). In the case of the RTBs a trip from either RTB would actuate a reactor trip. Therefore, the CTS contains the allowance to bypass a channel for a limited time to allow the required surveillance testing to be performed without causing a reactor trip. The proposed change is acceptable because it accomplishes the same thing as th a CTS requirement. The inclusion of a reference to the specific surveillance (4.3.1.1.1) is not required to ensure the RTS Function is properly tested without causing a reactor trip. The ISTS Action Note accomplishes this task with a simpler presentation and without introducing a technical change to the CTS requirements. The proposed change is designated administrative because no technical change is made to the CTS requirements. A.24 CTS Action 40 contains different Action requirements for the reactor trip breakers (RTBs) and for the undervoltage and shunt trip features that comprise the diverse trip mechanisms of the RTBs. The corresponding ISTS action Conditions N and Q separate the Actions applicable to the RTBs and the undervoltage and shunt trip mechanisms into two Action Conditions (Condition N for one inoperable RTB and Condition Q for one trip mechanism inoperable for one RTB. In addition, the CTS Action 40 allowances for bypassing the RTBs are retained as two notes in ITS Action Condition N for the RTBs. The CTS is revised to conform to the ISTS presentation of these Action requirements. This changes the CTS by separating the Actions for the RTBs from the Actions for the individual trip mechanisms. This DOC is only intended to address the re-organization of the CTS Action to conform to the ISTS. The other DOCs associated with CTS Action 40 address other changes to that Action. The proposed change is acceptable because it is necessary to conform to the ISTS and because it provides a more clear set of Actions by separating the CTS Action requirements into two separate Action Conditions. In addition, the proposed change is acceptable because it does not introduce a technical change to the CTS requirements. The proposed change only involves revising the format and BVPS Units 1 & 2 Page 51 Revision 2, 4/06 181

BVPS ISTS Conversion 3.3A RTS Instrumentation Enclosure 3 Changes to CTS presentation of the Action requirements and Notes within the Actions. As such, the! proposed change is designated administrative. A.25 Unit 1 only. The Unit 1 CTS RTS Function 14, Steam Generator (SG) Water Level - Low - Low, is modified by reference to a "Loop Stop Valves Open" permissive. The corresponding ISTS and Unit 2 CTS RTS Functions do not contain a similar reference. The Unit 1 CTS is revised to conform to the ISTS and Unit 2 CTS. This changes the Unit 1 RTS Function 14 by deleting the reference to the "Loop Stop Valves Open" permissive. The Unit I RTS Function for low SG level trip was originally designed with a permissive interlock with the RCS loop stop valves. The original intent of this design was to defeat the SG low level trip for a SG when the associated RCS loop was removed from service. This design would permit the water level in a SG removed from service to be below the reactor trip setpoints without actuating a reactor trip and allow continued plant operation with only two RCS loops in service. BVPS never licensed two loop operation and the permissive interlock with the RCS loop stop valves was removed by a plant design change. In addition, the CTS and proposed ITS require that all three RCS loDps be in operation when the SG Water level RTS trip Function is required operable. As such, the reference to the permissive interlock with the RCS loop stop valves no longer has a technical impact in the TS. The propose d change to delete the reference to this permissive interlock from the Unit 1 RTS TS is acceptable because the permissive interlock with the RCS loop stop valves is no longer part of the Unit I design and because the TS require that all three RCS loops be in service when this RTS Function is required operable. The proposed change makes the CTS conform more closely to the current plant design and does not result in a technical impact to the CTS requirements. As such, the proposed change is designated administrative. A.26 The Unit 1 and Unit 2 BVPS Units have different Turbine Trip RTS Functions. The Unit 1 Function 18.a is Auto Stop Oil Pressure. The Unit 2 Function 18.A is Emergency Trip Header Low Pressure. The corresponding ISTS Turbine Trip Function simply lists Low Fluid Oil Pressure. These Unit 1 and Unit 2 CTS RTS Functions are revised into a single RTS line item similar to the ISTS. This changes the CTS by combining the Unit 1 Auto Stop Oil Pressure and the Unit 2 Emergency Trip Header Pressure under one RTS "Low Pressure" Turbine Trip Function item on ITS Table 3.3.1-1. The Unit 1 and Unit 2 Turbine Trip RTS Functions monitor and actuate from different turbine parameters with different setpoints. Although the parameter monitored for this Function is different for each Unit, the RTS Function is the same, i.e., provide the necessary turbine trip signal to the RTS to actuate a reactor trip. The proposed B\'PS ITS consists of a single TS for bDth Units. As the number of instrument channels, Applicable Modes, and surveillance requirements are the same, these two RTS Functions may be combined into a single RTS Function in ITS Table 3.3.1-1 without introducing a technical change to the CTS requirements. The proposed BVPS IT'; Table 3.3.1-1 contains separate Allowable Value columns for Unit 1 and Unit 2. Therefore, the applicable CTS requirements for these RTS Functions may be retained in a single line item on BVPS ITS Table 3.3.1-1 that has a Unit 1 Allowable Value and a Unit 2 Allowable Value. The proposed change is acceptable because it does not introduce a technical change to the CTS requirements and because it is necessary to combine the different Unit Functions into a single TS. As the proposed change only BVPS Units 1 & 2 Page 52 Revision :2, 4/06 182

BVPS ISTS Conver;ion 3.3A RTS Instrumentation Enclosure 3 Changes to C TS represents a change in the format and presentation of the CTS, it is designated as administrative. A.27 Not used. A.28 The CTS RTS TS contains a separate Table (4.3-1) that contains the surveillance requirements associated with each RTS Function. In addition to the RTS Function surveillance requirements, CTS Table 4.3-1 contains a list of the RTS Functions arid the Applicable Modes for each RTS Function. Certain Table 4.3-1 Notes are also specifically associated with the Applicable Modes. The List of Functions and Applicable Modes in CTS Table 4.3-1 is essentially redundant to the list of RTS Functions and Applicable Modes in CTS Table 3.3-1. The purpose of CTS Table -4.3-I is to clearly specify the surveillance requirements associated with each RTS Function. The repetition of the RTS Function titles and Applicable Modes in Table! 4.3-1 is for convenience and ease of identification. The repetition of this information on CTS Table 4.3-1 is not intended to introduce technical changes to the corresponding requirements in CTS Table 3.3-1. In order to simplify and consolidate the RTS Function requirements, the corresponding ISTS for RTS presents all the RTS requirements in a single Table (3.3.1-1). ISTS Table 3.3.1-1 contains a single list of RTS Functions and a single list of Applicable Modes for each Function. The CTS is revised to conform to the ISTS. This changes the CTS by consolidating CTS Tables 3.3.1 and 4.3.1 into a single Table (ITS 3.3.1-1). The essential technical content of Table 4.3-1 (the surveillance requirements) is moved into the consolidated ITS Table. This DOC is intended to address the consolidation of the two CTS Tables and addresses the redundant list of Function titles and Applicable Modes (including any Notes) for which the changes have already been described in the markup of CTS Table 3.3-1. Other DOCs address any technical differences between the consolidated ISTS Table and CTS Table 4.3-1. The proposed change is acceptable because it conforms to the ISTS and because it does not introduce technical changes to the CTS requirements. The proposed change consolidates the RTS requirements in one table. The RTS information addressed by this DOC is redundant to the information contained in CTS Table 3.3-1. Technical changes to the RTS requirements affected by this DOC have already be en identified and discussed in the markup of CTS Table 3.3-1. As such, the proposed change only affects the format and presentation of the RTS requirements and does not introduce technical changes to those requirements. As the proposed change involves only the format and presentation of the RTS requirements, it is designated administrative. A.29 CTS Table 4.3-1 contains the surveillance requirements for the RTS Functions. The CTS specifies a Channel Functional Test for certain RTS Functions. In place of the Channel Functional Test, the ISTS specifies the following surveillance tests depending on the Function: Channel Operational Test (COT) Trip Actuating Device Operational Test (TADOT), and Actuation Logic Test The CTS is revised to replace the single Channel Functional Test requirement with the 3 new ISTS test requirements. The CTS Channel Functional Test as well as the new ISTS surveillance tests are defined terms specified in Section 1.0 of the TS. The BVPS Units I & 2 Page 53 Revision 2, 4/06 183

BVPS ISTS Conversion 3.3A RTS Instrumentation Enclosure 3 Changes to C:TS addition of the new ISTS defined terms for surveillance testing and the changes to the CTS Channel Functional Test are addressed in the changes made to TS Section 1.0, Definitions. Any technical changes to the requirements for individual RTS Functiors will be addressed in the detailed markup of those requirements in CTS Table 4.3-1. This DOC is intended to address the replacement of the Channel Functional Test requirement in Table 4.3-1 with one of the 3 new ISTS test terms. The ISTS COT is intended to address those RTS instrument channels that encompass equipment intended to process the source signal (e.g., convert current input to voltage output). The ISTS TADOT is intended to address those RTS instrument channels that consist of a more simple input such as a manual switch or other device that simply opens or closes contacts in the RTS. The ISTS Actuation Logic Test is intended to address the actuation logic in the RTS where the individual instrument channel inputs are combined to produce the required logic output. The CTS Channel Functional Test is currently utilized for testing all these different RTS Functions. Although the RTS Functions can be adequately tested using a single general test definition such as the Channel Functional test, some interpretation of the Channel Functional Test definition is necessary to adequately address the different RTS Functions. The specific ISTS test definitions provide accurate descriptions of the testing that is actually performed on each type of RTS Function. The proposed change is acceptable because the new test terms contain specific test requirements applicable to the RTS Functions that more accurately describe the required testing for each Function. The proposed change does not introduce a technical change to the method by which each type of Function is currently tested. The proposed change only results in the use of defined terms that more accurately describe the current test method for each RTS Function. As such, the RTS Functions continue to be tested in a similar manner as before but the testing being performed is more consistent with the TS defined terms being used to specify the required testing. The proposed change is designated administrative because it does not introduce technical changes to the surveillance testing currently performed for each RTS Function. A.30 CTS surveillance 4.3.1.1.3 requires that "The REACTOR TRIP SYSTEM RESPONSE TIME of each reactor trip function shall be demonstrated to be within its limit...." The CTS surveillance is a general requirement that is interpreted to be applicable to those RTS Functions with response time limits assumed in the safety analyses. The list of RTS Functions with response time requirements that must be verified is maintained outside of the TS in the Licensing Requirements Manual (LRM). The ISTS provides a specific response time surveillance requirement that is assigned to each RTS Function that has required response time limits. The CTS is revised to conform to the ISTS. This changes the CTS by assigning a response time surveillance requirement to each individual RTS Function that has a required response time limit identified in the LRM. The proposed change is acceptable because it more accurately identifies the RTS Functions with response time requirements and assures each of those Functions are assigned the response time surveillance requirement. The proposed change revises the presentation of the requirement to perform response time verification but does not change the intent of the requirement. In addition, the proposed change does not change the RTS Functions that are tested, the method of testing, or the frequency of testing. As such, the proposed change does not introduce any BVPS Units 1 &2 Page 54 Revision :2,4/06 184

BVPS ISTS Conversion 3.3A RTS Instrumentation Enclosure 3 Changes to CTS technical changes to the CTS. Therefore, the proposed change is designated administrative. A.31 The CTS surveillances for the Safety Injection Input from ESF and the RCP Breaker Position RTS Functions specified on Table 4.3-1 require a Channel Functional Test (CFT) to be performed once per refueling (18 months). The corresponding ISTS surveillance for these RTS Functions requires a Trip Actuating Device Operational Test (TADOT) to be performed once per 18 months. The ISTS surveillance is modified by a note that specifies "verification of setpoint is not required." The CTS surveillance is revised to conform to the ISTS surveillance. This changes the CTS by explicitly stating that setpoint verification is not required for these two RTS Functions. The change from the CTS CFT defined term to the ISTS TADOT defined term is addressed in the DOCs associated with TS Section 1.0, Definitions. This DOC is only intended to address the addition of the ISTS note that excepts the verification of setpoints. The proposed change is acceptable because the affected RTS Functions do not have a setpoint to verify. The Safety Injection Input Function simply initiates a reactor trip whenever a Safety Injection is initiated. The RCP Breaker Position Function initiates a reactor trip based on RCP breaker position (two-out-of-three RCP breakers open initiate a reactor trip). In addition, the proposed change is acceptable because it is consistent with the CTS CFT definition which does not require setpoints to be verified. Since the affected Functions do not have setpoints to verify, the proposed change does not introduce a technical change to the CTS requirements. As such, the prcposed change is designated administrative. A.32 CTS Table 4.3-1 contains a line item for the RTB Bypass Breakers. The CTS Table specifies two CFT surveillances for the RTB Bypass Breakers a monthly CFT and a refueling interval CFT. The corresponding ISTS Table 3.3.1-1 does not contain a specific line item for the RTB Bypass Breakers. The ISTS combines the surveillance requirements for the Bypass Breakers with the RTBs and the manual reactor trip function. The ISTS specifies one monthly (on a staggered test basis) TADOT for the RTBs and one 18 month TADOT for the manual reactor trip function. The CTS is revised to conform to the ISTS. This changes the CTS by eliminating a specific line item for the RTB Bypass Breakers and combining the CTS surveillances for the RTB Bypass Breakers with the RTB and manual reactor trip function surveillances. The differences between the CTS CFT defined term and the ISTS TADOT defined term are addressed in the DOCs associated with TS Section 1.0, Definitions. This DOC is intended to address the changes to the CTS Table 4.3-1 line item for the RTB Bypass Breakers. The purpose of the CTS monthly CFT specified in Table 4.3-1 for the Bypass Breakers is stated in the associated Note # 12. CTS Note 12 requires a local manual shunt trip prior to placing the Bypass Breakers in service. The intent of the CTS requirement is to test the Bypass Breakers (locally) each time they are placed in service to allow testing of the RTBs. The testing of the Bypass Beakers and RTBs orc Glnl['A I-P the fort thm Ptineae froantar m-,ef ho nIt-eA ;n ca;

                                                                         -     a4-  re th- 0Trc

BVPS ISTS Conversion 3.3A RTS Instrumental-ion Enclosure 3 Changes to CTS because the ISTS RTB surveillance retains the requirement to perform the surveillance on the Bypass Breakers prior to placing them in service and normally the Bypass Breaker is placed in service prior to testing the associated RTB. Thus, the Bypass Breakers continue to be tested in the same manner as before. The proposed change re-organizes the CTS to conform more closely to the relationship between the RTBs and the Bypass Beakers and the actual frequency of testing. The purpose of the refueling interval CFT specified on CTS Table 4.3-1 for the RTB Bypass Breakers is stated in the associated Note 13. CTS Note 13 states "automatic undervoltage trip." The intent of this surveillance is to allow the automatic undervoltage trip function on the Bypass Breakers to be tested during shutdown conditions when this trip Function can be actuated by the manual reactor trip switch. The undervoltage trip function can not be tested on line and is normally tested by actuating the manual reactor trip switch. The proposed change to this CTS surveillance (combining with the manual reactor trip Function) is acceptable because the Bypass Breaker undervoltage trip function continues to be tested in the same manner as before. The proposed change only re-organizes the surveillance requirements to more closely correspond to the actual testing performed using the manual reactor trip switch. The proposed changes are designated administrative because the affected Functions continue to be tested in the same manner as before. A.33 Unit I only. CTS Table 4.3-1 Note 5 states "each train tested every other month." The CTS Note is applicable to the surveillance requirements for the RTB and Automatic Trip Logic RTS Functions. The corresponding ISTS surveillance requirements for these RTS Functions specify that the surveillance is performed monthly on a STAGGERED TEST BASIS. The CTS is revised to conform to the ISTS. This changes the CTS by revising Note 5 from requiring that each train be tested every other month to the Function being tested monthly on a staggered test basis. The proposed change is acceptable because it does not introduce a technical change to the CTS surveillance requirements. The ISTS utilizes the defined term "Staggered Test Basis". The use of this term in a monthly surveillance results in each train of the affected RTS Functions being tested every other month. Thus, the proposed change results in the same surveillance frequency as the CTS. The proposed change simply adopts the ISTS terminology for this type of surveillance frequency. As the proposed change does not result in a technical change to the CTS requirements it is designated administrative. A.34 The CTS surveillance requirements specified on Table 4.3-1 for the Overtemperature AT RTS Function include a channel check, channel functional test, and channel calibration. The corresponding requirements in the ISTS include two additional surveillances. The ISTS includes the surveillances that require that the excore nuclear instrumentation be adjusted and calibrated to agree with the incore instrumentation. The incore/excore calibration requirements (SR 3.3.1.3 and SR 3.3.1.9) are also specified for the power range neutron flux high setpoint RTS Function. The CTS is revised to conform to the ISTS. This changes the CTS by assigning two additional surveillances to the Overtemperature AT RTS Function. The incore/excore calibration requirements are necessary to assure the f(AI) input to the Overtemperature AT RTS Function is accurate. As these surveillance BVPS Units 1 &2 Page 56 Revision 2, 4/06 186

BVPS ISTS Conversion 3.3A RTS Instrumentation Enclosure 3 Changes to CTS requirements support the operability of the Overtemperature AT RTS Function they should be associated with that Function. The proposed change is acceptable because it clarifies the association of these surveillance requirements with the Overtemperature AT RTS Function. The proposed change does not result in a technical change to the CTS. The surveillances continue to be performed in a similar manner as before and only the presentation of this information in the TS is affected. As such, the proposed change provides a clarification regarding the purpose of the affected surveillances without impacting the performance requirements. The proposed change is designated administrative as it does not introduce a technical change to the CTS. A.35 CTS Note 3 in Table 4.3-1 states "At least once every 31 Effective Full Power Days (EFPD) compare incore to excore axial imbalance above 15 percent of RATED THERMAL POWER. Recalibrate if absolute difference greater than or equal to 3 percent." The corresponding ISTS surveillance SR 3.3.1.3 is similar except that it states " Adjust NIS channel if absolute difference is 2 3%." The CTS is revised to conform to the ISTS. This changes the CTS by rewording the Note modifying the monthly comparison of the incore and excore detectors. The proposed change involves the specific surveillance instructions for equalizing the excore detector Al indications to the incore readings if the difference exceeds the limit. In actual practice the resetting (or adjustment) of the power range channel Al indications involves recalibration of the nuclear instrumentation system (NIS) to incorporate the new settings. The proposed change is acceptable because it does not substantially effect the necessary actions to incorporate any adjustments into the NIS. As such, the affected surveillance will continue to be performed in the same manner as before. The proposed change does not result in any reduction in the required surveillance testing of the NIS. The proposed change continues to provide adequate assurance that the NIS is maintained operable and performing within a Ga1a known tolerance. As the proposed change does not result in a technical change to the method for performing the surveillance or the surveillance acceptance criteria, it is designated administrative. BVPS Units 1 & 2 Page 57 Revision :2, 4/06 187

BVPS U N ITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQIUEST (LAR) NOS. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 REPLACEMENT PAGES ITS SECTION 3.3B REMAINDER OF INSTRUMENTATION LIST OF AFFECTED PAGES 8 59 21 64 31 74 32 82 33 142 34 218 35 219 36 220 37 38

Rev. 2 Change C-9, D-1 & D-12 BVPS PAM TABLE (combined Unit 1 and 2) I/ CONDITION REFERENCED FROM REQUIRED FUNCTION REQUIRED CHANNELS ACTION D.1

1. Power Range Neutron Flux 2(g) E D-12

2. Intermediate Range Neutron Flux 2(g) E

3. Source Range Neutron Flux 2(f) E

4. Reactor Coolant System (RCS) Hot Leg 2 E Temperature (Wide Range)

5. RCS Cold Leg Temperature (Wide Range) 2 E

6. RCS Pressure (Wide Range) 2 E

7. Reactor Vessel Water Level 2 F

8. Containment Sump Water Level (Wide Range) 2 E

9. Containment Pressure (Wide Range) 2 E

10. Containment Area Radiation (High Range) 2 F

11. Pressurizer Water Level 2 E

12. Steam Generator (SG) Water Level (Wide Range) 3 E

13. SG Pressure a) SG'A' 2 E b) SG'B- 2 E c) SG'C 2 E 2

I D1

14. Primary Plant Demineralized Water Storage Tank E Level

15. Refueling Water Storage Tank Level (Wide Range) 2 E

16. Penetration Flow Path Containment Isolation Valve 2 per peneltpn flow E Position path

17. Core Exit Temperature a) Quadrant 1 2(c) E b) Quadrant 2 2(c) E c) Quadrant 3 2(c) E d) Quadrant 4 2 (c) E

18. Secondary Heat Sink Indication a) SG'A' 2 (d) E b) SG'B- 2 (d) E c) SG-C- 2 (d) E

19. High Head Si Automatic Injection Header Flow I B(e) ,_.. I C*9

_ (d) The required channels may be satisfied by using any combination of SG Water Level (Narrow Range) channels and Auxiliary Feedwater Flow channels such that 2 channels are OPERABLE for each SG. (e) Condition B contains the appropriate Action for Function(s) with one required chane.l._ l C-9 (f) Source Range neutron detectors are not required to be energized above the P-6 Intermediate Range Neutron Flux Interlock. (g) Not required in MODE 3. 12 8

I Rev. 2 Change D-6 CREV Actuation Instrumentation

                                                                                                     \[f                        3.3..'

Table 3.3.7-1 (page 1 of 1) CREkS Actuation Instrumentation 3 FUNCTION APPLICABLE MODES OR OTHER SPECIFIED REQUIRED SUR VEILLANCE CONDITIONS CHANNELS REQI .JIREMENTS TRIP SETPOINT

1. Manual Initiation 1, 2,3,4,164& 2 trains SizR (a)

_1,2,3,4., \ 2_trains A NA Unit 2 SI 'D 0.476 mR/hr above background

                                                                                                                                /7              7'  I

( 8 b. Control Room Airnakes 1hr

                      \       l                                (a)                     _-     SR   3.37.7 SAWM  l,   iiA4-                           Refer to LCO 3.3.2, 'ESFAS Instrumentation," Function r all initiation Containment Isolation - Phase B   Ifunctions and requirements.

