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Volume 12, Revision 0, Davis-Besse, Unit 1 - Improved Technical Specifications Conversion, ITS Section 3.7 Plant Systems.
	ML072200477
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Site:	Davis Besse
Issue date:	08/03/2007
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Attachment 1, Volume 12, Rev. 0, Page 1 of 461 ATTACHMENT 1 VOLUME 12 DAVIS-BESSE IMPROVED TECHNICAL SPECIFICATIONS CONVERSION ITS SECTION 3.7 PLANT SYSTEMS Revision 0 Attachment 1, Volume 12, Rev. 0, Page 1 of 461

Attachment 1, Volume 12, Rev. 0, Page 2 of 461 LIST OF ATTACHMENTS

1. ITS 3.7.1

2. ITS 3.7.2

3. ITS 3.7.3

4. ITS 3.7.4

5. ITS 3.7.5

6. ITS 3.7.6

7. ITS 3.7.7

8. ITS 3.7.8

9. ITS 3.7.9

10. ITS 3.7.10

11. ITS 3.7.11

12. ITS 3.7.12

13. ITS 3.7.13 14 ITS 3.7.14

15. ITS 3.7.15

16. ITS 3.7.16

17. ITS 3.7.17

18. ITS 3.7.18 19 Relocated/Deleted Current Technical Specifications

20. Improved Standard Technical Specifications (ISTS) not adopted in the Davis-Besse ITS Attachment 1, Volume 12, Rev. 0, Page 2 of 461

Attachment 1, Volume 12, Rev. 0, Page 3 of 461 ATTACHMENT 1 ITS 3.7.1, MAIN STEAM SAFETY VALVES (MSSVs)

Attachment 1, Volume 12, Rev. 0, Page 3 of 461

, Volume 12, Rev. 0, Page 4 of 461 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 12, Rev. 0, Page 4 of 461

Attachment 1, Volume 12, Rev. 0, Page 5 of 461 IITS 3.7.1 ITS 3/4.7 PLANT SYSTEMS 3/4.7.1 TURBINE CYCLE SAFETY VALVES LIMITING CONDITION FOR OPERATION LCO3.7.1 3.7.1.1 All main steam line code safety valves shall be OPERABLE.

APPLICABILITY: MODES 1, 2 and 3.

ACTON *.. Add proposed ACTION S Note }A02 With one or more main steam line code safety valves inoperable,

a. o J**ours. in MODES 1, 2 and 3 may proceed provided that, within eration -itho ACTION A I-. the inoperable valve iss-e=Vzred to OPERABL status, or_

2. a) the High Flux Trip Setpoint is reduced per Equation Add ProposdctRequired 3.7-1 below, and ACTItNhB b) [there are a minimum of two OPERABLE safety valves per M01 steam generator, at least one with a setpoint not grieater than 1050 psig *' anda Table3.7.1-1 c) noOPERABLE safety valve has a setpoint greater than 1100 psig 1% ;

otherwise ACTIONB b. be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Ic. The provisions of Speci~firt-n 3.0.4 are not applicablei *05 Y

Equation 3.7-1: SP = -Z x W where, SP = Reduced High Flux Trip Setpoint (Not to exceed W)

Equation W = High Flux Trip Setpoint for four pump operation as specified 3.7.1-1 in Table 2.2-1 Y = Total OPERABLE relieving capacity per steam generator based on a summation of individual OPERABLE safety valve relief capacities per steam generator in lbs/hr Z = Required relieving capacity per steam generator of 6,585,600 lbs/hr SURVEILLANCE REQUIREMENTS Add proposed SR 3.7.1.1 Note A06 SR3.7.1.1 4.7.1.1 /No additional Surveillance Requirements other than those required by Specification 4.0.5, are applicable for the main steam line code safety valves.

[ Add proposed Ta~b1e:37.7.1-1 }*,A04*

The lif setn ressure shall corp -t abent conditions of thvlv

ýat nominal operating temperature ýa~ ressure. _

DAVIS-BESSE, UNIT 1 3/4 7-1 Amendment No. ;7,7f;, 153 Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 5 of 461

Attachment 1, Volume 12, Rev. 0, Page 6 of 461 DISCUSSION OF CHANGES ITS 3.7.1, MAIN STEAM SAFETY VALVES (MSSVs)

ADMINISTRATIVE CHANGES A01 In the conversion of the Davis-Besse Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1430, Rev. 3.1, "Standard Technical Specifications-Babcock and Wilcox Plants" (ISTS).

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

A02 CTS 3.7.1.1 Action a states, in part, that when one or more MSSVs are inoperable, within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months restore the inoperable valve to OPERABLE status or reduce the High Flux Trip Setpoint in accordance with the requirements of Equation 3.7-1. ITS 3.7.1 ACTIONS Note states "Separate Condition entry is allowed for each MSSV." This changes the CTS by explicitly specifying separate condition entry for each inoperable MSSV.

The purpose of CTS 3.7.1.1 Action a is to allow separate condition entry for each inoperable MSSV. Each time it is discovered that an MSSV is inoperable, entry is required and the Completion Time is allowed to complete the compensatory actions. The ITS 3.7.1 ACTIONS Note allows a separate Completion Time for each MSSV that is inoperable. This change is acceptable because it only provides clarification of the Completion Time when one valve is inoperable and, subsequently, a second valve becomes inoperable. This change is designated as administrative because it does not result in a technical change to the Specifications.

A03 CTS 3.7.1.1 Action a states, in part, that with one or more MSSVs inoperable to either restore the inoperable valve to OPERABLE status or to take an alternate, compensatory measure. ITS 3.7.1 ACTION A does not include the restoration requirement, only the alternate compensatory measure is provided. This changes the CTS by eliminating the explicit statement to restore the inoperable MSSV to OPERABLE status.

This change is acceptable because it results in no technical change to the Technical Specifications. Restoration of compliance with the LCO is always an option in an Action, so eliminating the restoration Action from CTS has no effect.

It is the convention of the ITS to not state such "restore" options explicitly unless it is the only action or is required for clarity. In both the CTS and the ITS, if the inoperable MSSV is not restored, actions are taken that result in reducing reactor power to within the relief capability of the OPERABLE MSSVs within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

This change is designated as administrative because it results in no technical change to the CTS.

A04 CTS 3.7.1.1 does not identify the OPERABILITY lift settings for the MSSVs nor the total number of required MSSVs. CTS 3.7.1.1 only states that all MSSVs shall be OPERABLE. ITS Table 3.7.1-1 identifies the total number of MSSVs, the lift setting for each of the MSSVs and that the lift settings for OPERABILITY are + 3% of the nominal lift setting. Furthermore, ITS SR 3.7.1.1 states that after Davis-Besse Page 1 of 4 Attachment 1, Volume 12, Rev. 0, Page 6 of 461

Attachment 1, Volume 12, Rev. 0, Page 7 of 461 DISCUSSION OF CHANGES ITS 3.7.1, MAIN STEAM SAFETY VALVES (MSSVs) testing, the lift setting shall be + 1%. This changes the CTS by clearly stating the required number of MSSVS and their OPERABILITY lift settings.

The as-found lift settings and their tolerances as well as the as-left lift setting requirements in the ITS are consistent with the Davis-Besse Inservice Testing Program requirements. ITS Table 3.7.1-1 lists a total of nine MSSVs per steam generator, which is all the MSSVs for a steam generator. Furthermore, the CTS 3.7.1.1 Actions a.2.b) and a.2.c) lift setting tolerances are describing the nominal lift settings of the required valves while in this Action. The parenthetical tolerance bands in the two Actions are only providing clarifying information to help identify the specific MSSV requirements, and the clarifying information is simply the as-left lift setting tolerance. Therefore, this change is acceptable and designated as administrative since it does not result in any technical change to the CTS.

A05 CTS 3.7.1.1 Action c states that the provisions of Specification 3.0.4 are not applicable. ITS 3.7.1 does not include this specific exception. This changes the CTS by deleting the specific exception to Specification 3.0.4.

This change is acceptable because it results in no technical change to the Technical Specifications. CTS 3.0.4 has been revised as discussed in the Discussion of Changes for ITS Section 3.0. ITS LCO 3.0.4, in part, states that when an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made when the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time. ITS 3.7.1 ACTION A requires the plant to reduce power and the High Flux Trip setpoints, and allows operation to continue for an unlimited period of time (provided one of the OPERABLE MSSVs has a lift setting of 1050 psig). Therefore, because the ITS still allows the plant to change a MODE or other specified condition in the Applicability, this change is considered to be consistent with the current allowances. This change is designated as administrative because it does not result in a technical change to the CTS.

A06 CTS 4.7.1.1 requires the MSSV lift setpoints to be verified in accordance with Specification 4.0.5, the Inservice Testing Program requirements. The Davis-Besse Inservice Testing Program requires this test to be performed in MODES 1, 2, or 3. ITS SR 3.7.1.1 requires verification of each MSSV lift setpoint in accordance with the Inservice Testing Program. In addition, the Note to SR 3.7.1.1 states that the Surveillance is only required to be performed in MODES 1 and 2. This changes the CTS by explicitly stating that the unit can transition from MODE 4 to MODE 3 without requiring the lift setpoints of the MSSVs to be verified (i.e., the Surveillance to be performed).

This change is acceptable because it results in no technical changes to the Technical Specifications. The CTS does not currently require the lift setpoint test to be complete prior to entering the Applicability of CTS 3.7.1.1 (MODES 1, 2, and 3). Due to the format of the ITS and requirements of ITS SR 3.0.4, this Surveillance Requirement Note is necessary to ensure the unit can transition from MODE 4 to MODE 3 without having the Surveillance performed, provided it Davis-Besse Page 2 of 4 Attachment 1, Volume 12, Rev. 0, Page 7 of 461

Attachment 1, Volume 12, Rev. 0, Page 8 of 461 DISCUSSION OF CHANGES ITS 3.7.1, MAIN STEAM SAFETY VALVES (MSSVs) is performed prior to transitioning to MODE 2. This change is designated as administrative because it does not result in a technical change to the CTS.

MORE RESTRICTIVE CHANGES M01 CTS 3.7.1 Action a.2.a states that the High Flux Trip Setpoint must be reduced per Equation 3.7-1 when one or more MSSVs are found to be inoperable. CTS Equation 3.7-1 provides the maximum allowable High Flux Trip Setpoint corresponding to the maximum number of inoperable MSSVs on any operating steam generator. ITS 3.7.1 ACTION A requires both a reduction in THERMAL POWER and a reduction in the High Flux Trip Setpoint consistent with the requirements of ITS Equation 3.7.1-1. The reduction in THERMAL POWER is based on RTP, not the High Flux Setpoint. This changes the CTS by adding an additional explicit statement to reduce THERMAL POWER consistent with ITS Equation 3.7.1-1.

The purpose of CTS 3.7.1.1 Action a is to reduce the High Flux Trip Setpoint to within the limits of the safety analyses. This reduction in the setpoint could cause a reactor trip if the THERMAL POWER is not reduced prior to the setpoint change. The unit will reduce THERMAL POWER before reducing the setpoints in order to stay on line. The required power reduction will maintain the same margin to the High Flux Trip Setpoint. This change is designated more restrictive because a specific THERMAL POWER reduction is required and controlled in the ITS.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 3 - Removing ProceduralDetails for Meeting TS Requirements or Reporting Requirements) Certain portions of CTS 3.7.1.1 Action are modified by footnote *, that states that the MSSV lift setting pressure shall correspond to ambient conditions of the valve at nominal operating temperature and pressure.

