L-07-010, License Amendment Request Nos. 296 and 169, Improved Standard Technical Specification Conversion, Draft Amendment and Safety Evaluation Comments

License Amendment Request Nos. 296 and 169, Improved Standard Technical Specification Conversion, Draft Amendment and Safety Evaluation Comments

ML070360546
Person / Time
Site:	Beaver Valley
Issue date:	02/01/2007
From:	Lash J FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-07-010, LAR 169, LAR 296
Download: ML070360546 (66)

Text

FENOC FirstEnergy Nuclear Operating Company James H. Lash 724-682-5234 Site Vice President Fax: 724-643-8069 February 1, 2007 L-07-010 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 License Amendment Request Nos. 296 and 169, Improved Standard Technical Specification Conversion, Draft Amendment and Safety Evaluation Comments FirstEnergy Nuclear Operating Company (FENOC) License Amendment Request (LAR)

Nos. 296 and 169 proposed changes to the Beaver Valley Power Station (BVPS) Unit Nos. 1 and 2 Technical Specifications to convert those Technical Specifications to the Improved Technical Specifications (ITS) for Westinghouse Plants, NUREG-1431. In addition, LAR Nos. 296 and 169 included changes necessary to combine the BVPS Unit Nos. 1 and 2 Technical Specifications into a single set of Technical Specifications for both BVPS units. The BVPS ITS conversion LAR was originally submitted by FENOC letter L-05-027 dated February 25, 2005.

By letter dated January 4, 2007, the NRC issued a draft Amendment and Safety Evaluation (SE) for the BVPS Unit Nos. 1 and 2 ITS Conversion LAR and requested that FENOC review the draft Amendment and SE and provide written comments within 30 days.

The purpose of this letter is to provide the requested FENOC comments on the draft Amendment and SE. The comments are provided in the attachment to this letter. The comments are provided in the form of marked-up pages of the draft Amendment and SE.

The attachment includes only the pages affected by FENOC comments.

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.

ADOo

License Amendment Request Nos. 296 and 169, Improved Standard Technical Specification Conversion, Draft Amendment and Safety Evaluation Comments L-07-010 Page 2 No new regulatory commitments are contained in this submittal.

questions or if additional information is required, please contact Mr.

Supervisor - FENOC Fleet Licensing, at (330) 315-6944.

If there are any Henry L. Hegrat, I declare under penalty of perjury that the foregoing is true and correct. Executed on February 1, 2007.

Sincerely, H. Lash

Attachment:

Marked-up pages of draft Amendment and SE showing FENOC comments.

c:

Ms. N. S. Morgan, NRR Project Manager Mr. P. C. Cataldo, NRC Senior Resident Inspector Mr. S. J. Collins, NRC Region I Administrator Mr. D. J. Allard, Director BRP/DEP Mr. L. E. Ryan (BRP/DEP)

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR)

Nos. 296 (Unit 1) & 169 (Unit 2)

A TTA CHMENT (to L-07-010)

MARKED-UP PAGES FROM DRAFT AMENDMENT AND SAFETY EVALUATION SHOWING FENOC COMMENTS

BVPS-DRAFT 2.

Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Facility Operating License No. DPR-66 is hereby amended to read as follows:

(2)

Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 278, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

a,,

This ent authorizes the relocation of certain current Technical Speci requirementsing license conditioons ac N

s s

et lua ee-,;ich i oculos ents.

Implementation of this a Cndtshall includ e toe A

these rerements to the other documents, as describe 1

.0 of the NRC staff's Safety Evaluation, and (2) Table LA of e

D Table R of Relocated Specifications att C staff's Safety Evalo which is eenclosed with this amendme e.*rrw License Condition has been added to Aplpen i ddress the Relocation of Certain Technical Specification Requirements License Amendment No. 278 authorizes the relocation of certain Technical o n Specifications to other licensee-controlled documents. Implementation of this amendment shall include relocation of the requirements to the specified documents, as described in (1) Sections 4D and 4E of the NRCus staff's Safety Evaluation, and (2)

• *Table LA, Removed Detail Changes, and Table R, Relocated Specifications, attached-to/

the RC staff's Safety Evaluation, which is enclosed in this amendment.

License condition, 2.C.(9), is deleted.

I the relocation of Technical Specification requirements and the New license conditions are added in Appendix C to addres~performanoe of new and revised Surveillance Requirements (SRs):

Schedule for New and Revised Surveillance Realuirements (SRs) 4-jI The schedule for performing the new or revised SRs in Amendment No. 278 shall be as follows:

For SRs that are new in this amendment, the first performance is due at the end of the first surveillance interval, which begins on the date of implementation of this amendment.

DRAFT

BVPS-2 DRAFT 2.

Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Facility Operating License No. NPF-73 is hereby amended to read as follows:

(2)

Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 161, and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto are hereby incorporated in the license. FENOC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

"3, This a tauthorizes the relocation of certain current Technical Spe '""n reurmnsa iglicense conditions to other licensee documents.

Implementation f this ame t shall include the r n of these requirements to the other documents, as describedi of the NRC staff's Safety Evaluation, and (2) Table LA ofee able R of Relocated Specifications attach e NRC staff's Safety Evalua hich is enclosed with this amendme W License Condition has been added to Appen o address the R elocation of Certain Technical SpecificatinRqieet License Amendment No. 161 authorizes therloaion of certain Technic1al Specifications to other licensee-controlled documents. Implementation of this"'

amendment shall include relocation of the requirements to the specified documents, as described in (1) Sections 4D and 4E of the NRC's staff's Safety Evaluation, and (2)

[

Table LA, Removed Detail Changes, and Table R, Relocated Specifications, attached to the NRC staff's Safety Evaluation, which is enclosed in this amendment.

"4, License condition, 2.C.(12), is deleted.

the relocation of Technical Specification requirements and the New license conditions are added in Appendix D to addresserformance of new and revised Surveillance Requirements (SRs):

4 Schedule for New and Revised Surveillance Requirements (SRs)

The schedule for performing the new or revised SRs in Amendment No. 161 shall be as follows:

DRAFT

Changes necessary to combine the BVPS-1 and 2 TS into a single document.

DRAFT Among the changes proposed by th licensee and found acceptable by the NRC staff are:

0 Identifying plant-cific wording for system names, etc.;

uirements currently grouped under a single current specification and moving them to more appropriate locations in two or more specifications of the ITS; Combining related requirements currently presented in separate specifications of the CTS into a single specification of ITS; Presentation changes that involve rewording or reformatting for clarity (including moving an existing requirement to another location within the TSs) but that do not involve a change in requirements; Wording changes and additions that are consistent with CTS interpretation and practice and that more clearly or explicitly state existing requirements; Deletion of TSs that no longer apply; Deletion of details that are strictly informational and have no regulatory basis;

and, Deletion of redundant TS requirements that exist elsewhere in the TSs.

Table A attached to this SE lists the dminjstrative nges being made in the BVPS-1 and 2 ITS conversion. Table A is organiz d in ATS rder whi includes the following:

1.

ITS/CTS Section; section

2.

DOC identifier;

3.

Summary description o e administrati changes; and

4.

Reference to ITS and CT uireme The NRC staff reviewed all of the administrative and editorial changes listed in Table A and finds them acceptable because they are compatible with the Writer's Guide and the ISTSs, do not result in any change in operating requirements, and are consistent with the Commission's regulations.

B. More Restrictive Changes to the CTS The licensee, in electing to implement the specifications of the ISTSs, proposed a number of requirements that are more restrictive than those in the CTSs. The ITS requirements in this category include requirements that are either new, more conservative than corresponding requirements in the CTSs, or have additional restrictions that are not in the CTSs, but are in the ISTSs. Examples of more restrictive requirements are placing an LCO on plant equipment that is not required by the CTS, more restrictive requirements to restor equipment, and more restrictive SRs. Table M attached to this SE lists the mor restrictive chan es being made in the BVPS-1 and 2 ITS conversion. Table M is organiz d in ITS rder whi includes the following:

1.

ITS/CTS Section; section

2.

DOC identifier; DRAFT DRAFT Category 8 -

Deletion of Reporting Requirements The CTS contains requirements that are redundant to reporting regulations in 10 CFR.

For example, CTSs include requirements that a "Reportable Event" is any of those conditions specified in 10 CFR 50.73. However, consistent with the ISTSs, the ITSs would omit many of the CTS reporting requirements because the reporting requirements in the regulations cited do not need repeating in the TSs to ensure timely submission to the NRC. Therefore, Category 8 changes have no impact on the safe operation of the plant. Deletion of these requirements is beneficial because it reduces the administrative burden on the licensee and in turn allows increased attention to plant operations important to safety.

Table L attached to this SE lists e less restrictive chang to the BVPS-1 and 2 ITS conversion. Table L is organize in I rder which inc des the following:

1.

ITS/CTS Section;\\

section

2.

DOC identifier;

3.

Summary description each less restric ve change adopted;

4.

Reference to ITS and CT -

r.em.e; and

5.

Type of change.

The NRC staff reviewed the less restrictive changes described in Table L and found them acceptable because they are consistent with current licensing practices and the Commission's regulations. The BVPS-1 and 2 designs were also reviewed to determine if the specific design bases and licensing bases are consistent with the technical basis for the model requirements in the ISTSs, and thus provide an acceptable basis for approval of the ITSs.

D. Removed Details When requirements have been shown to give little or no safety benefit, their removal from the TSs may be appropriate. In most cases, relaxations previously granted to individual plants on a plant-specific basis were the result of (1) generic NRC actions, (2) new NRC staff positions that have evolved from technological advancements and operating experience, or (3) resolution of the owners groups' comments on ISTSs.

A significant number of changes to the CTSs involved the removal of specific requirements and detailed information from individual specifications. These changes were grouped in the following categories:

Type 1 - Removing Details of System Design and System Description, Including Design Limits The design of the facility is required to be described in the UFSARs by 10 CFR 50.34.

In addition, the quality assurance (QA) requirements of Appendix B to 10 CFR Part 50 require that plant design be documented in controlled procedures and drawings and DRAFT DRAFT maintained in accordance with an NRC-approved Quality Assurance Progr Description (QAPD). The regulations at 10 CFR 50.59, specify controls r changing the facility as described in the UFSARs. The regulations at 10 CFR 50.54 ), specify criteria for changing the QAPD. The Licensing Requirements Manua (LRM) is a general reference in the UFSARs and changes to it are accordingly s bject to 1 FR 50.59. The ITS Bases also contain descriptions of system design. I1 5.5.

pecifies controls for changing the Bases. Removing details of system design i acceptable because the associated CTS requirements which are being retained wit these details are adequate to ensure safe operation of the facility. In addition, retaining suc details in TSs is unnecessary to ensure proper control of changes. For example, cycle-specific design limits are contained in the Core Operating Limits Report (COLR) in accordance with Generic Letter (GL) 88-16, "Removal of Cycle-Specific Parameter Limits From Technical Specifications," dated October 3, 1988.

Since the CTS requirements retained are adequate to ensure safe operation of the facility, the NRC staff concludes that it is acceptable to remove Type 1 details from the CTS and place them in licensee-controlled documents.

Type 2 - Removing Descriptions of System Operation The plans for normal and emergency operation of the facility are required to be described in the UFSARs by 10 CFR 50.34. ITSs 5.4.1.a and 5.4.1.e will require written procedures to be established, implemented, and maintained for plant operating procedures recommended in Appendix A of Regulatory Guide (RG) 1.33, "Quality Assurance Program Requirements (Operation)," Revision 2, dated February 1978, and in all programs specified in ITS Section 5.5, respectfully. The ITS Bases also contain descriptions of system operation. Controls specified in 10 CFR 50.59 apply to changes in procedures as described in the UFSARs and LRM. ITS 5.5.10 specifies controls for changing the Bases. Removing details of system operation is acceptable because the associated CTS requirements being retained without these details are adequate to ensure safe operation of the facility. In addition, retaining such details in TSs is unnecessary to ensure proper control of changes. Therefore, it is acceptable to remove Type 2 details from the CTS and place them in licensee-controlled documents.

Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements Details for performing TS SRs or for regulatory reporting are more appropriately specified in the plant procedures. Prescriptive procedural information in a TS requirement is unlikely to contain all procedural considerations necessary for the plant operators to comply with TSs and all regulatory reporting requirements, and referral to plant procedures is therefore required in any event. Changes to procedural details include those associated with limits retained in the ITS. For example, ITS 5.4.1 requires that written procedures covering activities that include all programs specified in ITS 5.5 be established, implemented, and maintained. ITS 5.5.4, "Inservice Testing Program,"

DRAFT

ITS DRAFT requir s a pr ram to prov de controls for inservice testing (IST) of American Society of Mecha ical E gineers Boil 3r and Pressure Vessel Code (ASME Code), Class 1, 2, and 3 comp nents. The progr m includes defining testing frequencies specified in the ASME 0 ratio and Mai tenance Standards and Codes (OM Codes), and applicable addenda.

e Iso ontain requirements to test specific components such as pumps and v s,an stablish IST of Quality Group A, B, and C pumps and valves performed in accor ance with the requirements for ASME Code, Class 1, 2 and 3 components specified in the ASME OM Codes and addenda, subject to the applicable provisions of 10 CFR 50.55a.

ITS Section 5.5.13, "Battery Monitoring and Maintenance Program" contains programmatic requirements for battery restoration and maintenance.

Since the CTS requirements retained are adequate to ensure safe operation of the facility, the NRC staff concludes that it is acceptable to remove Type 3 details from the CTS and place them in licensee-controlled documents.

Type 4 - Removal of Administrative Requirements Redundant to Regulations Certain CTS administrative requirements are redundant to regulations and thus are relocated to the UFSARs or other appropriate licensee-controlled documents, including the LRM, ODCM, QAPD, or ISI Plan (lIP). The Final Policy Statement allows licensees to relocate to licensee-controlled documents, CTS requirements that do not meet any of the criteria for mandatory inclusion in the TSs. Changes to the facilities or to procedures as described in the UFSARs are made in accordance with 10 CFR 50.59.

Changes made in accordance with the provisions of other licensee-controlled documents are subject to the specific requirements of those documents. For example, 10 CFR 50.54(a) governs changes to the QAPD, and ITS 5.5.10 governs changes to the ITS Bases. Based on the above, the NRC staff has determined that it is acceptable to remove Type 4 details from CTS and place them in licensee-controlled documents.

Type 5 - Removing Performance Requirements for Indication-Only Instrumentation and Alarms Certain CTS requirements are for instruments and alarms that are not required for operability of the LCO-required equipment, and thus may be relocated to the UFSAR or other appropriate licensee-controlled documents. Changes to the facility or to procedures as described in the UFSARs are made in accordance with 10 CFR 50.59.

Changes made in accordance with the provisions of other licensee-controlled documents are subject to the specific requirements of those documents. For example, 10 CFR 50.54(a) governs changes to the QAPD, and ITS 5.5.10 governs changes to the ITS Bases. Based on the above, the NRC staff has determined that it is acceptable to remove Type 5 details from CT ce them in licensee-controlled documents.

Table LA attached to this SE lists th proposed remove tail changes to the BVPS-1 and 2 ITS conversion. Table LA is organi ed in ITS "Zr ch I cludes the following:

DPR DRAFT E.2 Post-Accident Monitoring (PAM) System LCO CTS 3.3.3.8, DOC R.1 The following BVPS-1 and 2 CTS PAM functions are proposed for relocation to the LRM:

RCS Subcooling Margin Monitor Power-Operated Relief Valve (PORV) Limit Switch Position Indicator PORV Block Valve Limit Switch Position Indicator Safety Valve Position Indicator (BVPS-2), and Safety Valve Acoustical Detector Position Indicator (BVPS-1)

Discussion The purpose of the PAM instrumentation included in the TSs is to function in a post-accident environment to provide the following:

Primary indications necessary for operators to take manual actions (for which no automatic control is provided) to mitigate the consequences of an accident (i.e, RG 1.97, Type A variables), and Key indications (i.e, RG 1.97, Category 1 variables) that may be dee ed.rk significant because they are used to:

D

• Determine whether a system important to safety is performing its intended

function, Determine the likelihood of a gross breach of a barrier to radioactive release, or Determine the need to initiate action to protect the public and to estimate the magnitude of the threat.

10 CFR 50.36(c)(2)(ii), Criterion 1, applies to instrumentation used to detect RCS leakage and is satisfied by the instrumentation included in the RCS Leakage Detection Instrumentation TS.

10 CFR 50.36(c)(2)(ii), Criterion 2, applies to a process variable, design feature, or operating restriction that must be maintained within limits by a TS requirement to preserve an initial condition assumed in a DBA. Individual TSs for process variables such as boron concentration and operating limits such as Rod Insertion Limits address items that satisfy 10 CFR 50.36 (c)(2)(ii), Criterion 2. Based on the description of the PAM functions above, a required PAM TS indication may satisfy either Criterion 3 (primary indication to initiate an action) or Criterion 4 (risk) of 10 CFR 50.36(c)(2)(ii) when evaluating individual indications for retention in the PAM TS. Each BVPS-1 and 2 indication proposed for relocation is evaluated below.

DRAFT DRAFT or Monitor variables which operating experience or probabilistic risk assessment has shown to be significant to public health and safety.

Based on the above discussions, the alarm function of the BVPS-1 and 2 containment area radiation monitors and the BVPS-2 main steam discharge radiation monitors do not satisfy any of the 10 CFR 50.36(c)(2)(ii) criteria for retention in the TSs. Therefore, the proposed change to relocate the TS requirements for the above alarms is acceptable.

2.

BVPS-2 Main Steam Discharge Effluent Radiation Indication The BVPS-2 Main Steam Discharge Radiation indication may be used for the diagnosis of a steam generator tube rupture (SGTR) accident, which prompts an operator action for which no automatic actuation is provided. However, with the low fuel rod leakage history of current operating plants, secondary side radiation is not a reliable indicator of an SGTR accident. The history of diagnosis and response to an SGTR accident has typically been based on increased RCS inventory losses (e.g., decreasing pressurizer level and RCS pressure) and increasing water level in the affected steam generator (SG). These indications provide the most reliable diagnosis of an SGTR accident to prompt the appropriate operator actions and these indications are included in the PAM TS. In addition, the more sensitive radiation monitors (N16, SG blowdown, and condenser air ejector) are used for early detection of SG tube leakage. As such, the BVPS-2 Main Steam Discharge Radiation indication is not the primary or key indication relied on to diagnose or mitigate an SGTR accident.

Conclusion Therefore, based on the discussions above, the BVPS-1 and 2 Containment Area Radiation alarms and the BVPS-2 Main Steam Discharge Radiation alarm and indication functions do not satisfy either Criterion 3 or 4 of 10 CFR 50.36(c)(2)(ii) and should not be included in the PAM TS. The proposed changes to relocate the TS requirements for the above alarm and indication functions are acceptable.

E.4 Containment Purge and Exhaust Isolation a PS-i Radiation Monitoring LOg BVPS-1 CTS 3/4.3.3.1, 3/4.9.9 DO

.1 Instrument 1.b.i Purge & Exhaust Isolation BVPS-1 CTS 3/4.9.9 Containment P ge and Exhaust Isola n System Purge and Exhaust Isolation BVPS-1 CTS 3/4.3.3.1 Table 3.,,

Radiation Monitorin BVPS-1 CTS 3/4.3.3.1 Tabl

.3-3, InstrumentE 1..Purge & Exhaust Iso ion The above listed C COs contain the requirements for the aut atic and manual isolation of the Containmenturge and Exhaust System for BVPS-1. Th diation monitors specified in CTS 3/4.3.3.1 able 3.3-6 function to automatically isolate the Containment Purge and (RM-IVS 104 A & B)

DRAFT DRAFT Exhaust V es (fM 4 104 A & 1) o high radiation. The LCOs, Actions and SRs associated th the above equipme P

re proposed to be relocated to the LRM.

Discussion The proposed ITS 3.3.6, "Containment Purge and Exhaust Isolation Instrumentation" does not contain requirements for the BVPS-1 automatic or manual Purge and Exhaust System isolation.