(a) During movement of Irecently] irradiated fuel assemblies, ( ~ (a) , and during movement of fuel assemblies over recently irradiated fuel assemblies. v I> kU2j WOG STS 3.3.7 -4 Rev. 2, 04/30/01 21

Rev. 2 Change C-1 BVPS ISTS Conversion l Enl3.3 B Instrumentation Enclosure 1 Changes to ISTS, RWST level reaches the extreme low level setpoint. All actions associated with recirculation spray system however are automatic, and therefore no operator action is required in the design basis analyses based on the containment sump level. The narrow range sump level indication provides information regarding the! normal containment sump level and is limited to 0-12 inches of range. The normal containment sump level is not the primary indication for determining the level of water in the containment ECCS sump where the recirculation spray pumps take suction. The wide range sump level indication is located in the ECCS sump and provides the necessary range (0-200") to determine such post accident conditions as the water level in the ECCS sump at the time the recirculation spray system is started. The narrow range sump level indication may be used for RCS leak detection and is addressed in the technical specification for RCS Leakage Detection Instrumentation (BVPS ITS 3.4.15). Therefore, for the purpose of post accident monitoring, the wide range containment sump level indication provides the necessary indication and range to determine the ECCS sump level during accident conditions. The narrow range indication would not provide a direct indication of conditions in the ECCS sump required during post accident conditions and is limited to 12 inches of range. Therefore, the narrow range containment sump level indication is not required in the PAM TS to assure the necessary post accident monitoring information is available in the control room. The Unit 2 wide range sump level indication is included in the proposed PAM ITS. The PAM ITS requires 2 channels of wide range sump level indication operable which is sufficient to assure the capability to monitor sump level after an accident is maintained. The inclusion of the Unit 2 wide range sump level and not the narrow range level in the PAM ITS is consistent with the CTS requirements for both Unit 1 and 2. In addition, it should be noted that two channels of RWST level are also included in the proposed ITS PAM list. The RWST level also provides information directly related to the amount of water delivered to the RCS and subsequently to the containment during and after safety injection. Two channels of containment sump wide range level and RWST level are included in the proposed PAM ITS. The information provided by these instruments is sufficient to monitor the water level in the ECCS containment sump, even considering a single failure. Therefore, the inclusion of the containment sump narrow range indication in the PAM specification is unnecessary. The proposed PAM instrumentation is adequate to assure the capability to determine the amount of water in containment. Considering that the wide range containment sump level indication provides the necessary indication and range to determine the ECCS sump level during accident conditions and that the narrow range indication does not provide a direct indication of conditions in the ECCS sump required during post accident conditions and is limited to 12 inches of range, the narrow range containment BVPS Units 1 and 2 Page 3 Revision 2, 4i06 31

Rev. 2 Change C-1 BVPS ISTS Conversion 3.3 B Instrumentation Enclosure I Changes to IST'S sump indication does not fulfill the necessary PAM Function. Therefore, the narrow range containment sump level indication is not required in the PAM TS to assure the necessary post accident monitoring information is available in the control room. B. Unit 2 RCS Subcoolina Margin Monitor is not included in the proposed PAM TS. This Unit 2 variable was classified as a Type A and Category 2 variable in the Unit 2 Regulatory Guide 1.97 Report. Unit 1 classified the RCS subcooling monitor as monitoring a Regulatory Guide 1.97 Type B, Category 2 variable. The RCS subcooling indication provides information to the control room operators related to satisfying one of the Si termination criteria following a design basis accident. The inputs to the RCS subcooling monitor are the core exit thermocouples for RCS temperature and the wide range RCS pressure indication for RCS pressure. Since both of these indications are independently available in the control room and are also included in proposed BVPS PAM ITS, the RCS subcooling monitor only provides a verification of these other primary indications. The backup nature of the Unit 2 Subcooling Margin Monitor indication is identified in UFSAR (Table 7.5.4). In addition, the RCS hot leg temperature indication and RCS cold leg temperature indication are included in the BVPS PAM ITS. The RCS hot leg temperature indication can also be used to verify adequate core cooling, RCS subcooling, and in conjunction with the RCS cold leg temperature indication, the effectiveness of RCS heat removal by the secondary system. The RCS pressure and temperature variables were classified as Regulatory Guide 1.97 Type A and Category 1. Considering the variety of RCS temperature indications and the RCS pressure indication included in the proposed BVPS PAM ITS and that the RCS Subcooling Margin Monitor is clearly identified as a backup indication in the Unit 2 UFSAR, the inclusion of the RCS Subcooling Margin Monitor is unnecessary to assure the ability to determine adequate core cooling. The RCS temperature and pressure indications required operable in the proposed BVPS PAM ITS provide sufficient assurance that RCS subcooling can be determined. In addition, since the RCS Subcooling Margin Monitor is specified in the Unit 2 CTS PAM, it will be relocated from the TS to the Licensing Requirements Manual (LRM). The LRM contains other BVPS relocated TS and provides a more appropriate level of control for a backup PAM indication. The relocation of this Unit 2 requirement also serves to make the Unit 1 and Unit 2 PAM ITS requirements the same. Considering the primary inputs to the RCS subcooling monitor are the core exit thermocouples for RCS temperature and the wide range RCS pressure indication for RCS pressure and that both of these indications are included in proposed BVPS PAM ITS, the RCS subcooling monitor is not required to fulfill the necessary PAM Function. Therefore, the RCS subcooling monitor is not required in the PAM TS to assure the necessary post accident monitoring information is available in the control room. C. Unit 2 Secondary System Radiation (Main Steam Discharge Radiation Monitors) BVPS Units 1 and 2 Page 4 Revision 2, 4!06 32

Rev. 2 Change C:-I IBVPS ISTS Conversion 3.3 B Instrumentation Enclosure 1 Changes to IST'S is not included in the proposed PAM TS. Secondary system radiation was classified as a Type A and Category 1 variable in the Unit 2 Regulatory Guide 1.97 Report. These effluent radiation monitors may be used to detect a Steam Generator Tube Rupture (SGTR). However, the primary indications used for diagnosis and response to a SGTR accident are RCS inventory losses (i.e., decreasing pressurizer level and pressure) and increasing water level in the affected steam generator. These indications provide the most reliable diagnosis of a SGTR accident to prompt the appropriate operator actions and are included in the proposed BVPS PAM ITS. Although the main steam discharge radiation monitors; may provide an indication of steam generator tube leakage, earlier detection of steam generator tube leakage is provided by more sensitive radiation monitors such as the N-16 radiation monitors on each steam line, the steam generator blowdown radiation monitor, and the condenser air ejector radiation monitor. The use of these more sensitive radiation monitors to detect tube leakage is consistent with the EPRI Guidelines for PWR primary-to-secondary leak detection. As such, the Unit 2 secondary system radiation indication is not the primary indication relied on to diagnose or mitigate a steam generator tube rupture accident. The proposed PAM ITS requires pressurizer level, RCS pressure, and SG water level indications operable. The proposed PAM ITS requirements are sufficient to ensure a SGTR is detected. In addition, considering the low levels of fuel leakage in modern fuel assemblies, and the relatively high range of the Unit 2 Main Steam Discharge monitors, these monitors can not be relied on to provide a timely or reliable indication of a SGTR. It should be noted that the Main Steam Discharge Radiation Monitors are required OPERABLE in the CTS (Radiation Monitoring TS), however, the associated Actions permit unlimited continued operation when the monitors are inoperable. As these monitors are effluent monitors they are proposed for relocation to the Offsite Dose Calculation Manual (ODCM) consistent with the location of the corresponding Unit I steam discharge radiation monitors. The ODCM contains other effluent monitors relocated from the TS and provides the appropriate level of control for this backup type of PAM indication. The relocation of these Unit 2 radiation monitors to the ODCOIM makes the location of these monitors the same for both Unit I and Unit 2. Considering the relatively high range of the Unit 2 secondary system radiation monitors, making them unreliable indicators of a SGTR, and the fact that these monitors are not the primary indication relied on to diagnose or mitigate a steam generator tube rupture accident and that the proposed PAM ITS requires pressurizer level, RCS pressure, and SG water level indications to be operable (the prime indications of a SGTR), the Unit 2 Secondary System radiation monitors are not required to fulfill the necessary PAM Function. Therefore, the Unit 2 secondary system radiation monitors are not required in the PAM TS to BVPS Units 1 and 2 Page 5 Revision 2, 4,'06 33

Rev. 2 Change C-11 BVPS ISTS Conversion 3.3 B Instrumentation Enclosure 1 Changes to ISTS assure the necessary post accident monitoring information is available in the control room. D. Unit 2 neutron flux upper and lower range indication (i.e., the Gamma-Metrics full range neutron flux monitor) is not included in the proposed PAM TS and is not part of the CTS. The upper and lower range neutron flux indication was classified as a Type B and Category 1 variable in the Unit 2 Regulatory Guide 1.97 Report. The Unit 2 Westinghouse Nuclear Instrumentation System (i.e., source, intermediate and power range instrumentation) is proposed to be included in the PAM TS consistent with the corresponding Unit 1 PAM instrumentation. The Unit I response to RG 1.97 identified the Westinghouse Nuclear Instrumentation System source, intermediate, and power range neutron flux variables as the required PAM instrumentation. The Unit I response to RG 1.97 classified the Westinghouse Nuclear Instrumentation System source, intermediate, and power range neutron flux variables as Type B and Category 1 variables. The Unit 2 response to RG 1.97 identified upper and lower range neutron flux variables that utilize the full range Gamma-Metrics instrumentation. The NRC subsequently approved both unit responses to RG 1.97. The Unit 1 SER for the Westinghouse Nuclear Instrumentation System to be used as post accident monitoring instrumentation was transmitted by separate NRC letter dated 11/17/95 (TAC NO. M81201). The NRC found the Westinghouse Nuclear Instrumentation System to be acceptable based on the availability of alternate means of assuring the reactor is in a shutdown condition. The availability of fully qualified core exit temperature and RCS hot and cold leg temperature indications and confirmation of the negative reactivity added by the boron injected into the RCS during accident conditions was considered by the NRC to be sufficient to allow operators to determine that the reactor is in a shutdown condition. k;Ay The Unit 2 full range Gamma-Metrics instrumentation is not specifically required to fulfill the initial indicating function of the neutron flux variable (i.e., to confirm reactor trip). The Westinghouse Instrumentation can perform this function. In addition, if the Westinghouse Nuclear Instrumentation was not available due to adverse conditions within containment, long term core stability can be verified in the same manner as approved for Unit 1 by core exit temperatures and RCS hot and cold leg temperatures (both of which are included in the proposed PAM TS). Therefore, in order to make the Unit 1 and 2 PAM TS consistent and to provide an accurate indication of neutron flux to satisfy the required PAM function, the Westinghouse Nuclear Instrumentation System (i.e., source, intermediate, and power range indications) are included in the proposed PAM TS for both units. The status of the Unit 2 Gamma-Metrics instrumentation (not included in the CT'; or proposed ITS) will remain unchanged. E. Unit I Radiation Level in Primary Coolant (RCS letdown Radiation Monitors) is not included in the proposed PAM TS. The radiation level in the primary coolant was classified as a Type C Category 1 variable. The RCS letdown radiation monitors that perform this function are not in the Unit 1 CTS and Unit 2 does not BVPS Units 1 and 2 Page 6 Revision 2, 4,'06 34

Repaginated due to Rev. BVPS ISTS Conversion 2 Change C-Il 3.3 B Instrumentation Enclosure 1 Changes to ISTS list a corresponding RG 1.97 variable. The affected radiation monitors are located in the RCS letdown line, which is isolated upon the receipt of a safety injection signal. Although the RCS letdown radiation monitors may be used as diagnostic indications of fuel leakage, for the purposes of the protection of the health and safety of the offsite general public, the key indicators of the need to implement offsite emergency protective actions at BVPS Units 1 and 2 are high core exit thermocouple indications, high containment radiation levels, failure of complete containment isolation and/or high containment pressures. Other indications, including the RCS letdown line radiation level, are most useful to validate the loss of barriers, but not as primary indications of the potential for, or the loss of the barrier. The Emergency Action Levels in the E-Plan for BVPS Units 1 and 2 utilize the containment high range radiation monitors as an indication of a loss of one or more fission product barriers in the assessment of the declaration of a General Emergency level and the potential need for offsite radiological protection actions. The BVPS Unit 1 and 2 Core Damage Assessment also uses the containment high range radiation monitors as an input to the determination of core damage. Core exit temperature, containment radiation level, containment isolation valve position, and containment pressure instrumentation are all included in the proposed PAM TS and provide adequate assurance that the PAM function can be accomplished. Therefore, in order to make the Unit I and 2 PAM TS consistent and to only include the primary indications used to satisfy the PAM functions, the Unit I RCS radiation level indication is not included in the proposed PAM TS. The status of the Unit 1 RCS radiation monitors (not included in the TS) will remain unchanged. F. Unit I and 2 Containment Pressure (Narrow Range) is not included in the proposed PAM TS. The Containment Pressure Narrow Range indication is currently classified as Regulatory Guide 1.97 Type A, Category 1 for both BVPS Unit 1 and Unit 2. The narrow range containment pressure instrumentation is not included in the CTS. The Containment Pressure (Wide Range) instrumentation is proposed for inclusion in the PAM TS. The containment pressure indication is provided for assessing inadequate containment cooling and for determining the potential challenge to containment integrity. The significant post accident use of containment pressure indication is as an indicator of the potential loss of a fission product boundary in the Emergency Action Levels in the E-Plan for BVPS Units I and 2. Containment pressure is a key indicator in the declaration of a General Emergency level and the potential need for offsite radiological protection actions. The wide range containment pressure instrumentation provides an adequate range and sensitivity for this purpose. The narrow range containment pressure BVPS Units 1 and 2 Page 7 Revision 2, 4/06 35

l Repaginated due to Rev. l BVPS ISTS Conversion 2 Change C-11 3.3 B Instrumentation Enclosure I Changes to IST'S instrumentation is limited in range and does not extend sufficiently beyond the design basis pressure to provide the required indication during all types of post accident conditions. As such, the containment pressure narrow range indication is not required in the PAM TS as it does not provide any additional information pertinent to post accident monitoring that is not provided by the containment wide range pressure indication. The proposed PAM TS include 2 channels of wide range containment pressure indication. The proposed PAM requirements are adequate to assure the capability to monitor containment pressure after an accident (even considering a single failure). In addition, the inclusion of the Containment Pressure (Wide Range) instrumentation in the PAM TS is consistent with the CTS. G. Unit 1 and 2 Containment Hydrogen Monitors are not included in the proposed PAM TS. The Containment Hydrogen Concentration is currently classified as a Regulatory Guide 1.97 Type A, Category I variable for Unit 1 and a Category 1 variable for Unit 2. Although the Hydrogen Monitors are associated with a Category 1 variable (both Units) and Type A (Unit 1 only) they are not included in the BVPS PAM ITS. The Hydrogen Monitors were removed from the ISTS by TSTF-447, Rev. I which implemented in the technical specifications the NRC rule change to 10 CFR 50.44 (standards for combustible gas control in light-water-cooled power reactors). In addition, the Hydrogen Monitors were removed from the current BVPS technical specifications by License Amendment numbers 259 (Unit 1) and 149 (Unit 2) issued May 19, 2004. Currently requirements for the BVPS Unit 1 and Unit 2 Hydrogen Monitors are maintained in the BVPS Licensing Requirements Manual (LRM). Non-Type A or Category I Variables Added: H. Unit 1 AFW Flow was included in the proposed PAM TS. The Unit 1 AFW Flow indication is classified as a Regulatory Guide 1.97 Type D, Category 2 variable. This indication is in the CTS requirements for PAM and provides an important indication, similar to the Unit 2 AFW Flow indication, which was classified Regulatory Guide Type A, Category 1. The inclusion of this Unit 1 indication will help to make the PAM requirements for both units consistent. As the Unit 1 AFWtV Flow was not designed as a Regulatory Guide 1.97 Type A or Category 1 instrument, there is only one channel per SG. The AFW Flow indication is included in the proposed PAM ITS in a combined Function with SG Level (Narrow Range) indication. The combined Function is listed as "Secondary Heat Sink Indication" on PAM Table 3.3.3-1. The use of this combined Function allows two channels of indication to be specified for each SG. The required two channels of this Function can be met by any combination of the (3) SG Level (Narrow Range) channels and the single Unit 1 AFW Flow channel for each SG. Any of these channels provide the required post accident indication to assure an available heat sink. BVPS Units 1 and 2 Page 8 Revision 2,4/06 36

IRepaginated due to Rev. 2 Change C-1 BVPS ISTS Conversion 3.3 B Instrumentation Enclosure 1 Changes to ISTS I. Unit 2 Reactor Vessel Water Level was included in the proposed PAM TS. The Unit 2 Reactor Vessel Water Level indication is classified as a Regulatory Guide 1.97 Type B, Category 2 variable. This indication is in the CTS requirements for PAM and provides an important indication similar to the Unit I Reactor Vessel Water Level indication which was classified Regulatory Guide Type B, Category

1. The inclusion of this Unit 2 indication will help to make the PAM requirements for both units consistent.

J. Unit 2 Refueling Water Storage Tank (RWST) Level (Wide Range) is added to the proposed PAM TS. The Unit 2 RWST Level (Wide Range) indication is classified as a Regulatory Guide 1.97 Type D, Category 2 variable. However, this Unit 2 indication was determined to provide important information for Unit 2 similar to the Unit 1 RWST Level indication which was classified as a Regulatory Guide 1.97 Type A, Category 1 variable. The inclusion of this Unit 2 indication will help to make the PAM requirements for both units consistent. The inclusion of this indication in the PAM TS represents a new TS requirement for both units. K. Unit 2 Containment Isolation Valve Position Indication is added to the proposed PAM TS. The Unit 2 Containment Isolation Valve Position indication is classified as a Regulatory Guide 1.97 Type C, Category 2 variable. However, this Unit 2 indication was determined to provide important information for Unit 2 similar to the Unit 1 Containment Isolation Valve Position indication which was classified as a Regulatory Guide 1.97 Type B, Category I variable. The inclusion of this Unit 2 indication will help to make the PAM requirements for both units consistent. The inclusion of this indication in the PAM TS represents a new TS requirement for both units. L. Unit I and Unit 2 High Head Safety Iniection (SI) Automatic Injection Header Flow is added to the proposed PAM TS. The High Head Si Automatic Injection Header Flow indication is classified as a Regulatory Guide 1.97 Type D, Category 2 variable for both units. This indication is not in the CTS. As this variable is not classified as a Type A or Category 1 variable it was not designed as such. There is only a single channel of indication available for each unit. This variable has been identified as the preferred control room indication for confirming automatic Si initiation. Confirming automatic SI initiation is important in order to determine if manual action is needed to assure high head SI initiation. Although this variable does not meet the criteria for inclusion in the PAM ITS, it is, included in the proposed ITS for both units in recognition of its importance in confirming automatic high head Si initiation. As this indication does not meet the Regulatory Guide 1.97 classification requirement for inclusion in the PAM TS and was not designed with redundancy, it is assigned the same Action for a single inoperable channel as the other PAM Functions. The Action to restore the inoperable channel to operable status within 30 days or submit a report to the NRC is sufficient for this instrument Function. The standard Action for a single inoperable channel is acceptable for this BVPS Units 1 and 2 Page 9 Revision 2, 4,'06 37

REV. 2 Changes C-9 & BVPS ISTS Conversion Repagination due to C-11 3.3 B Instrumentation Enclosure I Changes to ISTS' Function considering that the Function is not required to be in the PAM ITS and that it does not meet the stringent design requirements of the other Functions that are required to be in the PAM TS. In addition, acceptable alternate indications exist in the control room to confirm automatic high head Si initiation. An alternate method of verifying SI initiation can be provided by the High Head SI pump amperage indication, the High Head Si header pressure indication, and the Si automatic valve position indication. A combination of these indications provides an acceptable long term alternate method to verify automatic Si initiation until the single channel of high head flow indication is restored to operable status.

6. The proposed PAM TS includes Function number 18, " Secondary Heat Sink Indication" and the associated footnote "d" which states "The required channels may be satisfied by using any combination of SG Water Level (Narrow Range) channels and Auxiliary Feedwater Flow channels such that 2 channels are OPERABLE for each SG." The proposed new Function combines the instrument channels for SG level (narrow range) and Auxiliary Feedwater Flow (AFW). The CTS for PAM only includes the AFW Flow indication. The addition of the SG Level (Narrow Range) represents a new TS requirement for the BVPS units. The ability to maintain the SG level within the NR indication also confirms an adequate water volume for decay heat removal as well as confirming the associated AFW system capability to feed the SG. The addition of the SG Water Level NR channels to the PAM TS makes the proposed change possible. The allowance to combine these indications into a single Function is acceptable as these indications serve a similar purpose (i.e., the maintenance of SG level to provide an adequate heat sink). The use of either indicator for this purpose is consistent with the Westinghouse Emergency Response Guidelines as implemented in the BVPS Unit I and Unit 2 Emergency Operating Procedures. In addition, the Unit 1 AFW Flow is not a Regulatory Guide 1.97 Type A or Category I instrument, and only one channel is available per SG. As such, the proposed new Function that allows AFW flow and SG level to be combined permits Unit 1 to have 2 channels of indication for each SG and makes both units the same. In addition, the use of the combined "Secondary Heat Sink Indication" Function in the PAM ITS was previously approved by the NRC for the D. C.

Cook plant in their conversion to the ISTS.

7. The proposed PAM Table 3.3.3-1 is revised by the addition of new Note (e) in the table column intended to provide direction when two or more inoperable channels are not restored to operable status in the specified time. The addition of the new note is associated with Function 19 on the table. Function 19 is the only Function with one c-s required channel. The addition of Note (e) is intended to clarify that Condition B is the correct Condition for Functions with only one required channel and that Conditions E and F (applicable for Functions with 2 or more required channels) do not apply for Functions with only one required channel. This note was added at the request of the NRC.