This information is not provided in ITS 3.7.1. This changes the CTS by moving this information to the Bases.

The removal of these details for performing Surveillance Requirements from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. ITS 3.7.1 still retains a requirement for the valves to be OPERABLE. Under the definition of OPERABILITY, the MSSVs must be capable of lifting at the assumed conditions, which includes the ambient operating conditions of the MSSVs themselves. Also, this change is acceptable because these types of procedural details will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated Davis-Besse Page 3 of 4 Attachment 1, Volume 12, Rev. 0, Page 8 of 461

Attachment 1, Volume 12, Rev. 0, Page 9 of 461 DISCUSSION OF CHANGES ITS 3.7.1, MAIN STEAM SAFETY VALVES (MSSVs) as a less restrictive removal of detail change because procedural detailsfor meeting Technical Specification requirements are being moved from the Technical Specifications to the ITS Bases.

LESS RESTRICTIVE CHANGES L01 (Category3 - Relaxation of Completion Time) CTS 3.7.1.1 Action a specifies the compensatory actions when one or more MSSVs are inoperable in MODES 1, 2, and 3. The action allows operation to continue provided that within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , either the inoperable valve is restored to OPERABLE status or the High Flux Trip Setpoint is reduced in accordance with the requirements of Equation 3.7-1.

ITS 3.7.1 Required Action A.2 requires the reduction of the High Flux Trip setpoint in accordance with Equation 3.7.1-1 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . This changes the CTS by extending the time allowed to reduce the High Flux Trip setpoint. The change that deletes the restoration option is discussed in DOC A03.

The purpose of CTS 3.7.1.1 Action a is to limit the time the unit can operate with inoperable MSSVs without reducing the High Flux Trip setpoints. This change is acceptable because the Completion Time is consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs, the low probability of a DBA occurring during the allowed Completion Time. This change extends the time allowed to reduce the High Flux Trip setpoints when the MSSVs are inoperable.

The time extension is from 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . However, the time to reduce THERMAL POWER to the same limits is maintained in ITS 3.7.1 Required Action A.1, as described in DOC M01. This change is acceptable since the Completion Time of 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months is based on a reasonable time to correct the MSSV inoperability, the time required to perform the power reduction, operating experience in resetting all channels of a protective function, and on the low probability of the occurrence of a transient that could result in steam generator overpressure during this period. In addition, the actual reactor power level continues to be required to be reduced to within the same limits within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

Thus operation of the unit at RATED THERMAL POWER with inoperable MSSVs is still only allowed for 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , consistent with the current allowance. This change is designated as less restrictive because additional time is allowed to restore parameters to within the LCO limits than was allowed in the CTS.

Davis-Besse Page 4 of 4 Attachment 1, Volume 12, Rev. 0, Page 9 of 461

Attachment 1, Volume 12, Rev. 0, Page 10 of 461 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 12, Rev. 0, Page 10 of 461

Attachment 1, Volume 12, Rev. 0, Page 11 of 461 CTS MSSVs 3.7.1 3.7 PLANT SYSTEMS 3.7.1 Main Steam Safety Valves (MSSVs) 3.7.1.1 LCO 3.7.1 The .MSSVs shall be OPERABLE as specified in Table3.7.1-1 a d jFiguT*3.7.1-1. 0 APPLICABILITY: MODES 1, 2, and 3.

ACTIONS

-atO i- -----e NOTE----- ---

-M--S------

DOC A02 Separate Condition entry is allowed for each MSSV.

CONDITION REQUIRED ACTION COMPLETION TIME Action a A. One or more r MSSVs inoperable, A.1 Reduce power to less than the reduced power 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months 0

uirerent of Fi ure 3.7.1-1. 0 Equation AND AND [High Flux A.2 Reduce then 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months loveypower trip setpoint in accordance with 0

Action a.2.b, B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Action b associated Completion oditionA nOt met. AND OR B.2 Be in MODE 4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months One or more steam generators with less than w MSSVs OPERABLE.

0 0

OR One or more steam generators with no MSSVs with a lift setting of 1050 psig +/- 3% OPERABLE.

BWMG STS 3.7.1-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 11 of 461

Attachment 1, Volume 12, Rev. 0, Page 12 of 461 CTS MSSVs 3.7.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.7.1.1 SR 3.7.1.1 NOTE Only required to be performed in MODES I and 2.

Verify each r MSSV lift setpoint per Table 3.7.1-1 in accordance with the Inservice In accordance with the Inservice 0

Testing Program. Following testing, lift settings Testing Program shall be within +/- 1%.

BWVOG STS 3.7.1-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 12 of 461

Attachment 1, Volume 12, Rev. 0, Page 13 of 461 CTS MSSVs 3.7.1 DOC A04 Table 3:7.1-1 (page 1 of 1)

Main Steam Safety Valve Lift.Settings FO VALVES LIFT SETTING

[ NUMBER (psig +/- 3N) 00 Mj MSSVs/steam generator [1050O 0

j MSSVs/stearn generator 01001 0

BWAOG STS 37.1-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 13 of 461

Attachment 1, Volume 12, Rev. 0, Page 14 of 461 CTS MSSVs 3.7.1 Equation 3.7 WY = SP; RP = Y x 100%

luxý z z ,"Reactor Protection System (RPS)

Instrumentation."

V Nucle overpowe trip setpoint for four pump operation as specified in LCO 3.3.1 (j Y = Total OPERABLE MSSV relieving capacity per steam generator based on summation of individual OPERABLE MSSV relief capacities per steam generator lb/hour 0 Z = Required relieving capacity per steam generator of M5,585,600 Ib/hour.

SP = l veower trp setpoint (not to exceed W).

RP = Reduced power requirement (not to exceed RTP).

These equations tre graphically represen ed below.

Operation is restri ed to the area below and to the right of line ýCDE.

0 711 (page 1 of 1) Flux Reduced Power andl Nucled/--Overpower Trp Setpoint versus OPERABLE Main Steam Safety Valves 00 BWOG STS 3.7.1-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 14 of 461

Attachment 1, Volume 12, Rev. 0, Page 15 of 461 JUSTIFICATION FOR DEVIATIONS ITS 3.7.1, MAIN STEAM SAFETY VALVES (MSSVs)

1. All of the installed MSSVs for Davis-Besse must be OPERABLE. All MSSVs listed in Table 3.7.1-1 (nine total MSSVs per steam generator) are required OPERABLE, and Figure 3.7.1-1 is only used when one or more of the MSSVs are inoperable.

Therefore, ISTS LCO 3.7.1 has been changed to delete the reference to Figure 3.7.1-1. Since all installed MSSVs are required, the term "required" in ISTS 3.7.1 Condition A and ISTS SR 3.7.1.1 have been deleted. Furthermore, the equation presented in ISTS Figure 3.7.1-1 is sufficient determine the necessary power reduction and High Flux trip setpoint reduction. Therefore, the graphical representation of the equation has been deleted and the Figure has been renamed as an Equation.

2. Changes are made which reflect the plant specific nomenclature.

3. This change has been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, TSTF-GG-05-01, Section 4.1.6.i.5.ii.

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

5. Editorial correction.

6. The Davis-Besse overpressure protection analysis requires one of the OPERABLE MSSVs be set at 1050 psig +/- 3%. Therefore, this requirement has been included in Condition B, similar to the minimum number of OPERABLE MSSVs requirement also included in Condition B.

Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 15 of 461

Attachment 1, Volume 12, Rev. 0, Page 16 of 461 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 12, Rev. 0, Page 16 of 461

Attachment 1, Volume 12, Rev. 0, Page 17 of 461 MSSVs B 3.7.1 B 3.7 PLANT SYSTEMS B 3.7.1 Main Steam Safety Valves .(MSSVs)

BASES BACKGROUND The primary purpose of the MSSVs is to provide overpressure protection for the secondary system. The MSSVs also provide protection against overpressurizing the reactor coolant pressure boundary (RCPB) by providing a heat sink for removal of energy from the Reactor Coolant System (RCS) if the preferred heat sink, provided by the Condenser and Circulating Water System, is not available.

Nine MSSVs are located on each main steam header, outside

- containment, upstream of the main steam isolation valves, as described iiQ heSAR, Sectionr-(Ref. 1). The MSSV rated capacitypas es e 0 0 i4 1 i ull steam flow at_ T4 Iwth the valves ful opej. This meets the is 14a17556 lb/hrwhimha requirements of the ASME Code,Section III (Ref. 2). The MSSV design osthetoalsecondary 1% t-include sta ered setpoints, according to Table 3.7.1-1 ffiM (DO system design flow. accom ern in LCO s hat ony the needed number of valve wi "actue.Staggered s tpoints reduce he potential for valve attering 1(3 be zuse of insuffici ht steam pressy'e to fully open all valve s following a(D ftuybine reactor triF*

APPLICABLE The design basis of the MSSVs comes from Reference 2 and its purpose SAFETY is to limit secondary system pressure to 5 110% of design pressure when ANALYSES passing 100% of design steam flow. This design basis is sufficient to cope with any anticipated operational occurrence (AOO) or accident considered in the Design Basis Accident (DBA) and transient analysis.

The events that challenge the relieving capacity of the MSSVs, and thus

{ RCS pressure, are those characterized as decreased heat removal events, and are presented in the4FSAR, Section r1 5M (Ref. 3). Of these, the full power turbine trip coincident with a loss o6 condenser heat sink is 00 the limiting AOO. For this event, the Condenser Circulating Water System is lost and, therefore, the Turbine Bypass Valves are not available to relieve Main Steam System pressure. Similarly, MSSV relief Ll capacity is utilized in thelFSAR for mitigation of the following events:

0

a. Loss of main feedwater

ýM b $team line break,,,

c. Steam generator tube ruptur Pal

d. Excessive heat removal due to feedwater system malfunction,*

-The MSSVs satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

le, Small break loss of coolant accident.I BWOG STS B 3.7.1-1 Rev. 3.1, 12101/05 Attachment 1, Volume 12, Rev. 0, Page 17 of 461

Attachment 1, Volume 12, Rev. 0, Page 18 of 461 MSSVs B 3.7.1 BASES LCO The MSSVs setpoints are established to prevent overpressurization as discussed in the Applicable Safety Analysis section of these Bases. The LCO requires all MSSVs to be OPERABLE to ensure compliance with the ASME Code following DBAs initiated at full power. Operation with less than a full complement of MSSVs requires limitations on unit THERMAL POWER and adjustment of the Reactor Protection System (RPS) trip setpoints. This effectively limits the Main Steam System steam flow while the MSSV relieving capacity is reduced due to valve inoperability. To be OPERABLE, lift setpoints must remain within limits, according to Table 3.7.1-1 in e a panygn .

0 The OPERABILITY of the MSSVs is defined as the ability to open within the setpoint tolerances, relieve steam generator overpressure, and reseat when pressure has been reduced.

The OPERABILITY of the MSSVs is determined by periodic surveillance testing in accordance with the Inservice Testing Program.

The lift settings, according to Table 3.7.1-1 in tea 1ranyinq LCO correspond to ambient conditions of the valve at nominal operating 0

temperature and pressure.

This LCO provides assurance that the MSSVs will perform the design safety function to mitigate the consequences of accidents that could result in a challenge to the RCPB.