ITS 3.3.6 is only applicable to BVPS-2. The CTS is revised to conform to the ITS. This changes the BVPS-1 CTS Purge and Exhaust System requirements for automatic isolation on high radiation and manual isolation by moving the CTS requirements to the BVPS-1 LRM.

The current BVPS-1 and 2 design-basis fuel handling accidents (FHAs) of record do not credit any automatic actuation to mitigate an FHA when moving non-recently irradiated fuel assemblies or fuel over assemblies that are not recently irradiated. Recently irradiated fuel is defined in the TS Bases as "...fuel that has occupied part of a critical reactor core within the previous 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />." Although BVPS-1 and 2 do not currently have safety analyses that support moving recently irradiated fuel assemblies, TS requirements have been retained to address the condition of moving recently irradiated f ies.

e equirements are retained because decay time limits for movi iradatd fuel are in the LRM a ld the NRC staff has determined that fuel handling limits *fould be retained in the TSs should Re licensee develop future capability to move recently* adiated fuel.* in containment The retained TS requirements which are applicable we oigrcently irradiat*: fuel or fuel assemblies over recently irradiated fuel a semblie dmcude Containment Purge,, d Exhaust System isolation for BVPS-2 and Containm tPurge and Exhaust aytm~

nt filtration for BVPS-1. Proposed ITS 3.9.3, "Containment Pe ons, c e BVPS-1 and 2 unit-specific requirements for the Containment Purge and Exhaust System. The current FHA analysis for moving non-recently irradiated fuel and the CTS requirements for moving recently irradiated fuel were approved by the NRC in Amendment Nos. 241 for BVPS-1 and 121 for BVPS-2, issued August 30, 2001.

The relocation of the BVPS-1 requirements for Containment Purge and Exhaust System isolation on high radiation and manual isolation to the LRM is acceptable because BVPS-1 can not credit Containment Purge and Exhaust System isolation to mitigate the consequences of an FHA in containment. Instead, BVPS-1 must rely on filtration of the effluent by an operable train of the Supplemental Leakage Collection and Release System (SLORS) when necessary to mitigate the consequences of an FHA inside containment. BVPS-1 must rely on filtration of the effluent instead of isolation because the Containment Purge and Exhaust System ductwork where the radiation monitors are located is not designed to withstand a seismic event.

Although the radiation monitors provide an isolation signal to the purge and exhaust valves to close, no credit for the isolation signal may be taken in the BVPS-1 design-basis FHA. The NRC staff concurred with this position in the NRC Safety Evaluation Report (SER) for BVPS-1 Amendment No. 23, issued December 12, 1979 (which added the TS requirement for the containment air to be exhausted through the SLCRS), as stated below; DRAFT DRAFT Sections 4.D and 4.E of this SE. The facility and procedures described in the UFSARs, TS Bases, and the LRM can be revised only in accordance with the provisions of 10 CFR 50.59, which ensure that records are maintained, and that appropriate controls are established for requirements removed from the CTSs. Other licensee-controlled documents contain provisions for making changes consistent with applicable regulatory requirements. For example, the ODCM can be changed only in accordance with ITS 5.5.1, and the administrative instructions that implement the QAPD can be changed only in accordance with 10 CFR 50.54(a) and 10 CFR Part 50, Appendix B.

The NRC staff finds that the BVPS-1 and 2 ITS provide clearer, more readily understandable requirements to ensure safer operation of the units. Further, based on the considerations discussed above, the NRC staff finds that the BVPS-1 and 2 ITS satisfies the Commission's Final Policy Statement and 10 CFR 50.36. Based on these findings, the NRC staff has determined concludes that the proposed ITS for BVPS-1 and 2, as documented in the licensee's application and supplemental

• s p,

cc fteos G.

Evaluation of Other TS hanqes (Beyond-Scope Issues) Inc* ded in the Aipplication for Conversion to ITS idniedI This section evaluates other T Z changes' i in Volume 10 he licensee's ITS conversion application. These changes inc de items that deviate from the CTSs and the ISTSs.

These changes are termed Beyont cope Issues BS ey were either identified by the licensee in its ITS application, or by the uring the course of its review. The BSls were included in the Notice of Consideration of Issuance of Amendments to Facility Operating Licenses and Opportunity for a Hearing published in the Federal Register on March 22, 2006 (71 FR 14554).

This section of the SE is divided into BSIs identified by the 1* see (Secti n G.1) and those identified by the NRC staff (Section G.2).

G.1 BSI Changes Identified by the Licensee:

G.1.1 BSIs-1 and 2, "Changes to BVPS-1 Anal g Rod Po ion lndicatio System" BSIs-1 and 2, propose changes to the BVPS-1 nalog d Position dication (RPI) system.

BVPS-2 uses a digital RPI system and the pro osed ange does ot apply to BVPS-2. The proposed changes would modify the CTS 3.1..2 n s to apply t 1-hour thermal soak time to all power levels instead of only to power level 50 perce and to apply the exception to the +/- 12 step-requirement during rod insertio and withdraw provided by the Mode 2 footnote) to any time "during rod motion." The notes would be moved directly to the ITS 3.1.4 LCO (ITS 3.1.4, DOC L.1, JFD 2, and ITS 3.1.7.1, DOC L.2, JFDs 2 and 5). In the CTS, BVPS-1 CTS 3.1.3.1 (ITS 3.1.4) refers to CTS 3.1.3.2 (ITS 3.1.7.1) for determining rod position. CTS 3.1.3.2 contains notes that provide allowances for a +12-step accuracy limit when using the analog RPI system to determine rod position.

DRAFT DRAFT BSIs-1 and 2 identified the following deviations from the Westinghouse ISTS in WCAP-1431:

(1) relocation of the affected BVPS-1 CTS 3.1.3.2 notes to ITS 3.1.4 LCO and SRs where the

+12-step accuracy limit is required (instead of referencing the other TSs); and (2) modifications of the BVPS-1 notes that provide allowances for the analog RPI System. The modifications for the affected notes contain (1) application of the 1-hour thermal soak allowance to all power levels instead of only to power levels below 50 percent, and (2) application of the exception to the +12-step requirement to any time during rod motion instead of the time during rod withdrawal or insertion limited by a Mode 2 footnote.

G.1.1.1 Regulatory Evaluation The requirement of General Design Criterion (GDC) 10 of Appendix A to 10 CFR Part 50, specifies that "[t]he reactor coolant system and associated auxiliary, control, and protection systems shall be designed with appropriate margin to assure that the design specified acceptable fuel design limits are not exceeded during any condition of normal operation, including anticipated operational occurrences."

10 CFR 50.36 specifies the Commission's regulatory requirements related to the content of TSs. Specifically, 10 CFR 50.36(c)(2)(ii)(B) requires that TS LCOs be established for process variables, design features, and operating restriction for which a value is assumed as initial condition of a design basis accident in the licensee's safety analyses.

NUREG-1431 was developed based on the criteria in 10 CFR 50.36(c)(2)(ii). Shutdown and control rod operability and alignment are directly related to power distribution and shutdown margin that are initial conditions assumed in the safety analyses. In accordance with Criterion 3 of 10 CFR 50.36(c)(2)(ii)(B) discussed above, a TS LCO is required for the shutdown and control rod operability and alignment.

Since BVPS-1 is a Westinghouse pressurized-water reactor (PWR) and BSIs-1 and 2 are TS changes deviating from NUREG-1431, the NRC staff's review of the proposed TS changes will be based on the compliance with GDC 10 requirements and consistencv with similar TSs previously approved by the NRC for Westingns.

./1 ? References not provided in SER G.1.1.2 Technical Evaluatio The NRC staff reviewed BSI -1 and.2 r

sed TS changes, associated JFDs, and discussions of change OCs in[References 2 and 3.

he staff's evaluation is provided below.

ITS 3.1.4 - Notes Added to L

.1.4 and SR 3.1.4.1 Westinghouse ISTS LCO 3.1.4 states that "[a]ll shutdown and control rods shall be OPERABLE and individual indicated rod positions shall be within 12 steps of their group step counter demand position." A note was added to this LCO in the proposed ITS 3.1.4. Specifically, the DRAFT

? added note states that "...verific ion of rod operability and that the individual indicated rod positions are within the 12 ste limit is not required during rod motion and for the first hour following rod motion." A si r

ar note allowing exception to the LCO requirements was added to the associated SR 3.1.4.1.

he added notes are only applicable to BVPS-1.

eferences 2 and in 'ate that the added notes are relocated from CTS 3.1.3.2 with mo i ations.

T

.1.3.2 for BVPS-1, the LCO requirements for the individual RPI system accuracy and the responding SR are modified by a note (Note 1) that states that "[d]uring ing rod motion, the group demand counter is the primary indicator of precise F

rod position information, with analog channels displaying general movement information. For power levels below 50 percent, a 1 -hour thermal soak time is allowed before the analog channels are required to perform within the ci e a The Mode 2 applicability requirements for CTS 3.1.3.2 include ano note footnote that specifies an exception to meeting the +12-step requirement during reactor s tup and sh tdown operations when the rods are being withdrawn or inserted.

1. r- -

iI When relocating the CTS notes to ITS 3.1(.,

e chanvere proposed to the CTS notes as follows.

(1)

Relocate the notes from the RPI LCO (CTS 3.1.3.2, "Position Indication System -

Operating) requirements to the rod alignment LCO (ITS 3.1.4, "Rod Group Alignment Limits.")

The NRC staff finds that the relocation of TS notes is editorial in nature and does not change the TS requirements. Therefore, it is acceptable.

(2 )

R e m o ve inco n siste n c ie s b e tw e e n the note s in C T S 3.1.3.2 LC O (N ot a n d the

phy, footnotes in APPLICABILITY requirements for Mode 2 Operation.

CTS 3.1.3.2 APPLICABILITY requirements indicated that for c re testing in Mode 2, the existing Mode 2 footnote allows an exception to m ting the +12-step requirement up to 1 -hour during reactor startup and shutdown op ons when t d

are being withdrawn or inserted. The licensee indicated that the allowanc ovided by the Mode 2 footnote is not consistent with the more general requirements in CTS 3.1.3.2 Note 1. CTS LCO 3.1.3.2 lists the specific operability requirements for the RPIs and includes Notel that provides an exception for the 1-hour allowance following any rod motion below 50 percent power levels (this includes Mode 2 startup and shutdown operations). Therefore, the licensee indicated, and the NRC staff agrees that Note 1 in CTS 3.1.3.2 provides a broader exception that is applicable to both Modes 1 and 2.

When relocating the Note 1 exception to ITS 3.1.4 LCO, the licensee removed the Mode 2 footnote that is bounded by Note 1. The staff has determined that the proposed TS modifications do not reduce the CTS requirements and thus, concludes that the proposed TS modifications are acceptable.

DRAFT DRAFT (3)

Increase the applicable power range from below 50 percent to all power levels for the 1-hour thermal soak allowance.

CTS 3.1.3.2 Note 1 provides for up to a 1 -hour allowance after control rod motion to verify satisfaction of the alignment limit for individual rod positions. The 1-hour allowance is based on the time necessary for the control rod shaft to reach thermal equilibrium under which individual rod alignment limit can be accurately verified using the analog position indicators. The licensee indicated that it initially requested the 1-hour thermal soak time for power levels below 50 percent, as previously approved by the NFIC and implemented in the CTS. The licensee originally considered that rod motion above 50 percent was too limited and not expected to induce significant thermal transients in the analog rod position indication instrumentation. However, the licensee's operating experience showed that rod movement and subsequent indication drift at power levels above 50 percent did occur (e.g., the monthly freedom of movement tests performed on the rods). Therefore, the licensee proposed to expand the allowances for rod motion and thermal soak time from the applicable range of power levels below 50 percent to all power levels.

Based on the results of its review, the NRC staff noted that the change only provides a short delay for analog indicators to stabilize after rod motion before the requirement of the LCO and surveillance are applied. The LCO and SRs are not revised. During the requested time, RPI continues to be available from both the analog system and demand counter.

The NRC staff also noted that the NRC had previously approved similar TS changes for other Westinghouse plants with the analog RPI. In the TSs of Point Beach Nuclear PBNP), a Westinghouse plant, the allowances for rod motion and 1-hour thermal soak ti pplicable up to all power levels were included in the rod alignment LCO. In SE? Reference rethe PBNP ~, as in the BVPS-1 and 2 ITS, the rod alignment LCO contains the notproide inreuirements r* rod operability and requires that the indicated individual rod positions nStErovdd are maintaitned

• thin an alignment limit of the demand position indicators. Failure to meet terodopeo bilitytheor alignment limit results in the application of a 1-hour Action to

• t..z.=,*.

ilit* or alignment followed by a plant shutdown. As indicated in the SE PL

%.(Reference

4) or e PBNP license amendment, the NRC's approval of allowances for

1 1 N )

or W

ro Io an1our thermal soak time is based on the following reasons: (1) during al* soak following rod motion the likelihood of an accident to occur during this period is small; and (2) in general, the rods will not be misaligned, only indicated to be misaligned. The staff determines that because of the similarity in the Westinghouse plant designs and TS changes, the bases for approval of the thermal soak allowance for the PBNP are applicable to BVPS-1 and 2.

In addition, the licensee indicated that to further assure the reliability and accuracy of the group demand counters, a CTS surveillance (SR 4.1.3.2.1.b) beyond the Westinghouse ISTS requirements is included in the proposed BVPS-1 and 2 ITS (SR 3.1.7.1.1). The additional surveillance requires verification of the accuracy of the bench DRAFT DRAFT board demand counters by comparing them to the logic solid state indicators in he Iogip cabinet. The retention of this CTS surveillance will provide additional assuranc of the demand counter accuracy and reliability for primary RPI during the first hour foil ing rod movement.

Therefore, based on the evaluation discussed for item (3) above, the NRC staff concludes that it is acceptable to extend the allowances for rod motion and 1-hour thermal soak time from power levels below 50 percent to all power levels.

ITS 3.1.7.1 Actions - Add a new Actions Condition A The BVPS-1 ITS 3.1.7.1 Actions are modified by the addition of a new Actions Condition A.

The added Action A.1 requires that if the RPI system indicates one or more potentially misaligned rods, the affected rod position shall be verified within 15 minutes by measuring the RPI primary voltage. Further, the added Action A.2.1 requires that if the rod position measurement determines that any rod is misaligned, ITS 3.1.4 shall be applied within 15 minutes. Alternatively, the added Action A.2.2 requires that the affected RPI shall be declared inoperable and the applicable Conditions and required Actions of ITS 3.1.7.1 shall be entered within 15 minutes.

The NRC staff finds that: (1) the added Actions Condition A (Actions A.1 and A.2.1) discussed above, is consistent with the CTS 3.1.3.2 Action a; (2) the CTS Action was modified by adding Action A.2.2 to give more complete directions for indication of potentially misaligned rods.

Therefore, the staff has determined that the added Actions Condition A does not reduce the CTS requirements and thus, concludes that the addition of the new Actions Condition A is acceptable.

Further, when implementing Actions Condition A in ITS 3.1.7.1, CTS 3.1.3.2 Action a was modified by adding a note stating that entry into Condition A is "not required for misalignment indications during rod motion and for up to 1-hour following rod motion." The note providing the allowances for rod motion and thermal soak time was also added to SR 3.1.7.1.2 that requires verification that each RPI agree "within 12 steps of group demand position for the full indicated range of rod travel" at least "once prior to criticality after each removal of the reactor head."

The added SR 3.1.7.1.2 note is based on BVPS-1 CTS 4.1.3.2.2.b, Note 1 (that is the same note as CTS 3.1.3.2 Note 1).

As the results of its review, the NRC staff finds that the added note provides the same allowances as the note added to ITS LCO 3.1.4. The addition of the note assures consistent application of the allowances to both ITS LCO 3.1.4, "Rod Group Alignment Limits" and ITS 3.1.7.1, "Rod Position Indication." Therefore, the staff has determined that the bases discussed above for approving the allowances for ITS LCO 3.1.4, Note 1, are applicable to the added ITS 3.1.7.1 note. Thus, the staff concludes that the added note is acceptable.

G.1.1.3 Conclusion The NRC staff has reviewed BSIs-1 and 2 dealing with changes in ITSs 3.1.4, "Rod Group Alignment Limits," and 3.1.7.1, "Unit 1 Rod Position Indication." Based on the evaluation DRAFT discussed above, the staff has determined that the TS changes do not reduce CTS requirements and are consistent with the similar TSs previously approved by the NRC for other Westinghouse plants in meeting the GDC 10 requirements. Therefore, the NRC staff finds that the proposed TS changes identified in BSIs-1 and 2 are acceptable.

G.1.2 BSIs-3 and 4 BSI-3 proposes changes to the ISTS time limit and power level specified in the note modifying SR 3.3.1.3. The proposed time limit would change from 1 to 7 days and the proposed power level would change from Ž15 percent rated thermal power (RTP) to 250 percent RTP (ITS 3.3.1 and SR 3.3.1.3 note, DOC M.12, JFDs 4 and 6). BSI-4 proposes changes to ISTS SR 3.3.1.6 (ITS SR 3.3.1.9) to change the time allowed to perform the surveillance from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after RTP is Ž_50 percent, to 7 days. Additionally, BSI-4 proposes to change the requirement to perform SR 3.3.1.9 every 92 effective full-power days (EFPD) thereafter, to perform the surveillance "once per fuel cycle" (ITS 3.3.1, SR 3.3.1.9 note, DOC M.19, JFD 7).

G.1.2 1, BSI-3, ISTS SR 3.3.1.3, Note 2.

The licensee proposes to revise ISTS SR 3.3.1.3, Note 2, to specify that SR 3.3.1.3 be performed seven days after the reactor reaches or exceeds 50 percent of RTP. This requirement does not affect the regular surveillance interval of 31 EFPD.

Surveillance Time After Ascent to Power ISTS SR 3.3.1.3, Note 2, provides a time limit for performing surveillance after a specified power level is exceeded. The corresponding CTS SR in Note 3 of Table 4.3-1 has a 31 -EFPD surveillance frequency but does not require surveillance after refueling or ascent to power. The ISTS surveillance frequency in SR 3.3.1.3 Note 2 is revised from a bracketed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 7 days.

SR 3.3.1.3 is performed every 31 EFP ut to the axial flux difference (AFD) and f(Al) input to the Overtemperature-AT (OTAT) tri function are maintained an rated in accordance with the incore detector measurements.

The change to increase the specified surveillance power level to 50 percent RTP was previously approved in License Amendment Nos. 274 (BVPS-1)

Power el to Conduct SR 3.3.1.3 and 155 (BVPS-2) issued February 27, 2006.

1~ S SR 3.3.1.3, Note 2, also specifies a p wer level of greater than or equal to 15 ercent of RTP to conduct the surveillan Ze. The proposed change specifies conducting the surveillance at 50 percent of RTP.

is cai teli with the proposed DVPS 1,,nd 2 ITS EAR, de*td Feuary 11, 285, to th-e SleC'fHwd S.iuvllICe puvowei level to 50 perce~nt RlTP.

The seven days requested to perform the calibration is a reasonable time interval because it is the last step in a series of actions that begin with a-full-power core flux-DRAFT DRAFT G.1.3 BSIs-5, 6, 7, 8, 9, 10, and 11 BSI-5 proposes a change to ITS SR 3.3.4.2 frequency for verifying the operability of the Remote shutdown System control and transfer switches from 18 months to 36 months. CTS 3.3.3.5 currently does not have operability or SRs for these control and transfer switches (ITS 3.3.4, SR 3.3.4.2, DOC M.4, JFD 1).

BSI-6 proposes a change to the improved STS note that modifies the precision heat balance SR to require the surveillance to be performed within 30 days of reaching the specified power level vice within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of reaching the specified power level (CTS 4.2.5.2 and its note 2 do not contain a specified time limit in which to perform the heat balance) (ITS 3.4.1, SR 3.4.1.4 note, DOC M.1, JFD 1).