BVPS Units 1 and 2 Page 10 Revision 2, 4,'06 38

LFIRe.2ChaI1ge D¶12 PAM Instrumentation B 3.3.3 BASES or the reliability of Clvs without vntrol room indication (i.e.,or open under adminisrative Sautomatic check valves and relief valves that are not controls in accordance with the dependent on an external power source or dosure signal) or provisions of the CIV technical LCO (continued) a"& cIose spcfcan valve prior knowledge of a passive alve, or vi system b ndary status. If a normally active CIV is known to be closed and deactivated, osition indication is not needed to determine status. Therefore, the position indication for valves in this state is not required to be OPERABLE. I Type A and Category I variables arel`equired to meet Regulatory Guide 1.97 Category I (Ref. 2) design and qualification requirements for seismic and environmental qualification, single failure criterion, utilization of emergency standby power, immediately accessible display, continuous readout, and recording of display., The following are discussions of the specified instrument Functions listed in Table 3.3.3-1. T-hese di cMeions are intonded as examples of what Shoetd-be proirdod for each CURGOnwhen the Unit pefiG list m,lraaedt P ,ower^R Rangeoanluxre na

                                                                                             "'1ani Ne                             Power, Intermediate, andSuc        l
                                           ]

7 Power Range and Soure Range Neutron Flux indication is provided to verify reactor shutdown. The " ranges are necessary to cover the full range of flux that may occur poaEr.jy r 3 Neutron flux is classified as a Neutron flux is used for accident diagnosis, verification of subcriticalily, and Category 1 variable. diagnosis of positive reactivity insertion. A Type A and g Reactor Coolant S stem (RCS) Hot and Cold e Temperatures I

                                           ]        RCS Hot and Cold Leg Temperatures are ategory I variables rovicled for verification of core cooling and long term surveillance. lde Range)

RCS hot and cold leg temperatures are used to determine RCS subcooling margin. RCS subcooling margin will allow termination of safety injection (SI), if still in progress, or reinitiation of SI if it has been stopped. RCa subcooling margin is also used for unit stabilization and cooldown control: Tk'

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                                                                     .. J- l       ---  H
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                                                                                                                                                -UV-UCb k-ne VWb IIle source range neutron detectors to be de-energized above the P-6 Intermediate Range Neutron Flux Interlock. Source Range channel op2rability, when the associated detector is de-energized, consists of being capable of performing its intended function once power is restored to the associated neutron detector. When the source range detectors are deenergized. the source range channels are also considered de-enegized and SR 3.3.3.1 is not applicable. Similarly, the required channels for Intermediate and Power Range indication on Ta le 3.3.3-1 are modified by footnote (9) which provides an exception to the MODE 3 OPERABILITY requirement for this indication. In MODE 3, the Source Range channels are adequate to provide the required reactivity monitoring function. The Intermediate and Power Range indication channels serve to confirm reactor shutdown in a post reactor trip condition from power operation.

WOG STS B 3.3.3 - 4 Rev. 2, 04/30/01 59

Re.hCange D-1 PAM Instrumentation Y1v B 3.3.3 BASES LCO (continued)

                                                   . etermine the nature of the accident in progress (e.g., verify an S         ,and 2

verify unit ions for termination of SI during se ary unit HELBs outside contairim At some units, operator action sed o ontrol room indication of SG level. The RCS response during a n basis small break LOCA depends on the break size. Fo ertain e of break sizes, the boiler condenser mode of heat trer is necessary move decay heat.

Extended startup ra evel is a Type A variable b se the operator must manually re and control SG level to establish boa ondenser heat transfer Oao cion is initiated on a loss of subcoe my Eeeder flow is increased until the indicated extended startup ran level rimary Plant hes the boiler condenser setpoint. \ Demineralized Water Storage Tank (PPDWST) oe t Se -T4nk4CS-T-) Level PPDWST levelpiswI_PDWST water supply safety for auxiliary (AFW). Theisensvf waterfeedwater The The PPDST level is / provides t ensured grade supply for the classified as a Category STr o tae I variable for Unit 1 and AFIytm Ie a Type A and Category I common outiet heade is monitored by a Oinch to 1144 variable for Unit 2. ion fe i6 displayed on a corol room (LS;2 The PPDWST Level indicator, strip catco room annunciator F,and unit GomputeF. In addition, a Gontra (for unit 2) indication is used for the diagnosis of the need to refill the tank to provide a At somne unit, A- w4, Level is considered a Type A variabb because the Lvli os I long term steam generator control room meter and annunciator are considered the primary indication heat sink for decay heat used by the operator.t

                        \                        ThA DR AA tha;t Die66r                     hels of electriG poweF, isteamn linE-I)eak The           is    e initial source of water for the AFW System. However, as the          sepleted, manual operator action is necessary to replenish the INSERT 5                   or align suction to the NEW pumps from the hotwell.

RWST Level \ INSERT CIV Position Indication di cussion (from Bases Page 7) WOG STS B 3.3.3 - 9 Rev. 2, 04/30/01 64

ITS 3.3.3 BASES INSERTS Rev. 2Change C-yo U~This indication provides confirmation of adequate SG inventory to ensure the required heat sink(s) are available. The availability of SG(s) for heat removal is important to safety to ensure adequate core cooling. This indication can also be used by the operator to confirm that the AFW System is in operation and delivering sufficient flow to each SG. AFW system initiation is important to safety because it provides information necessary for operator action to initiate alternate feedwater sources in the event of a failure of the AFW system. INSERT 8 BVPS HIGH HEAD SI AUTOMATIC INJECTION HEADER FLOW BASES

19. High Head Safety Iniection (SI) Flow High Head Safety Injection (SI) Flow is classified as a Category 2 variable.

High Head SI Flow indication is used to confirm automatic safety injection initiation following a design basis accident. Therefore, the required flow indicator for this PAM Function is the total flow indicator installed in the automatic High Head SI flow path. Failure to manually initiate SI flow when the automatic initiation fails can lead to a significant increase in core damage frequency. Operator action is based on the ECCS flow indication in the control room. Only high head safety injection is important for all accident sequences except the unlikely double-ended guillotine rupture of the largest reactor coolant pipe. Therefore, only the High Head SI Flow indication is required. This instrumentation was not designed to meet Regulatory Guide 1.97 Category 1 or Type A requirements. Only a single channel is available and required OPERABLE for each unit. The requirement for a single OPERABLE channel of this indication is acceptable due to design requirements for this instrument (i.e., not Category 1) and the additional information available in the control room to confirm high head SI initiation. For example, if the total High Head SI Flow indication is not available, alternate methods of verifying SI initiation can be provided by the High Head SI pump amperage indication, the High Head SI header '4 ~l~pressure indication, and the SI automatic valve position indication. As only one channel of High Head SI Flow indication is required OPERABLE, the information associated with this Function on Table 3.3.3-1 is modified by footnote (e). Footnote (e) clarifies that Action Condition B is the only applicable Action Condition for Functions with only one required channel that can not be restored to OPERABLE status within the Completion Time specified in Action Condition A. As Footnote (e) and Condition B are in the Table column for Conditions referenced from Required Action D.1, this Table notation also clarifies that Action Conditions C, D, E, and F are not applicable to Functions that only require a single OPERABLE channel. INSERT 9 BVPS ACTION CONDITION F BASES The following are examples of acceptable alternate indication methods for Reactor Vessel Water Level and Containment Area Radiation: Reactor Vessel Water provides information to indicate whether the core cooling safety function is being accomplished. As such, the core exit temperature and subcooling (RCS Pressure and Temperature) indications may be used in lieu of Reactor Vessel Water indication. Radiation monitor RM-1RM-201 (Unit 1) and 2RMR-RQ202B (Unit 2) or a portable radiation monitor (with appropriate multiplier if necessary) can be used as an alternate method of indication for Containment Area Radiation High Range. Page 4 74

Rev. 2 Change D-13 Insert BVPS Specific Table B 3.3.4-1 Table B 3.3.4-1 (page 1 of 1) Remote Shutdown System Indications and Controls Emergency Shutdown Panels PNL-SHUTDN (Unit 1) and PNL-2SHUTDN (Unit 2) REMOTE SHUTDOWN SYSTEM FUNCTION REQUIRED INDICATIONS AND CONTROLS NUMBER OF CHANNELS

1. Reactivity Control Function

a. Source Range Neutron Flux (indication) 1(a)

b. Boric Acid Transfer Pump (control) 1

2. Reactor Coolant System (RCS) Pressure Control Function

a. Pressurizer Pressure (indication) 1 or

b. Pressurizer heater (control) 1

3. Decay Heat Removal via Steam Generators (SGs) Function

a. RCS Hot Leg Temperature (indication) 1

b. RCS Cold Leg Temperature (indication)

c. SG Pressure (indication) IISG

d. SG Level (indication) I/SG

e. AFW Flow (indication) IISG

f. SG Atmospheric Dump Valve (control) 1 or

g. AFW pump (Control) 1

h. AFW Flow (Control) 1

4. RCS Inventory Control Function

a. Pressurizer Level (indication) 1

b. Charging Pump (Control)

c. Charging Flow (Control)

d. Letdown Flow (Control) 1

5. Support Systems

a. Component Cooling Water pump (control) 1

b. RiverWater pump (c&6troI (Unit 1 bntd) 1 C. 1 (a) Source Range neutron detectors are not required to be energized above the P-6 Intermediate Range Neutron Flux Interlock.

82

I Rev. 2 Change C-9, D-1 & D-12 I INSERTS for ITS 3.3.3 Table 3.3.3-1 YJ.IYi NEW PAM FUNCTIONS Ml~ CONDITION REFERENCED FROM REQUIRED FUNCTION REQUIRED CHANNELS ACTION D.1

1. Power Range Neutron Flux 2 g) E D-1 2

2. Intermediate Range Neutron Flux 2(9) E

3. Source Range Neutron Flux 2 in E

4. Reactor Coolant System (RCS) Hot Leg 2 E Temperature (Wide Range)

5. RCS Cold Leg Temperature (Wide Range) 2 E

6. RCS Pressure (Wide Range) 2 E

10. Containment Area Radiation (High Range) 2 F

12. Steam Generator (SG) Water Level (Wide Range) 3 E

13. SG Pressure a) SG "A" 2 E b) SG "B" 2 E c) SG"C" 2 E

14. Primary Plant Demineralized Water Storage Tank 2 E l D-1 Level

15. Refueling Water Storage Tank Level (Wide Range) 2 E

16. Penetration Flow Path Containment Isolation Valve 2 per peneMt n flow E Position path

18. Secondary Heat Sink Indication a) SG "A" 2 (d) E b) SG"B" 2(d) E c) SG"C" 2 (d) E

19. High Head Sl Automatic Injection Header Flow 1 B(e) I C-9 (a) Not required for isolation valves whose associated penetration is isolated by at least one dosed and deactivated automatic valve, closed manual valve, blind flange, or check valve with Dow thfough the valve secured.

(b) Only one position indication channel is required for penetration flow paths with only one installed control room indication channel. (e) Condition B contains the appropriate Action for Function(s) with one required channel. I C-9 (1) Source Range neutron detectors are not required to be energized above the P.6 Intermediate Range Neutron Flux Interlock. l D-12 (g) Not required in MODE 3. 142

Rev. 2 Change D-1 BVPS ISTS Conversion 3.3 B Instrumentation Enclosure 3 Changes to CTS acceptable, because it provides a more appropriate surveillance interval for this type of indication that is consistent with the surveillance interval for other PAM instrumentation. In addition, based on the operating experience for the other PAM instrumentation, the monthly interval for the Channel Check continues to provide adequate assurance that the required indication is maintained operable. As the proposed change continues to provide adequate assurance that the required indication is maintained operable, the change does not adversely affect the safe operation of the plant. The proposed change is designated less restrictive because a less frequent surveillance interval is required in the ITS than in the CTS. More Restrictive Changes (Al) M.1 The CTS PAM instrumentation listed on Table 3.3-11 is revised by the addition of new instrumentation consistent with the proposed list of PAM Functions on ITS Table 3.3.3-1. The following list includes the new PAM Functions introduced by the ITS and the associated Function number from ITS Table 3.3.3-1: Table 3.3.3-1 Function Number Function Title 1 Power Range Neutron Flux 2 Intermediate Range Neutron Flux 3 Source Range Neutron Flux 4 RCS Hot Leg Temperature (Wide Range) 5 RCS Cold Leg Temperature (Wide Range) 6 RCS Pressure (Wide Range) 10 Containment Area Radiation (High Range) (Moved from Radiation Monitoring TS) 12 SG Water Level (Wide Range)

13. a), b), & c) SG Pressure (SGs A, B, & C) 14 Primary Plant Demineralized Water Storage Tank Level 15 Refueling Water Storage Tank Level (Wide Range) 16 Penetration Flow Path Containment Isolation Valve Position

18. a), b), & c) Secondary Heat Sink Indication (For SGs, A, B, & C) 19 High Head SI Automatic Injection Header Flow BVPS Units 1 &2 Page 6 Revision :2, 4/06 218

BVPS ISTS Conversion Rev. 2 Change C-9 3.3 B Instrumentation Enclosure 3 Changes to CTS As the addition of ITS Function number 18 represents a relaxation in the CTS PAM requirements for AFW Flow indication, it is discussed in DOC L.4. All the PAM Functions listed above are used to monitor Regulatory Guide 1.97 Type A and or Category 1 variables (consistent with the guidance in NUREG-1431) except for the following Functions:

. Unit 2 Refueling Water Storage Tank (RWST) Level (Wide Range) is added to the proposed PAM TS. The Unit 2 RWST Level (Wide Range) indication is classified as a Regulatory Guide 1.97 Type D, Category 2 variable. However, this Unit 2 indication was determined to provide important information similar to the Unit 1 RWST Level indication which was classified as a Regulatory Guide 1.97 Type A, Category 1 variable. The inclusion of this Unit 2 indication will help to make the PAM requirements for both units consistent. The inclusion of this indication in the PAM TS represents a new TS requirement for both units.
& Unit 2 Containment Isolation Valve Position Indication is added to the proposed PAM TS. The Unit 2 Containment Isolation Valve Position indication is classified as a Regulatory Guide 1.97 Type C, Category 2 variable. However, this Unit 2 indication was determined to provide important information similar to the Unit 1 Containment Isolation Valve Position indication which was classified as a Regulatory Guide 1.97 Type B. Category I variable. The inclusion of this Unit 2 indication will help to make the PAM requirements for both units consistent. The inclusion of this indication in the PAM TS represents a new TS requirement for both units.
. Unit I and Unit 2 High Head Safety Iniection (SI) Automatic Iniection Header Flow is added to the proposed PAM TS. The High Head SI Automatic Injection Header Flow (i.e., high head SI total flow) indication is classified as a Regulatory Guide 1.97 Type D, Category 2 variable for both units. As this variable is not classified as a Type A o Category 1 variable it was not designed as such. There is only a single channel of control room indication available for each unit. This variable has been identified as the preferred control room indication for confirming automatic SI initiation. Confirming automatic SI initiation is important in order to determine if manual action is needed to assure high head SI initiation. Therefore, it is included in the proposed PAM TS for both units. Although this variable does not meet the criteria for inclusion in the PAM ITS (i.e., it is not classified as a Regulatory Guide 1.97 Type A or Category 1) it is included in the proposed ITS in recognition of its importance in confirming automatic high head SI initiation. Table note (e) is assigned to this new PAM Function.

The proposed additions include specifying (2) Required Channels for each of the new Functions except for the SG Water Level (Wide Range) Function which requires (3) total channels operable and the High Head SI Automatic Injection Header Flow (discussed above) which only requires a single operable channel. The requirement for two operable channels satisfies the PAM requirement for redundant channels to ensure at least one channel is operable in post accident BVPS Units 1 & 2 Page 7 Revision 2, 4/06 219

Rev.2 -12BVPS Chnge ISTS Conversion lRev. 2 Change D-12 3.3 B Instrumentation Enclosure 3 Changes to CTS conditions. The SGs are designed with a single wide range level channel per SG. Therefore, in order to ensure the continued operability of the SG wide range SG water level indication all three available channels are required operable in the proposed PAM ITS. The single channel of High Head Si Automatic Injection Header Flow specified in the proposed PAM ITS is discussed above. The proposed PAM Function additions listed above include the applicable footnotes (a arid b) necessary to clarify the number of required channels for the Containment Isolation Valve Position Indication Function. The addition of these footnotes is consistent with the corresponding ISTS footnotes and is necessary to define the channel requirements consistent with the containment isolation valve design. Footnote (c) is associated with the Core Exit Temperature Function and is described in DOC A.6. Footnote (d) is associated with Secondary Heat Sink Indication and is discussed in DOC L.4. The proposed neutron flux indication channels (Functions 1, 2, and 3) are modified by notes (f) and (g)to identify appropriate exceptions to the operability requirements for this new PAM instrumentation. The purpose of the PAM TS is to ensure sufficient indication instrumentation is maintained operable to provide the necessary indication in post accident conditions. The proposed change includes the addition of indicating instrumentation that provides information to the operators for use in mitigating the consequences of accidents. The proposed change also includes the appropriate surveillance requirements for each new Function to ensure the Functions are maintained operable in accordance with the PAM technical specification requirements. The proposed change enhances the existing CTS requirements by providing a more complete set of PAM indications in the TS. As such, the proposed change is acceptable because it provides additional assurance that instrumentation necessary to perform PAM functions is maintained operable. The addition of the instrumentation listed above serves to improve the diversity and redundancy of the required PAM instrumentation without adversely affecting equipment availability or the safe operation of the plant. The proposed change is, designated more restrictive because new instrumentation is added to the PAM TS. M.2 The 'S/U" frequency for the Channel Check on the Auxiliary Feedwater Flow Rate (i.e., the ITS Secondary Heat Sink Indication) PAM Function is revised to an NM" frequency. 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. The Channel Check requirement on current TS Table 4.3-7 for the AFW Flow Rate PAM Function specifies that the surveillance is only required during startup (S/U). The Channel Check requirement is further modified by an asterisk footnote which specifies that the Channel Check need only be performed in conjunction with Surveillance Requirement 4.7.1.2.7 following an extended outage. CTS Surveillance 4.7.1.2.7 is contained in AFW Technical Specification 3/4.7.1.2. The surveillance requires that AFW flow to the steam generators be verified after an extended shutdown (i.e., shutdown in Modes 5 or 6 for greater than 30 days). The CTS requirement is intended to specify the performance of a Channel Check only when the AFW system is in service (i.e., in conjunction with Surveillance Requirement 4.7.1.2.7 following an extended outage). The CTS requirement BVPS Units I & 2 Page 8 Revision :2, 04/06 220

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQ UEST (LAR) Nos. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 REPLACEMENT PAGES ITS SECTION 3.3C ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION LIST OF AFFECTED PAGES 10 73 93 11 74 98 12 76 99 13 80 100 15 80A 101 16 80B 103 18 80C 105 27 80D 106 29 80E 107 30 82 108 32 84 110 33 89 112 54 90 113 58 91 114 68 92 115 116 116A

r- - ESFAS Instrumentation Rev. 2 Change A-6 3.3.2 I Engineered Safety

1. Safety Injection

a. Manual 1.2,3,4 2 B SR Initiation

b. Automatic 1.2,3,4 2 trains C SR Actuation Logic SR and Actuation SR Relays

c. Containment 1,2,3 3 D ESR A-6 Pressure - SR High 4 SR SR

d. Pressurizer 1 ,2,3(a) P1 D SR Pressure - Low SR SR SR

e. Steam Line.f Pressur 0. I I 4 Low' t 1,23(a)] t 3 per steam t D SR line SR SR SR Differential Pressure Between Steam (a) Above the P-1I (Pressurizer Pressure) inlerlock.

(b) nts used Inthe lead/lag controller are t, 2 [501 seconds and t2 , 151seconds. (c) Above the P-12 (177 - Low dock. (d) Less than or equal to a funcion defined as AP cone to [44 % o w 1201% load, and AP increasing linearT, from 144]% full steam flow at [201% load to [1 14J% full steam d AP orresponding ll 141% full steam flow above 100%. load. (e) Less than or nction defined as AP corresponding to [401% full steam n1w between [01% an and then a AF in n early from [401%o steam flow at [201% load to 11101% full steam flow at [1001% load. INSERT 2 A-6 Notes (e)&(f) WOG STS 3.3.2 - 8 Rev. 2, 04/30/01 10

Rev. 2 Change A-6 ESFAS Instrumentation 3.3.2 Table 3.3.2-1 (page 2 of 8) UNIT 2 Engineered Safety Feature Actuation System InstrumentatiL ALLOWABLE FVALUE FUN ) APPLICABLE MODES OR OTHER SPECIFIED REQUIRED SURVEILLANCE ALLOWABLE CONDITIONS CHANNELS CONDITIONS REQUIREMENTS VALUE

f. H ig 1,2 ,3(c) 2 per steam D SR 3.3.2.1 . (d)

Flow in Two line SR 3.3.2.5 _ i Steam Unes SR 3.3.2.9 (\) er loop D SR 3.3.2.10 Coincident with 1,2,3 r oop D [550.6]jF Tv- Low Low T,8g-Low~~ow bR 3.3.2.59 ._ SR 3.3.2.10 ..

g. High Steam 1 ,2,3 (c) 2 am D 3.3.2.1 (d) . -

FlowhinTwo lieSR 5.--; i Steam Lines SR 3.32.. -"

                                                     /                                    ~SR   3.3.2.10;                                                    '

Coincident wiI 3 c per steam D SR 3.3.2.1 Ž65 Stea m line SR 3.3.2.5

j 9f; [

_ ure - Low SR 3.3.2.9 > t . SR, .3.323!0

2. Containment Spray

a. Manual 1,2.3,4 2 per train, 2 B SR 3.3.2.8 NA I Initiation trains , 3..... . ,

b. Automatic 1,2,3,4 2 trains C SR 3.3.2.2 Actuation Logic SR 3.3.2.4 f Ws and Actuation SR 3.3.2.6 :.

Relays

c. Containment 1,2.3 4 E SR .1 psig Pressure High - SR 3.3.2 ,- UA4 34-High Ni94 SR 3.3.2.

3 3 2 9..i' SR . . .V\jF.-' [.43S 11.4 (b nstants used in the lead/lag controller are tj 2 [50jseconds and t2 [15Jseconds. (c) Above the P-12 (TM - tertock. (d) Less than or equal to a function dne as ilow 201% load, and AP increasing linearly from [443% fuil steam flow at [201% load to [1141% full sa and AP corresponding to [1141% full steam flow abovo 100% load. (e) Less than or union defined as AP corresponding to [403% full steam flow between [03% and nd then a AF n linearly from [401% steam flow at 1201% load to 1 101% full steam flow at 1100]% load. INSERT 2 A-6 Notes (e)& (f) WOG STS 3.3.2 - 9 Rev. 2, 04/30/01 11

I Rev. 2 Change A-6 E ESFAS Instrumentation 34.3.:' 6 U1N1T 2 Table 3.3.2-1 (page 3 of 8) ALLOWABLE Engineered Safety Feature Actuation System Instrumentation WVLUE GUNITI

3. Containment Isolation

a. Phase A Isolation (1) Manual 1,2,3,4 B SR 3.3.2.8 NA Initiation (2) Automatic 1.2,3.4 2 trains C SR 3.3.2.2 'P I NA Actuation SR 3.3.2.4 Logic and SR 3.3.2.6 Actuation Relays (3) Safety Refer to Function I (Safety Injection) for all initiation functions and requirements.