APPLICABILITY In MODE 1ove [18]% RTP, th number of MSSVs r steam generator required tbe OPERABLE mu be within the accept ble region, accordi to Figure 3.7.1-1 in/e accompanying LO. Below [18]% RTP in MO ES 1, 2, and 3, only o MSSVs are requir d OPERABLE per ste generator.

In MODES 4 and 5, there is no credible transient requiring the MSSVs.

tINSERT 1 The steam generators are not normally used for heat removal in MODES 5 and 6, and thus cannot be overpressurized; there is no requirement for the MSSVs to be OPERABLE in these MODES.

ACTIONS The ACTIONS Table is modified by a Note indicating that separate Condition entry is allowed for each MSSV.

BWOG STS B 3.7.1-2 Rev. 3.1, 12/01/05 Attachment 1, Volume 12, Rev. 0, Page 18 of 461

Attachment 1, Volume 12, Rev. 0, Page 19 of 461 B 3.7.1 O INSERT I To support 100% RTP operation, all nine MSSVs on a steam generator are required to be OPERABLE. However, MODE 1 operation is permitted with inoperable MSSVs, provided the maximum permissible power level is reduced to a value less than that determined by Equation 3.7.1-1. In addition, in MODES 1,2, and 3 at least two MSSVs per steam generator must be OPERABLE, one of which must have a lift setting of 1050 psig + 3%.

Insert Page B 3.7.1-2 Attachment 1, Volume 12, Rev. 0, Page 19 of 461

Attachment 1, Volume 12, Rev. 0, Page 20 of 461 MSSVs B 3.7.1 BASES ACTIONS (continued)

A.1 and A.2 An alternative to restoring the inoperable MSSV(s) to OPERABLE status is to reduce power so that the available MSSV relieving capacity meets ASME Code requirements for the power level. Operation may continue, provided the ALL WABLE THERMAL POWER and RPS nu ler High Flux oveowerl trip setpoint are reduced by the application of the following formulas:

RP = V Y/4x 100%

and Q

SP=MYIZMX W where: HihFu Instrumentation 7 W = oNuclea/,-ver ower trip setpoint for four pump operation as specified in LCO 3.3.1, "Reactor Protection System (RPS)

Y = Total OPERABLE MSSV relieving capacity per steam generator based on a summation of individual OPERABLE MSSV relief capacities per steam generator lb/hou 00 Z = Required relieving capacity per steam generator of F6,585,600Zllb/hour-1-UI 00 RP = Reduced power requirement (not to exceed RTP)iand SP = utrip setpoint (not to exceed W).

These equations are rapica .7.1-aaccompn ying LCn. FOperaioi right of mine)3CDLI The operator should limit the ma ximum steady state power level to some value slightly below this setpoint to avoid an inadvertentovoe trip.

0 The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time for Required Action A.1 is a reasonable time period to reduce power level anc1 is based on the low probability of an event occurring during this perio d that would require activation of the MSSVs. An additional 32 hours3.703704e-4 days 0.00889 hours 5.291005e-5 weeks 1.2176e-5 months is allowed in Required Action A.2 to The individual relief capacity of the two MSSVs with a normal setpoint of 1050 psig is 583,574 lb/hr and the individual relief capacity of the other MSSVs is 0

845,759 Ib/hr. J BWOG STS B 3.7.1-3 Rev. 3.1, 12/01/05 Attachment 1, Volume 12, Rev. 0, Page 20 of 461

Attachment 1, Volume 12, Rev. 0, Page 21 of 461 MSSVs B 3.7.1 BASES ACTIONS (continued) High Flux trip reduce the setpoints. The Completion Time of 36:hours for Required Action A.2 is based on a reasonable time to correct the MSSV 0

inoperability, the time required to perform the power reduction, operating experience in resetting all channels of a protective function, and on the low probability of the occurrence of a transient that could result in steam generator overpressure during this period.

B.1 and B.2 With one or re MSSVs inopera le, a verification b/ administrative means that atIeast [two] required MSSVs per steam generator are OPERABLE,/with each valve frony a different lift set ng range, is 0

performed.

INSERT 2 If the MSSV/ cannot be restored)6 OPERABLE status in thoassociated ICompletio°r Time, the unit must be placed in a MODE in which the LCO 0

does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

SURVEILLANCE SR 3.7.1.1 REQUIREMENTS This SR verifies the OPERABILITY of the MSSVs by the verification of each MSSV lift setpoint in accordance with the Inservice Testing

___-_ Program. The Aeva test e performed in accordance with [1ASME OM for (Ref. Code are to According to Reference 3,the following tests are required for MSSVs:

"-4J 0

a. Visual examination

b. Seat tightness determination

c. Setpoint pressure determination (lift setting)

d. Compliance with owner's seat tightness criterialand

e. Verification of the balancing device integrity[ on balanced 0 valves.

BWOG STS B 3.7.1-4 Rev. 3.1, 12/01/05 Attachment 1, Volume 12, Rev. 0, Page 21 of 461

Attachment 1, Volume 12, Rev. 0, Page 22 of 461 B 3.7.1 O INSERT 2 If any Required Action and associated Completion Time of Condition A is not met, ifone or more steam generators have less than two OPERABLE MSSVs, or if one or more steam generators have no OPERABLE MSSVs with a lift setpoint of 1050 psig + 3%

Insert Page B 3.7.1-4 Attachment 1, Volume 12, Rev. 0, Page 22 of 461

Attachment 1, Volume 12, Rev. 0, Page 23 of 461 MSSVs B 3.7.1 BASES SURVEILLANCE REQU.IREMENTS (continued)

,FMCodel from each valve The ASME e testing of all valves every 5 years, with a minimum of 20% of the valves tested~every 24 months. 20jG Reference #provides the activitie-/and frequencies necesg ary to satisfy1 the requir ments. Table 3.7.1-1 allows a +/-W/, setpoint tolerance for 00 OPERABILITY; however, the valves are reset to +/- 1% during the Surveillance to allow for drift.

This SR is modified by a Note that allows entry into and operation in MODE 3 prior to performing the SR. The MSSVs may be either bench tested or tested in situ at hot conditions using an assist device to simulate lift pressure. If the MSSVs are not tested at hot conditions, the lift setting pressure shall be corrected to ambient conditions of the valve at operating temperature and pressure.

REFERENCES ET7IFSAR, Section 00

2. ASME, Boiler and Pressure Vessel Code,Section III, jArticle NC-7000, s.9§s 2 Component 1971 Edition I

.0 3.74FSAR, Section r1 51.

00

4. ASME Code for Operation and Maintenance of Nuclear Power Plants. ------ 1995 Edition with 1996 Addenda 0 15- ANSI/AS MEOM-1-1987.1 0

BVVOG STS B 3.7.1-5 Rev. 3.1, 12/01/05 Attachment 1, Volume 12, Rev. 0, Page 23 of 461

Attachment 1, Volume 12, Rev. 0, Page 24 of 461 JUSTIFICATION FOR DEVIATIONS ITS 3.7.1 BASES, MAIN STEAM SAFETY VALVES (MSSVs)

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

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

3. Changes are made to be consistent with similar phrases in other Bases.

4. These punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, TSTF-GG-05-01, Section 5.1.3.

5. Changes made to reflect changes made to the Specification.

6. Typographical error corrected.

7. Changes made to reflect the wording of the Specification.

8. This statement has been deleted since the activities and frequencies are previously described.

Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 24 of 461

Attachment 1, Volume 12, Rev. 0, Page 25 of 461 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 12, Rev. 0, Page 25 of 461

Attachment 1, Volume 12, Rev. 0, Page 26 of 461 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.7.1, MAIN STEAM SAFETY VALVES (MSSVs)

There are no specific NSHC discussions for this Specification.

Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 26 of 461

Attachment 1, Volume 12, Rev. 0, Page 27 of 461 ATTACHMENT 2 ITS 3.7.2, MAIN STEAM ISOLATION VALVES (MSIVs)

Attachment 1, Volume 12, Rev. 0, Page 27 of 461

, Volume 12, Rev. 0, Page 28 of 461 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 12, Rev. 0, Page 28 of 461

Attachment 1, Volume 12, Rev. 0, Page 29 of 461 ITS 3.7.2 ITS PLANT SYSTEMS MAIN STEAM LINE ISOLATION VALVES LIMITING CONDITION FOR OPERATION LCO 3.7.2 3.7.1.5 EZch main steam line isolation valve shall be OPERAFU .

L01

[-except when all MSlVsare closed MODES 1, 2 and 3ý APPLICABILITY:

ACTION:

MODE 1 - With one main steam line isolation valve inoperable, POWER ACTION A OPERATION may continue provided the inoperable valve is either 8 restored to OPERABLE status [or c osed wit.hin hours. *-herwise, ACTION B-I-MODE2 MODES 2 and 3 -With one main steam line isolation valve inoperable, subsequent M01 operation in MODES Er2 or 3 may proceed provided:

ACTION C -

in 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months L02

a. Ther* inoperable isolation [~~Add valve is proposed

a o .cl Required Acto D.1 }* *" Add proposed "- M03)

ACTION D- Ot_'herwise,ý be in HOT SHUTDOWN witi the next ours. Required Action C3.2(ý Lb. The provis~ous Ee of Specification 3.I.4 not appElicable.

SURVEILLANCE REQUIREMENTS SR 3.7.2.1 4.7.1.5 Each main steam line isolation valve shall be demonstrated OPERABLE per the requirements of Specification uhen tested w.3.2.

pursuant to Specification 4.0.5. I A03 4 [Add proposed SR 3.7.2.2 DAVIS-BESSE, UNIT 1 3/4 7-9 *Amendment No. 119 Page 1 of 3 Attachment 1, Volume 12, Rev. 0, Page 29 of 461

Attachment 1, Volume 12, Rev. 0, Page 30 of 461 ITS 3.7.2 ITS CONTAINMENT SYSTEMS 3!4.6.3 CONTAINMENT ISOLATiON VALVES LIMITING CONDITION FOR OPERATION A04 LCO 3.7.2 3.6.3.1 All containment isolation valves shall be OPERABLE with isolation SR 3.7.2.1 MODES J a except when all MSIVs are closed L l APPLICABILITY:

ACTION: @

With one or more of the isolation valve(s) inoperable, either: 8 L02 ACTION A a. Restore the inoperable valve(s) to OPERABLE status within .-

hours ordA**B*Rq~rdAct~

. Isolate each affected penetration within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months by use of I k at least one deactivated automatic valve secured in the isolation SeeITS position. or 3.6.3 J ACTION C -c. Isolate each affected oenetration within fl*ours by use of at least one closed manual valvelor blind flang; or 02 ACTION D d. Be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and See ITS in [COLD within the follo*q wDOWN 301 hours0.00348 days 0.0836 hours 4.976852e-4 weeks 1.145305e-4 months . 3.6.3 7 RL03

.SURVEILLANCE REQUIREMEN[S 4.6.3.1.1 The is ation valves shall b /demonstrated OPERABLE ior to returnin, the valve to ser/ice after maintenance repair or replacement ork that could affect the valfe s performance is peraormed on the valve or s associated actuator, co trol or power circuit performance of a cycling test and verificati3 of isolation time.

Surveillance testing of valves MS100, MSIOI, ICS11A and iCSIlB is not require . SeeITS prior to entering MODE 4 but shall be performed prior to enterinq MODE 3. .

3.6.3

' The or visions of Snecif/cation 3.0.4 ar not aplicalJ I Selected valves may be opened on an intermi-tent basis under administrative controls.