BSIs-7-11 propose revising the improved STS note for verifying reactor coolant pump (RCP) and residual heat removal (RHR) pump standby pump breaker alignment and power availability every 7 days (and within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the pump is not in operation) to remove the requirement for performing the surveillance within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the pump is not in operation and considering the SR to be met for a pump just removed from operation and to clarify that the starting time for the 7-day SR begins "when the pump is removed from operation" instead of when the pump "is not in operation." The CTS SRs do not have a note containing the 24-hour requirement for the RCPs and RHR pumps (ITS SR 3.4.5.3, DOC L.3, 2,*

OC L.4, JFD 2, SR 3.4.7.3, DOC L.5, JFD 4, SR 3.4.8.2, DOC L.4, JFD 3, nd SR D

O.

M.1,JFD 2).

3 1

G.1.3.1 BSI-5, Remote Shutdown System Instrumentation M

The licensee proposed to change the control and transfer switches surveillance frequency from 18 months to 36 months. BVPS-1 and 2 CTS SR 3.3.3.5 states that, "The remote shutdown monitoring instrumentation channels shown in Table 3.3-9 shall be OPERABLE with readouts displayed external to the control room."

Westinghouse ISTS SR 3.3.4.2 states that, "Verify each required control circuit and transfer switch is capable of performing the intended function." The surveillance frequency is [18]

months. The number in the bracket is a plant-specific number.

BVPS-1 and 2 CTS SR for the remote shutdown system do not include any operability or SR for control and transfer switches. The CTS requirements only address monitoring instrumentation.

Currently, BVPS-1 and 3 CTSs verify the operability of these switches every 54 months using existing plant procedures which are outside the scope of the TSs. Based on the operating experience, the control and transfer switches verified by this surveillance are designed to be reliable and are not subject to excessive wear from daily use or being in a harsh environment.

In addition, the inclusion of this instrumentation in the TS provides additional assurance that adequate post-maintenance testing will be performed to assure operability after modifications or design changes. Thus, the proposed surveillance frequency is different than the ISTS bracketed surveillance frequency, it is more conservative than the BVPS-1 and 2 CTS SR for DRAFT DRAFT G.1.4 BSI-12, "RCS Isolated Loop Startup" - ITS 3.4.18 BSI-12 proposes to change the ISTS 3.4.18, "Isolated Loop Startup," LCO and SRs related to the isolated loop temperature to be more consistent with the BVPS-1 and 2 safety analyses assumptions and CTS RCP start restrictions. The improved STS requires that the isolated loop temperature be no greater than 20 IF below the operating loop temperature before the cold leg isolation valve can be opened. The licensee proposes to change this requirement to, "the cold leg temperature must be _ the minimum reactor coolant system (RCS) temperature assumed in the analysis before the cold leg isolation valve can be opened." In addition, new temperature requirements are added similar to the temperature restrictions for starting an RCP in ITS 3.4.7, "RCS Loops-Mode 5" (ITS 3.4.18, DOC M.1, JFDs 1 and 2).

By letter dated July 10, 2006 (ADAMS Accession No. ML061940177), the licensee withdrew this proposed change.

G.1.5 BSIs-13 and 14, "MFIV/MSIV Stroke Time" - SRs 3.7.2.1 and 3.7.3.1 BSIs-13 and 14 propose to remove the valve isolation times from SR 3.7.2.1 for the main steam isolation valves (MSIVs), and from SR 3.7.3.1 for the main feedwater isolation valves (MFIVs),

main feedwater regulating valves and associated bypass valves and replace the times with a specific reference that the isolation time of each valve is "within limits." The valve isolation times would be relocated to the LRM and future changes would be controlled pursuant to 10 CFR 50.59. The licensee states that this is consistent with the previously approved relocation of other valve response times such as the relocation of containment isolation valve response tim es. The A

.a p hanged; however, the licensee has no C or F'Vs (ITS SR 3.7.2.1, DOC LA.1, JFD 3, and ITS DOC M.1, J F D 2 ).

I."

MSIVs/

air pressure (BVPS-1) and loss of control oractuation power (BVPS'2)'.

One M IV is located in each m steam line outside of the containme losing the MSIVs isolate each SG from the ot rs and isolates the turbi ypass system and other auxilia steam supplies fro the SG. The close on a main steam isolation signal gener ed by either low pressure gh containment pressure. The MSIVs fail close on loss of ntrol isolating the steam flow from the secondary side of the SG, the e ent overcc gthe reactor core following a high energy line break (HELB).

By preventing core overcooling, the MSIVs protect the reactor core from being damaged.

The licensee is proposing to relocate the required closure times for the MSIVs to the LRM.

Changes to the LRM are subject to the 10 CFR 50.59 process. The 10 CFR 50.59 criteria provide adequate assurance that prior staff review and approval will be requested by the licensee for changes to the LRM requirements with the potential to affect the safe operation of the plant. Furthermore, the MSIVs are subject to periodic testing and acceptance criteria in accordance with the Inservice Testing (IST) Program. Compliance with the IST Program is required by Section 5.5.4 of the BVPS-1 and 2 CTS and ITS and 10 CFR 50.55a. The IST DRAFT DRAFT Program includes specific baseline reference value operating times for valves that are not subject to arbitrary changes. 10 CFR 50.36 requires the inclusion of the periodic testing of the MSIVs in the SRs, but not the actual closure time of the valves. The BVPS-1 and 2 ITS contain the periodic testing requirements for MSIVs in accordance with 10 CFR 50.36.

Based on the requirements of 10 CF 50.59 and the BVPS-1 and 2 IST Program, the NRC staff has rmined that relocating e MSIV closure times to the LRM is acceptable.

/

st MFIVs, Main Feedw er Regulation Val s (MFRVs) and Asso ated Bypass Valves (BVs)

The purpose of MFI s And Vo and..... c thl.e 6 r.V,d 1Vc iso ate the nonsafety-related portions from the saf ated ortions of t system. In the event of a secondary side pipe rupture inside containment, these valves limit the quny igh energy fluid that enters the containment throu provi e a pressure boundarlr the controlled addition of auxiliary feed ater to the intact loops. The MFIVs and Bs, and e

MFRVs and BVs close on receipt f a T

,vv

.Et I

tamp (p-4) or G water level - high high signal. By i olating the feedwater fl from the affected SG, th MFIVs, MFRVs and BVs prevent overcooli the reactor core and over pressurizing of the co ainment due to feedwater pump runout.

Safety Injection signal The BVPS-1 and 2 CTS do not contain MFIV, MFRV an Ir e licensee is proposing to adopt the applicable TS from the Section 3.7.3 of NUREG-1431, Revision 2.0. As with the MSIVs, the licensee is also proposing to relocate the required closure times for the MFIVs, MFRVs and BVS to the LRM. Changes to the LRM are subject to the provisions of 10 CFR 50.59. The 10 CFR 50.59 criteria provide adequate assurance that prior NRC staff review and approval will be requested by the licensee for changes to the LRM requirements that have the potential to affect the safe operation of the plant. Furthermore, the MFIVs, MFRVs and BVs are subject to periodic testing and acceptance criteria in accordance with the IST Program. Compliance with the IST Program is required by Section 5.5.4 of the BVPS-1 and 2 CTS, ITS, and 10 CFR 50.55. The IST Program includes specific baseline reference value operating times for valves that are not subject to arbitrary changes. 10 CFR 50.36 requires the inclusion of the periodic testing of the MFIVs, MFRVs and BVs in the SRs, but not the actual closure time of the valves. The BVPS-1 and 2 ITS contain the periodic testing requirements for MFIVs, MFRVs and BVs, in accordance with 10 CFR 50.36.

Based on the requirements of 10 CFR 50.36, 10 CFR 50.59 and th VPS-1 and IST Program, the NRC staff has determined that relocating the MFIV, MFRVs and BVs losure times to the LRM is acceptable.,,7]

G.1.6 BSls-15, 16, and 17, "Inoperable CCW/SW Train"-

S3.7/3.8Actio C BSIs-15-17 propose changes to the ISTS 3.7.7 and 3.7.8 to provide aw Action.ndition C,

rather than the application of LCO 3.0.3, for the case where 2 component c ')water (CCW)

(ISTS 3.7.7) or 2 service water (SW) (ISTS 3.7.8) trains are inoperable resulting in insufficient DRAFT DRAFT G.1.10 BSI-21, "Diesel Generator Load Sequencing (Shutdown)," SR3.8.2.1 Note 2, and BSI-22, "Diesel Generator Load Sequencing (delete SI auto-start signal)," SR 3.8.2.1 Note 3 BSI-21 proposes a note to ITS SR 3.8.2.1 to address the surveillances (SRs 3.1.8.13 and 3.8.1.14) used to verify the capability of the automatic load sequencer function of the emergency diesel generators (EDGs). The note states that the load sequencer function SRs only include the verification of loads applicable (necessary for operability) in the shutdown modes of operation (Modes 5 and 6) addressed by ITS 3.8.2 (ITS SR 3.8.2.1 Note 2, DOC L.3, JFD 5).

BSI-22 proposes to revise improved STS SR 3.8.2.1 by the addition of Note 3. Proposed Note 3 to ITS SR 3.8.2.1 states, "SR 3.8.1.14 is only required to be met with the use of an actual or simulated loss of offsite power signal." SR 3.8.1.14 verifies the response of the emergency bus and EDG to an engineered safety features (ESF) signal in conjunction with a loss-of-offsite power (LOOP). The proposed note is intended to clarify that in the shutdown modes addressed by SR 3.8.2.1, there are no required ESF actuation signals. The ESF actuation instrumentation specified in ITS 3.3.2 is only required to be operable in Modes 1-4, and ITS 3.8.2 "

urces Shutdown," is only applicable in Modes 5 and 6 (ITS SR 3.8.2.1 Note 3, DOC JFD 6).

BSI-21 1.3 CTS SR 4.8.1.2 specifies the SRs applicable to alternating current (AC) ower sou ces duri shutdown conditions. CTS 4.8.1.2 states: "The above required A.C. elec nical po er source shall be demonstrated OPERABLE by the performance of each of the S veillan Requirements of 4.8.1.1.1 and 4.8.1.1.2 except for requirement 4.8.1.1.2..6." T

/e single exception is CTS SR 4.8.1.1.2.a.6 which corresponds to proposed ITS SR 8.-.

Like S

4.8.1.2, ITS SR 3.8.2.1 specifies the SRs applicable to AC sources during sh nditions.

However, SR 3.8.2.1 has 3 notes that modify the AC source surveillance required during shutdown conditions and relax the surveillance acceptance criteria applicable to AC sources during shutdown condition. BSI-21 relates to ITS SR 3.8.2.1, Note 2. Note 2 reads: "The verification of load sequencer functions in SRs 3.8.1.13 and 3.8.1.14 is only required to be met for those loads required in the applicable modes of LCO 3.8.2."

The SRs referred to in Note 2 address the capability to automatically sequence loads onto the EDG. During the shutdown conditions to which ITS 3.8.2.1 applies, the loads required to maintain the unit in a safe shutdown condition are small compared to the total number of loads that must normally be sequenced on the emergency bus. Note 2 clarifies that the load sequencer function is required only for those loads necessary for the shutdown modes of operation addressed by ITS 3.8.2. The Bases for the proposed note explains that the required loads referred to by the note consist of the equipment required operable by TS 3.8.2 as well as the equipment required to support the operability of the TS-required equipment. The proposed note is consistent with the intent of the ITS note it replaces. The NRC staff finds that the addition of ITS Note 2 is acceptable, because it clarifies that SR 3.8.2.1 applies only to the DRAFT DRAFT capability to sequence only those loads required for the safe operation of the unit during shutdown conditions.

BSI-22 BSI-22 relates to proposed Note 3, which clarifies that certain ESF actuation signals are not applicable in the shutdown modes addressed by SR 3.8.2.1. The ESF actuation instrumentation (specified in ITS 3.3.2) is only required operable in Modes 1 through 4 and is not applicable in Modes 5 and 6 and during fuel movement. Therefore, these ESF actuation (i.e., SI) signals are not required for the emergency bus or EDG during shutdown conditions.

The only applicable actuation signal specified in SR 3.8.1.14 is the loss of voltage (offsite power) actuation signal. The proposed change continues to assure the verification of the required system response to a loss of voltage. The change merely clarifies that the verification of the system response to certain ESF actuation signals is not required during the shutdown conditions applicable under ITS 3.8.2. The NRC staff finds the proposed Note 3 acceptable, because it clarifies that the only applicable actuation signal specified in SR 3.8.1.14 during shutdown conditions applicable under ITS 3.8.2 is the loss of voltage actuation signal.

On the basis of its review, the NRC staff finds that the proposed Notes 2 and 3 provide a clarification for the verification of load sequencer function and certain ESF actuation signals addressed by ITS 3.8.2. The load sequencer function is required only for those loads necessary for the shutdown modes of operation. The applicable actuation signal specified in SR 3.8.1.14 during shutdown conditions is the loss of voltage signal. Therefore, the changes proposed by BSIs-21 and 22 are acceptable.

G.. 1 BSI-23, "Containment Purge and Exhaust System," SR 3.9.3.c.2 BSI-23 prop s to revise ISTS SR 3.9.3.3 by making changes to ITS 3.9.3.c.2 i ded to be consistent with t esign and licensing basis for BVPS-1 and 2. The LCO uirement that specifies that each pe ration providing direct access from the contain t atmosphere to the outside atmosphere be ca le of being closed by an OPERABLE *;tainment purge and exhaust isolation system and it sociated surveillance (SR

..3) are made applicable to BVPS-2 only, and a provision is ad or BVPS-1 only 3.9.3.c.3) that allows the purge and exhaust system penetrations to be o when t ystem air is exhausted to an BVP-FHAs analsi relie uon the SLoRn npurg nlikexBVPs-the NRClstafiond th iiate this

~DRAFT SREPLACE SECTION G.1.11 WITH INSERTS FOLLOWING DRAFT SER PAGES 46 & 47 I

radilogcalconsqueces FHAin cntanmet. Fr BPS-,

emitiatin o th

REPLACE SECTION G.1.11 WITH INSERTS FOLLOWING DRAFT SER PAGES 46 & 47 DRAFT propos change accurately reflects the BVPS-1 design basis and is

ore, acceptable.

As stated above, BVPS-2 relies on the purge and exhaust isolation system to mitigate the radiological consequ an F ainment, as described in Section 15.7.4.1 of the BVPS-2

, Revision 111. Therefore, t

.rement in the ITS is retained cons' ith the ISTS and made applicable to BVPS-2 only.

RC staff finds that roposed BSI change is appropriate for the BVPS-2 desig and is alsoe.

G.1.12 BSI-24, "RHR-Low Water Level," ITS 3.9.4 and 3.9.5 BSI-24 proposes to incorporate a note into ITS 3.9.5, "RHR and Coolant Circulation - Low Water Level," and ITS 3.9.4, "RHR and Coolant Circulation - High Water Level." NRC-approved TSTF-21 Revision 0, incorporated a Bases change to ITS 3.9.5 that provides an exception to the requirement for the RHR loop to be circulating reactor coolant to allow both RHR pumps to be aligned to the refueling water storage tank (RWST) to support filling or draining of the refueling cavity or for performance of required testing. This exception was incorporated into NUREG-1431, Revision 3. In a letter dated April 29, 1999, from W. D.

Beckner, NRC, to J. Davis, Nuclear Energy Institute, the NRC recommended that TSTF-21, Revision 0 be revised to include an LCO exception note to remove the RHR loop from operation (i.e., from circulating coolant) to support cavity fill and drain or to support required testing. The licensee's note incorporates this NRC recommendation which was not incorporated into TSTF-21, Revision 0 or NUREG-1 431, Revision 3 (ITS 3.9.4, LCO Note 3 and ITS 3.9.5, LCO Note 3, DOC L.4, JFD 3).

This change was withdrawn by the licensee's letter of July 10, 2006 (ADAMS Accession No. ML061940177).

G.1.13 BSI-25, "ASME Test Frequencies," ITS 5.5.4.b BSI-25 proposes to revise ISTS 5.5.4.b which states, "The provisions of SR 3.0.2 are applicable to the above required Frequencies [improved STS 5.5.4.a] for performing inservice testing activities." The licensee states that the list in ISTS 5.5.4.a lists some of the test intervals referenced in the IST requirements but is not a comprehensive list. The licensee proposes to revise ITS 5.5.4.b to state, "The provisions of SR 3.0.2 are applicable to the above required Frequencies and other normal and acc s specified in the Inservice Testing Program for performing inservice tes g activities." This wo expand the applicability of SR 3.0.2 provisions to all inservice t sting re uirements interval and not just those listed in ITS 5.5.4.a (ITS 5.5.4.b, DOC L.4, JFD 4).

C BSI-25 involves a change to CTS 0.5 described i ITS 5.5. b, which changes the applicable surveillance intervals list d in CTS 4.0.5. (or ITS 5..4.a), for which the 1.25 factor provided in SR 3.0.2 would apply.

licensee provided ad iional information in its submittal dated April 19, 2006 (ADAMS Accessio-L06114

),which revised proposed ITS 5.5.4.b. Specifically, in the proposed ITS 5.5.4.b, the provisions of SR 3.0.2 would be DRAFT

Replacement Text For Section G.1.11 Insert Page Follows and adding ITS 3.9.3.c.3. ITS 3.7.12 was also revised to include supporting requirements for the changes to ITS 3.9.3. The requirements of ITS 3.9.3 and 3.7.12 are only applicable during fuel movement involving recently irradiated fuel.

The changes are

,3.9.3.c.3 and ITS 3.7.12, "Supplemental Leak ITS LCO Collection and Release System" (SLCRS)

G.1.11 BSI-23, "9ontainment Purge and Exhaust System,"if

.9.3.c.2l i

i BSI-proposes t revise ISTS *.

bymaking changes to ITS 3.9.3.c. intended t consistent with the design and licensing basis for BVPS-1 and 2. The LCO requirement that specifies that each penetr n

providing direct access from the containment atmosphere to the o ide atmosphere be capable of being closed by an OPERABLE co mine s

purge and exhaust isolation system and its associated su illanc 3.9.3-3) are made applicable to BVPS-2 only, and a ision is added for BVPS-1 only (ITS 3.9.3.c.3) that allows the purge d exhaust system penetrations to be open when the system air j exhausted to an Corresponding changes are made to ITS 3.7.12 to require one train of SLCRS OPERABLE when required to support ITS 3.9.3.c.3 for BVPS-1 and to provide an appropriate Action in ITS 3.7.12 if the required train was inoperable (ITS 3.7.12, JFD 1 and I 1

'OPERABLE.upplementai leak colec,-,-

d

,rlopso, system (SL, RS.

ITS 3.9.3 DOC L.1 Insert 1j

,,train (ITS 3.9.3.-.2, DOC L.1, JFD 3).,

w r

e In addition, the BVPS-1 does not rely on the contai ent purge and exhaust system proposed isolation to mitigate the radiologic consequences of an FHA in changes include containment. For BVPS-1, the itigation of the radiological consequences requirements in of an FHA in containment filtration of containment air exhaust by ITS 3.7.12 to SLthe CRS instead, consistent with the eGU-eRt-design and licensing basi irradiated fuel OPERABLE train as des ed in Amendment No. 23, issued December 12, 1979 (AD S

would rely of SLCRS is Accession N.L003766458), and in Section 14.2.1.4 of the BVP -1 available when UFSAR, Revision

81. Because the BVPS-1 FHA upon the required by ITS SLCRS, unlike BVPS-2*the NRC staff finds that this proposed BSI change fii393 to supportn fh accurately reflects the BAPS-1 design basis and is therefore, acceptable.

BVPS-1 containment exhaust.

As stated above, BVPS-2 f on the containment purge and exhaust isolation system to mitigate t e radiological consequences of an FHA in containment, as described in ýection 15.7.4.1 of the BVPS-2, UFSAR, Revision 11. Therefore, this re uirement in the ITS is retained consistent with the ISTS and made applica le to BVPS-2 only The NRC staff finds that this proposed BSI change is ppropriate for the ?VPS-2 design and is also acceptable.

for fuel would rely movement involving recently irradiated fuel.

and appropriate requirements for an OPERABLE train of SLCRS for BVPS-1 have been included in ITS 3.7.12,

INSERT 1 The current BVPS-1 and 2 design-basis FHA of record do not credit containment isolation or filtration of containment ventilation exhaust to mitigate a FHA involving non-recently irradiated fuel in containment.