Injection

b. Phase B Isolation (1) Manual 1,2,3,4 2pertrain,2 B SR 3.3.2.8 NA Initiation trains (2) Automatic 1,2,3,4 2 trains C SR 3.3.22 NA Actuation SR 3.3.2.4' Logic and SR 3.3.2.6, Actuation Relays (3) Contain- 1,2,3 (4 j E SR ment SR Pressure SR SR F

lA-6 INSERT 2 Notes (e) & (f) WOG STS 3.3.2- 10 Rev. 2, 04/30/01 12

I Rev. 2 Change A-6 I ESFAS Instrumentation 3.3.2 6 UNIT 2 Table 3.3.2-1 (page 4 of 8) ALLOWABLE Engineered Safet 'uem re Actuation Instrume VALUE cure Actutio APPLICABLE MODES I OR OTHER SPECiFIED REQUI RED SURVEILLANCE ALLOWABLE: FUNCTION CONDITIONS CHANI 4ELS CONDITIONS REQUIREMENTS VALUE

4. Steam Line l(Only applicable to Unit 2) 9+ per tr-n 2 trains!

Isolation '

a. Manual >/1,2 >3( 2 F SR 3 ..3.2 S NA Iniiation t

b. Automatic 1,2 ,3- 2 tral ins G SR 3.3.2.2 NA NA Actuation Logic SR 3.3.2.e'_ ____

and Actuation SR . .2.6 . 733 Relays

c. Containment 1, 2 (hr. { D SR 3.3.21 s A-6 Pressure SR 332 .(e(f psig 13 SR 3.332 Intermediate - High-High SR 33.2.

L 2494 psig with time L...J . constant 2I Ž50 secs.

d. Steam Une FC and t2 S 5 secr.

Pressure (1) Low 1, 2 (a) N 3 per sllearn D SR 3.3.2.1 8 . . 3 line e ~~~~SR 3 3.2., r ,: SR 3.33.2 495.8 psig with lime constznt. Ž2 SR 3 4 50 secs. and T2 5 sess (2) Negative 3t 3 per sl ileamn D SR 3.3.2 .1- . M - Rate - High line e ~~SR 3.3.2. 1 / ; K SR 3.3.2.r0 0--t_6 / _W I 103.6 psi with a time (a) Above the P-11 (Pressurizer Pressure) Interlock. s 104.2 psi with a time constant 2 5D secs rconstant 2q50o-snstant sers.. (TC.) I w. FA9 zcnRIA ured in l11 l2ad- cnlz . r- t- 2{50}erdcaj ars K-5 oondG

    'j          Below the P-1 1 (Pressurizer Pressure) interlock.-                                           when Si on steam line pressure low is blockff (9)

F~b)] Timo utilized in the Nontlane ~ 15) rate1ag Gon)roler is 6\ xExc epl when an MSIVs are dosed and~de-activaled3. )3 A-6

                             \l                   INSERT 2 l       Notes (e) &(f WOG STS                                                             3.3.2- 11                                                     Rev. 2, 04/30/01 13

Rev. 2 Change A-5 (Unit 2) & A-8 (Unit 1) l ESFAS Instrumentation I J _3.3.2

5. Turbine Trip and Feedwater (d)

Isolation

a. Automatic Actuation Logic

1. 2 ",43 I 2 trains JIIGJ and Actuation Relays

b. SG Water Level 1,2 '.43] [31 per SG 4D]

     - High High (P-1 4)

c. Safety Injection Refer to Function 1 (Safety Injection)

6. Auxiliary Feedwater

a. Automatic 1.2,3 2 trains G SR 3.3.2.2 NA Actuation Logic SR 3.3.2.

and Actuation SR 3.3.2.6 Relays (SoW Syletm) 2 trains G SR 3.3.2.3 1 . A A-5 WOG STS 3.3.2- 13 Rev. 2, 04/30/01 A-8 15

I Rev. 2 Change A-5 & A-6 I ESFAS Instrumentation 3.3.2 WOG STS 3.3.2 -14 Rev. 2, 04/30/01 16

Rev. 2 Changes A-5, A-6, & A-8 The Notes were added by Change A-5. Changes A-6 &A-8 reference the Notes added by A-5 INSERTS FOR ITS 3.3.2. ESFAS INSERT 1 - SR 3.3.2.6 Frequency Note 92 days OR Note PiMAIJ i provided a satisfactory contact loading analysis has been completed, and a satisfactory slave relay service life has been established, for the slave relay being tested. 12 Months AND Note Only applicable to UnitI 18 Months INSERT 2 - Table 3.3.2-1 Notes (e) & (f) (e) If the as-found channel setpoint is conservative with respect to the Allowable Value but outside its predefined as-found acceptance criteria band, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service. If the as-found instrument channel setpoint is not conservative with respect to the Allowable Value, the channel shall be declared A-5 inoperable. A-X A-8 (f) The instrument channel setpoint shall be reset to a value that is within the as-left tolerance of the Nominal Trip Setpoint, or a value that is more conservative than the Nominal Trip Setpoint; otherwise, the channel shall be declared inoperable. The Nominal Trip Setpoint and the methodology used to determine the Nominal Trip Setpoint, the predefined as-found acceptance criteria band, and the as-left setpoint tolerance band are specified in a document incorporated by reference into the Updated Final Safety Analysis Report. 18

l Rev. 2 Change A-5 I ESFAS Instrumentation B 3.3.2 k4Wy B 3.3 INSTRUMENTATION B 3.3.2 Engineered Safety Feature Actuation System (ESFAS) Instrumentation BASES 0 BACKGROUND The ESFAS initiates necessary safety systems, based on the values of selected unit parameters, to protect against violating core design limits and the Reactor Coolant System (RCS) pressure boundary, and to mitigate accidents.\ I The ESFAS instrumentation is segmented into three distinct but interconnected modules as identified below.

Field transmitters or process sensors and instrumentation: provide a measurable electronic signal based on the physical characteristics of the parameter being measured,
Signal processing equipment including analog protection system, field contacts, and protection channel sets: provide signal conditioning, bistable setpoint comparison, process algorithm actuation, compatible!

electrical signal output to protection system devices, and control board/control room/miscellaneous indications, and

Solid State Protection System (SSPS) including input, logic, and output bays: initiates the proper unit shutdown or engineered safety 2 feature (ESF) actuation in accordance with the defined logic and based on the bistable outputs from the signal process control and protection system.

lowable Value in conjunction with the trip setpoint and LCO estabi the threshold for ESFAS action to prevent exceed acceptable Iitsuch that the consequences of Design s Accidents (DBAs) will be acc le. The Allowable Value i nsidered a limiting value such that a channe OPERABLE if t epoint is found not to exceed the Allowable Value du th ANNEL OPERATIONAL TEST (COT). Note that, although a che "OPERABLE" under these circumstances, the ESFA point must b adjusted to within the established calibrati olerance band of the ES setpoint in accordance wi e uncertainty assumptions stated in referenced setpoinltlodology, (as-left criteria) and confirmed to be o ting wiThe statistical allowances of the uncertainty terms assigned. WOG STS B 3.3.2 - 1 Rev. 2, 04/30/01 27

ESFAS Instrumentation Rev. 2 Change A-5 B 3.3.2 BASES BACKGROUND (continued) _ provide the required reliability and redundancy. The circuit must be able to withstand both an input failure to the control system, which may then However, exceptions to the require the protection function actuation, and a single failure in the other requirement for four channels channels providing the protection function actuation. Again, a single are part of the design and failure will neither cause nor prevent the protection function actuation. licensing basis of the ESFAS le.g. steam generator level These requirements are described in IEEE-279-1971 (Ref. 4The aGtual instrumentation). number of cnnplh rir for each unit parameter is specifie kn ETechnical SpecificationI Table 3.3.2-1 .

                                .           i Allowab           alue nominal ESFAS Se           ints
                                                                                                             ,and LSSS and other trig devices 2

the BVPS Unit I and Unit 2 Th rip setpoints used in the bistables based on the analytical limits t etpoint methodology for sta-tedin. The selection of thes trip setpoints is such that protection systems (Ref. 3). adequate protection is provided when all sensor and processing time delays are taken into account. To allow for calibration telerances, Sar monrari uiirnertainties, mntrumemnamf, a.- 6cvo environmnen [ INSERT I I nrrnrr. *rr *h,-.pn L.I.L. fl CS r.h.nnale. VflTIflflflWWfl tI,.,* rn,,p* t.,nt*,rn in

                                                                                                                       . e     9 Insert pagesfollowthe            enRViFonment6 as defineci by 1i0 CFR 50.41 (Ref. 5), the Allowable Value- .nominal                                      trip Bases pages.                s~u lpecified in Table 3.3._1Iin the accompanying ILCOare nmnrP,;5efW-telii B      p                   repoct to the analytica H4imt6 A detailed description of                                   ethodology used to calculate the Allowable Values and ESFeA9tpoints including -t Refrence their explicit uncertainties, is provided in the plant specific setpoin methodology 6tudy (Ref. 6) which incorporates all of the known                                    I_._.__

uncertainties applicable to each channel. The magnitudes of thes nnal ipI uncertainties are factored into the determination of each point and corresponding Allowable Value. The netoint ipdevice l entered into the i-is more conservative than that specified by the Y Allowable Value to account for measurement errors detectable by the "K<iD COT. The Allowable Value serves as the Technical Specification OPERABILITY limit foF the purpoce of the COT. One example of such a change in measurement error is drift during the surveillance interval. If INSERT he measured setpoint ot exceed the Allowable Value, the r--ble I I is considered OPE E dvcs[ el / i l

                                              ;;; SFAS-setpoiare the values at which the                                         are set Eod the expected valu                     be achieved during calibration. The EFAS lo be within the trip device with a              .&setpoint value ensures the safety analysis limits are met for the                                    ccalibration tolerance.

nominal trip setpoint i rvpillqnrp intprygl opleted when a channel is adjusted bared m6R s-tat L channel uncertainties. Anyltl eis considered to be properly adjusted when the "as-left" setpoint value is within the band for GHAIE r o CALIBRATION uncertan'ty allowance (i.e., calibration tolerance toleran. j1 ---- I WOG STS B 3.3.2 - 3 Rev. 2, 04/30/01 29

ESFAS Instrumentation Rev. 2 Change A-5 B 3.3.2 BASES BACKGROUND (continued)

"nominal value" (i.e., expressed as a value without inequalities) for the purpesr of the COT and CHANNEL CALIBRATION. excpt for Operable ESFAS SItpointc adjusted consistent with the requirements of the Allowable manual Functions with _!ensure that the consequences of Design Basis Accidents (DBAs) channels setpoints maintained will be acceptable, providing the unit is operated from within the LCOs at andthe trip withi theAlloableof all main Values specified in the the onset of the DBA and the equipment functions as designed. feedwater Techicalpump Specifications Each channel can be tested on lineto verify that the signal processing channels, equipment and setpoint accuracy is within the specified allowance requirements of Reference . Once a designated channel is taken out of 3H i service for testing, a simulated signal is injected in place of the field instrument signal. The process equipment for the channel in test is then 3 tested, verified, and calibrated. SRs for the channels are specified in the IN SR section. inputs from field contacts, control board INSERTl K S-olid State Protection System switches and sItce n The SSPS equipment is used for the decision logic processing o 2 mi the signal processing equipment bistables. To meet the redundancy requirements, two trains of SSPS, each performing the same functions, are provided. If one train is taken out of service for maintenance or test purposes, the second train will provide ESF actuation for the unit. If both trains are taken out of service or placed in test, a reactor trip will result.

Each train is packaged in its own cabinet for physical and electrical separation to satisfy separation and independence requirements. The SSPS performs the decision logic for most ESF equipment actuation; generates the electrical output signals that initiate the required actuation; nput signals from field and provides the status, permissive, and annunciator output signals to the ccontacts, control board control room of the unit. switches and Th bistable outputs from the signal processing equipment are sensed by the SSPS equipment and combined into logic matrices that represent combinations indicative of various transients. If a required logic matrix combination is completed, the system will send actuation signals via master and slave relays to those components whose aggregate Function best serves to alleviate the condition and restore the unit to a safe condition. Examples are given in the Applicable Safety Analyses, LCO, and Applicability sections of this Bases. Each SSPS train has a built in testing device that can automatically test the1 ecision logic matrix functions an the actuatio, es while the l se e l partially test relay WOG STS B 3.3.2 - 4 Rev. 2, 04/30/01 30

ESFAS Instrumentation I B 3.3.:2 I Rev. 2 Change A-5 BASES SAFETY ANALYSES, LCO, and APPLICABILITY (continued) provided that the i The LCO requires all instrumentation performing an ESFAS Function to calibration tolerance band be OPERABLE. A channel is OPERABLE with-a tuip Setpeinvaluet remains the same and the outside its aleibRAto tgIAFiGehand provided the trip setpoint "as-found" Allowable Value is administratively controlled accordingly in the value does not exceed its associated Allowable Value and provided the trip setpoint "as-left' value is adjusted to a value within the calibration ElD conservative direction to tolerance band of the nominal trip setpoint. A trip setpoint may etet L_ meet the assumptions of the more conservative than the nominal trip setpoint as neces in setpoint methodology. The conservative direction is response to plant conditionsŽtoailure of any instrumenttenders the established by the direction affected channel(s) inoperable and reduces the reliability of the affected of the inequality applied to Functions. the Allowable Value. ___ /he LCO generally requires OPERABILITY of four or three channels in each instrumentation function and two channels in each logic and manual INSERT 8 linitiation function. The two-out-of-three and the two-out-of-four configurations allow one channel to be tripped during maintenance or testing without causing an ESFAS initiation. Two logic or manual initiation channels are required to ensure no single random failure disables the ESFAS. The required channels of ESFAS instrumentation provide unit protection in the event of any of the analyzed accidents. ESFAS protection functions are as follows:

1. Safety Iniection KYin Safety Injection (SI) provides two primary functions:

1. Primary side water addition to ensure maintenance or recovery of reactor vessel water level (coverage of the active fuel for heat removal, clad integrity, and for limiting peak clad temperature to

22001F), and

2. Boration to ensure recovery and maintenance of SDM (kff

                                                   < 1.0).

These functions are necessary to mitigate the effects of high energy line breaks (HELBs) both inside and outside of containment. The SI signal is also used to initiate other Functions such as: a Phase A Isolation, a s ntoi n ~ M.-, lo rbulelilun, bunlairlriluril r urge Icoloti^n WOG STS B 3.3.2 - 6 Rev. 2, 04/30/01 32

Rev. 2 Change D-17 ESFAS Instrumentation B 3.3.2 BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)

Reactor Trip,
Turbine Trip, a Feedwater Isolation,
Start of motor driven auxiliary feedwater (AFW) pumps,
Control room Ventiltion isolation, and
Enabling automatic switchover of Emergency Core Cooling Systems (ECCS) suction to containment sump.

These other functions ensure: Isolation of nonessential systems through containment penetrations,

Trip of the turbine and reactor to limit power generation,
Isolation of main feedwater (MFW) to limit secondary side mass losses,
Start of AFW to ensure secondary side cooling capability,

---

isolationOfthe-GGeFGI FeerntoeflGMe habitabilitv:-and

                     \\/                      Enabling ECCS suction from the refueling water storage tank and extreme low (Unit 2)          (RWST) switchover on lolew RWST level to ensure continued (tcooling via use of the containment sump.

except for the Unit 1 automatic high Safety Iniection - Manual Initiation head safety injection (HHSI) flow path isolation valves when LCO The LCO requires one channel per train to be OPERABLE. The 3.4.12, "Overpressure Protection operator can initiate SI at any time by using either of two I System," is applicable. Consistent l switches in the control room. This action will cause actuation of with the requirements of LCO all components in the same manner as any of the automatic 3.4.12, in MODE 4 when any RCS cold leg temperature is s the enable actuation signalsv temperature specified in the PTLR, the Unit 1 automatic HHSI flow path The LCO for the Manual Initiation Function ensures the proper must be isolated with power amount of redundancy is maintained in the manual ESFAS removed from the isolation valves. actuation circuitry to ensure the operator has manual ESFAS Therefore, when operating in the initiation capability. MODE 4 Applicability of LCO 3.4.12, the manual initiation of Unit 1 SI will require additional manual valve operation to establish an St injection flow path. WOG STS B 3.3.2 - 7 Rev. 2, 04/30/01 33

ESFAS Instrumentation I Rev. 2 Change D-1 I B 3.3.2 BASES severe environmentlin containift. reflects only steady state instrument

c. Turbine Trip and Feedwater Isolation - Safety Iniection Turbine Trip and Feedwater Isolation is also initiated by all Functions that initiate Si. The Feedwater Isolation Function 3 requirements for these Functions are the same as the requirements for their Si function. Therefore, the requirements are not repeated in Table 3.3.2-1. Instead, Function 1, SI, is except when all Main referenced for all initiating functions and requirements.

Feedwater Lines are isolated by either closed and deactivated MFIVs, or Turbine Trip and Feedwater Isolation Functions must be OPERABLE: MFRVs and associated in MODES 1 an4.2 land 31 except when all MFIVs, MFRV,[d bypass valves, or closed a-;ssorn6ciatd bynass vilvc1 sm rlosed nd [do mctiwitndl Fr isolted manual valves. In these h., -, A^-el u-. -l .. hp *ke INAMAI Q,-#*,m ;g o, -rpf;^- -1 Modes the MFW system I and turbine generator may tht n eneato may be in operation. In MODES [3A, 4, 5, be in service. and 6, the MFW System and the turbine generator are not in service and this Function is not required to be OPERABLE.

6. Auxiliary Feedwater The AFW System is designed to provide a secondary side heat sink Primary Plant Demineralized for the reactor in the event that the MFW System is not available.

Water Storage Tank. The system has two motor driven pumps and a turbine driven pump, making it available during normal unit operation, during a loss of AC The River Water (Unit 1) and power, a loss of MFW, and during a Feedwater System pipe break. Eervice Water (Unit 2) The normal source of water for the AFW System is the Grndepsate c.ystems provides a backup source of water for the AFW a n CST will automatically reaIons 1 not safety related. to the Essential e I sysem.iL :e.ASstemerafet The AFW System is aligned so that upon a pump start, flow is initiated to the FeepeGtiVe Finction 1.b text SGs immediately.

                                    \a. Auxiliary Feedwater - Automatic Actuation Logic and Actuation elavs (Solid State Protection Scsteom
*rhis LCO requires two trains to be OPERABLE. Actuation                 Aliirzhactio                           and actuation re            D         h logic consists of all circuitry                            features ESFt     and                     isamemanner
                                                                                                -      as described forh housed within the actuation subsystems, including the initiating relay contacts responsible for actuating the l-SF equipment.

WOG STS B 3.3.2 - 28 Rev. 2, 04/30/01 54

ESFAS Instrumentation I Rev. 2 Change D-2 I B 3.3.2 BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued) ( .' Automatic Switchover to Containment Sump In Unit 1, the low head SI

\zf I

(LHSI) pumps and At the end of the injection phase of a LOCA, the RWST will be nearly containment recirculation I empty. Continued cooling must be provided by the ECCS to remove spray (RS) pumps draw water from the containment decay heat. The source of water for the ECCS pumps is sump. The RS pumps pump automatically switched to the containment recirculation sumpl They the water through the RS loadesit removal (RHR) pumps and Cogains~ray heat exchanger to the pumps draw the wat i~nei lto supth recirculation spray headers. RHR

                                            -       pumps  pump    the    f    i     n         g       e      r         injec The LHSI pumps circulate               the water b                     CS        suoRCS15and the water back to the reactor and provide suction to the             Dther-ECC pums. ISwitchover from the RWST to the containment High Head SI (HHSI)                   sump must occur before the RWST empties to prevent damage to pumps. In Unit 2, during the           the RHR pumps and a loss of core cooling capability. For similar recirculation phase, one RS pump per train provides the            reasons, switchover must not occur before there is sufficient water in low head injection function            the containment sump to support ESF pump suction. Furthermore, and suction to the HHSI                early switchover must not occur to ensure that sufficient borated pump and one RS pump per               water is injected from the RWST. This ensures the reactor remains train provides the recirculation spray function.          shut down in the recirculation mode.

Both the Unit 2 RS pumps on each train draw water a. Automatic Switchover to Containment Sump - Automatic from the containment sump Actuation Logic and Actuation Relays and pump water through an RS heat exchanger. atic actuation logic and actuation rela s I am L and opergia nfmn as descrie o ESF (Unit 1)and extreme low (Unit 2) ] b, c. Automatic Switchover to ContainmenfSump - Refueling Water

                                                /Storage Tank (RWST) Level - Low 06w Coincident With Safety Function 1.b text
                                                /     et        -Cn -~MIIAl -et- nPn ;--r                        e-Kl During the injection phase of a LOCA, the RWST is the source
                                    /1            of water for all ECCS pumps. A low              level in the RWST This LCo requires two trains to           coincident with an SI signal provides rotection against a loss of be OPERABLE: Actuation                   water for the ECCS pumps and indites the end of the injection logic consists of all circuitry           phase of the LOCA The RWST itequipped with four level housed within the actuation subsystems, including the                 transmitters. T e transmitters rovide no control functions.

initiating relay contacts Therefore, so-out-of-four logi is adequate to initiate the responsible for actuating the protectio unction actuation. Ithough only three channels ESF equipment. wou e sufficient, a fourth c annel has been added for due to the energize ieased reliability, to trip design of these

                                                                                           /                           channels.

The SI interlock is maintained The RWST -low w All able Value/Tip Setpaint has both by latching relays until reset manually. upper and lower limi e lower limit is selected to ensure (Unit 1)and extreme Ilow (Unit 2). WOG STS B 3.3.2 - 32 Rev. 2, 04/30/01 58

ESFAS Instrumentation Rev. 2 Change D-10 B 3.3.2 BASES ACTIONS (continued)

                                    . Less of Offeite Powe,

Auxiliary Feedwater Pump Suction Tranfeor on Suction Pressuro

                        \                Lew; and
                                    . P-4 Interlock.