A05

\

DAVIS-BESSE, UNIT 1 3/4 6-14 Amendment No. 147 Page 2 of 3 Attachment 1, Volume 12, Rev. 0, Page 30 of 461

Attachment 1, Volume 12, Rev. 0, Page 31 of 461 ITS 3.7.2 ITS CONTAINMENT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) 4.6.3.1.2 Each isolation valve shall be demonstrated OPERABLE at least once each REFUELING INTERVAL, by: See ITS each

a. Verifying that on a containment isolation test signal, automatic isolation valve actuates to its isolation position.

b. DELETED SR 3.7.2.1 4.6.3.1.3 The isolation time of each power operated or automatic valve shall be determined to be within its limit when tested pursuant to Specification 4.0.5.

47, 24 3, 22 DAVIS-BESSE, UNIT 1 3/4 6-15 Amendment No. 1 Page 3 of 3 Attachment 1, Volume 12, Rev. 0, Page 31 of 461

Attachment 1, Volume 12, Rev. 0, Page 32 of 461 DISCUSSION OF CHANGES ITS 3.7.2, MAIN STEAM ISOLATION VALVES (MSIVs)

ADMINISTRATIVE CHANGES A01 In the conversion of the Davis-Besse Current Technical Specifications (CTS) to.

the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1430, Rev. 3.1, "Standard Technical Specifications-Babcock and Wilcox Plants" (ISTS).

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

A02 CTS 3.7.1.5 Action MODE 2 and 3 states that the provisions of Specification 3.0.4 are not applicable. ITS 3.7.2 does not include this specific exception. This changes the CTS by deleting the specific exception to Specification 3.0.4.

This change is acceptable because it results in no technical change to the Technical Specifications. CTS 3.0.4 has been revised as discussed in the Discussion of Changes for ITS Section 3.0. ITS LCO 3.0.4, in part, states that when an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made when the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time. ITS 3.7.2 ACTION A requires the plant to close the inoperable MSIV, and allows operation to continue for an unlimited period of time. Therefore, because the ITS still allows the plant to change a MODE or other specified condition in the Applicability, this change is considered to be consistent with the current allowances. This change is designated as administrative because it does not result in a technical change to the CTS.

A03 CTS 4.7.1.5 requires each MSIV to be demonstrated OPERABLE "per the requirements of Specification 3.3.2.2." Specification 3.3.2.2 provides the requirements for the Steam and Feedwater Rupture Control System (SFRCS)

Instrumentation. CTS 4.3.2.2.3 requires a SFRCS RESPONSE TIME test, and footnote *, in part, describes how the MSIV closure portion of the SFRCS RESPONSE TIME is to be measured. Thus, the CTS 4.7.1.5 requirement is referencing the MSIV closure time requirement. ITS SR 3.7.2.1 requires verification that the isolation time of each MSIV is within limits. This changes the CTS by explicitly stating the MSIV testing requirement in the MSIV Specification.

This change is acceptable because it results in no technical change to the Technical Specifications. The change explicitly states the actual MSIV requirement in the MSIV Specification, in lieu of providing a cross-reference to the Instrumentation Specification that requires a RESPONSE TIME test. This change is designated as administrative because it does not result in any technical changes to the CTS.

A04 CTS 3.6.3.1 requires the containment isolation valves to be OPERABLE with isolation times less than or equal to required isolation times. However, CTS 3.7.1.5 also requires the MSIVs to be OPERABLE. ITS 3.7.2 requires the MSIVs to be OPERABLE and ITS SR 3.7.2.1 requires the MSIVs isolation time to Davis-Besse Page 1 of 7 Attachment 1, Volume 12, Rev. 0, Page 32 of 461

Attachment 1, Volume 12, Rev. 0, Page 33 of 461 DISCUSSION OF CHANGES ITS 3.7.2, MAIN STEAM ISOLATION VALVES (MSIVs) be within limits. This changes the CTS by placing the MSIVs into a single Specification.

The purpose of ITS 3.7.2 is to provide all the requirements for the MSIVs in a single Specification. As such, this change is acceptable since it does not result in any technical changes. Any technical changes as a result of placing the MSIVs in a common Specification are described and justified in other DOCs.

This change is designated as administrative because it does not result in a technical change to the CTS.

A05 CTS 3.6.3.1 Action c provides the actions for inoperable MSIVs and includes Note **,which states that the provisions of Specification 3.0.4 are not applicable.

ITS 3.7.2 does not include this Note. This changes the CTS by deleting the specific exception to Specification 3.0.4.

This change is acceptable because it results in no technical change to the Technical Specifications. CTS 3.0.4 has been revised as discussed in the Discussion of Changes for ITS Section 3.0. ITS LCO 3.0.4, in part, states that when an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made when the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time. ITS 3.7.2 ACTION C requires the plant to close the MSIV and allows operation to continue for an unlimited period of time. Therefore, because the ITS still allows the plant to change a MODE or other specified condition in the Applicability, this change is considered to be consistent with the current allowances. This change is designated as administrative because it does not result in a technical change to the CTS.

MORE RESTRICTIVE CHANGES M01 CTS 3.7.1.5 Action MODE 1 requires restoring the inoperable MSIV to OPERABLE status or closing the MSIV. CTS 3.7.1.5 Action MODES 2 and 3 states, in part, that subsequent operation in MODE 1, 2, or 3 is allowed if the MSIV is maintained closed. ITS 3.7.2 ACTION A does not include the specific option to close the inoperable MSIV when in MODE 1, only the requirement to restore the MSIV is provided. This changes the CTS by eliminating the allowance to close the inoperable MSIV and continue to operate when in MODE 1.

The purpose of CTS 3.7.1.5 Action MODE 1 is to provide compensatory measures to be taken if an MSIV is inoperable while in MODE 1. The Davis-Besse design includes only two RCS loops and two steam generators, each with a single MSIV. Therefore, it is not currently possible for Davis-Besse to close one of the two MSIVs and operate with only a single steam generator in service. Thus, Davis-Besse cannot use this CTS allowance in MODE 1; if an MSIV is inoperable, the restoration requirement must be met or a unit shutdown to MODE 2 is required. Therefore, since this allowance cannot be used, and the ITS retains a requirement to restore compliance with the LCO, this change is acceptable. This change is designated as more restrictive because an Action Davis-Besse Page 2 of 7 Attachment 1, Volume 12, Rev. 0, Page 33 of 461

Attachment 1, Volume 12, Rev. 0, Page 34 of 461 DISCUSSION OF CHANGES ITS 3.7.2, MAIN STEAM ISOLATION VALVES (MSIVs) that would allow continued operation without requiring restoration of the LCO is being deleted from the CTS.

M02 CTS 3.7.1.5 Action MODE 1 states, in part, that if one inoperable MSIV cannot be restored to OPERABLE status or closed within the allowed time, to be in HOT SHUTDOWN (MODE 4) within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . Under similar conditions, ITS 3.7.2 ACTION B requires the unit to be shutdown to MODE 2 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

This changes the CTS by reducing the time to be outside the applicability of the Action statement.

The purpose of CTS 3.7.1.5 Action MODE 1 is to provide compensatory measures to be taken ifan MSIV is inoperable while in MODE 1. Once entry is made into MODE 1, the Action is not applicable, and CTS 3.7.1.5 Action MODES 2 and 3 must be taken. Thus, the CTS 3.7.1.5 Action MODE 1 requirement to be in MODE 4 is not required; the unit only has to be in MODE 2 within the current 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months period. This change is acceptable because the proposed time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is a sufficient and reasonable time to reach MODE 2 from MODE 1 conditions. This change is designated as more restrictive because less time is being provided to exit the applicability of the Action in the ITS than is provided in the CTS.

M03 CTS 3.7.1.5 Action MODES 2 and 3, in part, requires that when one MSIV is inoperable in MODE 2 or 3, the MSIV is to be maintained closed. Once closed, no actions are required to periodically verify the MSIV remains closed. When one MSIV is inoperable in MODE 2 or 3, ITS 3.7.2 Required Action C.1 requires the inoperable MSIV to be closed within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . In addition, ITS 3.7.2 Required Action C.2 requires a verification that the MSIV is closed once per 7 days. This changes the CTS by adding a periodic verification that the inoperable MSIV remains closed. The change in the time to close the MSIV is discussed in DOC L02.

The purpose of the CTS 3.7.1.5 Action MODES 2 and 3 is to place the inoperable MSIV in the condition assumed in the safety analysis. This change is acceptable because it provides added assurance that the inoperable MSIV is maintained in this condition, i.e., closed. The proposed 7-day periodic verification is also consistent with a similar requirement in CTS 3.7.1.9 (ITS 3.7.4) when a turbine stop valve (TSV) is inoperable. As discussed in the Bases for ITS 3.7.4, the TSVs are assumed in the safety analysis for the same reasons as the MSIVs. This change is designated as more restrictive because a new requirement is being added to the ITS that is not required in the CTS.

M04 CTS 3.7.1.5 Action MODES 2 and 3 states that if one main steam line isolation valve (MSIV) can not be restored to OPERABLE status or closed within the allowed time, to be in HOT SHUTDOWN (MODE 4) within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Under similar conditions, ITS 3.7.2 ACTION D states to be in MODE 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 4 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This changes the CTS by specifying that MODE 3 must be achieved within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

The purpose of the CTS 3.7.1.5 Action MODES 2 and 3 shutdown action is to place the unit outside the Applicability of the LCO. This change is acceptable because a new intermediate MODE must be reached, consistent with the Davis-Besse -Page 3 of 7 Attachment 1, Volume 12, Rev. 0, Page 34 of 461

Attachment 1, Volume 12, Rev. 0, Page 35 of 461 DISCUSSION OF CHANGES ITS 3.7.2, MAIN STEAM ISOLATION VALVES (MSIVs) requirements of CTS 3.0.3 and ITS LCO 3.0.3. The proposed Completion Time is sufficient to allow an operator to reduce power to MODE 3 from MODE 2 in a controlled manner without challenging unit safety systems. The 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months time provided to reach MODE 3 is consistent with the time provided in similar actions in both the CTS and ITS. This change has been designated as more restrictive because it requires the unit to be placed in MODE 3 within a specific time.

M05 CTS 3.7.1.5 does not include a requirement to verify that each MSIV actuates to the isolation position on an actual or simulated actuation signal. ITS 3.7.2.2 is being added to perform this requirement every 24 months. This changes the CTS by adding a new Surveillance Requirement.

The purpose of ITS SR 3.7.2.2 is to verify that the MSIVs can close on an actual or simulated actuation signal. This change is acceptable because the test is conducted to ensure that the MSIVs will perform their safety function. The 24 month Frequency is consistent with CTS 4.7.1.5, which requires the isolation time of each MSIV to be measured. This change is considered more restrictive because a new Surveillance Requirement is added to the ITS that is not included in the CTS.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES L01 (Category 2 - Relaxation of Applicability) CTS 3.7.1.5 is applicable in MODES 1, 2, and 3. CTS 3.6.3.1 is applicable in MODES 1,2, 3, and 4. ITS LCO 3.7.2 is applicable in MODE 1, and in MODES 2 and 3 except when all MSIVs are closed. This changes the CTS by making the Specification not applicable in MODES 2 and 3 when all MSIVs are closed. The change to the MODE 4 requirement is discussed in DOC L03.

The purpose of the CTS 3.7.1.5 and CTS 3.6.3.1 Applicability is to ensure that the MSIVs are OPERABLE and capable of closing when required to support the safety analyses. This change is acceptable because the requirements continue to ensure that the structures, systems, components are maintained in the MODES and other specified conditions assumed in the safety analyses and licensing basis. When all the valves are in the closed position, they are in their assumed accident position. This change is designated as less restrictive because the ITS LCO requirements are applicable in fewer operating conditions than in the CTS.