Recently irradiated fuel is defined in the TS Bases as "... fuel that has occupied part of a critical reactor core within the previous 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />."

Although BVPS-1 and 2 do not currently have safety analyses that support moving recently irradiated fuel assemblies, TS requirements have been retained to address the condition of moving recently irradiated fuel assemblies. These TS requirements are retained because decay time limits for moving irradiated fuel have been relocated to the LRM and the NRC staff has determined that fuel handling limits should be retained in the TSs should the licensee develop future capability to move recently irradiated fuel.

Movement of recently irradiated fuel can only be done if the dose analysis required by 10CFR50.59 indicates that the calculated dose increase is less than or equal to 10% of the difference between the current calculated dose value for a FHA involving non-recently irradiated fuel and the regulatory guideline value (10 CFR 50.67 or GDC 19, as applicable), and the increase in dose does not exceed the current SRP guideline value for the particular design basis event. The dose analyses for recently irradiated fuel will take credit for the SLCRS filtration for Unit 1 and containment isolation for Unit 2.

If the dose analysis indicates a calculated dose increase greater than 10%

as described above, the licensee must submit a license amendment request for NRC review and approval.

The retained TS requirements which are applicable when moving recently irradiated fuel or fuel assemblies over recently irradiated fuel include the containment penetration requirements of ITS 3.9.3. The current FHA analysis for moving non-recently irradiated fuel and the CTS requirements retained for moving recently irradiated fuel were approved by the NRC in Amendment Nos. 241 for BVPS-1 and 121 for BVPS-2, issued August 30, 2001.

DRAFT applicable to, not only the intervals listed in th ITS 5.5.4.a tab ut to "other ormal and accelerated Frequencies sp ied as 2 years or s in the I ervice Testing P gram" for performing IST activities/

c b

The licensee's proposed change to e BVPS-1 an 2 CTS

.0.5., described in ITS 5.5.4.b, would apply the 25-pe cent time e tension provid for in S 3.0.2 to other nor al and accelerated frequenci s specifi as 2 years or ss in the I T Program, in add'ion to those periods listed in the C S 4.0.5. Table. The C staff find that applying the xtension to these time periods, up t and including 2 yrs, is acceptable.

of the table is to more precisely define the

• nthly",

"quarterly", and other terms for time periods, such that surveillances are not delayed due to lack of precision of the stated time periods.

For example, the term "yearly" is defined by the table as 366 days, which prevents a scenario where testing is performed at any time during one year and testing is performed again at any time during the next year, which could result in an approximate doubling of the 366-day period.

With the proposed ITS 5.5.4.b, if a test frequency (e.g., monthly) is augmented and increased (e.g., to a two-week test frequency, which is not listed in the table), it could also have the 25-percent extension applied. This is consistent with the intent of the 25-percent extension as described in the Bases for SR 3.0.2, in that the extension would provide operational flexibility, but would not significantly degrade the quality of systems and components that results from performing the surveillance at the specified frequency. Further, the proposal to limit the applicability to frequencies of 2 years or less, limits the maximum incremental time period between surveillances, which could be added by the 25-percent extension, and is consistent with guidance provided in NUREG-1 482, Revision 1. Without this limitation, some components, such as safety and relief valves, which may be tested at surveillance intervals significantly greater than 2 years, could have extensions applied which would be much greater than that needed for operational flexibility.

The NRC requirements for TS SRs are provided in 10 CFR 50.36(c)(3). The NRC staff has determined that the proposed change to CTS 4.0.5.b, described in ITS 5.5.4.b, meets the requirements of 10 CFR 50.36(c)(3), since the change would not significantly degrade the quality of systems and components that results from performing the surveillance at the specified frequency. Therefore, the staff finds that the proposed ITS 5.5.4.b is acceptable.

G.2 BSI Changes Identified by the Staff:

The licensee stated that 5 proposed ITS changes were in accordance with pending TSTFs.

Because these TSTFs were pending and had not been approved by the NRC staff, the staff determined that inclusion of the proposed TS changes based on the pending TSTFs constituted BSIs until such time as the staff approved the TSTS from which the proposed ITS changes were developed. The staff, therefore, assigned these proposed changes BSI numbers 26-30.

G.2.1 BSI-26, "Turbine-Driven Auxiliary Feedwater (TDAFW) Pump," ITS 3.7.5 BSI-26 proposes to incorporate pending TSTF-412, Revision 0, which would provide actions and clarify the operability status when one steam supply to a TDAFW pump is inoperable.

DRAFT

Any two of the thre-e--AFW pumps are capable of

.4e supplying the required feedwater flow assumed in 7the

• m a~c accident analyses~k4n" TS L s for AFW systems are required in accordance with 0 CFR 50.36(c)(2)(ii)(C). The S are reflective of policies and practices that the NRC onsiders to be acceptable with respect to TS L*Os, Completion Times, and Action req rements. The BVPS-1 and 2 AFW systems consist of 2 motor-driven AFW (MDAFW) pu ps and one steam TDAFW pump configured'into three trains.

Hf th. A.4_F-,-AFW trains arfro,, the single TE)AFW ifa ~ eud for m1tigettng theo liffitng aeenario3 that Etrc deflincd by the foedwator "ne break cand ls rffnrmal feedwater events. Each MDAFW train feeds one of the 2 AFW

• ,*ppl**~cl supply leader feeds all3SsThTDFnid to automatically provide flow to one o e

W supp y eaders upon AFW actuation. The TDAFW pump turbine is aligned receive steam flow from at least 2 of the 3 main steam lines from upstream of the MSIVs. Each of the upply lines is sized to provide 100 percent of the steam flow that is essary for operating the T pump at full capacity.

BVPS-1 and 2, ITS 3.7.5, Pr sed Condition A steam supply The licensee proposes (adopt this IST equirement, with Condition modified to refer to the inoperability of a TDAF train due an inoperable steam supply, ins ad of referring to the inoperability of a TDAF pump s reflected in the ISTS. The propo ed ITS change maintains the train-oriented langu e in the BVPS-1 and 2 ITS for Conditio

, which is consistent with the approach that is used r the other Conditions that cified by ISTS 3.7.5. The licensee's proposed use of tr is editorial in nature and is preferred by the NRC staff because it tends to maintain clarity and consistency of the BVPS-1 and 2 ITS, while still reflecting the ISTS requirement that is specified. Therefore, the proposed change is considered to be acceptable.

BVPS-1 and 2, ITS 3.7.5, Proposed Condition C A new Condition C is proposed for when the TDAFW train is inoperable due to one inoperable steam supply at the same time that one MDAFW train is inoperable. Proposed Action C.1 requires restoration of the affected steam supply to operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Alternatively, proposed Action C.2 requires restoration of the inoperable MDAFW train to operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

The ISTS typically allows a 72-hour Completion Time for Conditions where the remaining operable equipment is able to mitigate postulated accidents as long as a concurrent single active failure is not imposed. In this particular case, a 24-hour Completion Time is proposed for a situation where the AFW system would be able to perform its function for most postulated events, and would only be challenged by situations such as a main steam line break or a feedwater line break that render the remaining operable steam supply to the TDAFW pump inoperable. The 24-hour Completion Time is based on the remaining operable steam supply to the TDAFW pump and the continued functionality of the TDAFW train, the remaining operable MDAFW train, and the low likelihood of an event occurring during this 24-hour period that would challenge the capability of the AFW system to perform its function. The proposed Completion Time for this particular situation is consistent with what was approved for Waterford Unit 3 by Amendment No. 173 for a similar Condition (ADAMS Accession No. ML012840538), and it is DRAFT DRAFT systems when those support systems have an LCO in the TS. This change makes the Bases consistent with the Specifications.

The proposed changes described in TSTF-482, Rev 0, have been incorporated into Revision 3.1 of NUREG-1431, and all future changes to the Bases will be controlled in accordance with the program requirements of ITS Section 5.5.10, "TS Bases Control Program." This program allows licensee to make changes to the Bases without prior NRC approval provided that the change 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, changes, tests and experiments.

Since the above changes do not affect the ITS, nor do they require prior NRC approval, the NRC staff has determined that the proposed changes to the BVPS-1 and 2 ITS Bases are acceptable.

5.0 PROPOSED DELETION OF BVPS-1 AND 2 LICENSE CONDITIONS In Revision 4 of the application, the licensee proposed that the BVPS-1 License Condition C.(9), "Steam Generator Surveillance Interval Extension" and BVPS-2 License Condition (C.12),

"Steam Generator Surveillance Interval Extension" be deleted from the facility operating licenses. These existing License Conditions provided a limited surveillance extension for the BVPS-1 and 2 Steam Generators based on specific dates which have expired. Therefore, BVPS-1 License Condition C(.9) and BVPS-2 License Condition (0.1 er applicable. The NRC staff finds the proposed changes to be adm' istrative in) nat e and, therefore, acceptable.

4 6.0 NRC COMMITMENTS In reviewing the proposed ITS conversion for BVPS-1 and 2, t NRC s ff has rel d upon the licensee's commitment to relocate certain requirements from th TS.licensee-ontrolled documents as described in Table LA, "Removed Details" (Attach nt to this S ) and Table R, "Relocated Specifications" (Attachment 6 to this SE). Thes s

d Sections 4.D and 4.E of this SE, reflect the relocations described in the licensee's submittals on the conversion. The NRC staff requested and the licensee submitted a set of license conditions to make these commitments enforceable (see Section 7.0 of this SE). Such commitments from the licensee are important to the ITS conversion because the acceptability of removing certain requirements from the TSs is based on those requirements being relocated to licensee-controlled documents where further changes to the requirements will be controlled by applicable regulations or other requirements (e.g., 10 CFR 50.59).

DRAFT

(batteries 1-3 & 1-4). DRAFT In addition, the license proposed that the current SRs to measure battery state-of-charge using specific gravity e replaced with float current monitoring. In its December 7, 2006, supplemental letter, he licensee provided letters from the battery manufacturers (C&D Technologies, an nerSys), confirming that float current monitoring is an acceptable method for determining t e state-of-charge of the BVPS-1 and 2, batteries. More specifically, C&D Technologies s ted that a float current value 2 2 amps is both a reliable and an accurate parameter to e to ascertain a state-of-full charge for the 125-V DC Station Batteries installed at BVPS-1

. C&D Technologies also stated that the accuracy and reliability of this reading will hold true over the expected life of these batteries (i.e., 20 years).

EnerSys also confirmed that float current monitoring is an acceptable method for determining the battery state-of-charge, but stated that a float current value of

• 2 amps indicates 95 percent available capacity for the 2GN-1 3 model batteries (BVPS-2 Batteries 2-3 and 2-4) and 98 percent available capacity for the 2GN-21 model battery (BVPS-1 Batteries 1-1 and 1-2 and BVPS-2 Batteries 2-1 and 2-2).

The licensee also stated in its December 7, 2006, supplemental letter that instrumentation with the appropriate range and accuracy for the expected current reading will be used to monitor the battery charging current. The use of instrumentation with the appropriate range and accuracy will assure a valid determination of the battery state-of-charge. Recognizing that the 2-amp float current value is an indication that the EnerSys batteries are either 95 percent or 98 percent charged, the licensee provided regulatory commitments to maintain at least 5-percent or 2-percent design margin, as applicable, for the appropriate batteries. The licensee also stated that it will list these values in the BVPS-1 and 2, TS Bases for ITS 3.8.4.

The NRC staff finds that the use of float current monitoring in lieu of specific gravity measurements will not have a significant impact on safety or the ability to accurately determine the operability of the BVPS-1 and 2, batteries for the following reasons:

1.

Battery manufacturers confirmed that float current monitoring is a reliable and accurate parameter for assessing battery state-of-charge.

2.

Float current monitoring will use instrumentation with appropriate range and accuracy.

3.

Licensee's commitment to maintain either 2-percent or 5-percent design margin, as applicable, for the appropriate EnerSys batteries.

The NRC staff considers the regulatory commitment to maintain adequate design margin for the EnerSys batteries and that these design margins would be specified in the TS Bases is sufficient for the purposes of approving this licensing amendment request.

DRAFT

Table A Administrative Changes Section 1.0 - Use and Application BVPS Units 1 and 2 Page 4 of 109

Table A Administrative Changes Section 3.1 - Reactivity Control Systems ITS #

DOC #

Description of Change ITS Requirement CTS Requirement CTS #

I statement more specific to the LCO requirements and incorporating the ISTS convention of separate condition entry for individual valves found not to meet the LCO requirements.

ITS 3.1.8 A.5 CTS 3.1.2.9 Action statement 3 requires that SDM be verified in accordance with the 3.1.8 Action 3.1.2.9 Action CTS 3.1.2.9 applicable specifications listed below. As CTS 3.1.2.9 is applicable in Modes 4, 5, and 6, the CTS Action contains a list of the Specifications with SDM requirements in that must be met in Modes 4, 5, and 6. The ISTS does not list the applicable SDM specifications. The corresponding ISTS Action requires that the specific surveillance for SDM be performed.

The CTS is revised to conform to the ISTS. This changes the CTS by simplifying the Action and referencing the applicable SDM surveillances that must be performed.

ITS 3.1.8 A.6 CTS surveillance 4.1.2.9 states "the above listed valve(s) shall be verified to be locked, SR 3.1.8.1 4.1.2.9 CTS 3.1.2.9 sealed or otherwise secured in the closed position." The corresponding ISTS surveillance (SR 3.1.8.1) states" Verify each valve that isolates unborated water sources is secured in the closed position." The CTS surveillance is revised to conform to the ISTS surveillance wording.

ITS 3.1.8 A.7 The CTS 3.1.2.9 footnote to Action 3 states 'This action is required to be completed 3.1.8 Action A 3.1.2.9 footnote CTS 3.1.2.9 regardless of when the requirements of the above specification are satisfied". The corresponding ISTS requirement is a similar Note in Action Condition A. The CTS footno 31 is moved into the Actions Condition consistent with the ISTS.

(

ITS 3.1.4 A.1 In the conversion of the Beaver Valley Power Station current Technical Specifications CTS 3.1.3.1 (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering or ordee, etc.) are made to obtain consistency with NUREG-1431, Rev. 2, "Standard Technical Specifications-Westinghouse Plants" (ISTS).

ITS 3.1.4 A.2 CTS 3/4.1.3.1 LCO, Actions, and surveillances use the term "full length" when describing 3.1.4 LCO 3.1.3.1 LCO CTS 3.1.3.1 rods. The ISTS does not utilize this descriptive term. The term "full length" is deleted from the LCO and Actions. As BVPS does not use part length rods, the term "full length" is no longer required to differentiate the rod type.

ITS 3.1.4 A.3 CTS 3/4.1.3.1 Actions reference the Shutdown Margin (SDM) requirements contained in 3.1.4 Actions 3.1.3.1 Actions CTS 3.1.3.1 Specification 3.1.1.1. In CTS Specification 3.1.1.1 the specific value for the SDM requirement was moved into the COLR as part of the conversion to the ISTS. Consistent with the ISTS references to the SDM are revised from Specification 3.1.1.1 to the COLR.

ITS 3.1.4 A.4 CTS 3.1.3.1 Actions that refer to misaligned rod(s) state "with one [Action c or] with more 3.1.4 Actions 3.1.3.1 Actions CTS 3.1.3.1 than one [Action b] full length rod misaligned from its group step counter demand position by more than +/- 12 steps (indicated position determined in accordance with Specification 3.1.3.2)...". The corresponding ISTS Actions state "one [Condition B or] more than one BVPS Units 1 and 2 Page 12 of 109

Table A Administrative Changes Section 3.3A - 3.3.1, Reactor Trip System Instrumentation ITS #

DOC # 1 Description of Change ITS Requirement CTS Requirement CTS #

I 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.

ITS 3.3.1 A.34 The CTS surveillance requirements specified on Table 4.3-1 for the Overtemperature AT SR 3.3.1.3 and Table 4.3-1 CTS 3.3.1.1 RTS Function include a channel check, channel functional test, and channel calibration.

SR 3.3.1.9 Overtemperature The corresponding requirements in the ISTS include two additional surveillances. The AT Function 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.

4,-..--

ITS 3.3.1 CTS 3.3.1.1 A.35 CTS Note 3 in Table 4.3-1 states "At leasp ce every 3 EOAective Full Power Days (EFPD) compare incore to excore axial imbala

?"abovee-17erce, of RATED THERMAL POWER.

Recalibrate if absolute difference grepfer than or(

ual to percent." The corresponding ISTS surveillance SR 3.3.1.3 is simi r except t at it stat "Adjust NIS channel if absolute difference is > 3%." The CTS is refised to cform to tlle ISTS. This changes the CTS by rewording the Note modifying the /onthly c) mparison o the incore and excore detectors.

SR 3.3.1.3 Table 4.3-1 Note 3 BVPS Units 1 and 2 Page 31 of 109

Table A Administrative Changes Section 3.3B - Instrumentation (Other than RTS & ESFAS)

ITS i J DOC #

Description of Change ITS Requirement CTS Requirement CTS i

referencing the required Remote Shutdown instrumentation by "Functions" instead of "channels".

ITS 3.3.4 A.3 CTS LCO 3.3.3.5 Action states 'With the number of OPERABLE remote shutdown Action A&B Actions CTS 3.3.3.5 monitoring channels less than required by Table 3.3-9, either: Restore the inoperable channel to OPERABLE status within 7 days, or be in HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />." ITS LCO 3.3.4 Action A requires "One or more required Functions inoperable.

Restore required Function to OPERABLE status in 30 days." Condition B states "Required Action and associated Completion Time not met be in MODE 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and be in MODE 4 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />." This changes the CTS requirements for the remote shutdown by stating the requirements in the ITS format (i.e., referring to Functions instead of channels).

ITS 3.3.4 A.4 The CTS 3.3.3.5 Action specifies that 'With the number of OPERABLE remote shutdown Actions Actions CTS 3.3.3.5 monitoring channels less than required...." The corresponding ITS 3.3.4 Action states "One or more required Functions inoperable." In addition, the ITS Action is modified by a Note, which states "Separate Condition entry is allowed for each Function." The CTS is 1/2 revised to be consistent with the ISTS. This changes the CTS by the addition of the ISTS note allowing separate condition entry for each inoperable Function.

I i

ITS 3.3.4 A.5 CTS 4.3.3.5 states "Each remote shutdown monitoring instrumentation channel shall be SR 3.3.4.'$

4.3.3.5 CTS 3.3.3.5 demonstrated OPERABLE by performance of the Channel Check and Channel Calibration

• ,*rations at the frequencies shown in Table 4.3-6." A note in CTS Table 4.3-6 modifies the re Range surveillance requirements. The Note states "Operability required in accordan with Specification 3.3.1. 1." Table 4.3-6 does not specify a Channel Calibration the Source e indication. However, Specification 3.3.1.1 requires a refueling interv 8 month) nel Calibration for the Source Range instrumentation with an exception fo utron detec-

. The remaining Remote Shutdown channels onP a

Sabe-3-6 have a frequ require ent for the Channel Calibration listed as R (R ueling or 18 mon SR 3.3.

stat s "Perform Channel Calibration for each req red<

indication instrumentation c el." The F quency for the ISTS Channel Calibration su lance is 18 months. The ISTS libration surveillance requirement is modified by a that states "Neutron Detectors are excluded from Channel Calibration". The CTS surveillance is revised to conform to the ISTS surveillance. This changes the CTS by including a separate 18-month Channel Calibration surveillance with a specific exception for neutron detectors. In addition the change adds the 18-month Channel Calibration requirement to the Remote Shutdown System Source Range indication.