For the Manual Initiation and the P-4 Interlock Functions, this action addresses the train orientation of the SSPS. For the Los6 of Offsite FLOWvd! Funcbtio, iflb acibHUN 1~7~f1E~ r g if ep m duF too manualf El tip VrowfbVNB for a failed channol. FEr the AFW System pump suction transfer channels, this action recognizes that placinra a failed channel in trip during; operation is not necossaril; a conseirvative action Spurius trip of this function could align the APN System to a source that is not immediately (10 capable of supporting pump suctien. If a train or channel is inoperable, 48 hours is allowed to return it to OPERABLE status. The specified Completion Time is reasonable considering the nature of these Functions, the available redundancy, and the low probability of an event occurring This Action Condition isintended during this interval. If the Function cannot be returned to OPERABLE to address an inoperability of the status, the unit must be placed in MODE 3 within the next 6 hours and actuation logic or relays MODE 4 within the following 6 hours. The allowed Completion Times are asscciated with an ESFAS train reasonable, based on operating experience, to reach the required unit that affects the integrated conditions from full power in an orderly manner and without challenging ESFAS response to an actuation sign 31.The relatively short unit systems. In MODE 4, the unit does not have any analyzed transients Completion Time of this ACTION or conditions that require the explicit use of the protection functions noted (6hours) isbased on the above. assumption that multiple ESF components within a train are G.1. G.2.1. and G.2.2 affected by the failure of the actuation logic or relays. Condition G applies to the automatic actuation logic and actuation relays Therefore, the short Completion Timo of this Action is appropriate for the Steam Line Isolation [,Turbine Trip and Feedwater lsolationAand and applicable whenever more AFW actuation Functions. than one ESF system isaffected l by the inoperable train of logic or The action addresses the train orientation of the SSPS and the master relays. and slave relays for these functions. If one train is inoperable, 6 hours However, If one or more are allowed to restore the train to OPERABLE status. The Completion anoeSFAS train only affect a Time for restoring a train to OPERABLE status is reasonable considering single ESF component or that there is another train OPERABLE, and the low probability of an event system, the applicable occurring during this interval. If the train cannot be returned to Actions Condition for the OPERABLE status, the unit must be brought to MODE 3 within the next affe:ted ESF component or 6 hours and MODE 4 within the following 6 hours. The allowed system should be entered and the relatively short Completion Times are reasonable, based on operating experience, to Completion Time of this reach the required unit conditions from full power conditions in an orderly Action Condition isnot app opriate or applicable. WOG STS B 3.3.2 - 42 Rev. 2, 04/30/01 68

ESFAS Instrumentation I Rev. 2 Change D-9 I B 3.3.2 BASES SURVEILLANCE REQUIREMENTS (continued) similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the two instrument channels could be an indication of excessive instrument drift in one of the channels or of something even more serious. A CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION. Ireadability Agreement criteria are determined by the unit staff, based on a combination of the channel instrument uncertainties, including indication an b. If a channel is outside the criteria, it may be an indication that the sensor or the signal processing equipment has drifted outside its limit. The Frequency is based on operating experience that demonstrates channel failure is rare. The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of the displays associated with the LCO required channels. SR 3.3.2.2 SR 3.3.2.2 is the performance of an ACTUATION LOGIC TEST. The SSPS is tested every 31 days on a STAGGERED TEST BASIS, using the semiautomatic tester. The train being tested is placed in the bypass condition, thus preventing inadvertent actuation. Through the semiautomatic tester, all possible logic combinations, with and without applicable permissives, are tested for each protection function. In addition, the master relay coil is pulse tested for continuity. This verifies that the logic modules are OPERABLE and that there is an intact voltage signal path to the master relay coils. The Frequency of every 31 days on a STAGGERED TEST BASIS is adequate. It is based on industry operating experience, considering instrument reliability and operating 3 history data. 3 N/A to BVPS l SR 3.3.2.3 is the nce of an ACTUATION L EST as described in SR 3.3.2.2, ex hat th ester is not used and the continuity check does not be performed, as explained in the Note. This SR is ap the balance nt actuation logic and relays that do no ehe SSPS test circuits install ize the tester or perform the continuity check. This te WOG STS B 3.3.2 - 47 Rev. 2, 04/30/01 73

ESFAS Instrumentation I Rev. 2 Change A-5 B 3.3.2 BASES SURVEILLANCE REQUIREMENTS (continued) p =rs on a STAGGERE 3 Frequency is adequate b rating experience, riity and operating SR 3.3.27[ SR 3.3.2. the performance of a MASTER RELAY TEST. The MASTER RELAY TEST is the energizing of the master relay, verifying contact operation and a low voltage continuity check of the slave relay coil. Upon master relay contact operation, a low voltage is injected to the slave relay coil. This voltage is insufficient to pick up the slave relay, but large enough to demonstrate signal path continuity. This test is performed every 31 days on a STAGGERED TEST BASIS. The time allowed for the testing (4 hours) and the surveillance interval are justified in Reference _ (excluding time constants which are verified SR 3.3.2 C [ during CHANNEL CALIBRATIONS). SR 3.3.2.fis the performance of a COT.Surveillance Requirer A COT is performed on each required channel to ns e entire an ~channel will perform the intended Function. Set s must be found ithin the Allowable Values specified in Table . .2- A successful test o required contact(s) of a channel rel may be performed by the verification of the change of state of ngle contact of the relay. This ,4 W, clarifies what is an acceptable C of a relay. This is acceptable because all of the other requi contacts of the relay are verified by other Technical Specifications am non Technical Specifications tests at least onRG per rofueling inter a! with applicable extencione. The difference between the current "as found" values and the previous test "as left" values must be consistent with the drift allowance used in the setpoint methodology. The setpoint shall be left set consistent with the assumptions of the current unit specific setpoint methodology. ThW~a-s WfounT a " ues must aa for consistency w o o iterval extension The Frequency of 92 days is justified in Reference I WOG STS B 3.3.2 - 48 Rev. 2, 04/30/01 74

ESFAS Instrumentation B 3.3.2 I Rev. 2 Change A-5 I BASES SURVEILLANCE REQUIREMENTS (continued) Surveillance Requirements. 6 the relay. This clarifies what is an acceptab TADOT of a relay. This is acceptable because all of the other require contacts of the relay are verified by other Technical Specifications nd-Technical Specifications tects at least once per refueling interval with applicable extensions. In some instances, the test includes actuation of the end device (i.e., pump starts, valve cycles, etc.). The Frequency is adequate, based on industry operating experience and is consistent with the typical refueling cycle. The SR is modified by a Note that excludes verification of setpoints during the TADOT ma initiatien Functions have no associated setpoints. SR 3.3.2 84 SR 3.3.2. is the performance of a CHANNEL CALIBRATION. A CHANNEL CALIBRATION is performed every418] months, or approximately at every refueling. CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to measured parameter within the necessary range and accuracy. CHANNEL CALIBRATIONS must be performed consistent with the 2 assumptions of the unit specific setpoint methodology. The difference between the current "as found" values and the previous test "as left" values must be consistent with the drift allowance used in the setpoint methodology. I The Frequency of f181 months is based on the assumption of an f181 month calibration interval in the determination of the magnitude of equipment drift in the setpoint methodology. This SR is modified by a Note stating that this test should include verification that the time constants are adjusted to the prescribed values where applicable. wr 3.3.appliable SR Licensing Requirements Manual

2. 4 O' -F 3 This SR ensures the individual channel ESF RESPONSE TIME are less than or equal to the maximum values assumed in the accident Analysis.

Response Time testing acceptance criteria are included in the Requirements Manual, Soction 15 (Ref. 9). Individual component response times are not modeled in the analyses. The analyses model the overall or total elapsed time, from the point at which the parameter WOG STS B 3.3.2 - 50 Rev. 2, 04/30/01 76

I Rev. 2 Change A-5 I 3.3.2 BASES INSERTS

1. The nominal trip setpoints account for calibration tolerances, instrument uncertainties, instrument drift, and severe environment errors for those ESFAS channels that must function in harsh environments as defined by 10 CFR 50.49 (Ref. 4). The nominal trip setpoints are specified in the Licensing Requirements Manual (LRM). The Allowable Values specified in the Technical Specifications are determined by adding (or subtracting) the calibration accuracy of the trip device to the nominal trip setpoint in the non-conservative direction (i.e., toward or closer to the safety analysis limit) for the application. The Allowable Values remain conservative with respect to the analytical limits. For those channels that provide trip actuation via a bistable in the process racks, the calibration accuracy is defined by the rack calibration accuracy term. For a limited number of channels that provide trip actuation without being processed via the process racks (e.g., undervoltage relay channels) the Allowable Value is defined by device drift or repeatability (Ref. 3). The application of the calibration accuracy term (or device drift as applicable) to each ESFAS setpoint results in a "calibration tolerance band" for each setpoint. Thus, the trip setpoint value is considered a "nominal" value (i.e., expressed as a value with a calibration tolerance) for the purposes of the COT and CHANNEL CALIBRATION. The calibration tolerance band for each ESFAS setpoint is specified in plant procedures.

2. This is achieved by specifying limiting safety system settings (LSSS) in terms of parameters directly monitored by the ESFAS as well as specifying LCOs on other system parameters and equipment performance.

Technical Specifications are required by 10 CFR 50.36 to contain LSSS defined by the regulation as "...settings for automatic protective devices...so chosen that automatic protective action will correct the abnormal situation before a Safety Limit (SL) is exceeded." The Analytical Limit is the limit of the process variable at which a safety action is initiated, as established by the safety analysis, to ensure that a SL is not exceeded. Any automatic protection action that occurs when reaching the Analytical Limit therefore ensures that the SL is not exceeded. However, in practice, the actual settings for automatic protective devices must be chosen to be more conservative than the Analytical Limit to account for instrument loop uncertainties related to the setting at which the automatic protective action may actually occur. The nominal trip setpoint is a predetermined setting for a protective device chosen to ensure automatic actuation prior to the process variable reaching the Analytical Limit and thus ensuring that the SL would not be exceeded. Technical Specifications contain values related to the OPERABILITY of equipment required for safe operation of the facility. OPERABLE is defined in Technical Specifications as

  "...being capable of performing its safety functions(s)." For each automatic protective device there is a setting beyond which the device would not be able to perform its function due, for example, to greater than expected drift. The value of this setting is specified in the Technical Specifications in order to define OPERABILITY of the devices and is designated 80

Rev. 2 Change A-5 3.3.2 BASES INSERTS (Insert 2 continued) as the Allowable Value. The Allowable Value specified in Table 3.3.2-1 serves as the OPERABILITY limit such that a channel is OPERABLE if the trip setpoint is found not to exceed the Allowable Value. Note that, although the channel is "OPERABLE" under these circumstances, the trip setpoint should be left adjusted to a value within the established trip setpoint calibration tolerance band, in accordance with the assumptions stated in the BVPS Unit 1 and Unit 2 setpoint methodology for protection systems (Ref. 3). If the actual setting of the device is found to have exceeded the Allowable Value the device would be considered inoperable from a Technical Specification perspective. This requires corrective action including those actions required by 10 CFR 50.36 when automatic protective devices do not function as required. In addition to the channel OPERABILITY guidance discussed above, the CHANNEL OPERATIONAL TEST (COT) and CHANNEL CALIBRATION Surveillance Requirements (SRs) specified on Table 3.3.2-1 for certain ESFAS Functions are modified by Notes (e) and (f) that specify additional Technical Specification requirements. The applicable Notes are specified directly on Table 3.3.2-1 next to the numerical SR designations for the affected ESFAS Functions. The additional Technical Specification requirements for these ESFA'; Functions include OPERABILITY evaluations for setpoints found outside the as-found acceptance criteria band and the requirement to reset the setpoint to within the as-left tolerance of the nominal trip setpoint or a value that is more conservative than the nominal trip setpoint or declare the affected channel inoperable. These additional Technical Specification requirements are only applicable to the ESFAS Functions with the Notes modifying their COT and CHANNEL CALIBRATION SR numbers on Table 3.3.2-1.

3. As discussed earlier, for certain ESFAS Functions, the COT and CHANNEL CALIBRATION SR numbers specified on Table 3.3.2-1 are modified by Notes that impose additional Technical Specification requirements for channel OPERABILITY.

4. The Nominal Trip Setpoint is based on the calculated total loop uncertainty per the plant specific methodology documented in the Licensing Requirements Manual. The setpoint methodology, used to derive the Nominal Trip Setpoints, is based upon combining all of the uncertainties in the channels. Inherent in the determination of the Nominal Trip Setpoinis are the magnitudes of these channel uncertainties. Sensors and other instrumentation utilized in these channels should be capable of operating within the allowances of these uncertainty magnitudes. Occasional drift in excess of the allowance may be determined to be acceptable based on the other device performance characteristics. Device drift in excess of the allowance that is more than occasional, may be indicative of more serious problems and would warrant further investigation.

80A

I Rev.' 2 Change A-5 l 3.3.2 BASES INSERTS

5. For most ESFAS Functions the Allowable Value specified on Table 3.3.2-1 is the LSSS required by 10 CFR 50.36. However, for certain ESFAS Functions, the COT and CHANNEL CALIBRATION SR numbers specified on Table 3.3.2-1 are modified by Notes (e) and (f) that impose additional Technical Specification Requirements for channel OPERABILITY and change the LSSS for the affected Functions. For each ESFAS Function in Table 3.3.2-1 with Notes modifying the required COT and CHANNEL CALIBRATION SR numbers, the nominal trip setpoint specified in the Licensing Requirements Manual is the LSSS.

This definition of the LSSS is consistent with the guidance issued to the industry through correspondence with NEI (Reference NRC-NEI Letter dated September 7, 2005). The definition of LSSS values continues to be discussed between the industry and the NRC, and further modifications to these TS Bases will be implemented as guidance is provided. Table 3.3.2-1 Notes (e) and (f are applicable to the COT and CHANNEL CALIBRATION SRs for specific instrument functions since changes to Allowable Values associated with these instrument functions were already under review by the NRC at the time the revisei NRC setpoint criteria were documented and made available to the industry in an NRC letter to the Nuclear Energy Institute. Changes to the remaining instrument functions may be pursued after guidance endorsed by both the NRC and NEI is issued.

6. For certain ESFAS Functions the required COT (SR 3.3.2.4 specified in Table 3.3.2-1) is modified by Notes (e) and (0. These Notes specify additional requirements for the affected instrument channels.

Note (e) specifies the following:

If the as-found channel setpoint is conservative with respect to the Allowable Value but outside its predefined as-found acceptance criteria band, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service, and
If the 'as-found' instrument channel setpoint is not conservative with respect to the Allowable Value, the channel shall be declared inoperable.

The evaluation of channel performance required by Note (e) involves an assessment to verify the channel will continue to behave in accordance with design basis assumptions, and to ensure confidence in the channel performance prior to returning the channel to service. In addition, if the 'as found" trip setpoint value is non-conservative with respect to the Allowable Value, or is found to be outside of the two sided predefined acceptance criteria band on either side of the nominal trip setpoint, the affected channel will be evaluated under the corrective action program. Note (e) specifies the following: 80B

I Rev. 2 Change A-5 3.3.2 BASES INSERTS (Insert 6 continued)

The instrument channel setpoint shall be reset to a value that is within the as-left tolerance of the nominal trip setpoint, or a value that is more conservative than the nominal trip setpoint; otherwise, the channel shall be declared inoperable, and
The nominal trip setpoint and the methodology used to determine the nominal trip setpoint, the predefined as-found acceptance criteria band, and the as-left setpoint tolerance band are specified in a document incorporated by reference into the Updated Final Safety Analysis Report.

For BVPS, the document containing the nominal trip setpoint, the methodology used to determine the nominal trip setpoint, the predefined as-found acceptance criteria band, and the as-left setpoint tolerance band is the LRM. For the ESFAS Functions with a COT modified by Note (f), the Note requires that the instrument channel setpoint be reset to a value within the 'as left" setpoint tolerance band on either side of the nominal trip setpoint or to a value that is more conservative than the nominal trip setpoint. The conservative direction is established by the direction of the inequality sign applied to the associated Allowable Value. Setpoint restoration and post-test verification assure that the assumptions in the plant setpoint methodology are satisfied in order to protect the safety analysis limits. If the channel can not be reset to a value within the required 'as left" setpoint tolerance band on either side of the nominal trip setpoint, or to a value that is more conservative than the nominal trip setpoint (if required based on plant conditions) the channel is declared inoperable and the applicable ACTION is entered. For the ESFAS Functions with a COT modified by Notes (e) and (e, the 'as found" and 'as left" setpoint data obtained during COTs or CHANNEL CALIBRATIONS are programmatically trended to demonstrate that the rack drift assumptions used in the plant setpoint methodology are valid. If the trending evaluation determines that a channel is performing inconsistent with the uncertainty allowances applicable to the periodic surveillance test being performed, the channel is evaluated under the corrective action program. If the channel is not capable of performing its specified safety function, it is declared inoperable.

7. For certain ESFAS Functions the required CHANNEL CALIBRATION (SR 3.3.2.8 specified in Table 3.3.2-1) is modified by Notes (e) and (f). These Notes specify additional requirements for the affected instwument channels.

Note (e) specifies the following: If the as-found channel setpoint is conservative with respect to the Allowable Value but outside its predefined as-found acceptance criteria band, then the channel shall be evaluated to verify that it is functioning as required before retuming the channel to service, and 80C

Rev. 2 Change A-5 3.3.2 BASES INSERTS (Insert 7 continued) If the 'as-found" instrument channel setpoint is not conservative with respect to the Allowable Value, the channel shall be declared inoperable. The evaluation of channel performance required by Note (e) involves an assessment to verify the channel will continue to behave in accordance with design basis assumptions, and to ensure confidence in the channel performance prior to returning the channel to service. In addition, if the 'as found" trip setpoint value is non-conservative with respect to the Allowable Value, or is found to be outside of the two sided predefined acceptance criteria band on either side of the nominal trip setpoint, the affected channel will be evaluated under the corrective action program. Note (f specifies the following:

The instrument channel setpoint shall be reset to a value that is within the as-left tolerance of the nominal trip setpoint, or a value that is more conservative than the nominal trip setpoint; otherwise, the channel shall be declared inoperable, and
The nominal trip setpoint and the methodology used to determine the nominal trip setpoint, the predefined as-found acceptance criteria band, and the as-left setpoint tolerance band are specified in a document incorporated by reference into the Updated Final Safety Analysis Report.

For BVPS, the document containing the nominal trip setpoint, the methodology used to determine the nominal trip setpoint, the predefined as-found acceptance criteria band, and the as-left setpoint tolerance band is the LRM. For the ESFAS Functions with a CHANNEL CALIBRATION modified by Note (f, the Note requires that the instrument channel setpoint be reset to a value within the "as left" setpoint tolerance band on either side of the nominal trip setpoint or to a value that is more conservative than the nominal trip setpoint. The conservative direction is established by the direction of the inequality sign applied to the associated Allowable Value. Setpoint restoration and post-test verification assure that the assumptions in the plant setpoint methodology are satisfied in order to protect the safety analysis limits. If the channel cal not be reset to a value within the required 'as left" setpoint tolerance band on either side of the nominal trip setpoint, or to a value that is more conservative than the nominal trip setpoint (if required based on plant conditions) the channel is declared inoperable and the applicable ACTION is entered. For the ESFAS Functions with a CHANNEL CALIBRATION modified by Notes (e) and (I), the 'as found" and 'as left' setpoint data obtained during COTs or CHANNEL CALIBRATIONS are programmatically trended to demonstrate that the rack drift assumptions used in the plant setpoint methodology are valid. If the trending evaluation determines that a channel is performing inconsistent with the uncertainty allowances applicable to the periodic surveillance test being performed, the channel is evaluated under 80D

I Rev. 2 Change A-5 3.3.2 BASES INSERTS (insert 7 continued) the corrective action program. If the channel is not capable of performing its specified safety function, it is declared inoperable.

8. In addition to the channel OPERABILITY guidance discussed above, the CHANNEL OPERATIONAL TEST (COT) and CHANNEL CALIBRATION Surveillance Requirements (SRs) specified on Table 3.3.2-1 for certain ESFAS Functions are modified by Notes (e) and (f) that specify additional Technical Specification requirements. The applicable Notes are specified directly on Table 3.3.2-1 next to the numerical SR designations for the affected RTS Functions. The additional Technical Specification requirements for these ESFAS Functions include OPERABILITY evaluations for setpoints found outside the as-found acceptance criteria band and the requirement to reset the setpoint to within the as-left tolerance of the nominal trip setpoint or a value that is more conservative than the nominal trip setpoint or declare the affected channel inoperable. These additional Technical Specification requirements are only applicable to the ESFAS Functions with the Notes modifying their COT and CHANNEL CALIBRATION SR numbers on Table 3.3.2-1.

80E

I Rev. 2 Change A-5 & D-9 I

                                                        '                           BVPS ISTS Conversion 3.3C ESFAS Instrumentation Enclosure 2 Changes to The ISTS Bases ITS 3.3.2 Engineered Safety Feature Actuation System Instrumentation Bases JUSTIFICATION FOR DEVIATION (JFD)

1. This JFD addresses all changes made to the Bases that are editorial in nature or to correct l r minor typographical errors that do not affect the technical content of the Bases. The changes addressed by this JFD are made to correct spelling, grammar, and capitalization errors as well as incorporate wording preferences. In some cases, these changes are necessary to make the descriptions of reference content correct (e.g., the content of the BVPS UFSARs may not be exactly the same as described in the ISTS Bases) or to make the actual location of information discussed correct for BVPS (e.g., the location of trip setpoints outside of the TS or the location of the list of the number of required channels for each ESFAS Function). The reasons for the changes addressed by this JFD are considered self-explanatory and a separate more detailed explanation unnecessary. These changes do not significantly impact the technical discussions contained in the Bases and in general improve the clarity or correctness of the affected text or make the text more specific to BVPS. As such, the proposed changes are acceptable.

2. Changes are made to the ISTS Bases to reflect the BVPS specific setpoint methodology and changes introduced by Amendment numbers 270 Unit 1 and 152 (Unit 2). These Amendments introduced Notes to the COT and Channel Calibration SRs that affect the definition of the LSSS for certain ESFAS Functions. The BVPS trip setpoints associated with the ESFAS Functions are nominal values with a calibration tolerance. The nominal trip setpoints are specified inthe Licensing Requirements -5 Manual not the TS. The BVPS Allowable Value is determined by the nominal trip setpoint calibration tolerance. The BVPS ESFAS Function operability is determined by verifying the Function is within the specified Allowable Value (setpoint calibration tolerance). The changes associated with this JFD are required to maintain consistency with the current BVPS setpoint methodology and the current BVPS licensing basis as modified by Amendment numbers 270 and 152.