Davis-Besse Page 4 of 7 Attachment 1, Volume 12, Rev. 0, Page 35 of 461

Attachment 1, Volume 12, Rev. 0, Page 36 of 461 DISCUSSION OF CHANGES ITS 3.7.2, MAIN STEAM ISOLATION VALVES (MSIVs)

L02 (Category 3 - Relaxation of Completion Time) CTS 3.7.1.5 Action MODE 1, in part, requires that when one MSIV is inoperable, the MSIV is restored to OPERABLE status or closed within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months or a shutdown is required.

CTS 3.7.1.5 Action MODES 2 and 3, in part, requires that when one MSIV is inoperable, the MSIV is to be maintained closed or a shutdown is required.

CTS 3.6.3.1 also provides two alternate actions for inoperable MSIVs.

CTS 3.6.3.1 Action a requires restoration of the inoperable MSIV within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and CTS 3.6.3.1 Action c requires the affected penetration flow path to be isolated by use of a closed manual valve (i.e., the MSIV) within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

ITS 3.7.2 ACTION A allows 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to restore an inoperable MSIV prior to requiring a unit shutdown when in MODE 1. ITS 3.7.2 ACTION C allows 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to close an inoperable MSIV prior to requiring a unit shutdown when in MODE 2 or 3. This changes the time allowed in the CTS to restore an inoperable MSIV from 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months when in MODE 1 and changes the time to close an inoperable MSIV from immediately (i.e., "maintained" closed implies an immediate requirement) or 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months when in MODE 2 or 3. The deletion of the closure allowance in CTS 3.7.1.5 Action MODE 1 is discussed in DOC M01.

The purpose of the CTS 3.7.1.5 and CTS 3.6.3.1 Actions is to provide time to restore or close the inoperable MSIVs. This change is acceptable because the Completion Time is consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the allowed Completion Time. The turbine stop valves (TSVs) are available and required by CTS 3.7.1.9 and ITS 3.7.4 to provide the required isolation for the postulated accidents. This change is also acceptable because of the low probability of an accident occurring during the allowed time which would require closure of the MSIVs. While the 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time is greater than that normally allowed for containment isolation valves, MSIVs are valves that isolate a penetration that is neither part of the reactor coolant pressure boundary nor is connected directly to the containment atmosphere. Furthermore, the proposed 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months time is consistent with the time allowed to close the TSVs in CTS 3.7.1.9. This change is designated as less restrictive because additional time is allowed to restore parameters to within the LCO limits than was allowed in the CTS.

L03 (Category2 - Relaxation of Applicability) CTS 3.6.3.1 requires the MSIVs to be OPERABLE in MODES 1, 2, 3, and 4. Furthermore, when one or more MSIVs are inoperable and a unit shutdown is required by CTS 3.6.3.1 Action d, the unit must be in HOT STANDBY (MODE 3) within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN (MODE 5) within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . ITS 3.7.2 requires the MSIVs to be OPERABLE in MODE 1, and MODES 2 and 3 except when all MSIVs are closed.

When a shutdown of the unit is required due to an inoperable MSIV, ITS 3.7.2 ACTION D requires the unit to be in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This changes the CTS by deleting the MODE 4 requirements for the MSIVs. Due to this change, the shutdown action has also been changed to only require entry into MODE 4, which exits the new Applicability. The change in the Applicability related to the exception concerning closed MSIVs is discussed in DOC L01.

Davis-Besse Page 5 of 7 Attachment 1, Volume 12, Rev. 0, Page 36 of 461

Attachment 1, Volume 12, Rev. 0, Page 37 of 461 DISCUSSION OF CHANGES ITS 3.7.2, MAIN STEAM ISOLATION VALVES (MSIVs)

The purpose of the MSIV requirements in CTS 3.6.3.1 is to ensure the MSIVs can be isolated if a main steam line break (MSLB) or feedwater line break (FWLB) occurs. While the MSIVs are containment isolation valves, they do not receive a containment isolation signal. They are closed on a Steam and Feedwater Rupture Control System (SFRCS) signal. The MSIVs help isolate the steam generators to establish control of fission products released to the secondary system from the primary system following an MSLB or FWLB.

Furthermore, the MSIVs are not subject to 10 CFR 50 Appendix J, Option B leak rate testing. Thus, leakage through these valves is not included in the Type C leakage limit. Therefore, this change is acceptable because the requirements continue to ensure that the structures, systems, components are maintained in the MODES and other specified conditions assumed in the safety analyses and licensing basis. Due to this change in Applicability, the shutdown action has also been modified to only require entering MODE 4, which will exit the new Applicability. The proposed time to reach MODE 4 is reasonable, based on operating experience, to reach MODE 4 from full power conditions in an orderly manner and without challenging plant systems. This change is designated as less restrictive because the ITS LCO requirements are applicable in fewer operating conditions than in the CTS.

L04 (Category 4 - Relaxation of Required Action) CTS 3.6.3.1 provides the actions for an inoperable MSIV. CTS 3.6.1.3 Action a requires the restoration of the inoperable MSIV and if not restored, CTS 3.6.1.3 Action d requires a unit shutdown to COLD SHUTDOWN (MODE 5). When in MODE 1, if an inoperable MSIV is not restored to OPERABLE status, ITS 3.7.2 ACTION B only requires a unit shutdown to MODE 2. Once in MODE 2, ITS 3.7.2 ACTION C allows an additional 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to close the inoperable MSIV and requires verification every 7 days the MSIV is closed. This changes the CTS by allowing the unit an additional 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to close the inoperable MSIV once the unit has been placed in MODE 2. The change also requires periodic verification the MSIV is closed.

The purpose of the CTS Actions is to provide compensatory measures when an MSIV is inoperable. This change is acceptable since the proposed Action to allow more time to isolate the MSIV after the unit has been placed in MODE 2 is already allowed in another CTS requirement. If the unit is in MODE 1, CTS 3.7.1.5 MODE 1 Actions require the MSIV to be restored, and if not restored to shut down the unit. Once in MODE 2, CTS 3.7.1.5 MODES 2 and 3 Actions allows additional time to close the MSIV prior to shutting down the unit to MODE 4. Therefore, the proposed change is consistent with an allowance already approved by the NRC. While the times to restore or close the MSIV are changed, these are justified in other DOCs. This change is designated as less restrictive because the Required Actions are less stringent in the ITS than in the CTS.

L05 (Category 5 - Deletion of Surveillance Requirement) CTS 4.6.3.1.1 describes tests that must be performed prior to returning a MFSV to service after maintenance, repair or replacement work is performed on the valve or its associated actuator, control or power circuit. The ITS does not include these testing requirements. This changes the CTS by deleting this post-maintenance Surveillance.

Davis-Besse Page 6 of 7 Attachment 1, Volume 12, Rev. 0, Page 37 of 461

Attachment 1, Volume 12, Rev. 0, Page 38 of 461 DISCUSSION OF CHANGES ITS 3.7.2, MAIN STEAM ISOLATION VALVES (MSIVs)

The purpose of CTS 4.6.3.1.1 is to verify OPERABILITY of containment isolation valves following their maintenance, repair or replacement. This change is acceptable because the deleted Surveillance Requirement is not necessary to verify that the equipment used to meet the LCO can perform its required functions. Thus, appropriate equipment continues to be tested in a manner and at a Frequency necessary to give confidence that the equipment can perform its assumed safety function. Any time the OPERABILITY of a system or component has been affected by repair, maintenance, modification, or replacement of a component, post-maintenance testing is required to demonstrate the OPERABILITY of the system or component. This is described in the Bases for ITS SR 3.0.1 and required under SR 3.0.1. The OPERABILITY requirements for the containment isolation valves are described in the Bases for ITS 3.6.3. In addition, the requirements of 10 CFR 50, Appendix B, Section XI (Test Control),

provide adequate controls for test programs to ensure that testing incorporates applicable acceptance criteria. Compliance with 10 CFR 50, Appendix B, is required under the unit operating license. As a result, post-maintenance testing will continue to be performed and an explicit requirement in the Technical Specifications is not necessary. This change is designated as less restrictive because Surveillances which are required in the CTS will not be required in the ITS.

Davis-Besse Page 7 of 7 Attachment 1, Volume 12, Rev. 0, Page 38 of 461

Attachment 1, Volume 12, Rev. 0, Page 39 of 461 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 12, Rev. 0, Page 39 of 461

Attachment 1, Volume 12, Rev. 0, Page 40 of 461 CTS MSIVs 3.7.2 3.7 PLANT SYSTEMS 3.7.2 Main Steam Isolation Valves (MSIVs) 3.7.1.5, LCO 3.7.2 Two MSIVs shall be OPERABLE.

3.6.3.1 APPLICABILITY: MODE 1, MODES 2 and 3 except when all MSIVs are closed land deoivated] 0 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME 3.7.1.5 Action MODE 1, 3.6.3.1 Action a A. One MSIV inoperable in MODE 1.

A.1 Restore MSIV to OPERABLE status.

@8ghours 0

3.7.1.5 Action B. Required Action and B.1 Be in MODE 2. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months MODE 1, associated Completion DOC L02 Time of Condition A not met.

3.7.1.5 Action MODES 2 and 3 C.- -------.-- NOTE ------------

Separate Condition entry C.1 Close MSIV. R8Ehours 0 3.6.3.1 Action c is allowed for each AND MSIV.

C.2 Verify MSIV is closed. Once per 7 days One or more MSIVs inoperable in MODE 2 or 3.

3.7.1.5 Action D. Required Action and D.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months MODES 2 and 3 associated Completion 3.6.3.1 Action d Time of Condition C not AND met.

D.2 Be in MODE 4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months BWOG STS 3.7.2-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 40 of 461

Attachment 1, Volume 12, Rev. 0, Page 41 of 461 CTS MSIVs 372 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.7.1.5, 4.6.3.1.3 SR 3.7.2.1 Only requ ed to be perfo

--- .E d in MOD 1 and 2. 0 Verify isolation time of each MSIV is _<(6] siconds In accordance ~TSTF~

with the Inservice

[within limits Testing Program DOC M05 S R 3.7.2.2 - ------------------------ N Only requred to be perfoImed in MOD 1 and 2.

1 Dý24 Verify each MSIV actuates to the isolation position on an actual or simulated actuation signal.

A months 0

BWOG STS 3.7.2-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 41 of 461

Attachment 1, Volume 12, Rev. 0, Page 42 of 461 JUSTIFICATION FOR DEVIATIONS ITS 3.7.2, MAIN STEAM ISOLATION VALVES (MSIVs) 1, The brackets have been removed and the proper plant specific information/value has been provided.

2, The Notes to ISTS SR 3.7.2.1 and SR 3.7.2.2 have been deleted. Davis-Besse normally performs the first Surveillance in MODE 4, in accordance with the Davis-Besse IST Program. The second Surveillance can also be performed in MODE 4 when the first is performed. Therefore, the allowance to perform the SRs in MODE 3 is not required.

Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 42 of 461

Attachment 1, Volume 12, Rev. 0, Page 43 of 461 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 12, Rev. 0, Page 43 of 461

Attachment 1, Volume 12, Rev. 0, Page 44 of 461 MSIVs B 3.7.2 B 3.7 PLANT SYSTEMS B 3.7.2 Main Steam Isolation Valves (MSIVs)

BASES BACKGROUND The MSIVs isolate steam flow from the secondary side of the steam main steam or1 fewateer J generators following n line break H terminates.fiow from the unaffected (intact) steam generator.