ITS 3.3.4 A.6 CTS surveil 3.3.5 requires that "Each remote shutdown monito g instrumentation SR 3.3.4. & SR 4.3.3.5, Table 4.3-6 channel all be de strated OPERABLE by performance of the ANNEL CHECK and 3.3.4 CHANN L CALIBRATI N operations at the frequencies shown In able 4.3-6. The correspo ding I TS su illance requirements (SR 3.3.4.1 and S 3.3.4.,2.specify a Channel eck and Ch nel Calibration for each Remote Shutdovn Systehrristrument

/

2 BVPS Units 1 and 2 Page 35 of 109

Table A Administrative Changes Section 3.3B - Instrumentation (Other than RTS & ESFAS)

ITS #

DOC #

Description of Change 1 ITS Requirement CTS Requirement CTS #

I J

CTS 3.3.1.1 (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-1 431, Rev. 2, "Standard Technical Specifications-Westinghouse Plants" (ISTS).

ITS 3.3.8 A.2 CTS LCO 3.3.1.1 requires the reactor trip system (RTS) instrumentation channels of Table NA Table 3.3-1, 6.b CTS 3.3.1.1 3.3-1 shall be OPERABLE.

For Function 6.b, the CTS Table specifies the channels required to trip as zero. The corresponding ITS LCO 3.3.8, "Boron Dilution Detection Instrumentation" specifies one Source Range channel operable. The ITS does not describe the number of channels required to trip but the number of channels required operable. The CTS is revised to conform to the ITS. This changes the CTS by deleting the number of channels to trip from Table 3.3-1.

ITS 3.3.8 A.3 CTS LCO 3.3.1.1 requires the reactor trip system (RTS) instrumentation channels of Table 3.3.8 LCO Table 3.3-1, 6.b CTS 3.3.1.1 3.3-1 shall be OPERABLE. RTS Function 6.b Source Range Neutron Flux on Table 3.3-1 requires a minimum of one Source Range channel to be OPERABLE. ITS LCO 3.3.8 "Boron Dilution Detection Instrumentation" requires one Source Range instrument channel to be OPERABLE. The CTS is revised to conform to the ITS. This changes the CTS by moving the Source Range instrumentation minimum channel operable requirement from the RTS Functions on Table 3.3-1 to the new ITS 3.3.8.

ITS 3.3.8 A.4 Unit 2 only. Unit 2 CTS Table 3.3.1 Function 6 specifies the Source Range Neutron Flux NA Table 3.3-1, Note 8 CTS 3.3.1.1 requirements. The Unit 2 requirements are modified by Note (8) that states "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." The corresponding ITS LCO 3.3.8 does not contain a similar note. The CTS is revised to conform to the ISTS. This changes the CTS by deleting the portion of the note that states" until detector functions are modified to permit equivalent alarm and trip functions."

ITS 3.3.8 A.5 CTS LCO 3.3.1.1 requires the reactor trip system (RTS) instrumentation channels of Table Action A Action 5 CTS 3.3.1.1 3.3-1 shall be OPERABLE. CTS Table 3.3-1 Function 6.b, Source Range Neutron Flux, requires a minimum of one Source Range channel to be OPERABLE. For an inoperable Source Range channel CTS Action 5 must be entered. The Action requires the suspension of operations involving positive reactivity additions, closing of the unborated water source isolation valves within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, and *S Shutdown Margin (SDM) verification within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> ther ter."The c responding ITS LCO 3.3.8 "Boron Dilution Detection Instrumentation" Condition A/*specifs an alternate Action (A.2.1) within the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> allowed by the CTS to close'dnborated wajer source isolation valves. The alternate ITS Action A.2.1 provides the option store e inoperable Source Range channel to operable status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> instead of c os-*g the unborated water source isolation valves. The CTS Actions are revised to conform to the ITS. This changes the CTS by providing an alternate Action to dosing the unborated water source isolation valves.

BVPS Units 1 and 2 Page 43 of 109

Table A Administrative Changes Section 3.4 - Reactor Coolant System ITS #

DOC #

Description of Change ITS Requirement CTS Requirement CTS #

I Specifications-Westinghouse Plants" (ISTS).

ITS 3.4.9 A.2 The CTS 3.4.4 LCO requirement states that the pressurizer shall be operable with at least LCO LCO CTS 3.4.4 150 kW of pressurizer heaters. The CTS Action is applicable with less than 150 kw of heaters supplied by an emergency bus. The corresponding ISTS LCO provides a more specific requirement that specifies two groups of heaters with the required kW capacity and capable of being powered from an emergency power supply. The CTS LCO and Actions are revised to be more consistent with the ISTS LCO and Action requirements. This revises the CTS LCO to specify two sets of heaters required operable with each set consisting of _ 150 kW capacity and powered from an emergency bus. The Action becomes applicable when one required set of heaters is inoperable.

ITS 3.4.9 A.3 The CTS 3.4.4 LCO requirement states that the pressurizer shall be operable with a steam LCO, Action LCO, Action CTS 3.4.4 bubble. The corresponding CTS Action for loss of steam bubble is applicable when the pressurizer is inoperable for reasons other than the required heaters. The corresponding ISTS LCO requirement specifies a maximum pressurizer level (92%) that assures a steam bubble is maintained within the pressurizer. The ISTS Action associated with this LCO requirement is applicable when the pressurizer level is not within the required limit. The CTS LCO and Action are revised to be consistent with the ISTS. This changes the CTS by specifying a maximum water level in the pressurizer (92%) instead of simply requiring a steam bubble and labeling the associated Action such that it specifically applies when the pressurizer water level is not within the limit instead of when the pressurizer is inoperable for other reasons.

ITS 3.4.20 A.1 In the conversion of the Beaver Valley Power Station current Technical Specifications 3.4.

3.4.5 CTS 3.4.5 (CTS) to the plant specific Improved Technical Specifications (ITS), certain L

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).

ITS 3.4.20 A.2 Unit 2 CTS 3.4.5, Steam Generator (SG) Tube Integrity provides the requirements 4

4.4.5.1 CTS 3.4.5 regarding SG tube integrity and the requirement to plug or repair tubes meeting the Stea Generator Program criteria. The Unit 1 CTS 3.4.5 provides the same requirements as the Unit 2 CTS, with the exception that the Unit 1 CTS 3.4.5 does not contain any provisions 3.4.20 for SG tube repair. As the Unit 1 SGs are relatively new, no approved tube repair provisions are currently included in the Unit 1 Steam Generator Program. Therefore, based on the BVPS ITS being a common set of technical specifications for both Unit 1 and Unit 2 a modification is proposed to the Unit 2 CTS 3.4.5 to make it acceptable for use by both Units. The proposed modification would annotate each occurrence of the word

_repair" or 'repaired' with footnote (1). Proposed footnote (1) states that "SG Tube Repair BVPS Units 1 and 2 Page 57 of 109

Table A Administrative Changes Section 3.4 - Reactor Coolant System ITS #

DOC #

Description of Change ITS Requirement CrS Requirement CTS #

j ITS 3.4.12 A.1 In the conversion of the Beaver Valley Power Station current Technical Specifications 3.4.12 3.4.9.

CTS 3.4.9.3 (CTS) to the plant specific Improved Technical Specifications (ITS), certain U1 CTS changes (wording preferences, editorial changes, reformatting, revised numbering or order, 3.5.4 etc.) are made to obtain consistency with NUREG-1 431, Rev. 2, "Standard Technical Specifications-Westinghouse Plants" (ISTS).

ITS 3,4.12 A.2 CTS surveillance 4.4.9.3.2.b requires a "Performance of a CHANNEL FUNCTIONAL TEST SR 3.4.12.6 4.4.9.3.2.b CTS 3.4.9.3 on the PORV actuation channel." The corresponding ITS surveillance SR 3.4.12.6 requires that a Channel Operational Test (COT) be performed on the required PORVs. The CTS is U1 CTS revised to be consistent with the ITS. This changes the CTS by specifying a COT instead 3.5.4 of a Channel Functional Test for the PORV surveillance.

ITS 3.4.12 A.3 Unit 1 only. CTS 3/4.5.4, "HHSI Flow Path" contains requirements that affect the ECCS 3.4.12 3/4.5.4 CTS 3.4.9.3 and is part of the ECCS Section of the CTS. Unit 2 does not have a corresponding U1 CTS requirement. The requirements of CTS 3/4.5.4 are intended to prevent an over pressure U5 CTS event at low RCS temperature conditions (i.e., when operating below the Overpressure Protection System enable temperature specified in the Pressure Temperature Limits Report (PTLR)). CTS 314.5.4 has no corresponding TS requirements in the ISTS.

However, in the ISTS, all requirements related to preventing an overpressure event at low RCS temperatures are contained in ISTS 3.4.12. Therefore, the CTS is being revised to combine the requirements of CTS 3/4.5.4 into the proposed ITS 3.4.12. This changes the CTS by consolidating all the low temperature overpressure protection related requirements into a single TS (ITS 3.4.12).

ITS 3.4.12 A.4 Unit 1 only. CTS 3/4.5.4, "HHSI Flow Path" specifies that the Unit 1 ECCS automatic high LCO Note 4.5.4 CTS 3.4.9.3 head safety injection flow path be isolated. CTS surveillance 4.5.4 requires that the affected flow path be verified isolated at least once per 7 days. The CTS surveillance U1 CTS contains an exception to the requirement for the flow path to be isolated. The exception allows the flow path to be unisolated for the purposes of flow testing or valve stroke testing.

In the ISTS, similar exceptions are contained in LCO Notes not within the surveillances.

The corresponding ITS 3.4.12 specifies this CTS exception in LCO Note 3. This changes the CTS by moving the exception to the HHSI flow path isolation requirement from the CTS surveillance to an ITS LCO Note.

ITS 3.4.11 A.1 In the conversion of the Beaver Valley Power Station current Technical Specifications 3.4.11 3.4,11 CTS 3.4.11 (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).

)

BVPS Units 1 and 2 Page 63 of 109

Table A Administrative Changes Section 3.8 - Electrical Power Systems ITS #

DOC #

Description of Change ITS Requirement CTS Requirement CTS #

ITS 3.8.1 ITS A.1 In the conversion of the Beaver Valley Power Station current Technical Specifications 3.8.1, 3.8.3 3.8.1.1 3.8.3 (CTS) to the plant specific Improved Technical Specifications (ITS), certain CTS 3.8.1.1 changes (wording preferences, editorial changes, reformatting, revised numbering or order, etc.) are made to obtain consistency with NUREG-1 431, Rev. 2, "Standard Technical Specifications-Westinghouse Plants" (ISTS).

ITS 3.8.1 ITS A.2 CTS LCO 3.8.1.1.b.1 requires a separate day and engine mounted tanks for Unit 1 SR 3.8.1.4.1 and 3.8.1.1.b.1, 3.8.3 containing a minimum of 900 gallons of fuel oil. Unit 2 LCO 3.8.1.1.b.1 requires a separate 3.8.1.4.2 4.8.1.1.2.a.1 CTS 3.8.1.1 day tank containing a minimum of 350 usable gallons of fuel oil. Surveillance requirement 4.8.1.1.2.a.1 for both units requires the verification of level in the day tank and engine-mounted tank for Unit 1. ITS SR 3.8.1.4.1 and 3.8.1.4.2 require verification each DG day tank (and engine mounted tank on Unit 1 only) contains the required inventory of fuel oil.

The inventory for Unit 1 day tank and engine mounted tank contain a combined total of _>

900 gal and for Unit 2 day tank > 350 gal. Each SR is modified by a Note that states which unit the SR applies. This changes the CTS by stating the DG fuel oil requirements in the ISTS SR format.

ITS 3.8.1 ITS A.3 Unit 1 LCO 3.8.1.1 requirement 3.8.1.1.b.2 requires a separate fuel storage system SR 3.8.3.1 3.8.1.1.b.2, 3.8.3 containing a minimum of 17,500 usable gallons of fuel. Unit 2 LCO 3.8.1.1 requirement 4.8.1.1.2.a.2 CTS 3.8.1.1 3.8.1.1.b.2 for fuel storage system requires 53,225 gallons of fuel. Surveillance requirement 4.8.1.1.2.a.2 for each unit requires the verification of fuel level in the fuel storage tank. ITS SR 3.8.3.1 states "Verify each fuel oil storage tank contains: for Unit 1 I 17,500 gal and for Unit 2 > 53,225 gal." This changes the CTS by stating the DG fuel oil requirements in the ISTS SR format.

ITS 3.8.1 ITS A.4 LCO 3.8..1b requi two separate and independent diesel generators to be OPERABLE.

8.1 3.8.1.1.b 3.8.3 ITS LCO 3.8.1 b stat "Two diesel generators (DGs) capable of supplying the onsite CTS 3.8.1.1 Class 1 E wer ditributi subsystem(s)," shall be OPERABLE. This changes the CTS by stating that Gs are pable of supplying the required electrical power to the distribution subsys at they serve.

ITS 3.8.1 ITS A.5 LCO 3.8.1.1.a states two physically independent circuits between the offsite transmission 3.8.1.a 3.8.1.1.a 3.8.3 network and the onsite Class 1E distribution system shall be OPERABLE. ITS LCO 3.8.1.a CTS 3.8.1.1 states two qualified circuits between the offsite transmission network and the onsite Class 1 E AC Electrical Power Distribution System shall be OPERABLE. This changes the CTS requirement by modifying the description of the offsite circuits from "physically independent" to the ITS requirement for the circuits description of "qualified."

ITS 3.8.1 ITS A.6 Not used.

3.8.3 CTS 3.8.1.1 BVPS Units 1 and 2 Page 85 of 109

Table A Administrative Changes Section 3.8 - Electrical Power Systems ITS #

DOC #

Description of Change ITS Requirement CTS Requirement CTS #

OPERABLE diesel satisfies the diesel generator test requirement of Action Statement b.

ITS Condition D does not contain these required actions, This changes the CTS by eliminating the specific requirements for an inoperable offsite circuit or DG.

ITS 3.8.1 ITS A. 11 CTS Action d states that following restoration of one offsite source, Action Statement a with Action C Action d 3.8.3 the time requirement of that Action Statement based on the time of initial loss of the CTS 3.8.1.1 remaining inoperable offsite A.C. circuit. ITS Condition C does not specific these required actions to be performed. This changes the CTS by deleting the stated requirement.

ITS 3.8.1 ITS A.12 CTS Action e states that following restoration of one diesel generator unit, follow Action Action E Action e 3.8.3 Statement b with the time requirement of that Action Statement based on the time of initial CTS 3.8.1.1 loss of the remaining inoperable diesel generator. A successful test of diesel OPERABILITY per Surveillance Requirement 4.8.1.1.2.a.5 performed under this Action Statement for a restored to OPERABLE diesel satisfies the diesel generator test requirement of Action Statement b. ITS Condition E does not contain these required actions. This changes the CTS by eliminating the specific requirements for two inoperable DGs.

ITS 3.8.1 ITS A.13 CTS Action e requires a demonstration of the OPERABILITY for two offsite A.C. circuits by Action E Action e 3.8.3 performing Surveillance Requirement 4.8.1.1.1.a within one hour and at least once per 8 CTS 3.8.1.1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> thereafter. ITS Condition E does not contain these required actions. This changes the CTS by eliminating the specific requirements for two inoperable DGs.

ITS 3.8.1 ITS 3.8.3 CTS 3.8.1.1 A. 14 CTS LCO 3.8.1.1 Actions a, b, c, d, and e provide an action to restoring an inoperable offsite circuit(s) and diesel generator(s) within specified times. If the required equipment can not be returned to OPERABLE status within the Action's allowed outage time, the unit is required to be in at least HOT STANDBY within the next six hours and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. ITS 3.8.1 Action G states that the Required Action and associated Completion Time of Condition A, B, C, D, E, and F are not met the unit must be placed in MODE 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 5 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. This changes the CTS by collecting all of the shutdown requirements into a single Action.

Action H Actions a, b, c, d, and e ITS 3.8.1 ITS A.15 CTS LCO 3.8.1.1 Action c states that if one offsite circuit and one diesel generator are 3.8.3 inoperable, demonstrate the OPERABILITY of the remaining A.C. sources by performing CTS 3.8.1.1 Surveillance Requirement 4.8.1.1.1.a within one hour and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter; Additionally, the Action requires the restoration one of the inoperable sources (offsite or DG) to OPERABLE status within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. ITS Condition Required Actions D.1 and D.2 require the restoration of a source (offsite or DG) within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. This changes the CTS by eliminating the requirement for verifying the remaining A.C. sources within an hour and at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter.

ITS 3.8.1 ITS A.16 CTS LCO 3.8.1.1 Actions a, b, c, d, and e provide an action to restoring an inoperable 3.8.3 offsite circuit(s) and diesel generator(s) within specified times. The Actions limit the BVPS Units 1 and 2 Page 87 of 109

Table A Administrative Changes Section 3.8 - Electrical Power Systems ITS 9 DOC #

Description of Change ITS Requirement CTS Requirement CTS #

ITS 3.8.10 assemblies." Unit 2 LCO 3.8.2.2 applicability states MODES 5 and 6 and, 'During CTS 3.8.2.2 movement of recently irradiated fuel assemblies and, During movement of fuel assemblies over recently irradiated fuel assemblies." ITS LCO 3.8.8 Applicability states MODES 5 and 6 and, "During movement of irradiated fuel assemblies and, during movement of fuel assemblies over irradiated fuel assemblies for Unit 1 and, During movement of recently irradiated fuel assemblies and, during movement of fuel assemblies over recently irradiated fuel assemblies for Unit 2." This changes the CTS by combining the applicability of ITS LCO 3.8.8 into a requirement for each unit.

ITS 3.8.8 A.3 Unit 1 LCO 3.8.2.2 Action in part states, "during movement of irradiated fuel assemblies Action A.2.2 Actions ITS 3.8.10 and, during movement of fuel assemblies over irradiated fuel assemblies." Unit 2 LCO 3.8.2.2 Action in part states, "during movement of recently irradiated fuel assemblies and, CTS 3.8.2.2 during movement of fuel assemblies over recently irradiated fuel assemblies." ITS LCO 3.8.8 Action A.2.2 states "During movement of irradiated fuel assemblies and during movement of fuel assemblies over irradiated fuel assemblies for Unit 1, during movement of recently irradiated fuel assemblies, during movement of fuel assemblies over recently irradiated fuel assemblies for Unit 2." This changes the CTS by combining the Action of LCO 3.8.8 into a requirement for each unit.

ITS 3.8.8 A.4 Not used.

ITS 3.8.10 CTS 3.8.2.2 ITS 3.8.8 A.5 Not used.

ITS 3.8.10 CTS 3.8.2.2 ITS 3.8.8 A.6 CTS LCO 3.8.2.2 states in part that at a minimum, one of the following trains of A.C.

LCOs LCO ITS 3.8.10 Busses shall be OPERABLE. Each train requires specific 4160, 480, and 120 VAC buses to be OPERABLE. The 120 VAC buses required inverter to supply the required electrical CTS 3.8.2.2 power. ITS LCOs 3.8.8, "Inverters - Shutdown," requires two inverters to be OPERABLE and 3.8.10, "Distribution Systems - Shutdown," requires the distribution systems necessary to support the necessary equipment to provide the required safety functions.

This changes the CTS by dividing the AC distribution requirement during shutdown into the/

ITS LCOs for Inverters and Power Distribution System requirements.

ITS 3.8.8 A.7 CTS 3.8.2.2 Action, in part, states "With less than the above required train of A.C.

3.8.

AAction Actions ITS 3.8.10 Emergency Busses not fully energized in the required manner, immediately suspend all A.2.

CTS 3.8.2.2 operations involving CORE ALTERATIONS, positive reactivity ang7 LCO 3.9.8.

requires one RHR loop to be OPREABLE and in operation. ClS LCO 3.98.2.riquires 2 1 RHR loops to be OPERABLE. ITS LCO 3.8.10 Required Acticn A.2states "Detlare Page 93 of 10 9 BVPS Units 1 and 2

Table A Administrative Changes Section 5.0 - Administrative Controls ITS #i DOC #

Description of Change ITS Requirement CTS Requirement CTS #

CTS are revised to conform to the ISTS. This changes the CTS by providing a statement of applicability of ITS SR 3.0.2 (CTS 4.0.2) and ITS SR 3.0.3 (CTS 4.0.3) to ITS 5.5.2 (Radioactive Effluent Control Program) and a statement of applicability of ITS SR 3.0.3 (CTS 4.0.3) to ITS 5.5.4 (Inservice Testing Program).