3. The standard bases text is deleted or revised to make the generic bases discussion more accurate or complete for BVPS. The proposed revisions include changes resulting from revisions to the corresponding TS requirements that are justified in the associated JFDs for the TS. The proposed changes also include additional or revised references, additional or revised design or safety analysis descriptions that make the standard bases discussion more specific to the corresponding BVPS documentation, design, safety analyses, or licensing basis. In some cases, additional information is added that was moved from the CTS or that is consistent with the existing CTS Bases. The proposed changes enhance the ISTS Bases discussion and help to make the generic bases text more specific to each BVPS Unit.

4. The ISTS Bases text is revised to remove the details of specific instrument locations in the plant. This level of detail is not necessary in the TS bases to understand the purpose of the ESFAS Function or to determine the ESFAS Function operability. As this information was not included in the RTS Bases, the proposed change makes the level of detail in the RTS and ESFAS Bases more consistent. In addition, the TS are not intended to control the details of the plant design and this type of design information is contained in other more BVPS Units 1 &2 Page 1 Revision 2, 4/06 82

Rev. 2 Change D-10 BVPS ISTS Conversion i 3.3C ESFAS Instrumentation Enclosure 2 Changes to The ISTS Bases setpoint methodology are met provides the required assurance that the ESFAS setpoints are maintained operable and effectively encompasses the requirements of the deleted paragraph.

8. The Bases description of ISTS SR 3.3.2.11 is deleted consistent with the elimination of this surveillance from the corresponding ITS 3.3.2 in Enclosure 1. This surveillance is only applicable to the P-4 interlock. The BVPS ITS assigns ITS SR 3.3.2.7 (ISTS SR 3.3.2.8) to the P4 interlock instead of ISTS 3.3.2.11. See the JFD associated with the change to the corresponding surveillance requirement in the Enclosure I markup of ITS 3.3.2.

9. The response time surveillance bases is revised to reflect potential alternative response time testing methods with regard to testing instrument channels with time constants. The use of a step change input signal to verify the response time of a channel eliminates the need to set the time constants to one and results in the same response time whether the time constants are set to nominal values or one. This method may be used in some cases due to the difficulty in resetting certain time constants back to their nominal values following testing.

10. The ISTS Bases text for Action Conditions C and G are revised to incorporate a clarification regarding the applicability of the Action. These Actions address an inoperable train of ESFAS actuation logic or actuation relays. The Completion Time of 6 hours is a relatively short Action time intended to address the loss of a train of actuation logic or relays.

However, there are many actuation relays that must be addressed by this Action and the ISTS ESFAS Actions do not include an Action applicable to less than an entire train of actuation relays. In the course of surveillance testing or maintenance, it is likely that a single inoperable relay may be discovered that only affects a single ESF component or system. In this case, the application of the short Completion Time associated with the failure of an entire train of logic and relays would be overly conservative and inappropriate. The proposed clarification addresses this situation and directs the tech spec user to enter the applicable Actions of the affected ESF system or component instead of the Actions for an entire train of ESFAS logic and relays. The proposed clarification is reasonable and appropriate considering that if the affected ESF system or component were inoperable for reasons other than the actuating relay, substantially more time may be available in the Action Condition(s) applicable to that ESF component or system. In addition, the proposed clarification is similar to a Bases clarification approved by the NRC in the Farley Nuclear Plant ISTS conversion.

11. The ISTS Bases text describing ESFAS Function 5, Turbine Trip and Feedwater Isolation, is revised to remove redundant and unrelated text. The deleted paragraph seems to primarily describe other Si and P4 interlock functions. The SI function is fully described in the Sl portion of the ESFAS bases and the P4 interlock is fully described in the P4 Bases (Function 8.a on ESFAS bases page 34).

The inclusion of this additional text describing SI and Pa Functions in the bases for the Turbine Trip and Feedwater Isolation Function is unnecessary to understand the Turbine Trip and Feedwater Isolation Function and potentially confusing as it gives the impression that the Turbine Trip and Feedwater Isolation Function also starts the AFW pumps. The elimination of this descriptive text does not introduce a technical change to the explanation of the Turbine Trip and Feedwater Isolation Function. BVPS Units 1 & 2 Page 3 Revision 2, 4/06 84

E: Cll ALLOWABLE APPLICA AE VALUE MODES ACTION

1. SAFETY INJECTION AND FEEDWATER ISOLATION

a. Manual Initiation 2 N.A. 1, 2, 3, 4 4X

b. Automatic Actuation 2 N.A. 1, 2, 3, , __6 Logic and Actuation Relays

c. Containment 3 5 5.3 psig 1, 2, 3 4 Pressure-High

d. Pressurizer 3 2 1852 psig 1, 2, 44 D Pressure-Low lsteamline 3

e. Steamline Pressure-Low 3/loop (a)4 2 494 psig*

N.A. 1, 2, 3, 4 E"44 Coincident with Injection Signal

b. Refueling Water Storage Tank Level-4 2 at" 3 31' 8" and < 31' 1, 2, 3, 4 zTI Extreme Lo i

Time constants utilized in the lead-lag controllers for Steam Line Pressure-Low are T1 2 50 seconds and T2 S 5 seconds. ICHANNEL CALIBRATION shall ensure that these time constants are adjusted to these values.]

BEAVER VALLEY - UNIT 2 3/4 3-16 Amendment No. 153 l A-6 CO Co

- C. I Rev. 2 Change A-6_ I REQUIRED I TABLE ()Continued UNIT 2 , A4 FUNCTION ENGINEERE SAFETY FEATURE A &ATION SYSTEEM INSTR OR OTHER SPECIFIED ENTATION ! CONDITIONS I CONDInON MINIMUM A TOTAL NG. CHANNELS CHANNEL ALLOWABLE APPLI FUNCTIONAR. UNT QF CHANNELS TO TRIP PERABL VALUE MODES _ATO

2. CONTAINMENT SPRAY

a. Manual Initiation set 1 set N.A. 1, 2, 3, 4 48 e ( ce

b. Automatic Actuation 2 N.A. 1, 2, 3, 4 43 Logic and Actuation RelaysA1

c. Containment Pressure---

11.4 psig 1, 2, 3

                                                                                                                                  -/1E 14 High-High

3. CONTAINMENT ISOLATION

a. Phase "A" Isolation (

1) Manual Initiation \ N.A. 1, 2, 3, 4

2) Automatic Actuation N.A. 1, 2, 3, 4 43 Logic and Actuation Relays

3) Safety Injection See Item 1. above for all Safety Injection initiating functions and requirements.

b. Phase "B" Isolation

1) Manual Initiation s 1, 2, 3, 4

2) Automatic Actuation (;j)

Logic and Actuation RelaysA 2_ 1, 2, 3, 4 43 x/0

3) Containment 4 S 11.4 psig 1, 2, 14 Pressure--High-High BEAVER VALLEY - UNIT 2 3/4 3-17 Amendment No. 153 l A.6 (0

0

Le' -I-(b) ExceptwhenallMSs areclosedand deactivated.

Time constants utilized in the lead-lag controllers for Steam Line Pressure-Low are T. 2 50 seconds and Tg 5 seconds. CHANNEL CALIBRATION shall ensure that these time constants are adjusted to these values.

FE _ BEAVER VALLEY - UNIT 2 3/4 3-18 endment No.153 l A-6 CD

r7 BEAVER VALLEY - UNIT 2 3/4 Amendment No.152 i A-i CD

le- E : BEAVER VALLEY - UNIT 2 3/4 3-20 Amendment No.152 I A.5 CO w,

V £ BEAVER VALLEY - UNIT 2 3/4 3-33 Amendment No.153 l A-6 (0 00

lChannel Operational Test (COT), Trip Actuating Device Operatlonal Testl ITS SR 3.3.2.9 Verify ESFAS TADOT), Actuation Logic Test, Master Relay Test, and Slave Relay Test Rev. 2 Change A-6 a ManncuTl Initiatio N.A. N. TALE .- (ninuA9 =_ Changes to Modes are Changes to in N.addressed Inmarkup addressed In SURVEILLANCE REOUIREMENTA markup of Table\ \, 3.3. \ :w AN < MODES 'INWHICH/

                                    -CHANNEL                                                                   CHANNEL              FU~OA                   SURVEILLANCE/
           \FUNCTIONAL                    UNIT                       /CHECK                                CALIBRATION                            /TS\REQUIRED/

a ONTAINMENT SPRAY /lSR 3.3.2.2, SR 3,3.2.3, SR 3.3.2.6 llSR 3.3.2.7l \/

                     \     . Manual         Initiation                /N.A.                                N.A.                    R,2,                   I\          3,    4/
                              .         Automatic Actuaio              gic,          N.A.                  N.A.                 '1,                                   3, 4 Actuation Relas and                                                                    SR 3.3.2.

_ 3 \mContainment

c. Pre sure- 1, 2 3 h-High/Hig\

ITS Table 3.3.2-1 Notes (e)&( l)

3. CONTAI T ISO 2 3/4 3 A d No. 1 A.6

a. Phas ""solation 'V

1. M~slInitiation N.A. N.A. Ril, l, 2, 4

2. A fmatic Actuation N.A. N.A. 9PIf4+ l, 2, /3\4 ogiX and Actuation /\

                                       /elay.                                          SR 3.3.2.2, SR 3.3.2.3, SR 3.3.2.6l/                                               \          .

3 Safety Sjection See Functional Unit l above for all Safet In] ctior

                                              /          \                          ~Surveillance            Requirements./                                                   \
                                                         / \                      ,                 _                                    l SR 3.3.2.7l          /\

b. /Phase "B"31 Isolatn F SR 3.3.2.~2,SR 3.3.2.3, SR 3.3.2.6_J RAl /

                         /      .       Manual        Inita         on               N.A.                  N.A.                                           1 ,2,       3,    4\
                       /      2.        Automatic          Actu     ~on              N.A.                  N.A.                     Mwi                   l      2,   3,    4\
                   /                   ~~Logic      and    Actuatto
                /Relays                                                  \        lSR 3.3.2.1 l       lSR 3.3.2.8 ljS                   ...

3. Containment Presu -GQ/l2,34\lA6

_ High-High \ 9 2, 3,4 l ITS Table 3.3.2-1 Notes (e) & (f) l BEAVER VALLEY - UNIT 2 3/4 3-34 Amendment No. 153 lA-6 CD (o

             /             \ITS                  Table 3.3.2.1 Notes (e) & (f)  l

c. Safety Injection See Functional Unit 1 above for all Safety

 /__                            \ Surveillance Requirements.

BEAVE - TAhIT n 3B/ILEYV 32I 3- I ( Above the P-11 (Pressurizer Pressure) Interlock. (a) o (c) Below the P-1I (Pressurizer Pressure) Interlock 0 when SI on steam line pressure low is blocked.

I ip BEAVER VALLEY - UNIT 2 3/4 3-36 Amend-ent No. 152 I A-5 0L

Rev. 2 Change A-5 Frequency of SR 3.3.2.2, Actuation Logic: j Test and SR 3.3.2.3 Master Relay Test (4) Each train or logic channel shall be tested 3l days. (2) If the as-found channel setpoint is conservative with respect to the Allowable Value but outside its predefined as-found acceptance criteria band, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service. If the as-found instrument channel setpoint is not conservative with respect to the Allowable Value, the channel shall be declared inoperable. A-5 (3) The instrument channel setpoint shall be reset to a value that is within the as-left tolerance of the Nominal Trip Setpoint, or a value that is more conservative than the Nominal Trip Setpoint; otherwise, the channel shall be declared inoperable. The Nominal Trip Setpoint and the methodology used to determine the Nominal Trip Setpoint, the predefined as-found acceptance criteria band, and the as-left setpoint tolerance band are specified in a document incorporated by reference into the Updated Final Safety Analysis Report. ITS Table 3.3.2-1 Notes (e) & (f) BEAVER VALLEY - UNIT 2 3/4 3-38 Amendment No. 152 I A-5 103

Cr-L P l Rev. 2 Change A-6 T narnr.r 2 2-n I nDAC DArA=DAM 11 and Actuation Relays \ / I IENGINEERED S l L--AR#302 ll FUNCTIONAL UNIT / X

Time constants utilized in the lead-lag controllers for Steam line Pressure-Low are Tj 2 50 seconds and T2 S 5 seconds. CHANNEL CALIBRATION shall ensure that these time constants are adjusted to these values.l

                                                                  \8    Note InChannel Calibration SR.      A BEAVER VALLEY -   UNIT 1                            3/4 3-15                                          Amendment No.

01 en

wr kL Changes to this Unit I material are addressed In the Unit 2 markup. ) TABLE 3.3-3 (Cont'Inued) I Rev. 2 Change A-6 I ENGINEERED SAFETY FEATURE - ACTUATION -SSYSTEMI S E - TOTAL NO. S CHANNELS ALLOWABLE FUNCTIONAL UNIT TO TRIP OPERABLE VALUE 1.1 SAFETY INJE FRO ION TO THE RE-

                    - -TT.1nN-nv BEAVER VALLEY - UNIT 1                                3/4 3-16                              Amendment No. 271 A-6 0)

A( C.or BEAVER VALLEY - UNIT I 3/4 3-17 Amendment No.271 i A-

-4

a lz I.

a. Automatic Actuation Logic and Actuation Relays 2 Trains NA 1, 2, 3 G i c. Safety InJection Refer to Function 1 (Safety Injection) for all initiation functions and requirements.

M11

Time constants utilized in the lead-lag controllers for Steam line Pressure-Low are r1 2 50 seconds and T2 < 5 seconds. FCHi1NEL CALIBRATION shall ensure that these time constants are adjusted to these values.

BEAVER VALLEY - UNIT 1 3/4 3-18 Amendment No. I I Note in Channel Calibration SR. C

Cll f-E.- IC-A- EAVVEP VAT.T.1.V - tTNTT 1 9a

                                     '!4 w-n  Amendment No. 273 0L

to Changes to this Unit 1 material are addressed in the Unit 2 markup. I __..-

                                                                                    /J             ev. 2 Change RIl            A-6    I I

ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATIO SURVEILLANCE REQUIREMENTS x CHANNEL MODES IN WHIC C EL CHANNEL FUNCTIONAL SURVEILLA FUNCTIONAL UNIT CHE CALIBRATION TEST D

1. SAFETY INJECTION AND FEEDWATER ISOLATION

a. Manual Initiation N.A. N.A. 1, 2, 3, 4

b. Automatic Actuation Logiw N.A. N.A. 1, 2, 3, 4 C. Containment Pressure-High\ S R(2) ( 2, 3 I A-6

d. Pressurizer Pressure--Low\ S R Q 1, 2,

e. Steam Line Pressure--Low S R Q 1, 2, 3\

K and Actuation Relays M9

Changes to this Unit I material are addressed In the Unit 2 markup. BEAVER VALLEY - UNIT 1 3 /4 3 -29 Amendment No.271 I A-S

t i~c IC" l Changes to this Unit I material are addressed in the Unit 2 markup. I I Rev. 2 Change A-6 I TABLE 4.3-2 (Continued) ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION SURVEILLANCE REOUIREMENTS CHANNEL C CHANNEL CHANNEL SURVEILLANCE FUNCTIONAL UNIT HECK ON TEST REOUIRED 1.1 SAFETY INJECTION-T INJEC ECIRCULATION I i (L13)a. 3 Manual In .. - . 1. 2, 3, 4

                       .AtmtcActuation Logic                      N.A.            N.A.             M ()1,               2, 3
                       ~~-_

oncientwith Signal Safety__- I I3

c. Refueling " tora e S (2)(3) Q()31, 2, 32v lA.6 Tank Level-Low

2. CONTAINMENT SP a n itiation R 1, 2, 3, 4

b. Automatic Actuation Logi N.A. N.A. M, 2, 3, 4

c. Containment Pressure- l R(2)(3) Q(2)(3) A-6 High-High MEand Actuation Relays I IChanges to this Unit 1 material are addressed In the Unit 2 markup.

BEAVER VALLEY - UNIT 1 3/4 3-29a Amendment No.271 I ASr

Changes to this Unit I material are addressed in the Unit 2 markup. TABLE 4.3-2 (Continued)

                    / NGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUME'NTATO
                       /                    ~SURVEILLANCE REQUIREMENTS\

CHANNEL MODES IN WHICR CHANNEL CHANNEL FUNCTIONAL SURVEILLA FNlXAL UNIT CHECK CALIBRATION TEST REQUIR~

3. CONTAINMENT T ION/

a. Phase "All Iso at

1) Manual N.A. N.A. R 1, 2, 3, 4

2) From Safety Injection N.A. M ) 1, 2, 3, 4 Automatic Actuation N Logic " /

b. Phase "B" Is(:llation

1) Manual \N.A. X1, 2, 3, 4

2) Automatic Actu ioN.A. / NA. M (1) , 2, 3, 4 Logi

3) Containment Pressu -- S R(2)(3) 1, 2, High-High and Actuation Relays Changes to this Unit I material are addressed in the Unit 2 ma BEA'v.R V'ALLJn' - BONITO 43 271 ! A-6

C. L Moved to ITS LCO 3.3.5.'Changes to CTS Function 6 are addressed In the markups and DOCs associated with ITS LCO 3.3.5. BEAVER VALLEY - UNIT 1 3/4 3-31 Amendment No.273 I A-8 enL

                                                                                                                           =C ein the Unit 2 markup.                                          Rev. 2 Change A-5 TABLE 4.3-2        (Continued)

ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION SURVEILLANCE REQUIREMENTS Automatic Actuation Logic and Actuation Relays CHANNEL MODES . l_ I CHANNEL CHANNEL FUNCTIONAL, S gYILNE FUNCTIONAL UNIT CHECK CALIBRATION TEST REQUIRED

7. AUXILIARY FEEDWATER __/

           .Steam     Generator Water                                          (2  R2(3)     1  Q(21 (31       1,  2,  3         l      A-6 L vel- ow-Low/

b. er e -RCP S Q l , 2

c. S.I. \See ove (all SI surveillance requirements)

d. (Deleted)

e. Trip of Main R 1, 2, 3 Feedwater Pumps

8. ESF INTERLOCK a.N.A. N.A. R 3 ,2, N.A. R Q 1 3 P-7N-A- 1. 2.3 Changes to this Unit 1 material are addressed in the Unit 2 markup.

BEAVER VALLEY - UNIT 1 3/4 3-31a Amendment No.270 A-5

I Rev. 2 Change A-5 TABLE 4.3-2 (Continued)- TABLE NOTATION (1) Each train o logic channel shall be tested a east every other 31 days.\ (2) If the as-found ch a 1 setpoint is c ervative with respect: to the Allowable Value but utside its edefined as-found acceptance criteria band, then the c el s 1 be evaluated to verify that it is functioning as requi efore returning the channel to service. If the as-found n rument channel setpoint is not A-5 conservative with respect the A owable Value, the channel shall be declared inoperable. (3) The instrument ch eX setpoint shall be et to a value that is within the as- t tolerance of the Nominal rip Setpoint, or a value that more conservative than the Nomi1 Trip Setpoint; otherwise, he channel shall be declared inoperab . The Nominal Trip S oint and the methodology used to determin the Nominal Trip etpoint, the predefined as-found acceptance crit ia band, a the as-left setpoint tolerance band are specified in a cument ncorporated by reference into the Updated Final Safety Ana sis Report. IChanges to this Unit I material are addressed in the Unit 2 markup. BEAVER VALLEY - UNIT 1 3/4 3-32 Amendment No. 270 l A-5 116A

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQ UE:ST (LAR) NOs. 296 (UNIT 1) & 1 69 (UNIT 2) REVISION 2 REPLACEMENT PAGES ITS SECTION 3.4 REACTOR COOLANT SYSTEM LIST OF AFFECTED PAGES 6 75 223 13 81 227 15 95 229 18 116 232 20 121 235 29 126 237 38 129 270 55 135 272 59 138 295 60 139 296 61 144 304 62 145 312 63 149 319 64 172 326 67 173 370 68 210 371

I Rev. 2 Change C-12 J RCS Pressure, Temperature, and Flow DNB Limits 3.4.1 y;j A SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.1.1 Verify pressurizer pressure is greater than or equal to 12 hours the limit specified in the COLR. SR 3.4.1.2 Verify RCS average temperature is less than or equal to 12 hours the limit specified in the COLR. SR 3.4.1.3 Verify RCS total flow rate is 2 greater than or equlemit 000] gpm and specified in the COLR. 12 hours KD SR 34.1.4

                                                 - NOTE -

0Not required to be performed until 21 hours after _ fy by precision heat balance that RCS total flow rate fI 81 months is 2 , gpm and greater than or equal to the limit specified in the COLR. WOG STS 3.4.1 -2 Rev. 2, 04/30/01 6

I Rev. 2 Change C-5 I RCS Loops - MODE :3 (n) CTS Values I 3.4.5 SURVE ANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.4.5.2 \Verify steam generator secondary side water levels are 12 hours A-J 6 for required RCS loops. SR 3.4.5.3

                                      -NOTE-Not required to be performed until 24 hours after a required pump is not in operation.

Verify correct breaker alignment and indicated power 7 days are available to each required pum not in operation. WOG STS 3.4.5-3 Rev. 2, 04/30/01 13

I Rev. 2 Change C-5 I RCS Loops - MODE 4 3.4.13 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME A.2

                                                    - NOTE -

Only required if RHR loop is OPERABLE. Be in MODE 5. 24 hours t RE:G~-14, R B. Two required loops B.1 Suspend operations that Immediately inoperable. would cause introduction-into the RCST-Gcooant-with of coolant OR boron concentration less than required to meet SDM Required loop not in of LCO 3.1.1. operation. AND B.2 Initiate action to restore Immediately one loop to OPERABLE status and operation. 28% (Unit 1), Ž..% nW2) SURVEILLANCE REQUIREMENTS I SURVEILLANCE FREQUENCY SR 3.4.6.1 Verify required RHR or RCS loop is in operation 12 hours SR 3.4.6.2 Verify SG secondary side water levels are 2 [1q% for 12 hours required RCS loops. I SR 3.4.6.3

                                      - NOTE -

Not required to be performed until 24 hours after a required pump is not in operation. I not in operationi. I Verify correct breaker alignment and in ed power 7 days are available to each required pum WOG STS 3.4.6 - 2 Rev. 2, 04/30/01 15

RCS Loops - MODE 5, Loops Filled Rev 2ChangejC5 3.4.7 SURVEILLANCE REQUIREMENTS . _= SURVEILLANCE FREQUENCY SR 3.4.7.1 Verify required RHR loop is in operation. 12 hours SR 3.4.7.2 Verify SG secondary side water levels is 2! n 112 hours required SGs. ~N 28% (Unit 1), 2 B

                                                                     .~                 ,    W SR 3.4.7.3
                                   - NOTE -

Not required to be performed until 24 hours after a required pump is not in operation.