MSIV closure

-LB.

0 One MSIV is located in each main steam line outside of, but close to, containment. MSIVs are downstream from the main steam Theaner safety valves (MSSVs) rgencyfeedwater pump turbine's steam supply to prevent their being isolated from the steam generators by MSIV 0

closure. Closing the MSIVs isolates each steam generator from the other, and isolates the turbine, Turbine Bypass System, and other auxiliary steam supplies from the steam generators.

The signalMSIVs generatedclose by a Steam and Feedwater Rupture Control System on eitherilow Main Steam Line steary(generator pressur/e" or steaml 0

Pressure -Low or Feedwater/Steam generator toedwater dierentia ressure The MSIVs fail closed on Generator Differential loss of control or actuation power. The MSIVs may also be actuated

- High A dmanually. iiPressure A description of the MSIVs is found in the4SAR, Section r10.--a (Ref. 1).

APPLICABLE The design basis of th MSIVs is established by the containment analysis SAFETY for the large steam lin break (SLB) inside contain ent, as discussed in ANALYSES the FSAR, Section [6 ] (Ref. 2). It is also influen d by the accident analysis of the SLB ents presented in the FSAR Section [15.4]

(Ref. 3). The design precludes the blowdown of ore than one steam generator, assumin a single active component f lure (i.e., the failure of one MSIV to close n demand).

The limiting case f containment with r the containment analysis is e SLB inside loss of offsite power followin turbine trip and failure of 0

the MSIV on the ected steam generator to cl se. At 100% RTP, the steam generator ventory and temperature ar at their maximum, maximizing the ss and energy release to thi containment.

Due to reverse f ow, failure of the MSIV to clo e contributes to the total release of the a ditional mass and energy in he steam headers downstream of he other MSIV. Other failur considered are the failure of a main feed ter isolation valve to close, nd failure of an emergency diesel genera r (EDG) to start.

BWVOG STS B 3.7.2-1 Rev. 3.1, 12/01/05 Attachment 1, Volume 12, Rev. 0, Page 44 of 461

Attachment 1, Volume 12, Rev. 0, Page 45 of 461 B 3.7.2 0 INSERT 1 The design basis of the MSIVs is to isolate flow from the secondary side of the steam generators to limit blowdown following a main steam line break (MSLB) or a feedwater line break (FWLB), as discussed in the UFSAR, Sections 15.4.4 (Ref. 2) and 15.2.8 (Ref. 3), respectively. The MSIVs also isolate the steam generators to establish control of fission products released to the secondary system from the primary system following a steam generator tube rupture, as discussed in UFSAR, Section 15.4.2 (Ref. 4). The turbine stop valves (TSVs) also provide a means for main steam isolation in the event of an MSLB. Closure of the TSVs ensures that both steam generators do not blow down following an MSLB in conjunction with the MSIV associated with the unaffected steam generator failing to close. The TSV requirements are provided in ITS 3.7.4, "Turbine Stop Valves (TSVs)."

Insert Page B 3.7.2-1 Attachment 1, Volume 12, Rev. 0, Page 45 of 461

Attachment 1, Volume 12, Rev. 0, Page 46 of 461 MSIVs B 3.7.2 BASES APPLICABLE SAFETY ANALYSES (continued)

The accident analysis mpares several different SLB ev nts against different acceptance c iteria. The large SLB outside con inment upstream of the MSIV/ is limiting for offsite dose, althoug *a.break in this short section of main team header has a very low prob bility. The large SLB inside contain t at full power is the limiting case for a post trip return to power. The analysis includes scenarios with o site power available and with a I ss of offsite power following turbi e trip. With offsite power availab e, the reactor coolant pumps cont ue to circulate coolant through the team generators, maximizing the eactor Coolant System (RCS) cool own. With a loss of offsite power, the response of mitigating systems, uch as the High Pressure Injecti n (HPI) System pumps, is delayed. Significant single failures conside ed include failure of an MSIV to close, f ilure of an EDG, and failure of an HPI pump.

The MSIVs serve nly a safety function and remain pen during power operation. These alves operate under the following ituations:

a. An HELB, a SLB, or main feedwater line brea s (FWLBs). inside containment In order to maximize the mass a d energy release into 0

the contain ent, the analysis assumes the M IV in the affected steam gene tor remains open. For this scen rio, steam is discharged nto containment from both steam enerators until closure of the MSI in the intact steam generator occ rs. After MSIV closure, st am is discharged into containmen only from the affected steam gen rator and from the residual stea in the main steam header do stream of the closed MSIV in th intact loop.

b. An SLB o tside of containment and upstrea from the MSIVs is not a contain ent pressurization concern. The uncontrolled blowdown of more tha one steam generator must be pr vented to limit the potential for uncontrolled RCS cooldown a d positive reactivity addition Closure of the MSIVs isolates th break and limits the blowdo to a single steam generator.

c. A brea downstream of the MSIVs will be isolated by the closure of the M Vs. Events such as increased st am flow through the turbine or the team bypass valves will also ter nate on closing the MSIVs.

BWOG STS B 3.7.2-2 Rev. 3.1, 12/01/05 Attachment 1, Volume 12, Rev. 0, Page 46 of 461

Attachment 1, Volume 12, Rev. 0, Page 47 of 461 MSIVs B 3.7.2 BASES APPLICABLE SAFETY ANALYSES (continued)

d. Following a st am generator tube rupture, closur of the MSIVs isolatesthe r ptured steam generator from the*htact steam generator. n addition to minimizing radiologi6 I releases, this enables e operator to maintain the pressur of the steam generator with the uptured tube below the.MSIVs s toward olating flow through the rupture.

oints, a necessary step 0

e. The SIVs are also utilized during oth r events such as an FVVLB.

The MSIVs satisfy Criterion 3 of 10CFR 50.36(c)(2)(ii).

LCO This LCO requires that the MSIV in both steam lines be OPERABLE. The MSIVs are considered OPERABLE when the isolation times are within limits and they close on an isolation actuation signal.

This LCO provides assurance that the MSIVs will perform their design safety function to mitigate the consequences of accidents that could result in offsite exposures comparable to the 10 CFR 100 limits (Ref. 4).

APPLICABILITY The MSIVs must be OPERABLE in MODE 1 and in MODES 2 and 3 with any MSIV2 open, when there is significant mass and energy in the RCS and steam generator; therefore, the MSIVs must be OPERABLE or 0 closed. When the MSIVs are closed, they are already performing the safety function.

In MODE 4, the steam generator energy.is low. Therefore, the MSIVs are not required to be OPERABLE.

In MODES 5 and 6, the steam generators do not contain much energy because their temperature is below the boiling point of water; therefore, the MSIVs are not required for isolation of potential high energy secondary system pipe breaks in these MODES.

ACTIONS A.1 Fmi7lvWth one MSIV inoperable in MODE 1, action must be taken to restore the-to OPERABLE status within B8:hours. Some repairs can be made to the MSIV with the unit hot. TheI8EJ]hour Completion Time is reasonable, considering the probability of an accident that would require actuation of the MSIVs occurring during this time interval. The turbine Stop valves areavailable to provide the required isolation for[J o l accidents.

0 BWOG STS B 3.7.2-3 Rev. 3.1, 12/01/05 Attachment 1, Volume 12, Rev. 0, Page 47 of 461

Attachment 1, Volume 12, Rev. 0, Page 48 of 461 MSIVs B 3.7.2 BASES ACTIONS (continued)

The p]hour Completion Time is greater than that normally allowed for containment isolation valves because the MSIVs are valves that isolate a 0

closed systemenetrating contai Inent. These valveyiffer from other/

containment,6 valvessolation ine at the closed systnA provides an additional ans for contai nt isolation.

penetration that is neither part of the reactor coolant pressure I boundary nor is connected directly to the containment atmosphere.JQL)

B.1 If the MSIV cannot be restored to OPERABLE status within MSJhours, the unit must be placed in MODE 2 and the inmo the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The Completion Times closed within reasonable, based on 0

operating experience, to reach MODE 2.

C.1 and C.2 Condition C is modified by a Note indicating that separate Condition entry is allowed for each MSIV.

Since the MSIVs are required to be OPERABLE in MODES 2 and 3, the inoperable MSIVs may either be restored to OPERABLE status or closed.

When closed, the MSIVs are already in the position required by the assumptions in the safety analysis.

The phour Completion Time is consistent with that allowed in Condition A.

0 Inoperable MSIVs that Icannot be resptdred to OPERABLE status withinj 0 Ithe specified Comietion Time, but are closedomust be verified on a periodic basis to be closed. This is necessary to ensure that the assumptions in the safety analysis remain valid. The 7 day Completion Time is reasonable, based on engineering judgment, in view of MSIV status indications available in the control room, and other administrative controls, to ensure these valves are in the closed position.

BWOG STS B 3.7.2-4 Rev. 3.1, 12/01/05 Attachment 1, Volume 12, Rev. 0, Page 48 of 461

Attachment 1, Volume 12, Rev. 0, Page 49 of 461 MSIVs B 3.7.2 BASES ACTIONS (continued)

D.1 and D.2 If the MSIV cannot be restored to OPERABLE status or closed in the associated Completion Time, the.unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 :hours and in MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from MODE 2 conditions in an orderly manner and without challenging unit systems.

SURVEILLANCE S R 3.7.2.-1 '

REQUIREMENTS -- *'

. , ~This SR verifies that F-ý1closure time of each MSIV is- [6 s/cns. F" within the limit given in...-- - '

Reference 5 and is within that ntm sasmdi h cldnldgtte** SrRh*(SV2t fh 44) analyses. This rvane61 normally performed upon returning the unit IC This SR also verifies the valve to operation following a refueling outage, because the MSIVs should not closure time is Testing the Inservice in accordance with Program. vcoL at power since even a partstroke exercise increases the risk of be tested ia- ý -

ta valve closure with the unit generating power. As the MSIVs are not to be tested at power, they are exempt from the ASME Code (Ref. TSF requirements during operation in MODES 1 and 2. _

The Frequency for this SR is in accordance with the Inservice Testing Program.

This test is cono cted in MODE 3, wio the unit at operatihg temperature and pressure. This SR is modified b, a Note that allows/entry into and operation in MPDE 3 prior to perforring the SR. This a1lows delaying testing until MPDE 3 in order to estoblish conditions co sistent with those 0

under which the acceptance criteriln was generated.

SR 3.7.2.2 This SR verifies that each MSIV can close on an actual or simulated actuation signal. This Surveillance is normally performed upon returning the lant to operation following a refueling outage. The Frequency of MSIV testing is eve months. Thejjr-nonth Frequency for testing is based on the refueling cycle. Operating experience has shown that 0

these components usually pass the Surveillance when performed at the E-M]month Frequency. Therefore, this Frequency is acceptable from a 0 reliability standpoint.

BWVOG STS B 3.7.2-5 Rev. 3.1, 12/01/05 Attachment 1, Volume 12, Rev. 0, Page 49 of 461

Attachment 1, Volume 12, Rev. 0, Page 50 of 461 MSIVs B 3.7.2 BASES REFERENCES {]I7. FSAR, Section D1OI3 00 2"--1.FSAR, Section r.2;

3. ---FSAR, Section V15.4A

4. 10CFR 100.11.