ITS 5.0 A.8 CTS 6.8.6 provides requirements for the Radioactive Effluent Controls Program. ITS 5.5.2 5.5.2 6.8.6 CTS 6.0 includes the sam euirements for the Radioactive Effluent Controls Program, except that the CTS [efrernces to-r-a*'awn exposure and dose are modified to reflect the revised ITS 5.0 A.9 Nosed.

3----1 CTS 6.0 ITS 5.0 A.10 S 6.9.5 in des a list of Tehnical Specifications (TS) for which core operating Ii ts 5.6.

6.5 CTS 6.0 e estab ed and docume ed in the CORE OPERATING LIMITS REPORT (COL CTS 60 I S56 includes a similar ýsst of TS, but also includes LCO 3.1.1, "SHUTDOWN MAR!I (biMW, LCO3.1.3, =Mod fator Temperature Coefficient (MTC)," and LCO 3.9.1, "Boron ITS 5.0 A.11 CTS 6.1 inment Leakage Rate Testing Program, exempts the requirements of CTS 5.5.12 6.17 CTS 6.0 4.0.2 from applying to the frequencies specified in the Primary Containment Leakage Rate Testing Program. ITS 5.5.12, Containment Leakage Rate Testing Program, does not include this explicit exemption of the requirements of ITS SR 3.0.2, but states that

.nothing...shall be construed to modify the testing Frequencies required by 10 CFR 50, Appendix J." This changes the CTS by replacing the explicit exemption of CTS 4.0.2 (ITS SR 3.0.2) with a more general statement.

ITS 5.0 A.12 CTS 4.0.5.a.1 and a.2 state inservice inspection and inservice testing required by 10 CFR NA 4.0.5.a.1 and a.2 CTS 6.0 50.55a(g) and 10 CFR 50.55a(f) shall be performed. The ISTS does not include these requirements. The CTS are revised to conform to the ISTS. This changes the CTS by eliminating the explicit requirement to comply with the requirements of 10 CFR 50.55a(f) and 10 CFR 50.55a(g).

ITS 5.0 A.13 CTS 4.0.5.b includes a definition of inservice testing surveillance intervals. The CTS listing 5.5.4 4.0.5.b CTS 6.0 does not include a definition "Biennially or every 2 years. The ISTS requirements for inservice testing (5.5.4) do include a definition of the Frequency "Biennially or every 2 years. The CTS are revised to conform to the ISTS. This changes the CTS by adding a definition of "Biennially or every 2 years."

ITS 5.0 A.14 CTS 4.0.5 provides the Inservice Testing Program requirements. CTS 6.8.6.a provides the 5.5.2, 5.5.4 4.0.5, 6.8.6.a CTS 6.0 Radioactive Effluent Control Program requirements. Both of these CTS programs contain BVPS Units 1 and 2 Page 106 of 109

Table L Less Restrictive Changes Section 1.0 - Use and Application ITS #

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

[

Requirement ITS 1.0

[1 The CTS definition of CHANNEL FUNCTIONAL TEST requires the use of a 1.0 Definitions 1.11 Specific CTS 1.0 simulated signal when performing the test. The ISTS CHANNEL OPERATIONAL TEST (COT) definition allows the use of an actual or simulated signal when performing the tests. This changes the CTS by allowing the use of an actual signal instead of a simulated signal to perform the Surveillance if sufficient information is collected to satisfy the surveillance test requirements.

ITS 1.0

[.2 The CTS definition for SHUTDOWN MARGIN (SDM) specifies that the single 1.0 Definitions 1.13 Specific CTS 1.0 rod duster assembly of highest reactivity worth is assumed to be fully withdrawn for calculating the SDM. The ISTS definition for SDM provides an exception to this requirement. The ISTS definition allows the following relaxation "with all RCCAs verified fully inserted by two independent means, it is not necessary to account for a stuck RCCA in the SDM calculation. The CTS definition is revised to incorporate the ISTS relaxation.

ITS 1.0

[.3 The CTS average Coolant Temperatures specified in Table 1.1 for Refueling is 1.0 Definitions Table 1.1 2

CTS 1.0 revised consistent with the ISTS. The CTS Table specifies < 140'F for this Mode of operation. The corresponding ISTS Table 1.1-1 does not specify a temperature for Refueling Mode and "NA" is used instead of a temperature.

As CTS Table 1.1 specifies the conditions of Applicable Modes, this change is considered a relaxation of Applicability.

ITS 1.0 L.4 Unit 2 Only. The CTS requirement for actuation logic test is revised to be 1.1 Definitions Unit 2 32 Specific CTS 1.0 consistent with the ISTS definition of ACTUATION LOGIC TEST. The CTS (ESFAS) and ISTS requirements are effectively the same with the exception of the ISTS allowance to use "simulated or actual" input combinations. The CTS is revised 3(4.3.2 to incorporate the ISTS relaxation. This changes the CTS by allowing the use of an actual signal instead of a simulated signal to perform the Surveillance if sufficient information is collected to satisfy the surveillance test requirement.

ITS 1.0 L.5 Unit 2 only. The CTS requirement for slave relay testing is revised consistent 1.1 Definitions Unit 2 -

CTS 1.0 with the ISTS definition of SLAVE RELAY TEST. The CTS requires that "a (ESFAS) continuity check of associated actuation devices that are not testable" be performed during each SLAVE RELAY TEST. The less restrictive change introduced by the ISTS definition requirement is the allowance to only "include a continuity check of associated required testable actuation devices". This changes the CTS by not requiring a continuity check of actuation devices that are not testable.

BVPS Units I and 2 Page I of 107

Table L Less Restrictive Changes Section 3.1 - Reactivity Control Systems ITS #

DOC #

Description of Change ITS Requirement CTS Category CTS #

j Requirement ITS - NA NONE CTS 3.10.1, 3.10.2, &

3.10.3 (Ul)

ITS 3.1.9 L.1 ITS 3.1.9 states that the nu berofrequir channels rLCO3.3.1,"RTS 3.1.9 LCO 3.10.3 and 3.10.4 CTS 3.10.3 Instrumentation," Functions

, 3,'6, and may reduced to "3" required LCO (Unit 2) channels, during the perform ce of PHYSIC TS. The CTS (3.10.3 or 3.10.4) does not contain this allowance.-

e CTS is revised to conform to the CTS 3.10.4 ISTS. This changes the CTS by reducing LCO requirements for the number of (Unit 1 )

Power Range Neutron Flux channels from "4" to "3" during PHYSICS TESTS initiated in MODE 2.

ITS 3.1.9 L.2 CTS 4.10.3.2 requires that tests be performed on each Intermediate and SR 3.1.9.1 4.10.3.2 7

CTS 3.10.3 Power Range channel within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> prior to initiating PHYSICS TESTS.

(Unit 2)

The corresponding ISTS surveillance (ITS SR 3.1.9.1) requires that the testing be performed prior to initiation of PHYSICS TESTS in accordance with CTS 3.10.4 the existing instrumentation TS (3.3.1) surveillances (ITS SR 3.3.1.6 and ISTS (Unit 1 )

SR 3.3.1.7). The CTS is revised to conform to the ISTS. This changes the CTS by eliminating the additional test required within a specific time prior to the initiation of PHYSICS TESTS.

ITS 3.1.9 L.3 CTS 3.10.4, PHYSICS TESTS, provides exceptions to several LCOs in order 3.1.9 LCO 3.10.4 LCO CTS 3.10.3 to perform routine post refueling outage physics testing. The corresponding (Unit 2)

ISTS PHYSICS TEST Exception (ITS 3.1.9) contains one additional exception that is not included in CTS 3.10.4. The ISTS Test Exception provides an CTS 3.10.4 exception to LCO 3.4.2, Minimum Temperature for Criticality. The ISTS also (Unit 1) contains Action and surveillance requirements to verify and maintain the RCS temperature within the required limit. The Unit 1 CTS 3.10.4 is revised to conform with the ISTS test exceptions. This changes CTS 3.10.4 by adding the exception to the LCO minimum temperature for criticality.

ITS 3.1.10 NONE CTS - NA BVPS Units 1 and 2 Page 16 of 107

Table L Less Restrictive Changes Section 3.3A - 3.3.1, Reactor Trip System Instrumentation ITS #

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

Requirement ITS 3.3.1 L.19 CTS Table 4.3-1 specifies the surveillance requirements for the RTS Functions.

Intermediate Table 4.3-1 2

CTS 3.3.1.1 As part of the surveillance requirements, CTS Table 4.3-1 specifies the required Range Function Intermediate modes for performing the surveillances. In the case of the Intermediate Range Applicability Range Function RTS Function, CTS Table 4.3-1 specifies Mode 1 for performing surveillances, Applicability The corresponding ISTS requirements for the RTS Function do not include a separate Table for surveillance requirements. All the requirements associated with an RTS Function are presented in ISTS Table 3.3.1-1. In addition the ISTS, does not require the Intermediate Range RTS Function to be operable above P-10 (approximately 10% RTP). CTS Table 3.3-1 which also contains Applicable Modes for the RTS Function specifies the Intermediate Range Function may be bypassed above P-1 0. The CTS applicable Mode specified in Table 4.3-1 for the Intermediate Range RTS Function is revised to conform to the ISTS and to be more consistent with the Mode specified on CTS Table 3.3-1. This changes the CTS by combining the requirements for the RTS Functions into a single Table and relaxing the current Mode 1 requirement for performing surveillances by the addition of Footnote (b) to Mode 1 which identifies that the Function is only required in Mode 1 below P-10.

ITS 3.3.1 CTS 3.3.1.1 L.20 CTS Table 4.3-1 specifies the surveillance requirements for the RTS Functions.

As part of the surveillance requirements, CTS Table 4.3-1 specifies the required modes for performing the surveillances. In the case of the Source Range RTS Function, CTS Table 4.3-1 specifies Mode 2 for performing surveillances. The corresponding ISTS requirements for the RTS Function do not include a separate Table for surveillance requirements. All the requirements associated with an RTS Function are presented in ISTS Table 3.3.1-1. In addition the ISTS, does not require the Source Rane RTS Function to be operable above P-6 (approximately 9 X 10-amps). CTS Table 3.3-1 which also contains Applicable Modes for the RTS Function specifies the source Range Function may be bypassed above P-6. The CTS applicable Mode specified in Table 4.3-1 for the Source Range RTS Function is revised to conform to the ISTS and to be more consistent with the Mode specified on CTS Table 3.3-1. This changes the CTS by combining q

ments for the RTS Functions into a single Table and relaIn n Mode-2 quirement for performing surveillances by the addi

• of Foo~tnoe to M 2 which identifies that the Function is only re ired in Mode /elow P-6.1.

Source Range Function Applicability Table 4.3-1 Source Range Function Applicability 2

I BVPS Units 1 and 2 Page 27 of 107

Table L Less Restrictive Changes Section 3.31 - instrumentation (Other than RTS & ESFAS)

ITS #

DOC #

Description of Change ITS Requirement CTS Category CTS #

I I

Requirement ITS 3.3.4 L.1 Unit 2 only. CTS LCO 3.3.3.5 requires instrumentation channels to be Actions A&B 3.3.3.5 Action 4

CTS 3.3.3.5 OPERABLE for the remote shutdown panel for various parameters. The Action requires "With the number of OPERABLE remote shutdown rnonitorng channels less than required by Table 3.3-9, either restore the inoperable channel to OPERABLE status within 7 days, or be in HOT SHUTDOWN within

-*he next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />." ITS LCO 3.3.4 states "The Remote Shutdown System F

ction shall be OPERABLE. ITS LCO 3.3.4 Action A states "One or more req ed Functions inoperable, restore required Function to OPERABLE

status, ith an allowed Completion Time of 30 days. ITS Action B is entered if the Req Action cannot be accomplished within the allowed time. ITS

-oondition B tates "Required Action and associated Completion Time not me-" -_equir d Action B.1 requires the unit to be in MODE 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and

• ,MODEnOE* in f2 hours.T rThe C

e form to the ISTS. This hanes; tl CTS by allo 0dysisedoays for a remote shutdown Fun-SE11-o b inpere before requiring the unit *hton ITS 3.3.4 L.2 Not used.

indication CTS 3.3.3.5 ITS 3.3.4 L.3 CTS surveillance quirement 4.3..5 states "Each r ote shutdown SR 3.3.4.1 4.3.3.5, Table 4.3-6 CTS 3.3.3.5 monitoring instru ntation chann shall be demons ated OPERABLE by 6 Note 4 performance of the HANNEL CH CK and CHAN L CALIBRATION operations at the fre uencies show in Table 4.3-6. The CTS Source Range Channel Check requi ments on Ta le 4.3-6 are dified by CTS Note 4 that states "Below P-6." Th orrespondiig ITS LCO R 3.3.4.1 states "Perform CHANNEL CHECK for eac quire nstrume tion channel that is normally energized." ITS Table 3.3.4-1 in lists the instrumentation channels for which ITS SR 3.3.4.1 applies but does not include any notes modifying the Source Range Instrument requirements. The CTS surveillance requirements are revised to conform to the corresponding ISTS surveillance requirement. This changes the CTS by specifying a CHANNEL CHECK be performed for each required channel only if the channel is normally energized.

In addition, the proposed change eliminates the Note modifying the Source Range instrument Channel Check.

BVPS Units 1 and 2 Page 34 of 107

Table L Less Restrictive Changes Section 3.3B - Instrumentation (Other than RTS & ESFAS)

ITS #

DOC #1 Description of Change ITS Requirement CTS Category CTS #

I I

Requirement ITS 3.3.5 L.2 CTS Action 33 applies when one loss of power channel is inoperable and Action D Action 33 3

CTS 3.3.2.1 requires that the associated DG be declared inoperable immediately. The corresponding ITS Action Condition D is also applicable to a single inoperable channel but allows one hour to restore the inoperable channel to operable status prior to declaring the associated DG inoperable. The CTS Action is revised to conform to ITS Action Condition D (similar to ISTS Action Condition B). This changes the CTS by providing an additional hour to restore the inoperable channel.

ITS 3.3.5 L.3 CTS Action 34 requires that "With the number of OPERABLE channels one Action B Action 34 3

CTS 3.3.2.1 less than the Minimum Number of Channels, place the inoperable channel in the tripped condition within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />...." The corresponding ISTS Action Condition A (ITS Condition B) provides a 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> completion time to place a channel in trip. The CTS Action is revised to conform to the ISTS. This changes the CTS by providing additional time to place an inoperable channel in trip.

ITS 3.3.5 L.4 CTS Action 34 requires that an inoperable loss of power channel be placed in Action B Action 34 4

CTS 3.3.2.1 the trip condition and allows operation to continue with the affected channel in trip. The corresponding ITS Action Condition B is similar except for the Required Action Note that states, "The inoperable channel may be bypassed for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for surveillance testing of other channels provided the corresponding instrument channels, electrical bus, and DG in the other train are OPERABLE." The CTS is revised to conform to the ITS. The proposed change provides an allowance to perform routine surveillance testing n,*a remaining operable channel on an electrical bus when oethtochannels on that bus is in trip.

ITS 3.3.5 L.5 The CTS surveillances for the loss of power Fun' ns specified in Table 4.3-2 SR 3.3.5.

Table 4.3-2 6

CTS 3.3.2.1 require a quarterly Channel Functional Test (CF.

The corresponding ITS CT

.321surveillance requirement for this ESFAS Function (SR 3.3.5.Vpxife quarterly Trip Actuating Device Operational Test D'OT). Tlhe ITS TAD0OT'-

requirement is modified by a note that specifies that v cation of setpoints is not required. The CTS surveillance is revised to conform to This changes the CTS by adding a specific exception for setpoint verification when performing the quarterly functional test.

BVPS Units 1 and 2 Page 36 of 107

Table L Less Restrictive Changes Section 3.3C - 3.3.2, Engineered Safety Feature Actuation System (ESFAS) Instrumentation ITS #

DOC #

Description of Ch ITS Requiremeý CTS Category CTS #

/

j Requirement ITS 3.3.2 L.1 CTS surveillance 4.3.2.1.3 specifies the resfons ti e tes ng requirements SR 3.3.2.

4.3.2.1.3 7

CTS 3.3.2.1 for the ESFAS Functions. The correspond g I TS R 3.2.ý ntains a note that provides an allowance for verifyin he reions time 3h.7bfo driven AFW pump. The ISTS allowance providg time alay applicable--

during plant startups and that is based on reaching the resired steam ci pressure for operating the turbine pump. TherCTS ESFAS ponse time surveillance is revised to incorporate the allowance provided b Th.J S note.

The proposed change modifies the ISTS allowance consistent with the f,

pressure provisions of a similar allowance that exists in CTS Section 3.7 for testing the turbine-driven AFW pump. This changes the CTS by providing a delay time for testing the AFW pump to allow for the necessary plant condition (steam pressure) to ensure proper turbine operation.

In addition, the proposed change makes the ESFAS response tim6 test requirement for the turbine-driven AFW pump consistent with the CTS test requirements for this pump in Section 3.7 of the CTS.

ITS 3.3.2 L.2 The Unit 1 and 2 CTS ESFAS requirements for steamline isolation include the NA LCO, Action, SR 1,4, 5 CTS 3.3.2.1 manual switches for the individual main steam isolation valves. The Unit 2 ESFAS requirements also include the system level steam line isolation manual initiation switches. The ISTS only requires a single manual initiation feature for steam line isolation. The CTS requirements are revised to be more consistent with the ISTS requirements and the BVPS Unit 1 and 2 ESFAS design. This changes the Unit 1 and 2 CTS by eliminating the individual main steam isolation valve control switches from the ESFAS Instrumentation TS.

The proposed change includes the elimination of the LCO, Action, and Surveillance requirements associated with this instrumentation.

ITS 3.3.2 L.3 CTS Table 3.3-3 Note (1) states that the "trip function may be bypassed in this Table 3.3.2-1 Note Table 3.3-3 Note 1 2

CTS 3.3.2.1 MODE below P-1." The CTS Note is used to modify the Mode 3 Applicability for (a) certain ESFAS Functions associated with the P-1 1 interlock. The corresponding ISTS Note (a) states; "Above the P-11 (Pressurizer Pressure) interlock. The ISTS Note is also used to modify the Mode 3 Applicability of ESFAS Functions associated with the P-11 interlock. The CTS is revised to conform to the ISTS.

This changes the CTS by relaxing the Applicability such that the ESFAS Functions are only required operable in Mode 3 above the P-11 interlock.

BVPS Units 1 and 2 Page 41 of 107

113.41 Table L Less Restrictive Changes Section 3.4 - Reactor Coolant System ITS#

DOC#1 Description of Change ITS Requirement CTS Category CTS #

,JRequirement ITS;-s:1-L.1 e CTS action statement for DNB parameters not within limits requires that Action Action 3

CTS 3.2.5 ethe parameter be restored to within the limit within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or that power be reduced to less than 5% RTP within the following 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. The corresponding ISTS Actions also allow 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to restore the affected parameter(s) to within the limit but the ISTS provides 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to reach Mode 2 ( < 5% power) if the parameter(s) are not restored to within the limit. The CTS Action time is revised to be consistent with the ISTS. This changes the CTS by allowing more time to reach Mode 2.

ITS 3.4.2 L.1 CTS Surveillance 4.1.1.5 states that the RCS Tavg shall be determined to be >

SR 3.4.2.1 4.1.1.5 7

CTS 3.1.1.5 541 'F within 15 minutes prior to achieving reactor criticality and every 30 minutes when the RCS Tavg < 5511F and the Tag deviation alarm not reset.

The corresponding ISTS SR 3.4.2.1 requires RCS Tavg in each loop to be verified to be _> 541'F every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The CTS is revised to conform to the ISTS. This changes the CTS Surveillance Frequency by requiring that the RCS Tavg for each loop be verified every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> which would include one verification within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> prior to achieving criticality. In addition, this change makes the greater than symbol used in the surveillance consistent with the required greater than or equal to symbol specified in the LCO.