                                                                                       -L~sJ Verify correct breaker alignment and indicated power       7 days are available to each required RHR pumas not inoperation.        -K31 WOG STS                            3.4.7 - 3                              Rev. 2, 04/30/01 18

RCS Loops - MODE 5, Loops Not Filled Rev. 2 Change C-5 3.4.8 of c ACTIONS (continued) CONDITION REQUIRED ACTION /COMPLETION TIME B. No required RHR loop B.1 Suspend operations that/ Immediately I OPERABLE. would cause introductiort into the RCS GeoIaRt with OR boron concentration less than required to meet SDM lLNURE1431, Re. Required RHR loop not in of LCO 3.1.1. operation. AND B.2 Initiate action to restore Immediately one RHR loop to OPERABLE status and operation. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.8.1 Verify required RHR loop is in operation. 12 hours SR 3.4.8.2

                                      -NOTE-Not required to be performed until 24 hours after a required pump is not in operation.

Verify correct breaker alignment and indicated power 7 days are available to each required RHR pump' no _noeain WOG STS 3.4.8 -2 Rev. 2, 04/30/01 20

I Rev. 2 Change D-17 H sy.t12 3.4P 3.4 REACTOR COOLANT SYSTEM (RCS)

I ev 2CangeB-1I RCS PIV Leakage 3.4.14 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4-_ SR 3.4.14.1

                                                  - NOTES -

1. Not required to be performed in MODES 3 and 4.

                ,A 2.Not required to be performed on the RCS PlVs
                       \located in the RHR flow path when in the
                        \,shutdown cooling mode of operation.

Prior to entering MODE 2 P 3. Rated (luring ce of this after the plant isplaced in Surveillance are to be tested more MODE 5 for refueling than o rpetitve testin not be oided. b5 Verify leakage from each RCS PIV is equivalent to Wacrdance s 0.5 gpm per nominal inch of valve size up to a with fheJ)rvice maximum of 5 gpm at an RCS pressure 2 f2215J psig Tes tam, and

f2255J psig. [ 18]monthW.

AND

                                          -NOTE-Only applicable to PlVs requiring additional testing as specifically              Prior to entering identified inthe list of PlVs.                                                    MODE 2 whenever the unit has been 4I                                                            in MODE 5 for 7 days or more, if leakage testing has not been performed in the

3. The RCS PIV leakage may be verified at a pressure lower than N previous 9 months the specified RCS pressure range provided the observed leakage rates are adjusted to the function maximum pressure 1~ /ND in accordance with ASME OM Code. I

4. Leakage rates > 0.5 gpmrinch diameter but s 5.0 gpm are With 24hos acceptable if the latest measured rate has not exceeded the followin v Ze rate determined by the previous test by an amount that actuatio ue to reduces the margin between measured leakage rate and the autom tic maximum permissible rate of 5.0 gpm by Ž 50%. mar al actio or fI4 through the\

Salve WOG STS 3.4.14 - 3 Rev. 2, 04/30/01 38

Rev. 2 Change C-12 BVPS ISTS Conversion 3.4 Reactor Coolant System Enclosure 1 Changes to ISTS ITS 3.4.1 RCS Pressure, Temperature, and Flow DeparturefromNucleate Boiling (DNB) Limits JUSTIFICATION FOR DEVIATION (JFD)

1. The ISTS surveillance note that modifies the precision heat balance requirement is revised to require the surveillance to be performed within 7 days after reaching 95%

RTP instead of 24 hours after reaching 90% RTP. The corresponding BVPS CTS does not contain a time limit in which to perform the heat balance surveillance. Currently the performance of this surveillance is controlled administratively by plant procedures. The time in which the surveillance is performed is not a specific assumption of a safety analysis. However, establishment of the conditions for performance of the precision heat balance is time consuming dependent on other startup testing, and requires stable operating conditions. The ISTS requirement of 24 hours after exceeding the required power does not allow sufficient time to establish stable plant conditions, install required instrumentation, perform the surveillance, and analyze the results. In addition, other required testing at high power levels after a refueling outage, such as physics testing and flux mapping, may interfere with establishing optimum conditions for the performance of the heat balance surveillance. Therefore, BVPS proposes that the note allow 7 days after reaching the specified power to complete the required heat balance surveillance. The 7 day allowance to perform the surveillance after reaching 95% RTP is acceptable considering that the Frequency for performing this surveillance is 18 months. As such the 7 day allowance after reaching 95% RTP provides a sufficient operating restriction to ensure the surveillance is performed in a timely manner while providing time to accommodate any additional required testing, achieve stable operating conditions after startup, install the necessary test equipment, perform the test, and analyze the results. In addition, the NRC has previously approved the 7 day and 95% RTP allowance to perform this testing for other Westinghouse Plants in their conversion to the ISTS. BVPS Units 1 & 2 Page 1 Revision 2, 04/06 55

I Rev. 2 Change C-5 I BVPS ISTS Conversion 3.4 Reactor Coolant System Enclosure 1 Changes to ISTS ITS 3.4.5 RCS Loops - AMode 3 JUSTIFICATION FOR DEVIATION (JFD)

1. ITS 3.4.5 Condition D is revised to be consistent with the BVPS specific design and CTS requirements. In ITS 3.4.5, one or two of the three RCS loops are required to be in operation depending on whether or not the rod control system is capable oU rod withdrawal or not. ITS Condition C addresses the condition where 1 required loop out of two is not in operation. In order for ITS Condition C and Condition D to work properly, Condition D should address the condition where no RCS loops are operating. ITS Condition D contains the immediate Actions appropriate for a loss of function similar to CTS Action statement c. If ITS Condition D specifies "Required' loops not in operation (as it appears in the ISTS) it may be considered to be applicable at the same time as Condition C (1 required loop not in operation) and cause confusion. Therefore, Condition D is revised to more consistent with the corresponding CTS Action statement c (with no reactor coolant loop in operation).

This maintains the current BVPS licensing basis for this Action as specified in the CTS.

2. Not used.

BVPS Units I & 2 Page 5 Revision 2,4/06 59

BVPS ISTS Conversion I Rev. 2 Change C-5 I 3.4 Reactor Coolant System Enclosure 1 Chanqes to ISTS

3. ISTS surveillance 3.4.5.3 requires the verification of correct breaker alignment and indicated power to each required pump every 7 days. The corresponding CTS surveillance (4.4.1.2.2) specifies a similar requirement with one important clarification. The corresponding CTS surveillance is only applicable to the non-operating pumps. The ISTS surveillance is revised to incorporate the CTS clarification that the surveillance is only applicable to the non-operating pumps.

The CTS clarification is reasonable and appropriate since the verification of correct breaker alignment and indicated power is not necessary for operating equipment. A separate surveillance continues to verify the required pump/loop(s) are in operation and provides adequate verification of the operating equipment. Considering that the operating pump/loop must be verified in operation every 12 hours, the ISTS requirement to verify the breaker alignment and power availability to the same operating pump every 7 days does not add a significant safety benefit. The proposed change makes the two surveillances (operating and non-operating equipment verifications) work together logically to provide adequate verification of the required pump/loop status and to assure the plant is operated in a safe manner. The proposed change is consistent with the similar Mode 6 ISTS surveillance (SR 3.9.6.2) that verifies the breaker alignment and power availability to the required RHR pump that is not in operation. The proposed change is also consistent with the current licensing basis for BVPS as approved by the NRC in the CTS. Therefore, the proposed change is acceptable and does not reduce the level of assurance provided by the TS. BVPS Units 1 & 2 Page 6 Revision :2, 4/05 60

BVPS ISTS Conversion Rev. 2 Change C-5 3.4 Reactor Coolant System Enclosure 1 Changes to ISTS ITS 3.4.6RCSLoops - Mode 5 JUSTIFICATION FOR DEVIATION (JFD)

1. ISTS 3.4.6 LCO Note 2 specifies limitations applicable to starting RCPs at low RCS temperature conditions. The standard ISTS note is revised to incorporate the provisions of the corresponding CTS 3.4.1.3 note. The significant changes to the ISTS note are the applicability of the note being changed to the start of the first RCP and qualifying the application of the note to non-isolated loops only. These changes are consistent with the CTS and have already been reviewed and approved by the NRC. In summary, once the first pump is started, sufficient mixing in non-isolatel loops assures the temperature limit is met for subsequent pump starts. In addition, loop isolation valves are part of the BVPS design and loops may be isolated during shutdown conditions. Therefore, unlike many Westinghouse plants, the BVPS specific version of this note must address whether or not the loop is isolated.

2. Not used.

BVPS Units 1 & 2 Page 7 Revision 2, 4/06 61

I Rev. 2 Change C-5 BVPS ISTS Conversion 3.4 Reactor Coolant System Enclosure I Changes to ISTS

3. ISTS surveillance 3.4.6.3 requires the verification of correct breaker alignment arid indicated power to each required pump every 7 days. The corresponding CTS surveillance (4.4.1.3.2) specifies a similar requirement with one important clarification. The corresponding CTS surveillance is only applicable to the non-operating pumps. The ISTS surveillance is revised to incorporate the CTS clarification that the surveillance is only applicable to the non-operating pumps.

The CTS clarification is reasonable and appropriate since the verification of correct breaker alignment and indicated power is not necessary for operating equipment. A separate surveillance continues to verify the required pump/loop(s) are in operation and provides adequate verification of the operating equipment. Considering that the operating pump/loop must be verified in operation every 12 hours, the ISTS requirement to verify the breaker alignment and power availability to the same operating pump every 7 days does not add a significant safety benefit. The proposed change makes the two surveillances (operating and non-operating equipment verifications) work together logically to provide adequate verification of the required pump/loop status and to assure the plant is operated in a safe manrer. The proposed change is consistent with the similar Mode 6 ISTS surveillance (SR 3.9.6.2) that verifies the breaker alignment and power availability to the required RHR pump that is not in operation. The proposed change is also consistent with the current licensing basis for BVPS as approved by the NRC in the CTS. Therefore, the proposed change is acceptable and does not reduce the level of assurance provided by the TS. BVPS Units I & 2 Page 8 Revision 2, 4/06 62

Rev. 2 Change C-5 BVPS ISTS Conversion 3.4 Reactor Coolant Sysltem Enclosure 1 Changes to 1ITS ITS 3.4.7 RCS Loops - Mode 5, Loops Filled JUSTIFICATION FOR DEVIATION (JFD)

1. ISTS 3.4.7 LCO Note 3 specifies limitations applicable to starting RCPs at low RC S temperature conditions. The standard ISTS note is revised to incorporate the provisions of the corresponding CTS 3.4.1.3 note. The significant changes to the ISTS note are the applicability of the note being changed to the start of the first RCP and qualifying the application of the note to non-isolated loops only. These changes are consistent with the CTS and have already been reviewed and approved by the NRC. In summary, once the first pump is started, sufficient mixing in non-isolated loops assures the temperature limit is met for subsequent pump starts. In addition, loop isolation valves are part of the BVPS design and loops may be isolated during shutdown conditions. Therefore, unlike many Westinghouse plants, the BVPS specific version of this note must address whether or not the loop is isolated.

2 The ISTS LCO 3.4.7 requirement for the secondary side steam generator water level contains an option for how many steam generators are required. The LCO requirement is based on the number of steam generators required to assure a sufficient heat sink to remove decay heat via natural circulation. For BVPS, a single steam generator has sufficient capacity to remove decay heat via natural circulation. The LCO, and corresponding Actions, are revised accordingly.

3. ISTS surveillance 3.4.7.3 requires the verification of correct breaker alignment and indicated power to each required pump every 7 days. The corresponding CTS surveillance (4.4.1.3.2) specifies a similar requirement with one important clarification. The corresponding CTS surveillance is only applicable to the non-operating pumps. The ISTS surveillance is revised to incorporate the CTS clarification that the surveillance is only applicable to the non-operating pumps.

The CTS clarification is reasonable and appropriate since the verification of correct breaker alignment and indicated power is not necessary for operating equipment. A separate surveillance continues to verify the required pump/loop(s) are in operation and provides adequate verification of the operating equipment. Considering that the operating pump/loop must be verified in operation every 12 hours, the ISTS requirement to verify the breaker alignment and power availability to the same operating pump every 7 days does not add a significant safety benefit. The proposed change makes the two surveillances (operating and non-operating equipment verifications) work together logically to provide adequate verification cf the required pump/loop status and to assure the plant is operated in a safe manner. The proposed change is consistent with the similar Mode 6 ISTS surveillance (SR 3.9.6.2) that verifies the breaker alignment and power availability to the required RHR pump that is not in operation. The proposed change is also consistent with the current licensing basis for BVPS as approved by the NRC in the CTS. Therefore, the proposed change is acceptable and does not reduce the level of assurance provided by the TS.

4. Not used.

BVPS Units I & 2 Page 9 Revision 2,4/06 63

Rev. 2 Change C-5 BVPS ISTS Conversion 3.4 Reactor Coolant System Enclosure 1 Changes to ISTS

5. The ISTS 3.4.7 and ISTS 3.4.8 applicability of Mode 5 with RCS loops filled (3.4.7) and Mode 5 with RCS loops not filled (3.4.8) are revised to take into account the BVPS RCS loop isolation valves. The BVPS specific version of the ISTS 3.4.7applicability is "Mode 5 with one or more RCS Loops Unisolated and Filled".

The BVPS specific version of the ISTS 3.4.8 applicability is " All RCS Loops Isolated or Unisolated RCS Loops not Filled." BVPS Units 1 & 2 Page 10 Revision 2, 4106 64

BVPS ISTS Conversion IZe. han e77C-5 3.4 Reactor Coolant Sys tern Enclosure 1 Changes to ISTS proposed change makes the two surveillances (operating and non-operating equipment verifications) work together logically to provide adequate verification cf the required pump/loop status and to assure the plant is operated in a safe manner. The proposed change is consistent with the similar Mode 6 ISTS surveillance (SR 3.9.6.2) that verifies the breaker alignment and power availability to the required RHR pump that is not in oDeration. The proposed change is also consistent with the current licensing basis for BVPS as approved by the NRC in the CTS. Therefore, the proposed change is acceptable and does not reduce the level of assurance provided by the TS.

3. Not used.

BVPS Units 1 & 2 Page 13 Revision 2, 4/06 67

BVPS ISTS Conversion IRev. 2 Change C-5 I 3.4 Reactor Coolant System Enclosure 1 Changes to ISTS BVPS Units I & 2 Page 14 Revision 2, 4/06 68

Rev. 2 Change D-17 BVPS ISTS Conversion I __ I 3.4 Reactor Coolant System Enclosure 1 Changes to ISTS ITS 3.4.12 OverpressureProtectionSystem JUSTIFICATION FOR DEVIATION (JFD)

1. The ISTS LCO requirements for low temperature overpressure protection are revised to conform to the corresponding CTS requirements and the BVPS design.

This includes the following revisions: a) The name of the over pressure protection system used in the IST'S is changed to the current BVPS nomenclature for this system (i.e., Overpressure Protection System (OPPS)), b) The BVPS design does not include high pressure RCS injection pumps other than the charging pumps. Therefore, the ISTS reference to other high pressure injection pumps is deleted, c) The BVPS specific safety analysis for low temperature overpressure protection does not include the RHR valves. The only valves modeled in the analysis are the PORVs. Therefore, the RHR valves can not currently be credited for this protection and references to the RHR valves are deleted from the LCO, d) Due to design differences between the BVPS units the RCS vent size assumed in the safety analysis for low temperature overpressure protection is different for each unit. Therefore, two different RCS vent sizes (one for each unit) are included in the BVPS specific LCO, e) The additional Unit 1 specific requirement to isolate the ECCS high head SI (HHSI) flow path is included in the BVPS version of this LCO. The requirement to isolate the HHSI flow path is consistent with Unit 1 CTS 3/4.5.4, "HHSI Flow Path". Unit 2 does not have a corresponding requirement. This requirement is necessary as the Unit 1 low temperature over pressure protection safety analysis does not consider this flow path (SI high head injection) when evaluating mass injection events. Therefore, the Unit I TS require that this potential mass injection flow path be isolated such that an inadvertent SI signal would not cause an over pressure condition in the RCS. This Unit I requirement was previously in the ECCS section of the TS but is only applicable when operating with an RCS temperature less than or equal to the over pressure protection system enable temperature. Therefore, the requirement is moved into ITS 3.4.12 to consolidate all the low temperature over pressure protection system requirements in the same TS. The changes to the ISTS listed above are consistent with the CTS and the BVPS design.

2. The ISTS Applicability is revised consistent with the corresponding CTS Applicability. This includes changing the bracketed options for the specific temperature to "the enable temperature" consistent with the BVPS nomenclature for this term.

BVPS Units I & 2 Page 21 Revision 2, 04/06 75

BVPS ISTS Conversion I 2 I 3.4 Reactor Coolant System Enclosure 1 Changes to ISTS The proposed ITS note 3 (CTS note 5) is consistent with the ISTS 3.4.14 bases for the PIV LCO requirements which states:

              "Reference 7 [ASME code for Operation and Maintenance of Nuclear Power Plants or ASME OM Codel permits leakage testing at a lower pressure differential than between the specified maximum RCS pressure and the normal pressure of the connected system during RCS operation (the maximum pressure differential) in those types of valves in which the higher service pressure will tend to diminish the overall leakage channel opening.

In such cases, the observed rate may be adjusted to the maximum pressure differential by assuming leakage is directly proportional to the pressure differential to the one half power." The proposed ITS note is acceptable because it maintains the CTS requirements and is consistent with the intent of the ISTS and the ASME OM Code as explained in the ISTS Bases. Due to the ISTS surveillance requiring a specific RCS pressure (2215-2255 psig) for leakage rate verification, the provision in the CTS Note that allows verification at a lower pressure is retained within the proposed BVPS specific surveillance SR 3.4.14.1 as Note

3. As a surveillance note, the allowance provided by the CTS Note is more clearly established than if a description contained only in the Bases is relied on for this interpretation. The CTS TS note together with the ISTS bases description will provide a more complete description of the intended provisions of the surveillance.

The retention of these BVPS notes maintains the proposed ITS consistent with the current BVPS licensing basis as documented in the CTS.

5. The ISTS surveillance 3.4.14.1 Frequency is revised to be consistent with the corresponding CTS frequency for performing this surveillance. In the CTS, two separate surveillances identified the required frequencies for verifying the RCS PIV leakage is within limits. One frequency identified in CTS 4.4.6.3.1 is applicable to all RCS PIVs listed on Table 4.4-3 and requires leakage to be verified prior to entering Mode 2 after each refueling.

CTS 4.4.6.3.2 identified a second frequency for verifying the RCS PIV leakage that was only applicable to certain valves identified on Table 4.4-3. The second frequency required leakage verification of select valves more often than the first Frequency or prior to entering Mode 2 after each time the plant is placed in Mode 5 for more than 72 hours (7 days in the ISTS) unless testing has been performed within the previous 9 months. The two CTS frequencies described above correspond closely with the first two ISTS 3.4.14.1 surveillance frequencies. However, the CTS does not contain any frequency similar to the third ISTS frequency of "within 24 hours following valve actuation due to automatic or manual action or flow through the valve." Therefore, the third ISTS frequency is deleted. The CTS PIV requirements were reviewed and approved by the NRC in Unit 1 Amendment 124 (issued 5/2/38). This amendment revised the entire BVPS PIV TS including the surveillance requirements. The Unit 2 requirements are the same as those reviewed and approved in this Unit 1 amendment. Regarding the two CTS Frequencies for verifying PIV leakage, the NRC Safety Evaluation Report (SER) for Amendment 124, explained that the additional leakage testing required by 4.4.6.3.2 was intended for "Event BVPS Units 1 &2 Page 27 Revision 2,4/06 81

RCS Pressure, Temperature, and Flow DNB Limits I Rev. 2 Change C-12 1 B3.4.1 BASES SURVEILLANCE RE( )UIREMENTS (continued) E 100% This SR is modified by a Note that all ws entry into MODE 1,without having performed the SR, and place ent of the unit in the best condition for performing the SR. The Note that the SR is not riaquired t performed until T orfter 2 g}RTP. This exception is appnoate~ since the heat balance req plant.to.be.- .h {90RTP to obai th jae*I S nlow accuracies. The Surveillance shall be perorewten 24each" ing fcnP- RTP. REFERENCES 1 TAD SontrsnidR pq.7 as S/ I UFSAR, Chapter 14 (Unit 1), and UFSAR Chapter 15 (Unit 2). l WOG STS B 3.4.1 - 5 Rev. 2, 04/30/01 95

RCS Loops - MODE 3 B 3.4.5 l Rev. 2 Change C-5 I BASES SURVEILLANCE REQUIREMENTS (continued) not inoperation SR 3.4.5.3 Verification that each required RCP is OPERABLE ensures that safety analyses limits are met. The requirement also ensures that an additional RCP can be placed in operation, if needed, to maintain decay heat emoval and reactor coolant circulation. Verification is performed by viifying proper breaker alignment and power availability to each required RC . Altematively, verification that a pump is in operation also verifies proper breaker alignment and power availability. This SR is modified by a Note that states the SR is not required to be performed until 24 hours after a required pump is not in operation. REFERENCES None. WOG STS B 3.4.5- 6 Rev. 2, 04/30/01 116

RCS Loops - MODE '1 B 3.4.6 Rev 2 ha~nge C-5 BASES SURVEILLANCE REQUIREMENTS (continued) indications available in the control room to alert the operator to the loss of SG level. S3.4.6.3 not in operation rification that each required pump is OPERABLE ensures that an ad al RCS or RHR pump can be placed in operation, if needed, to maintain cay heat removal and reactor coolant circulation. Verification is performed erifying proper breaker alignment and power available to each required pun. Alternatively, verification that a pump is in operation also verifies proper breaker alignment and power availability. The Frequency of 7 days is considered reasonable in view of other administrative controls available and has been shown to be acceptable by operating experience. This SR is modified by a Note that states the SR is not required to be performed until 24 hours after a required pump is not in operation. REFERENCES None. WOG STS B 3.4.6-5 Rev. 2, 04/30/0 1 121

Rev. 2 Change C-5 RCS Loops - MODE 5, Loops Filled B 3.4.7 BASES 28 orUit_ o 2 15.5% for Unit 2 SURVEILLANCE REQUIREMENTS (continued) SR 3.4.7.2 nnioae l X / l Verifying that at least As SG& aeOPERA E by ensuring secondary side narrow range water levels are ensures an alternate decay heat removal method via natural circulation in the event that the second RHR loop is not OPERABLE. If both RHR loops are OPERABLE, this Surveillance is not needed. The 12 hour Frequency is considered adequate in view of other indications available in the control room to alert the operator to the loss of SG level. SR 3.4.7.3 28% for Unit I or l l oneunisolated 1 15.5% for Unit,2 Verification that each requi ed RHR pump is PERABLE ensures that an additional pump can be pl;ced in operation, needed, to maintain decay not in operation, N eat removal and reactor/coolant circulatio Verification is performed by ye proper breaker alignment and po er available to each required RHR pum Alternativ9ly, verification tha a pump is in operation also verifies proper breakeyalignment and pwer availability. If secondary side water level is 2 fr1%in at least SGr, this Surveillance is not needed. The Frequency of 7 days is considered reasonable in view of other administrative controls available and has been shown to be acceptable by operating experience. This SR is modified by a Note that states the SR is not required to be performed until 24 hours after a required pump is not in operation. REFERENCES 1. NRC Information Notice 95-35, "Degraded Ability of Steam Generators to Remove Decay Heat by Natural Circulation."