{' ASME Code for Operation and Maintenance of NuclearPower 2)41(T

[@

Plants.

5. Technical Requirements Manual.

BWOG STS B 3.7.2-6 Rev. 3.1, 12/01/05 Attachment 1, Volume 12, Rev. 0, Page 50 of 461

Attachment 1, Volume 12, Rev. 0, Page 51 of 461 JUSTIFICATION FOR DEVIATIONS ITS 3.7.2 BASES, MAIN STEAM ISOLATION VALVES (MSIVs)

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

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

3. Changes are made to reflect changes made to the Specification.

4. Typographical error corrected.

5. Editorial change for clarity. The only components required by this Specification are MSIVs.

6. Change made to be consistent with the Specification.

Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 51 of 461

Attachment 1, Volume 12, Rev. 0, Page 52 of 461 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 12, Rev. 0, Page 52 of 461

Attachment 1, Volume 12, Rev. 0, Page 53 of 461 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.7.2, MAIN STEAM ISOLATION VALVES (MSIVs)

There are no specific NSHC discussions for this Specification.

Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 53 of 461

Attachment 1, Volume 12, Rev. 0, Page 54 of 461 ATTACHMENT 3 ITS 3.7.3, MAIN FEEDWATER STOP VALVES (MFSVs), MAIN FEEDWATER CONTROL VALVES (MFCVs), AND ASSOCIATED STARTUP FEEDWATER CONTROL VALVES (SFCVs)

Attachment 1, Volume 12, Rev. 0, Page 54 of 461

, Volume 12, Rev. 0, Page 55 of 461 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 12, Rev. 0, Page 55 of 461

Attachment 1, Volume 12, Rev. 0, Page 56 of 461 ITS 3.7.3 ITS PLANT SYSTEMS MAIN FEEDWATER CONTROL VALVES AND STARTUP FEEDWATER CONTROL VALVES LIMITING CONDITION FOR OPERATION LCO 3.7.3 3.7.1.8 The Main Feedwater Control Valves (MFCVs) and associated Startup Feedwater Control Valves (SFCVs) shall be OPERABLE. A except when all MFSVs, MFCVs, and associated L0 1 SFCVs are closed or isolated by a closed manual valve APPLICABILITY: MODES 1,2, and AIOCN SN T 4 Add proposed ACTIO NS Note ]" -- - -

ACTIONS With one or more MFCVs or SFCVs inoperable, isolate the affected flowpath within 72J hours and B,C, and D verify the flowpath is isolated once per 7 days, or be in at least HOT STANDBY within the next 6 ACTION E _/-hours and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

SURVEILLANCE REQUIREMENTS SR 3.7.3.2 4.7.1.8 Each MFCV and SFCV shall be demonstrated OPERABLE by performance of Surveillanceý-

FRequirement 4.3.2.2.3*

Add proposed SR 3.7.3-3 M02 DAVIS-BESSE, UNIT I 3/4 7-12d Amendment No. 246 Page 1 of 3 Attachment 1, Volume 12, Rev. 0, Page 56 of 461

Attachment 1, Volume 12, Rev. 0, Page 57 of 461 ITS 0 ITS 3.7.3 CONTAINMENT SYSTEMS 3/4.6.3 CONTAINMENT ISOLATION VALVES LIMITING CONDITION FOR OPERATION A04 I-LCO 3.7.3, 3.6.3.1 All containment isolation valves shall be OPERABLE with isolation SR 3.7.3.1 except when all MFSVs. MFCVs, and associated SFCVs "L01 APPLICABILITY: NODES 1, 2, 3'-are closed or isolated by a closed manual valve ACT I ON: _JAdd proposed ACTIONS No) A02*

ACTIONS A and D With one or more of the isolation valve(s) inoperable, either:

a. Resto/e the inoperable valve(s to OPERABLE st4,"s within 4ý A0 hous,sor /

."b. Isolate each affected penetration within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months by use of at least one deactivated automatic valve secured in the isolation position, or See ITS 3.6.3 ]

L03 ACTIONS A and D -c. Isolate each affected penetration within L4 hours by use of at least one closed manual valvelor blind flange]; or i Seel TS 3.6.3 ACTION E d. Be in at'least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in ICOLDnUTOOWN w~ithin the fo114ing 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

MODE 4 12 L02 SURVEILLANCE REQUIREMENTS 4.6.3.1.1 The is ation valves shall be emonstrated OPERABLE/prior to returnin, the valve to serv ce after maintenance, epair or replacement ork that could affect the valve's performance is perfored on the valve or i s associated actuator, contr I or power circuit by p rformance of a cycli g test and verification of isolation time.

ISee ITS

Surveillance testing of valves MSIOO, MSlOl, ICS11A and ICS1IB is not require L 3.6.3J prior to entering MODE 4 but shall be performed prior to entering MODE 3.

I m I SThe prov}e.ions of Specifigafion 3.0.4 areR6t aoplicable.

Imay be openeU an an intermiitent basis under administratlo-r=cntrols.

m ,

Se ecte v ISee ITS 3.6.3 J DAVIS-BESSE, UNIT 1 3/4 6-14 Amendment No. 147 Page 2 of 3 Attachment 1, Volume 12, Rev. 0, Page 57 of 461

Attachment 1, Volume 12, Rev. 0, Page 58 of 461 ITS 0 ITS 3.7.3 CONTAINMENT SYSTEMS SURVEILLANCE REQUIREMENTS (Continuedl 4.6.3.1.2 Each isolation valve shall be demonstrated OPERABLE at least once SeeITS 3.6.3 each REFUELING INTERVAL, by:

a. Verifying that on a containment isolation test signal, each automatic isolation valve actuates to its isolation position.

b. DELETED Se3.S 4.6.3.1.3 The isolation time of each power operated [or automaticvalve SR 3.7.3.1 shall be determined to be within its limit when tested pursuant to Specification 4.0.5. M2 Add popose SR 37.3.

3/4 6-15 47,24-3., 221 Amendment No. .-.

DAVIS-BESSE, UNIT 1 Page 3 of 3 Attachment 1, Volume 12, Rev. 0, Page 58 of 461

Attachment 1, Volume 12, Rev. 0, Page 59 of 461 DISCUSSION OF CHANGES ITS 3.7.3, MAIN FEEDWATER STOP VALVES (MFSVs), MAIN FEEDWATER CONTROL VALVES (MFCVs), AND ASSOCIATED STARTUP FEEDWATER CONTROL VALVES (SFCVs)

ADMINISTRATIVE CHANGES A01 In the conversion of the Davis-Besse Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1430, Rev. 3.1, "Standard Technical Specifications-Babcock and Wilcox Plants" (ISTS).

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

A02 CTS 3.7.1.8 Action states, in part, that when one or more MFCVs or SFCVs are inoperable, to isolate the affected flowpath. CTS 3.6.3.1 Action states, in part, that when one or more isolation valves are inoperable, to isolate the affected penetration. ITS 3.7.3 ACTIONS Note states "Separate Condition entry is allowed for each MFSV, MFCV, and SFCV." This changes the CTS by explicitly specifying separate condition entry for each inoperable MFSV, MFCV, and SFCV.

This change is acceptable because it clearly states the current requirement. The CTS considers each MFSV, MFCV, and SFCV to be separate and independent from the others. This change is designated as administrative because it does not result in a technical change to the Specifications.

A03 CTS 4.7.1.8 requires each MFCV and SFCV be demonstrated OPERABLE "by performance of Surveillance Requirement 4.3.2.2.3." Specification 3.3.2.2 provides the requirements for the Steam and Feedwater Rupture Control System (SFRCS) Instrumentation. CTS 4.3.2.2.3 requires a SFRCS RESPONSE TIME test once per REFUELING INTERVAL (i.e., every 24 months). Thus, the CTS 4.7.1.8 requirement is referencing the MFCV and SFCV closure time requirement. ITS SR 3.7.3.2 requires verification that the isolation time of each MFCV and SFCV is within limits every 24 months. This changes the CTS by explicitly stating the MFCV and SFCV testing requirement in the MFCV and SFCV Specification.

This change is acceptable because it results in no technical change to the Technical Specifications. The change explicitly states the actual MFCV and SFCV requirements in the MFCV and SFCV Specification, in lieu of providing a cross-reference to the Instrumentation Specification that requires a RESPONSE TIME test. This change is designated as administrative because it does not result in any technical change to the CTS.

A04 CTS 3.6.3.1 requires the containment isolation valves to be OPERABLE with isolation times less than or equal to required isolation times. ITS 3.7.3, in part, requires the MFSVs to be OPERABLE, and ITS SR 3.7.3.1 requires the MFSVs isolations time to be within limits. This changes the CTS by placing the MFSVs into a Specification with the other main feedwater isolation valves (MFIVs); i.e.,

the MFCVs and SFCVs.

Davis-Besse Page 1 of 6 Attachment 1, Volume 12, Rev. 0, Page 59 of 461

Attachment 1, Volume 12, Rev. 0, Page 60 of 461 DISCUSSION OF CHANGES ITS 3.7.3, MAIN FEEDWATER STOP VALVES (MFSVs), MAIN FEEDWATER CONTROL VALVES (MFCVs), AND ASSOCIATED STARTUP FEEDWATER CONTROL VALVES (SFCVs)

The purpose of ITS 3.7.3 is to provide all the requirements for the MFIVs (MFSVs, MFCVs, and SFCVs) in a single Specification. As such, this change is acceptable since it does not result in any technical changes. Any technical changes as a result of placing the MFSVs in a common Specification with the other MFIVs are described and justified in other DOCs. This change is designated as administrative because it does not result in a technical change to the CTS.

A05 When one or more of the MFSVs are inoperable, CTS 3.6.3.1 Action a requires restoring the inoperable valve(s) to OPERABLE status within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months or taking one of the other specified compensatory actions. ITS 3.7.3 does not state the requirement to restore an inoperable isolation valve to OPERABLE status, but includes other compensatory Required Actions to take within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , as applicable. This changes the CTS by not explicitly stating the requirement to restore an inoperable valve to OPERABLE status. The change in the time allowed to meet the compensatory Required Actions (72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months and 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ) is discussed in DOC L03).

This change is acceptable because the technical requirements have not changed. Restoration of compliance with the LCO is always an available Required Action and it is the convention in the ITS to not state such "restore" options explicitly unless it is the only action or is required for clarity. This change is designated as administrative because it does not result in any technical changes to the CTS.

A06 CTS 3.6.3.1 Action c provides the actions for inoperable MFSVs and includes Note **, which states that the provisions of Specification 3.0.4 are not applicable.

ITS 3.7.3 does not include this Note. This changes the CTS by deleting the specific exception to Specification 3.0.4.

This change is acceptable because it results in no technical change to the Technical Specifications. CTS 3.0.4 has been revised as discussed in the Discussion of Changes for ITS Section 3.0. ITS LCO 3.0.4, in part, states that when an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made when the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time. ITS 3.7.3 ACTIONS A and D require the plant to close the MFSV or isolate the MFSV or affected flow path and allow operation to continue for an unlimited period of time. Therefore, because the ITS still allows the plant to change a MODE or other specified condition in the Applicability, this change is considered to be consistent with the current allowances. This change is designated as administrative because it does not result in a technical change to the CTS.