ITS 3.4.4 NONE CTS 3.4.1.1 ITS 3.4.5 L.1 CTS Action Statement b provides the requirements for less than two RCS Action C Action b 3

CTS 3.4.1.2 loops in operation and specifies immediate Actions be taken. The Corresponding ISTS Action is limited to one required RCS loop not in operation and provides 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> for completion of the Actions. The CTS is revised to conform to the ISTS Action. This changes the CTS by limiting the Action Condition to a single RCS loop not in operation and allowing up to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> for completion of the required Actions.

BVPS Units 1 and 2 Page 47 of 107

Table L Less Restrictive Changes Section 3.4 - Reactor Coolant System ITS #

DOC #

Description of Change ITS Requirement CTS Category CTS #

Requirement ITS 3.4.12 L.3 CTS 4.4.9.3.3 is applicable hen the RCS vent is required. The CTS SR 3.4.12 4.4.9.3.3 7

CS 3.4.9.3su lance requires that a open vent (i.e., removed pressurizer safety valve) or unl cked open vent valv be verified every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The corresponding U1 CTS3.5.4IXTS,, urveillanice SR 3.4.1 A.)@;31.day-s for the verification of an open vent,spch as a removed prI ssurizer safeylaýsrvsd to be cons tent with the ISTS.

is changes the CTS by extending the su-3eftnmo-

'Mftef'val for an open vent from 2hurs to every 31 days.

ITS 3.4.11 L. 1 Not used.

CTS 3.4.11 ITS 3.4.11 L.2 CTS Actions d and e address inoperable block valves. The corresponding Actions C & F Actions d & e 4

CTS 3.4.11 ISTS Action Conditions C and F contain Notes that provide an exception to the associated Actions for inoperable block valves when the block valve is inoperable solely as a result of complying with Required Actions to remove the power. The CTS Actions are revised to conform to the ISTS. This changes the CTS by providing an exception to the Actions associated with inoperable block valves when the block valves are inoperable solely as a result of complying with Required Actions to remove the power.

ITS 3.4.11 L.3 CTS surveillance 4.4.11.2 requires that each PORV block valve be operated SR 3.4.11.1 4.4.11.2 7

CTS 3.4.11 through one complete cycle of full travel once per 92 days unless the block valve is closed to meet required Actions b or c. The corresponding ISTS surveillance SR 3.4.11.1 specifies a similar 92 day requirement to cycle the valve except that the surveillance is not required if the block valve is closed to meet any required Action of the LCO. The CTS surveillance is revised to conform to the ISTS surveillance. This changes the CTS by expanding the CTS allowance to not perform the surveillance if the valve is closed to meet Actions b or c to not require the surveillance to be performed if the valve is closed to meet any required Action of the LCO.

BVPS Units 1 and 2 Page 57 of 107

Table L Less Restrictive Changes Section 3.5 - Emergency Core Cooling Systems ITS #

DOC #

Description of Change ITS Requirement [

CTS Category CTS #

I Requirement ITS 3.5.1 L.1 Unit 2 only. CTS 4.5.1.c for Unit 2 requires the verification that power is SR 3.5.1.5 4.5.1.c 7

CTS 3.5.1 rem each accumulator isolation valve operator control circuit at least e

ry 31 days w never RCS pressure is > 1000 psig. ITS SR 3.5.1.5 ontains the same uirements, but is onlynecessary whenever RCS ressure is'%2000 psi This changes the Unit 2 CTS by only requiring erification Q power re val above 2000 psig and tm ing the urveillance f iquency.

e Unit 1 CTS currently lects a re irement of >

000 psig.

ITS 3.5.2 L.1 C

3.5.2 Action a sta s that when cine tra' is in rable, it ust be Actions Actions 4

CTS 3.5.2 retu d to OPERABLF status within 72 ho rs.

3.5.2 Act' n A states, when o s are inoperable, re= or~e the trains JrPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. ITS 3.5.2 ACTION C s a h less than 100% of the ECCS flow equivalent to a single OPERABLE ECCS train available, enter LCO 3.0.3 immediately. This changes the CTS by allowing combinations of equipment in each train to be credited with meeting the ECCS safety function provided 100% of the ECCS flow equivalent to a single OPERABLE ECCS train is available.

ITS 3.5.2 L.2 CTS 3.5.2 Action b requires that a Special Report be prepared and submitted NA Action b 8

CTS 3.5.2 to the NRC within 30 days following an ECCS actuation that results in water being injected into the Reactor Coolant System. The report is to describe the circumstances of the actuation and the total accumulated actuation cycles to date. ITS 3.5.2 does not include this requirement. This changes the CTS by deleting this reporting requirement.

ITS 3.5.2 L.3 CTS LCO 3.5.2 states that two ECCS systems shall be Operable. ITS 3.5.2 LCO Note LCO CTS 3.5.2 states that two ECCS trains shall be Operable and provides an LCO Note that allows, in MODE 3, both low head safety injection pump flow paths to be isolated by closing the isolation valves for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to perform pressure isolation valve testing per SR 3.4.14.1. This changes the CTS by adding an exception in MODE 3 allowing the low head safety injection pump flow paths to be blocked for a limited time (2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />) to accomplish RCS pressure isolation valve (PIV) testing at elevated RCS pressure conditions.

BVPS Units 1 and 2 Page 60 of 107

Table L Less Restrictive Changes Section 3.6 - Containment Systems ITS #

DOC #

Description of Change ITS Requirement CTS Category CTS #

[

Requirement ITS 3.6.7 L.1 CTS surveillance 4.6.2.2.b requires that each RSS subsystem be verified NA 4.6.2.2.b 5

CTS 3.6.2.2 operable when tested pursuant to Specification 4.0.5, by manually starting each recirculation spray pump and verifying the pump shaft rotates. The corresponding ISTS surveillance do not include this requirement. The CTS is revised to conform to the ISTS. This changes the CTS by deleting CTS surveillance requirement 4.6.2.2.b.

ITS 3.6.7 L.2 CTS Surveillances 4.6.2.2.c and 4.6.2.2.e.2 require verification of the SR 3.6.7.3.a and 4.6.2.2.c and 6

CTS 3.6.2.2 automatic actuation of RSS components on a Containment pressure high-high SR 3.6.7.3.b 4.6.2.2.e.2 signal and a test signal. The corresponding ISTS SR 3.6.7.3.a and SR 3.6.7.3.b specify that the testing may be performed with an actual or simulated actuation signal. The CTS is revised to conform to the ISTS. This changes the CTS by explicitly allowing the use of either an actual or simulated signal for the test.

ITS 3.6.7 L.3 The U2 CTS surveillance 4.6.2.2.e.1 requires cycling each power operated NA 4.6.2.2.e.1 5

CTS 3.6.2.2 (excluding automatic) valve in the flow path through at least one complete cycle of full travel every 18 months. The U 1 version of this surveillance is the same except it applies to valves that are not testable during plant operation.

The corresponding ITS 3.6.7 does not contain a similar surveillance to the U 1 or U2 CTS 4.6.2.2.e.1. The CTS is revised to conform to the ISTS. This changes the CTS by deleting surveillance 4.6.2.2.e.1.

ITS 3.6.7 L.4 CTS Surveillance 4.6.2.2.e.2 requires verification that each automatic valve i SR 3.6.7.3.a\\

4.6.2.2.e.2 6

CTS 3.6.2.2 the flow path actuates to its correct position on a test signal. ISTS SR 3.6.7.3.a requires verification that each automatic valve in the flow path that is not locked, sealed, or otherwise secured in position actuates to its correct position on an actual or simulated actuation signal. The CTS surveillance is revised to conform to the ISTS. This changes the CTS by excluding those valves that are locked, sealed, or otherwise secured in position from this test.

ITS 3.6.7 L.5 Unit 1 only. Unit 1 CTS 3.6.2.2 Action statement b applies to two inoperable Action B & D Action b 3

CTS 3.6.2.2 RSS subsystems and requires one subsystem to be restored to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or the plant must be placed in Mode 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and Mode 5 in 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. The corresponding ISTS Actions for two inoperable subsystems (ITS 3.6.7 ConditionsB and D) are similar except that a total of 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br /> (ITS 3.6.7 Cond D) are allowed to reach Mode 5 instead of a total of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> (6 plus 30) that the Unit 1 CTS Action b allows. The CTS is revised to conform to the ISTS. This changes the CTS by extending the time allowed by the Actions to reach Mode 5 from Mode 3. The proposed change effectively allows 48 additional hours after the plant is placed in Mode 3 to reach Mode 5 (6+48+30= 84).

BVPS Units 1 and 2 Page 69 of 107

Table L Less Restrictive Changes Section 3.8 - Electrical Power Systems ITS #

DOC #

Description of Change ITS Requirement CTS Category CTS #

Requirement ITS 3.8.1 ITS L.8 CTS surveillance requirement 4.8.1.1.2.b.7 states, "Verifying that the load 3.8.1.c, Actions 4.8.1.1.2.b.7 3.8.3 sequence timer is OPERABLE with each load sequence timer within +/- 10 % of F.1 &F.2 CTS 3.8.1.1 its required value.' If the requirement can not be met, the diesel generator is declared inoperable and the appropriate Actions are entered. ITS LCO 3.8.1.c requires the following AC electrical sources shall be OPERABLE with automatic load sequencers for each required DG. ITS Condition F states that with one load sequencer timer inoperable, Required Actions F.1 and F.2 must be completed immediately. A Note modifies the Condition. The Note states that separate condition entry is allowed for each sequence timer. Required Action F.1.1 specifies the affected component will be placed in a condition that prohibits the component from loading to the emergency bus. Required Ac F. 1.2 states enter appropriate Conditions and Required Actions for m,

subsystem, or component made inoperable by the load sequen imer(s).

Required Action F.2 provides an option by allowing the D e declared inoperable. This changes the CTS requirements by al*

ng a component(s) and engine mour ted tank (Unit 1 only) served by an inoperable load sequence timer to be eclared inoperable, instead of the DG.

ITS 3.8.1 ITS L.9 CTS surveillance requirement 4.8.1.1.2.c. 1 req res a check for an emoval SR 3.8.1.5 4.8.1.1.2.c.1 5

3.8.3 of accumulated water from each diesel generat r day tank eve 1 days. In CTS 3.8.1.1 addition, the check for and removal of water is (equired afte ach operation of a diesel that is greater than an hour in duration ITS S

.1.5 states "Check for and remove accumulated water from each d tan.

This SR must be performed every 31 days. This changes the CTS leting the re ui o

check for and remove water from the day tank when a erated more than an hour.

ITS 3.8.1 ITS LAO CTS surveillance reqj u requires the verification of load SR 3.8.1."1 4.8.1.1.2.b.7 6

3.8.3 sequence times e within specified limits. This surveillance is required to CTS 3.8.1.1 be perfo-during shutdown (MODE 5 or 6). ITS SR 3.8.1.

the ve fn rt,"i,

,m, for--

I re enrec od sequec e.Antemdfes the SR that states the I13 s rveillance shall not normally e performed in MODE 1, 2, 3, and 4. The note Ilows the performance of th SR in MODE 1, 2, 3, or 4 to reestablish OPERABILITY for the DG povides an assessment can determine that the safety of the plant can be aintained or enhanced. The note also allows credit to be taken for unplanne events. This changes the CTS by allowing the performance of the su illance in MODE 1, 2, 3, or 4 if an assessment determines that plant!afety is maintained or enhanced.

that the automatic load sequence time is within + 10% of the required value e84 of 107 BVPS Units 1 and 2

Table L Less Restrictive Changes Section 3.8 - Electrical Power Systems ITS #

DOC #

Description of Change ITS Requirement CTS Category CTS #_

Requirement ITS 3.8.1 ITS L.25 CTS surveillance 4.8.1.1.2.e requires verification that fuel oil particulate 5.5.9.c 4.8.1.1.2.e 6

3.8.3 contaminants are <10 mg/liter. The corresponding ITS 5.5.9.c requires that CTS 3.8.1.1 fuel oil particulate contaminants be verified to be <10 mg/liter. The CTS is revised to conform to the ITS. This changes the CTS limit for particulate contamination to <10 mg/liter from <10 rag/liter.

ITS 3.8.2 L.1 CTS 3.8.1.2 in part states 'With less than the above minimum required A.C.

Action A.1 Actioa" 4

CTS 3.8.1.2 electrical power sources OPERABLE," perform specific actions until the required minimum equipment is restored. ITS 3.8.2 Action A.1 states "Declare affected required feature(s) with no offsite power available inoperable." This is a requirement of LCO 3.0.2. This must be performed immediately, or the Required Actions for suspending CORE ALTERATIONS, movement of irradiated fuel assemblies or recently irradiated fuel assembles, and reactivity changes must be followed. This changes the CTS by allowing CORE ALTERATIONS,,I"_v

nt of irradiated fuel assemblies

,*ivy changes with Itss tan t

• minimum AC source be' PERABLE."*

ITS 3.8.2 L.2 CTS 3.8.1.2 Aci nspý cifies with less than the equired AC electrical Actions Action/

4 CTS 3.8.1.2 sources OPERAB, o

rations involving positiv reactivity changes shall be 4

immediately suspene ITS 3.8.2 Required Acti s

a E.2.3 and reqireentap fy this1.4 requirement and state, "Suspend operations invol Iing positive reatvy

\\

additions that could result in loss of required SDM 1.2r boron concentration."

This changes the CTS requirement by allowing ope tions that are a positive A7,24 a n~d :B. 4 I re a ctiv ity c h a n g e.

.10 III ITS 3.8.2 L.3 CTS surveillance 4.8.1.2 specifies the surveillance requiremen ts ap 4.8.1.26 CTS 3.8.1.2 AC sources during shutdown conditions. CTS 4.8.1.2 states, "The above required A.C. electrical power sources shall be demonstrated OPERABLE by the performance of each of the Surveillance Requirements of 4.8.1.1.1 and 4.8.1.1.2 except for requirement 4.8.1.1.2.a.6." The CTS shutdown surveillance refers to the surveillances required by the AC sources operating specification and only contains a single exception to the surveillances required for AC sources operating. The single exception is CTS surveillance 4.8.1.1.2.a.6 that corresponds to ITS SR 3.8.1.3. Similar to CTS 4.8.1.2, ITS SR 3.8.2.1 specifies the surveillance requirements applicable to AC sources during shutdown conditions. However, SR 3.8.2.1 contains three notes that modify the AC source surveillances required during shutdown conditions and effectively relax the surveillance acceptance criteria applicable to AC sources during shutdown conditions.

BVPS Units 1 and 2 Page 88 of 107

Table L Less Restrictive Changes Section 3.8 - Electrical Power Systems ITS #

I DOC #

Description of Change ITS Requirement CTS T Category CTS #

j D RequirementJ ITS 3.8.7 L.2 CTS 3.8.2.1 Action a, in part, states "With one of the required trains of A.C.

Action A Action a 4

ITS 3.8.9 emergency busses not fully energized, re-energize the train within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />."

ITS LCO 3.8.9 Action A states 'One or more AC electrical power distribution CTS 3.8.2.1 subsystems inoperable, restore the AC electrical power distribution subsystem(s) to OPERABLE status," within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. ITS Condition E provides the Required Action if 2 or more distribution subsystem become inoperable and a loss of safety function occurs. This changes the CTS by allowing more than one subsystem to be mno Lh ITS 3.8.8 L.1 CTS 3.8.2.2 A on specifies with less than the required train of A.C.

A.2.

ITS 3.8.10 Emergency Bu es not fully energized in the required manner, immediately suspend all ope iations invol~iiiiiii positive reactivity changes. ITS 3.8.8 and CTS 3.8.2.2 3.8.10 Required ctions A.2.

nd state, "Suspend operations involvi positive reactivity additions that could result in os5 o 4

required SDM or b on concentration." This changes the CTS requirement by allowing operations t are a positive reactivity change.

ITS 3.8.8 L.2 CTS 3.8.2.2 in part states' W

,I than the above minimum required A.C.

Action A.1 Action 4

ITS 3.8.10 electrical power sources OPERABLE, irrmwjjjtely suspend all operations CTS 3.8.2.2 involving CORE ALTERATIONS, positive reactivi ovement of irradiated fuel assemblies or movement of fuel assemblies over irra la assemblies for Unit 1, and movement of recently irradiated fuel assemblies or movement of fuel assemblies over recently irradiated fuel assemblies for Unit 2," perform specific actions until the required minimum equipment is restored.

ITS 3.8.8 and 3.8.10 Action A.1 states "Declare affected required feature(s) inoperable." This must be performed immediately, or other specific Required Actions must be followed. This changes the CTS by allowing CORE ALTERATIONS, movement of irradiated fuel assemblies, and reactivity changes with less than the minimum AC source being OPERABLE.

BVPS Units 1 and 2 Page 90 of 107

Table L Less Restrictive Changes Section 3.9 - Refueling Operations IT DC#

ecipin fChneITS Requirement 1 CTS 1Category CTS#

ý-,INRequirement]

ITS 3.9.2 L.3 CTS surveillance requirement 4.9.2 specifies that a CHANNEL FUNCTI S

4.9.2 5

CTS 3.9.2 TEST is required for the source range neutron flux monitors at least onc per 7 days and within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> prior to the initial start of CORE ALTERATION The corresponding ISTS surveillance requirements do not include thexh performance of CHANNEL FUNCTIONAL TESTS for the source range is monitors. This changes the CTS by deleting the CHANNEL FUNCTIONAL TEST requirements for the source range monitors in Mode 6.

ITS NA NONE CTS 3.9.3 ITS 3.9.3 L. 1 The CTS LCO requirement 3.9.4.c.2 specifies each penetration providing LCO LCO CTS 3.9.4 direct access from the containment atmosphere to the outside atmosphere be capable of being closed by an OPERABLE Containment Purge and Exhaust Isolation System with the containment air being exhausted through this system at a flow rate of Sp 7500 cfm to at least one OPERABLE filtered SLCRS train is revised to be consistent with the design and licensing bases associated with BVPS Units 1 and 2. The proposed changes are made to more accurately reflect the BVPS specific design. The proposed revisions to the CTS include the following changes to the LCO 3.9.4.c. requirement and associated surveillances: a) The requirement to be capable of being closed by an operable Containment Purge and Exhaust System and the associated surveillances which verify isolation valve actuation and the system flow rate (necessary for response time) are made applicable to Unit 2 only, and b) The requirement for the Purge and Exhaust System air flow to be exhausted to an OPERABLE Supplemental Leak Collection and Release System (SLCRS) train and the surveillance to verify an operable SLCRS train are made applicable to Unit 1 only.

BVPS Units 1 and 2 Page 101 of 107

Table L through ITS SR 3.9.5.4 Less Restrictive Changes Section 3.9 - Refueling Operations ITS #

fDOC # [Description of Cha ITS Requirement CTS Category CTS #

Requirement ITS 3.9.5 L.2 CTS Surveillance 4.9.8.2 re

'res verification that each RHR oop is NA 4.9.8.2 5

CTS 3.9.8.2A OPERABLE per Specification 4. 5. The corresponding IST does not contain this Surveillance. The CT *revised to conform to tt ISTS. This changes the CTS by replacing CTS 4.

2 with the ISTS su illance applicable for this TS (ITS SR 3.9.5.1

. )..52I ITS 3.9.5

.3

ýOr containment closure in CTS 3.9.8.1 are appl able to CTS Action B.5.2 Actions 4

CTS 3.9.8.2 3.9.8.2. CTS 3...

n han one RHR loop in operation, close all containment penetrations providing direct access from the containment atmosphere to the outside atmosphere within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. The corresponding ISTS 3.9.5 states, in part, that with the RHR loop requirements not met, within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> close each penetration providing direct access from the containment atmosphere to the outside atmosphere with a manual or automatic isolation valve, blind flange, or equivalent, or verify each penetration is capable of being closed by an OPERABLE Containment Purge and Exhaust Isolation System. The CTS is revised to conform to the ISTS. This changes the CTS Actions by allowing penetrations capable of being closed by an OPERABLE Containment Purge and Exhaust Isolation System to remain open when the RHR requirements are not met.