2. Westinghouse Letter # FENOC-04-228, "Beaver Valley Units 1 and 2 Mode 5, Loops Filled l Natural Circulation Cooling Assessment, dated January 31, 2005."

WOG STS B 3.4.7 - 5 Rev. 2, 04/30/01 126

RCS Loops - MODE 5, Loops Not Filled B 3.4.8 Rev. 2 Change C-5 BASES ACTIONS (continued) assure continued safe operation. With coolant added without forced circulation, unmixed coolant could be introduced to the core, however coolant added with boron concentration meeting the minimum SDM maintains acceptable margin to subcritical operations. The immediate Completion Time reflects the importance of maintaining operation for heat removal. The action to restore must continue until one loop is restored to OPERABLE status and operation. SURVEILLANCE SR 3.4.8.1 REQUIREMENTS This SR requires verification every 12 hours that the required loop is in operation. Verification includes flow rate, temperature, or pump status monitoring, which help ensure that forced flow is providing heat removal. The Frequency of 12 hours is sufficient considering other indications and alarms available to the operator in the control room to monitor RHR loop performance. SR 3.4.8.2 Verification that each required pump is OPERABLE ensures that an additional pump can be placed in operation, if needed, to maintain decay not in operation, heat removal and reactor coolant circulation. Verification is performed by nrifying proper breaker alignment and power available to each required pun. Alternatively, verification that a pump is in operation also verifies proper breaker alignment and power availability. The Frequency of 7 days is considered reasonable in view of other administrative controls available and has been shown to be acceptable by operating experience. This SR is modified by a Note that states the SR is not required to be performed until 24 hours after a required pump is not in operation. REFERENCES None. WOG STS B 3.4.8 - 3 Rev. 2, 04/30/01 129

Pressurizer Safety Valves I Rev. 2 Change D-17 I B 3.4.10 B 3.4 REACTOR COOLANT SYSTEM (RCS) B 3.4.10 Pressurizer Safety Valves The Unit 1 pressurizer safety valve-are totally enclosed, pilot-actuated, self-actuated valves. The Unit 2 BASES

L__ BACKGROUN( The pressurizer safety valves provide, in conjunction withl he Reactor Protection System, overpressure protection for the RCS. Me pressurizer is 345,000 Ibm/hr safety valves are totally enclosed pop type, spring loaded, self actuated (Unit 1) and 378.200 valves with backpressure compensation. The safety valves are designed Ibm-/hr (Unit 2). The to prevent the system pressure from exceeding the system Safety Limit capacity of the pressurizer safety (SL), 12735*psig, which is 110% of the design pressure. valves is based on the valve geometry. Because the safety valves are totally enclosed and self actuating, they The pressurizer are c%3siderad incipdendent components. The relief capacity for each safety valve capacity is used in the analysis vnlptIvrzl based on postulated overpressuni inciss of the complete loss conditions resulting fro t the turbine. of steam flow to the This event results n su O the presiunzer. wbich _ turbine event, to demonstrate that the um relief capacity for the safe The discharg capacity is sufficient flow from the pressurizer safety valves is directed to the pressurizer relief to maintain RCS pressure below 110% tank. This discharge flow is indicated by an increase in temperature of the design downstream of the pressurizer safety valves or increase in the pressurizer pressure. relief tank temperature or level. Overpressure protection is required in MODES 1, 2, 3, 4, and 5; however, in MODE 4, with one or more RCS cold leg temperatures

127-50F] [Low

                                         ~fpratust~                     PrAcefiotna LTP rmin temperature specified in the PTLR], and MODE 5 and MODE 6 with the reactor vessel head on, overpressure protection is provided by operating procedures and by meeting the requirements of LCO 3.4.12, "Low Temperatur.:e Overpressure Protection (LTOP) Sy                          s    teO The 1%ASME tolerance I

requirement is met by The upper and lower pressure limits are based on the +/- 1% tolerance ass nring the as left lift setting requirement (Ref. 1) for lifting pressures above 1000 psigAThe lift setting is %ithin 1% of 2485 psig. is for the ambient conditions associated with MODES 1, 2, and 3. This requires either that the valves be set hot or that a correlation between hot and cold settings be established. 4 The pressurizer safety valves are part of the primary success path and mitigate the effects of postulated accidents. OPERABILITY of the safety valves ensures that the RCS pressure will be limited to 110% of design pressure. The consequences of exceeding the American Society of Mechanical Engineers (ASME) pressure limit (Ref. 1) could include damage to RCS components, increased leakage, or a requirement to perform additional stress analyses prior to resumption of reactor operation. WOG STS B 3.4.10 - 1 Rev. 2, 04/30/01 135

Rev. 2 Change B-1 Pressurizer Safety Valves B 3.4.1(0 BASES 2 The lift setting shall correspond to ambient conditions of the valve at nominal temperature and pressure. Nominal temperature and pressure includes MODE 3 operating conditions as provided in the Applicabilivy Note allowing 54 hours for testing and examination of the ACTIONS (continued) valves in MODE 3. power and pressure), lo'Ners the potential for large pressurizer insurges, and thereby removes the need for oprpressure protection by [three] pressurizer safety valves. / SURVEILLANCE SR 3.4.10.1 / REQUIREMENTS SRs are specified in the Inservi/e Testing Program. Pressurizer safety s are +/- 3% of 2485 psig valves are to be tested in acco tance with the requirements of SeGtion XI for Unit 1and +1.6%/-3% of the ASME Code (Ref. 4), wiich provides the activities and Frequencies I of 2485 psig for Unit 2 necessary to satisfy the SRs. No additional requirements are specified. of 2485

                        ' "I nraccitrizer The             'lA cnfetfv
                                                - -y   valve
                                                        .S -aw cefnnin owa'        MI     for Q1                            psig however, the valves are reset to +/- 1 1                  drift.

REFERENCES 1. ASME, Boiler and Pressure Vessel Code, Section 1II. code for Operation and Maintenance of Nuclear Power Plants. WOG STS B 3.4.10 - 4 Rev. 2, 04/30/01 138

Rev. 2 Change D-17 Pressurizer PORVs B 3.4.11 B 3.4 REACTOR COOLANT SYSTEM (RCS) B 3.4.11 Pressurizer Power Operated Relief Valves (PORVs) BASES BACKGROUND The pressurizer is equipped with two types of devices for pressure relief: pressurizer safety valves and PORVs. The PORVs are air operatedl (N valves ha are controlled to open at a specific set pressure when the pressurizer pressure increases and close when the pressurizer pressure decreases. The PORVs may also be manually operated from the control room. Block valves, which are normally open, are located between the pressurizer and the PORVs. The block valves are used to isolate the PORVs in case of excessive leakage or a stuck open PORV. Block valve closure is accomplished manually using controls in the control room. A stuck open PORV is, in effect, a small break loss of coolant accident (LOCA). As such, block valve closure terminates the RCS depressurization and coolant inventory loss. The PORVs and their associated block valves may be used by plant operators to depressurize the RCS to recover from certain transients if normal pressurizer spray is not available. Additionally, the series arrangement of the PORVs and their block valves permit performance of surveillances on the valves during power operation. The PORVs may also be used for feed and bleed core cooling in the case of multiple equipment failure events that are not within the design basis, such as a total loss of feedwater. The P R ,-eblock valves, and their controls are poe1 INSERT vital buses that normi-at ypower fro s oer sources, but are also capable of being po rncy power sources in the event of a los r. Two PORVs a sociated block val powered from two separate safety trains (Ref. 1): Each PORV has a relief capacity of A _c A W , each having a rolief capacity of 210,000 lb/h, 210,000 Ibrn/hr at at 2335 psig. The functional design of the PORVs is based on 2500 psia for Unit maintaining pressure below the Pressurizer Pressure - High reactor trip ibm/hr at 2350 psia setpoint following a step reduction of 50% of full load with steam dump. for Unit 2. In addition, the PORVs minimize challenges to the pressurizer safety valves and also may be used for low temperature overpressure protection (1.41). See LCO 3.4.12, "Low Tomperaturo Overpressure Protection (ITOP) System I WOG STS B 3.4.11 - 1 Rev. 2, 04/30/01 139

Pressurizer PORVs I Rev. 2 Ch B 3.4.11 BASES ACTIONS (continued) lbasedcn the small Potential for- challenaes to the sVytem

                               - - -                                         I during this time
                       - -1 __
                     -_n_

3_ pr4VIao _. . 0OFMCo Wim 1o cORr Ma SiualioR. The Required Actions F.1, F.2, and F.3 are modified by a Note stating that the Required Actions do not apply if the sole reason for the block valve being declared inoperable is a result of power being removed to comply with other Required Actions. In this event, the Required Actions for inoperable PORV(s) (which require the block valve power to be removed once it is closed) are adequate to address the condition. While it may be desirable to also place the PORV(s) in manual control, this may not be possible for all causes of Condition B or E entry with PORV(s) inoperable and not capable of being manually cycled (e.g., as a result of failed control power fuse(s) or control switch malfunctions(s)). G.1 and G.2 If the Required Actions of Condition F are not met, then the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours and to MODE 4 within 12 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. In MODES 4 and 5, automatic PORV OPERABILITY may be required. See LCO 3.4.12. SURVEILLANCE SR 3.4.11.1 REQUIREMENTS Block valve cycling verifies that the valve(s) can be opened and closed if needed. The basis for the Frequency of 92 days is the ASME CodeT SeGtion XI (Ref. 3). The Nate This SR is modified by t Note]. modifies this SR by stating that 3__ it is not required to be performed with the block valve closed in accordance with the Required Actions of this LCO. Opening the block valve in this condition increases the risk of an unisolable leak from the RCS since the PORV is already inoperable. hNote 2 modifies this SR to allow ontr3 into and epcration in MODE 3 prior to pernfoin the SR-. This allows the test to be performed in MODE 3 undor operating temperature and preoro cGnditionc, prior to entering MODE= 1 or2r.-[n accordance with Reference 1, administrative controls require this t9at be pe&rmFod in MODE 3 cr1 to adequately cimulato operating temnpreature and pressure effects oan PORV oeation WOG STS B 3.4.11 - 6 Rev. 2, 04/30/01 144

Rev. 2 Change B-1I Pressurizer PORVt; B 3.4.11 YiJAw~ BASES .1 and SR 3.4.11.2.2 l Inaddition, the Unit I surveillance (SR3.4.11.2.1) requires thateach PORV be cycled using both the normal air supply and the tackup nitrogen supply. Cycling the Unit 1 PORVs using both the normal and VEILANC REUIR MENT (c tined) backup supply systems actuates the solenoid control valve:. and o-VEILLANCE REQUIREMENTS (nued) check valves to ensure that both the normal and backup supplies are rhese Unit 1 and22 R 3.4.11.2 surveillances\ _surveilances2 requires a complete cycle of each rating a PORV through one complete cycle ensures th t the PORV can be 3 Tle surveillances manually actuated for mitigation of an SGTR. The Frequency of ar modified by f18-months is based on a typical refueling cycle and industry accepted Notes that identify practice. The Note modifies this SR to allow entry into and operation in MODE nor to performing the SR. This allows the test to be performed E 3 under operating temperature and pressure conditions neor to entea MODE 1 or 2. [In accordance with Reference 4, a inistrative controls uire this test be performed in MODE 3 or 4 adequately simulate o ting temperature and pressure effect PORV operation.] [SR 3.4.11.3 Operating the solenoid control valvend check valves on the air accumulators ensures the RV co of system actuates properly when called upon. The Frequency o onths is based on a typical refueling cycle and the Frequ cy the other Surveillances used to demonstrate PORV OPE ILITY.\ [ SR 3.4.11.4 /\ This Surveilla e is not required for plants with p anent I E power suppliese Iaves.\ The rveillance demonstrates that emergency power can provided is performed by transferring power from normal to emerge supply and cycling the valves. The Frequency of [18] months is based on typical refueling cycle and industry accepted practice. l REFERENCES 1. Regulatory Guide 1.32, February 1977.

2. SR 8tQ 4~4 ASME, Boiler ad P~e5GUFO Ve66ekCode,StGtinnXI code for Operation an J

                                                                                                             -,   Maintenance I     UFSAR Chapter 14 (Unit 1), and UFSAR Chapter 15 (Unit 2)

III of Nudear Power Plants. WOG STS B 3.4.11 - 7 Rev. 2, 04/30/01 145

I Rev. 2 Change D-17 I TOP 2y;41a K) B 3.4 REACTOR COOLANT SYSTEM (RCS) B 3.4.12 Low Tempeiatufa Overpressure Protection 10P) Syste 13 BASES P BACKGROUND The H em controls RCS pressure at low temperatures so the integrity of the reactor coolant pressure boundary (RCPB) is not compromised by violating the pressure and temperature (P/T) limits of 10 CFR 50, Appendix G (Ref. 1). The reactor vessel is the limiting RCPE; component for demonstrating such protection. The PTLR provides the maximum allowable actuation logic setpoints for the power operated relief 2. valves (PORVs) and the maximum RCS pressure for the existing RCS temperature during cooldown, shutdown, and heatup to meet the Reference ments during the MODE wheMDlow temperature The reactor vessel material is les tuh at low temperatures than at overpressure normal operating temperature. As the vessel neutron exposure protection is accumulates, the material toughness decreases and becomc eesl requiredl to pre66uro st ess at low temperatures (Ref. 2). RCS pressure, _esirtast therefore, is maintained low at low temperatures and is increased only as temperature is increased. The potential for vessel overpressurization is most acute when the RCS is water solid, occurring only while shutdown; a pressure fluctuation can occur more quickly than an operator can react to relieve the condition. Exceeding the RCS P/T limits by a significant amount could cause brittle cracking of the reactor vessel. LCO 3.4.3, "RCS Pressure and Temperature (P/T) Limits," requires administrative control of RCS In addition, the Unit 1 pressure and temperature during heatup and cooldown to prevent ECCS automatic high head safety injection exceeding the PTLR limits. (HHSI) flow path must be isolated. This LCO provides RCS overpressure prote ion by having a minimum f coolant input capability and having adequae pressure relief capacity Limiting coolant input capability requires a but injoction (HPI)] pump [ Pd one charging pomp] incapable of injection into the RCS and isolating the accumulators. The pressure relief capacity requires either two redundant RCS relief valves or a depressurized RCS and an RCS vent of sufficient size. One RCS relief valve or the open RCS vent is the overpressure protection device that acts to terminate an increasing pressure event. aid With mkiimum coolant input capabilityhe ability to providLore coolant when low temperature additionis restricted. he LCO doo not ui the makeup or oe rI overpressure protection is 67TxTTW}v n~itp ci~ztimtai in. r cs~faltv intianfimn (S1) szrt- stinn c-ircuwits,blo-kckL. Vow §VWVYT[VVWXS VVWV __ required Due to the lower pressures in the ITOP MODES'Iid the exper tEo-WOG STS B 3.4.12 - 1 Rev. 2, 04/30/01 149

Rev. 2 Change B-1 RCS PIV Leakage B 3.4.14 for all

                                 /E                                                                                                          listed in I/The                                list of valves for which this surveillance is                                 p_o toeR

~CTS ]SUR V ELgC SR 3.4.14. 1 applicable is contained in the LRM. ientoeringo REQUIRE NTS _ Mode 2 To satisfy ALARA Performance of leakage testing on each RCS PIV or iso n valve used aler plant the is requirements, leakage may to satisfy Required Action A.1 andis required to placed in be measured indirectly (as verify that leakage is below the specified limit and to identify each leaking MODE 5 pressure indicators) if valve. The leakage limit of 0.5 gpm per inch of nominal valve diameter up r accomplished in accordance to 5 gpm maximum applies to each valve. Leakage testing requires a with approved procedures stable pressure condition. and supported by computations showing that the method is capable of For the two PIVs in series, the leakage requirement applie each valve demonstrating compliance individually and not to the combined leakage across valves. If the within the valve leakage PIVs are not individually leakage tested, one va ay have failed valves where the leakage completely and not be detected if the other e in series meets the rate can be continuously leakage requirement. In this situation, prot i provided by monitored during plant operation, no other leakage redundant valves would be lost. f rate testing is required. The leakage rate of valves Testing is to be performed continously monitored shall be recorded at intervals that th p dM E t T satisfy the required Frequenc sGent wh 10 CFR 50.55a( Ref ) as contain d in the surveillance Frequency. lnserv Testing Program, is within frequency allowed by the Am ican

    ,which results in testing the               of Mechanical Engineers (ASME) Code-SeGtioGi-Xl-(Ref. ) and is PlVs approximately every            ased on the need to perform such surveillances under the conditions thaH 18 months, is within the           apply during an outage and the potential for an unplanned transient if the does not requirements of                    Surveillance were performed with the reactor at power. 4                                        predude performance of In a" Wo testing must be performed once after the valve                                         this opened by flb            ercised to ensure tight reset                           disturbed in power, if the performance of this                llance sho            o be tested unless                  necessary to documentation shows that an i                    ting loop cannot practically be                 OPERABILITY, narior to entealng MODE 2            avoided. Testing mu                 erformed withn                rs after the valve has when itcan be whenever the unit has been            been reseale         ithin 24 hours is a reasonable an                         al time limit accomplished ir MODE 5 for 7 days or              fing             this test after opening or reseating a valve,                                   mainea     ra.

rrore, if leakage testing has manner.i n at been performed in the p evious 9 months is The leakage limit is to be met at the RCS pressure associated with a )plicable to certain PIVs. MODES 1 and 2. This permits leakage testing at high differential ITodified by a note that pressures wth-stable Gn 6itkel not possible in the MODES with lower clarifies that this Frequency is l higher o ily applicable to PIVs ' ' .' . '.\8 specifically identified in the Entry into MODES 3 and 4 is allowed to establish the l locl;ary alditional testing isspeLrTed differential pressures nondi f or performance of fcr PIVs identified as "Event this Surveillance. The Note that llows this provision is complementary to (potential toss of coolant the Frequency of prior to entry int? MODE 2 whenever the unit has been a cident outside containment) type PlVs in MODE 5 for 7 days or more, if leakage testing has not been performed amnsistentwith References 2 in the previous 9 months. In additi n, this Surveillance is not required to aid 3. - if necessary WOG STS B 3.4.14 - 5 Rev. 2, 04/30/01 172

RCS PIV Leakage B 3.4.14 ILRv.2 hange B1I BASES SURVEILLANCE REQUIREMENTS (continued) Note 3 provides the allowance be performed on the RHR System when the RHR System is aligned to that the RCS PIV leakage may be the RCS in the shutdown cooling mode of operation. PIVs contained in vet fied at a pressure lower than the required RCS pressure range the RHR shutdown coollng flow path must be leakage rate tested after provided the observed leakage RHR is secured and stable unit conditions and the necessary differential rates are adjusted to the function pressures are established. maximum pressure in accordance wits ASME OM Code (Ref. 4). R 3.4.14.2 and SR 3.4.14.3 I Note 4 provides an exception to the 0.5 gpmdlnch diameter lea kage limit of the LCO. The Verifying t the RHR autoclosure interlocks are OPERABLE ues Ncte allows leakage rates > 0.5 that ROS presre will not pressurize the RHR system be 125% of gp W/inch diameter but *5.0 gpm its design pressur [600] psig. The interlock setpoi at prevents the tot 3tprovided the latest me asured rate has not exceeded valves from being open.is set so the actual R ressure must be the rate determined by the < [425] psig to open the val This setpo nsures the RHR design previous test by an amount that pressure will not be exceeded an- e relief valves will not lift. The reduces the margin between me asured leakage rate and the [18] month Frequency is based on ed to perform the Surveillance mz ximum permissible rate of 5.0 under conditions that apply dig a plant o e. The [181 month gp n by 2 50%. Frequency is also accep e based on conside ion of the design reliability (and coniin operating experience) of t uipment. These SR modified by Notes allowing the RHR autoclos function to be bled when using the RHR System suction relief valves fold o~pressure protection in accordance with SR 3.4.12.7. ] WASH-1400 (NUREG-75/014), Appendix V, October 1975. I NUREG-0677, May 1980. code for Operation and Maintenance of Nuclear Power Plants. EK6' Documontl GOntamma 1r.1of 11V.L& A by A_ ram!@__ __ AWL toi~e~--r J aa ossur vesse-l 6oaa. Section A.' _ V e I

8. 10 GFR 50.55a(g);

WOG STS B 3.4.14 - 6 Rev. 2, 04/30/01 173

Rev. 2 Change D-17 l BVPS ISTS Conversion I13.4 Reactor Coolant System Enclosure 2 Changes to The ISTS Bases ITS 3.4.12 Overpressure Protection System (OPPS) Bases JUSTIFICATION FOR DEVIATION (JFD)