ITS 3.9.5 L.4 Not used.

CTS 3.9.8.2 4

+

ITS 3.9.3 L.1 (Unit 2 only) CTS surveillance 4.9.9 specifies the testing required for the ITS 3.3.6 containment purge and exhaust isolation valves. Surveillance 4.9.9 requires containment purge and exhaust system valve actuation and isolation timing CTS 3.9.9 verification every 7 days. The corresponding ITS SRs 3.9.3.3 and 3.9.3.4 require that the containment isolation valve actuation on a simulated or actual actuation signal (hi radiation and manual) as well as isolation timing be verified every 18 months. A note that takes exception to the surveillance when the valves are closed per the LCO requirement modifies the ISTS surveillance.

The CTS is revised to conform to the ISTS. This changes the CTS valve actuation and isolation timing verification surveillance interval from 7 days to 18 months.

SR 3.9.3.3 & SR 3.9.3.4 4.9.9 BVPS Units 1 and 2 Page 103 of 107

D abesito ofCA ng oain Cag ye si CTSActo 5RmvdDtails l

Sec ion 3.3 B - Instrumentation (Other than RTS & ESFAS)

TS 3.3.8 LA.3 Table 3.3-1, e applicable Modes in CTS Table 3.3-1 for the Source Range Bases ITS 5.5.10 2

C S3..

.1Notes 8 & 9 strumentation specify Modes 3, 4, and 5. The Modes are modified by Note 8 (Unit 1) and Note 9 (Unit 2)." The Note states, 'in this condition.

source range Function does not provide reactor trip but does provide indication." The corresponding ITS LCO 3.3.8 "Boron Dilution Detection Instrumentation" does not contain a similar note. The CTS is revised to conform to the ITS. This changes the CTS by moving the description of specfic3-o to the ITS 3.3.8 bases.

ITS 3.3.8 LA5

'-CTS Action 5 states, in part, for an inoperable Source Range channel, Bases ITS 5.5.10 CTS 3.3.1.1 Noe"5Cplicabe u

rto d wth e

r sourcRne instruenttio

n.

valve (

15 2CH-9 T

abln43-ITS does not include specific valve numbers in the specification. The ITS retains the specific valve numbers in the Bases for ITS 3.1.8, "Unborated Water Source Isolation Valves." The Bases for ITS 3.3.8 refers to ITS 3. 1.8 for the specific valves. The CTS Action is revised to conform to the ITS.

This changes the CTS by moving the specific valve ID numbers from the

_______specification to the ITS 3.1.8 Bases.

ITS 3.3.8 LA.5 Table 4.3-1, CTS LCO 3.3.1 Table 4.3-1 specifies the surveillance requirements Bases ITS 5.5.10 1

CTS 3.3.1.1 Note 15 applicable to the Source Range instrumentation. Note 15 on Table 4.3-1 modifies the Source Range instrumentation surveillance requirements by specifying "Surveillance Requirements need not be performed on alternate detectors until connected and required for OPERABILITY."

The corresponding ITS LCO 3.3.8 surveillance requirements are not modified by a similar note. The CTS requirements are revised to conform to the ITS. This changes the CTS by moving the statement that surveillance requirements need not be performed on alternate detectors until connected and required for OPERABILITY from the specification to the ITS Bases.

Changqe Types:

1 - Removing Details of System Design and System Description, Including Design Limits 2 - Removing Descriptions of System Operation 3 - Removing Procedural Details for Meeting Tech Spec Requirements and Related Reporting Requirements 4 - Removing Administrative Requirements Redundant to Regulations 5 - Removing Performance Requirements for Indication-only Instruments and Alarms BVPS Units 1 and 2 Page 15 of 53

Table M More Restrictive Changes Section 3.2 - Power Distribution Limits ITS #

DOC #

Description of Change ITS Requirement CTS Requirement CTS #

ITS 3.2.3 NONE CTS 3.2.1 ITS 3.2.1 NONE CTS 3.2.2 ITS 3.2.2 M1 CTS 3.2.3, Action c, requires that with FNAH exceeding its limit, subsequent POWER 3.2.2 Condition A 3.2.3 Action c CTS 3.2.3 OPERATION may proceed provided that FNAH is demonstrated through incore mapping to be within its limit at a nominal 50% of RATED THERMAL POWER prior to exceeding this THERMAL POWER, at a nominal 75% of RATED THERMAL POWER prior to exceeding this THERMAL POWER, and within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after attaining 95% or greater RATED THERMAL POWER. However, under the general rules of TS usage (CTS 3.0.2) these measurements do not have to be completed if at any time compliance with the LCO is reestablished. The corresponding ISTS 3.2.2 Condition A contains a Note that states, "Required Actions A.2 and A.3 must be completed whenever Condition A is entered." ISTS Required Actions A.2 and A.3 require performance of a FNOH measurement every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and prior to exceeding 50% RTP, 75% RTP, and within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after THERMAL POWER 2> 95% RTP. The CTS is revised to conform to the ISTS. This changes the CTS by the addition of the ISTS Note. The ISTS Note requires the Actions that measure FNH prior to each specified power level and every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to be completed even if FN AH is restored to within its limit and compliance with the LCO is re-established.

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

verification to be performed at equilibrium conditions.

ITS 3.2.4 M.2 CTS Action e (ITS A.5) requires that QPTR be restored to within the limit. CTS Actio f 3.2.4 Action e & f 3.2.4 Action AA5 CTS 3.2.4 (ITS A.6) requires a follow up verification of core status by measuring peaking factor after A.6 power has been increased. However, under the general rules of TS usage (CTS 3.0 2) the*

peaking factor measurements required by CTS Action f (ITS A.6) do not have to be completed if compliance with the LCO is reestablished in CTS Action e (ITS A.5).

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

Table M More Restrictive Changes Section 3.3A - 3.3.1, Reactor Trip System Instrumentation ITS #

DOC #

Description of Change ITS Requirement CTS Requirement CTS #

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

ITS 3.3.1 M.9 Unit 1 only (Unit 2 does not use Action 3 or 12 for the RTS Interlock Functions). CTS Action Actions 0 & P Action 3 CTS 3.3.1.1 3 is applicable to the Unit 1 RTS P-6 Interlock Function. CTS Action 12 is applicable to the other RTS interlocks (P-8, P-9, P-10). The CTS Action 3 and 12 require that action be taken "With less than the Minimum Number of Channels OPERABLE...." The CTS minimum channels operable requirement for the RTS Interlock Functions is one less than the total number of Interlock channels. As such the CTS does not require any Action when a single interlock channel is inoperable. The corresponding ITS Action Conditions 0 and P specify that Action be taken when "one or more channels are inoperable". The ITS Actions are based on the "Required" or total number of channels. As such, the ITS Actions for the RTS interlocks require that action be initiated as soon as a single interlock channel becomes inoperable. The CTS is revised to conform to the ISTS. This changes the CTS by specifying that action be initiated when a single interlock channel becomes inoperable.

ITS 3.3.1 M.10 Unit 1 only (Unit 2 already requires the P-10 interlock in Modes 1 and 2). The CTS P-I1 Applicability P-IO Applicability CTS 3.3.1.1 Applicability for the P-I1 RTS Interlock Function requires the Function to be operable in Mode 1. The ISTS Applicability for the P-10 RTS Function (and the BVPS Unit 2 Applicability) require the P-10 RTS Interlock Function to be operable in Modes 1 and 2. The Unit 1 CTS is revised to conform to the ISTS (and BVPS Unit 2). This changes the CTS by requiring the P-10 RTS Interlock Function on Unit 1 CTS Tables 3.3-1 and 4.3-1 to be operable in Mode 2 as well as Mode 1.

ITS 3.3.1 CTS 3.3.1.1 M.11 The CTS daily channel calibration surveillance assigned to the power range neutron flux high setpoint on Table 4.3-1 consists of adjusting the power range instrument channels to match the calorimetric heat balance calculation each day. The CTS surveillance is modified by Note 2 that states the surveillance is only required above 15% RTP.

The corresponding ISTS SR 3.3.1.2 specifies that the power range channel output be adjusted if calorimetric heat balance calculation results exceed power range channel output by more than + 2% RTP.

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

/-

SR 3.3.1.2 Note Table 4.3-1 Note 2 ITS 3.3.1 CTS 3.3.1.1 M.12 The CS monthly chan I calibration requirement associated flux hi~h setpoint on Tab e4.3-1 is modified by Note 3. CTS N surveilance consist of an in ore-excore comparison every 31 E that ttle Nuclear Instrument"on System (NIS) be recalibrated differ nce is"K3%. The corr sponding proposed BVPS ITS su an acddition N61e that sDecifi s the first performance of the surv (11" t J BVPS Units 1 and 2

Table M More Restrictive Changes Section 3.3A-3.3.1, Reactor Trip System Instrumentation ITS #

DOC #

Description of Change ITS Requirement CTS Requirement CTS #

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

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

ITS 3.3.1 M.17 Unit 1 only. The Unit I CTS surveillance requirements specified on Table 4.3-1 for the Table 3.3.1-1 Table 4.3-1 CTS 3.3.1.1 manual reactor trip function do not include the Applicable Modes for this RTS Function. In Applicability Applicability addition, the surveillance requirements specified on Table 4.3-1 for the power range neutron flux - low trip setpoint RTS Function do not include Mode 1 below the P-10 Interlock in the Applicable Modes for this RTS Function. The ISTS indudes all the Applicable Modes for each RTS Function in the single combined ISTS Table 3.3.1-1. The CTS is revised conform to the ISTS. This changes the CTS Table 4.3-1 by combining it wij4 Table 3.3-1 such that each RTS Function has all the associated requirement ing the Applicable Modes as modified by footnotes (a) and (b)) specified on a siye Table. The proposed (J

change results in the applicable Modes being correctly an nsistently specified each E

affected Function in the RTS TS.

r ITS 3.3.1 M.18 CTS Table 3.3-1 contains a line item that addresses the -equirements for the re or Trip Table 3.3.1-1 Table 3.3-1 CTS 3.3.1.1 Breakers (RTBs). CTS Table 3.3-1 does not contain an reference to th bypass breakers. The corresponding ISTS Table 3.3.1-1 contail s a footnote'W Eat modifies the requirements for the RTBs such that the RTB requireme its are applicable to an RTB bypass breaker when the bypass breaker is racked in and close, ýto bypass an RTB. The CTS is revised to conform to the ISTS. This changes the CTS bypviding specific requirements that are applicable to the bypass breakers when they are used-i ITS 3.3.1 M.19 A new ITS surveillance BVPS ITS SR 3.3.1.9 (ISTS 3.3.1.6) is added to the CTS SR 3.3.1.9 Table 4.3-1 CTS 3.3.1.1 surveillances for the power range neutron flux high trip setpoint on CTS Table 4.3-1. The new surveillance requires that the excore nuclear instrumentation channels be calibrated to agree with incore detector measurements once per refueling cycle. The new surveillance is modified by a note that establishes the criteria for the initial performance following a refueling outage. The note requires that the surveillance be performed within 7 days after thermal power exceeds 50% RTP. The CTS is revised to incorporate this new surveillance requirement.

BVPS Units 1 and 2 Page 14 of 52

Table M More Restrictive Changes Section 3.38 - Instrumentation (Other than RTS & ESFAS)

ITS #

DOC #

Description of Change ITS Requirement CTS Requirement CTS #

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

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

ITS 3.3.4 M.2 Not used.

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

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

ITS 3.3.4 CTS 3.3.3.5 M.4 CTS 3.3.3.5 only contains requirements for monitoring instrumentation. CTS surveillance requirement 4.3.3.5 states "Each remote shutdown monitoring instrumentation channel shall be demonstrated OPERABLE by performance of the Channel Check and Channel Calibration operations at the frequencies shown in Table 6." The re ments only specify a Channel Check and Channel Calibra iorr the specified monitori channels. The corresponding ISTS 3.3.4 includes re irements for control and t sfer switches as well as monitoring instrumentation. ITS R 3.3.4,..provides requirem nts to verify the operability of the control and transfer switchs. ITS SR 3.3.4.ireauires hat SR 3.3.4.2 4.3.3.5 BVPS Units 1 and 2 Page 17

Z_/_ý Table M More Restrictive Changes Section 3.3C - 3.3.2, Engineered Safety Feature Actuation System (ESFAS) Inst ITS #

DOC #

Description of Change CTS #

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

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

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

ITS 3.3.2 M.4 The CTS Action #16 requires that the inoperable channel be placed in the bypassed condition.

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

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

Table M More Restrictive Changes Section 3.3C - 3.3.2, Engineered Safety Feature Actuation System (ESFAS) Instrumentation ITS#

DOC#

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

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

ITS 3.3.2 M.7 Not used.

CTS 3.3.2.1 ITS 3.3.2 M.8 Unit 1 only. The Unit 1 general ESFAS surveillance requirement 4.3.2.1.1 specifies th Table SRs 4.2.1.1 CTS 3.3.2.1 instrumentation to be tested and the surveillances that must be performed in a similar manner as the corresponding Unit 2 general surveillance requirement. However, unli Unit 2, the Unit 1 requirement does not specify that interlock, automatic actuation logic, an 3.3.2-1 master and slave relay instrument functions are included in the ESFAS surveillance requirements. The corresponding ISTS ESFAS requirements do not include a generalal surveillance requirement similar to CTS 4.3.2.1.1. Instead, the ISTS surveillance requirements are specified in detail on Table 3.3.2-1. However, the ISTS ESFAS surveillance requirements, similar to the Unit 2 ESFAS TS, specify that testing be performed on interlock, automatic actuation logic, and master and slave relay instrument functions. The Unit 1 CTS surveillance 4.3.2.1.1 is revised to conform more closely to the corresponding Unit 2 and ISTS ESFAS surveillance requirements. This changes the Unit 1 CTS by adding a more specific surveillance requirement for the interlock, automatic actuation logic, and master and slave relay instrument functions.

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

ITS 3.3.2

. M.10I Unit 1 only. The CTS requirements for the automatic actuation logic and RWST level BVPS Units 1 and 2 Page 23 of 52

Table M More Restrictive Changes Section 3.4 - Reactor Coolant System ITS #

DOC #

Description of Change ITS Requirement CTS Requirement CTS #

[

1 and B applicable in Modes 1-4 are similar to the CTS Actions described above. However, the ISTS 3.4.3 Action Condition C, states that with the requirements of the LCO not met any time in other than MODE 1, 2, 3, or 4, initiate immediate action to restore the parameter(s) to within limits and determine the RCS is acceptable for continued operation prior to entering MODE 4. The CTS is revised to conform to the ISTS. This changes the CTS by adopting the new ISTS Action C that requires an immediate action to restore the parameters to within limits when the LCO is not met any time in other than MODE 1, 2, 3, or4.

ITS 3.4.12 M.1 CTS surveillance 4.4.9.3.3 verifies an R vent of the sp ifed size iavailable when SR 3.4.12.

4.4.9.3.3 CTS 3.4.9.3 required. The surveillance requires that open vjlye wit remote p sition indication be verified open every 31 days. The corresp riding I STS sur eillance St 3.4.12.

1_.

U1 CTS provides the 31-day surveillance interval fo valv s that ar locked or cured in the o position. In the ISTS surveillance, unlocke pen vent v ves must be ified every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The CTS is revised to conform to the S*. Thin/changes the CTS requiring valves with remote position indication that are notToc'* or secured in the op

• siint be verified open every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> instead of every 31 days.*

ITS 3.4.11 NONE CTS 3.4.11 ITS 3.4.19 M.1 Applies to Unit 1 only. CTS surveillance 4.10.5.2 specifies in part that a Channel SR 3.4.19.2 and 4.10.5.2 Ul CTS Functional Test be performed on the P-7 interlock function. The corresponding ITS SR 3.4.19.3 3.10.5 surveillance requirements (SR 3.4.19.2 and SR 3.4.19.3) specify a Channel Operational Test be performed on the P-10 and P-13 interlock functions and an Actuation Logic Test U2 CTS be performed on the P-7 interlock function. This changes the CTS by specifying more 3.10.4 specific (defined) surveillance requirements for each function.

BVPS Units 1 and 2 Page 31 of 52

Table M More Restrictive Changes Section 3.9 - Refueling Operations ITS # ]

DOC #

Description of Change ITS Requirement CTS Requirement CTS #

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

ITS 3.9.4 M.2 CTS 3.9.8.1 Actions b and c specify, in part, that "the residual heat removal loop may be LCO Notes Actions b & c CTS 3.9.8.1 removed from operation for up to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> per 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> period" and that "the residual heat removal loop may be removed from operation for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> per 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> period during the performance of Ultrasonic In-service Inspection inside the reactor vessel nozzles." The corresponding ISTS requirement (LCO Note) contains a provision that limits the applicab.ility of the CTS allowances. The ISTS limitation states "provided no operations are permitted that would cause introduction into the Reactor Coolant System, coolant with boron concentration less than required to meet the minimum required boron concentration of LCO 3.9.1." The CTS is revised to incorporate the ISTS limitation. This changes the CTS allowance by prohibiting operations that will cause introduction into the RCS, coolant with a boron concentration less than required to meet the boron co t,,.48,*,.

of 6G&-*

ITS 3.9.4 M.3 CTS 4.9.8.1 requires that an RHR loop be v in operation and circulating a specified SR 3.9.4.

4.9.8.1 CTS 3.9.8.1 flow only in certain circumstances ng dilution and reduced inventory operations).

The corresponding ITS surveiln. (SR 3.9.4.1 i G

reurd2H opb verified in operation every 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> hschne the CTS by requjlnng teý'

e_

required RHR loop in operation every ir, g,%pgnrd*ess of the RCS water level or dilution operations.

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

ITS 3.9.5 M.1 CTS 3.9.8.2 requires two independent RHR ps to be OPERABLE and at least one loop SR 3.9.5.,

NA CTS 3.9.8.2 to be in operation. The corresponding IS specifies a surveillance that requires verification every seven days of correct b eaker alignment and indicated power available to\\

the RHR pump not in operation. The CT* does ot have a corresponding surveillance.

4 The CTS is revised to adopt the ITS SR *.9.5.,Vb-or taný "h~artes the CTS by adding a new Surveillance Re urmet ITS 3.9.3 NONE ITS 3.3.6 BVPS Units 1 and 2 Page 48 of 52

Table M More Restrictive Changes Section 5.0 - Administrative Controls ITS #

DOC #

Description of Change ITS Requirement CTS Requirement CTS #

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

ITS 5.0 M.2 CTS 6.8.1 specifies that written procedures be established, implemented, and maintained 5.4. 1.e 6.8.1 CTS 6.0 covering the activities referenced in CTS 6.8.1.a through 6.8.1.h. ITS 5.4.1.e is added to the list of CTS activities to cover all programs and manuals specified in ITS 5.5. This changes the CTS by requiring written procedures be established, implemented, and maintained covering all programs and manuals specified in ITS 5.5.

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

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

ITS 5.0 M.5 (Unit 2 only) CTS 3/4.7.8.1, "Supplemental Leak Collection and Release System (SLCRS)"

5.5.7.e NA CTS 6.0 requires the heater controls to be operational. This requirement is reflected in ITS 3.7.12.

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

ITS 5.0 CTS 6.0 M.6 Unit 2 CTS 4.7.7.1.c provides the Frequency for performing in-place testing of CREVS and Unit 2 CTS 4.7.7.1.d provides the Frequency for performing carbon sample laboratory testing of the CREVS. The corresponding ITS 5.5.7 Freque ain an additional requirements for both in-place testing and laboratory te ng of the CI In addition to the Unit 2 CTS 4.7.7.1.c requirements for in-place testi g, ITS specifi the required in-place testing be performed "...following significant p inting, fire, chemic release in the vicinity of control room outside air intakes while the stem is ope ting." I1 ddition to the CTS 4.7.7.1.d requirements for carbon sample labora

analysis, S 5.5.7

• quires 5.5.7 4.7.7.1.c 4.7.7.1.d x

BVPS Units 1 and 2 Page 51 of 52