Davis-Besse Page 2 of 6 Attachment 1, Volume 12, Rev. 0, Page 60 of 461

Attachment 1, Volume 12, Rev. 0, Page 61 of 461 DISCUSSION OF CHANGES ITS 3.7.3, MAIN FEEDWATER STOP VALVES (MFSVs), MAIN FEEDWATER CONTROL VALVES (MFCVs), AND ASSOCIATED STARTUP FEEDWATER CONTROL VALVES (SFCVs)

MORE RESTRICTIVE CHANGES M01 The CTS 3.7.1.8 Action states, in part, that with one or more MFCVs or SFCVs inoperable, to isolate the affected flowpath within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . ITS 3.7.3 ACTION D will require isolation of the affected flowpath within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months if a MFSV is inoperable in the same flowpath as the inoperable MFCV or SFCV. This changes the CTS by reducing the time to isolate the affected penetration if a MFSV is inoperable concurrent with an inoperable MFCV or SFCV in the same flowpath.

The purpose of ITS 3.7.3 ACTION D is to limit the time valves in the same flowpath are concurrently inoperable. This change is acceptable since when both the MFSV and the MFCV or SFCV are inoperable in the same flowpath, no MFIVs are OPERABLE to automatically isolate the affected flowpath and perform the required safety function. Therefore, the time allowed to isolate the flowpath is restricted to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months in lieu of the current 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This change is designated as more restrictive since less time is provided to isolate the affected flowpath in the ITS than is provided in the CTS.

M02 CTS 3.7.1.8 does not include a requirement to verify that each MFCV and SFCV actuate to the isolation position on an actual or simulated actuation signal.

CTS 3.6.3.1 does not include a requirement to verify that each MFSV actuate to the isolation position on an actual or simulated actuation signal. (While CTS 4.6.3.1.2 requires an actuation test, the test signal specified, a containment isolation test signal, does not actuate the MFSVs; thus the MFSVs are not covered by an actuation test). ITS SR 3.7.3.3 is being added to perform this requirement every 24 months. This changes the CTS by adding additional Surveillance Requirements.

The purpose of ITS SR 3.7.3.3 is to verify that the MFSVs, MFCVs, and SFCVs can close on an actual or simulated actuation signal. This change is acceptable because the test is conducted to ensure that the MFSVs, MFCVs, and SFCVs will perform their safety function. The 24 month Frequency is consistent with CTS 4.7.1.8, which requires the isolation time of each MFCV and SFCV to be measured. The Frequency is also consistent with CTS 4.3.2.2.3, the SFRCS RESPONSE TIME Surveillance, which requires the isolation time of each MFSV, MFCV, and SFCV to be measured. This change is designated as more restrictive since a Surveillance Requirement is being added to the ITS that is not required by the CTS.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None Davis-Besse Page 3 of 6 Attachment 1, Volume 12, Rev. 0, Page 61 of 461

Attachment 1, Volume 12, Rev. 0, Page 62 of 461 DISCUSSION OF CHANGES ITS 3.7.3, MAIN FEEDWATER STOP VALVES (MFSVs), MAIN FEEDWATER CONTROL VALVES (MFCVs), AND ASSOCIATED STARTUP FEEDWATER CONTROL VALVES (SFCVs)

LESS RESTRICTIVE CHANGES L01 (Category 2 - Relaxation of Applicability) CTS 3.7.1.8 is applicable in MODES 1, 2, and 3. CTS 3.6.3.1 is applicable in MODES 1, 2, 3, and 4. ITS LCO 3.7.3 is applicable in MODES 1, 2, and 3 except when all MFSVs, MFCVs, and SFCVs are closed or isolated by a closed manual valve. This changes the CTS by making the Specifications not applicable in MODES 1, 2, and 3 when all MFSVs, MFCVs, and SFCVs are closed or isolated by a closed manual valve. The change in the MODE 4 Applicability for CTS 3.6.3.1 is discussed in DOC L02.

The purpose of the ITS 3.7.3 Applicability is to ensure that the MFSVs, MFCVs, and SFCVs are OPERABLE and capable of closing to support the safety analyses. This change is acceptable because the requirements continue to ensure that the structures, systems, components are maintained in the MODES and other specified conditions assumed in the safety analyses and licensing basis. When all the valves are in the closed position or are isolated by a closed manual valve, they (or their flowpath) are in their assumed accident position.

This change is designated as less restrictive because the ITS LCO requirements are applicable in fewer operating conditions than in the CTS.

L02 (Category 2 - Relaxation of Applicability) CTS 3.6.3.1 requires the MFSVs to be OPERABLE in MODES 1, 2, 3, and 4. Furthermore, when one or more MFSVs are inoperable and a unit shutdown is required by CTS 3.6.3.1 Action d, the unit must be in HOT STANDBY (MODE 3) within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN (MODE 5) within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . ITS 3.7.3 requires the MFSVs to be OPERABLE in MODES 1, 2, and 3 except when all MFSVs, MFCVs, and SFCVs are closed or isolated by a closed manual valve. When a shutdown of the unit is required due to an inoperable MFSV, ITS 3.7.3 ACTION E requires the unit to be in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This changes the CTS by deleting the MODE 4 requirements for the MFSVs. Due to this change, the shutdown action has also been changed to only require entry into MODE 4, which exits the new Applicability. The change in the Applicability related to the exception concerning closed or isolated MFSVs, MFCVs, and SFCVs is discussed in DOC L01.

The purpose of the MFSV requirements in CTS 3.6.3.1 is to ensure the MFSVs can be isolated if a main steam line break (MSLB) or feedwater line break (FWLB) occurs. While the MFSVs are containment isolation valves, they do not receive a containment isolation signal. They are closed on a Steam and Feedwater Rupture Control System (SFRCS) signal. The MFSVs help isolate the steam generators to establish control of fission products released to the secondary system from the primary system following an MSLB or FWLB.

Furthermore, the MFSVs are not subject to 10 CFR 50 Appendix J, Option B leak rate testing. Thus, leakage through these valves is not included in the type C leakage limit. Therefore, this change is acceptable because the requirements continue to ensure that the structures, systems, components are maintained in the MODES and other specified conditions assumed in the safety analyses and licensing basis. Due to this change in Applicability, the shutdown action has also been modified to only require entering MODE 4, which will exit the new Davis-Besse Page 4 of 6 Attachment 1, Volume 12, Rev. 0, Page 62 of 461

Attachment 1, Volume 12, Rev. 0, Page 63 of 461 DISCUSSION OF CHANGES ITS 3.7.3, MAIN FEEDWATER STOP VALVES (MFSVs), MAIN FEEDWATER CONTROL VALVES (MFCVs), AND ASSOCIATED STARTUP FEEDWATER CONTROL VALVES (SFCVs)

Applicability. The proposed time to reach MODE 4 is reasonable, based on operating experience, to reach MODE 4 from full power conditions in an orderly manner and without challenging plant systems. This change is designated as less restrictive because the ITS LCO requirements are applicable in fewer operating conditions than in the CTS.

L03 (Category 3 - Relaxation of Completion Time) CTS 3.6.3.1 Action c allows 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to isolate the affected penetration when one or more of the MFSVs are inoperable. ITS 3.7.3 ACTION A will allow 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to close or isolate the MFSV when a MFSV is inoperable, and once isolated, will require verification that the flowpath remains isolated every 7 days. However, if a MFSV and a MFCV or a SFCV in the same flowpath are concurrently inoperable, ITS 3.7.3 ACTION D will only allow 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to isolate the affected flowpath. This changes the CTS by extending the Completion Time from 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months when a MFSV is inoperable and from 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months when both a MFSV and either a MFCV or SFCV in the same flowpath are concurrently inoperable.

The purpose of CTS 3.6.3.1 Action c is to provide a degree of assurance that the affected flowpath with an inoperable MFSV maintains the containment penetration isolation boundary. This change is acceptable because the Completion Time is consistent with safe operation under the specified Condition, the capacity and capability of remaining features, a reasonable time for repairs or replacement of required features, and the low probability of a DBA occurring during the allowed Completion Time. While the MFSVs are containment isolation valves, they do not receive a containment isolation signal. They are closed on a Steam and Feedwater Rupture Control System (SFRCS) signal. The MFSVs help isolate the steam generators following a MSLB or MFWB. Furthermore, the MFSVs are not subject to 10 CFR 50 Appendix J, Option B leak rate testing.

Thus, leakage through these valves is not included in the type C leakage limit.

The MFSVs do not communicate with the containment atmosphere or reactor coolant pressure boundary, thus 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is a reasonable time period considering the relative stability of a system to act as a penetration isolation boundary and the redundancy provided by the remaining MFIVs in the associated flowpath (i.e., the MFCV and SFCV). The 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months is a reasonable time period considering the relative stability of a system to act as a penetration isolation boundary and the low probability of a MSLB or FWLB. In addition, the periodic 7 day verification will ensure that the closed or isolated MFSV remains in the correct position. This change is designated as less restrictive because additional time is allowed to isolate the MFSVs than was allowed in the CTS.

L04 (Category 5 - Deletion of Surveillance Requirement) CTS 4.6.3.1.1 describes tests that must be performed prior to returning a MFSV to service after maintenance, repair or replacement work is performed on the valve or its associated actuator, control or power circuit. The ITS does not include these testing requirements. This changes the CTS by deleting this post-maintenance Surveillance.

Davis-Besse Page 5 of 6 Attachment 1, Volume 12, Rev. 0, Page 63 of 461

Attachment 1, Volume 12, Rev. 0, Page 64 of 461 DISCUSSION OF CHANGES ITS 3.7.3, MAIN FEEDWATER STOP VALVES (MFSVs), MAIN FEEDWATER CONTROL VALVES (MFCVs), AND ASSOCIATED STARTUP FEEDWATER CONTROL VALVES (SFCVs)

The purpose of CTS 4.6.3.1.1 is to verify OPERABILITY of containment isolation valves following their maintenance, repair or replacement. This change is acceptable because the deleted Surveillance Requirement is not necessary to verify that the equipment used to meet the LCO can perform its required functions. Thus, appropriate equipment continues to be tested in a manner and at a Frequency necessary to give confidence that the equipment can perform its assumed safety function. Any time the OPERABILITY of a system or component has been affected by repair, maintenance, modification, or replacement of a component, post-maintenance testing is required to demonstrate the OPERABILITY of the system or component. This is described in the Bases for ITS SR 3.0.1 and required under SR 3.0.1. The OPERABILITY requirements for the containment isolation valves are described in the Bases for ITS 3.6.3. In addition, the requirements of 10 CFR 50, Appendix B, Section XI (Test Control),

provide adequate controls for test programs to ensure that testing incorporates applicable acceptance criteria. Compliance with 10 CFR 50, Appendix B, is required under the unit operating license. As a result, post-maintenance testing will continue to be performed and an explicit requirement in the Technical Specifications is not necessary. This change is designated as less restrictive because Surveillances which are required in the CTS will not be required in the ITS.

Davis-Besse Page 6 of 6 Attachment 1, Volume 12, Rev. 0, Page 64 of 461

Attachment 1, Volume 12, Rev. 0, Page 65 of 461 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 12, Rev. 0, Page 65 of 461

Attachment 1, Volume 12, Rev. 0, Page 66 of 461 CTS JMFSVs, MFCVs, and Associated SFCVsE 3.7.3 (D

3.7 PLANT SYSTEMS 3.7.3 Dilain Feedwater Stop Valves (MFSVs), Main Feedwater Control Valves (MFCVs),

and Associated Startup Feedwater'Control Valves (SFCVs)z 0 3.7.1.8, 3.6.3.1 LCO 3.7.3 MlwofFSVsgMFCVs or] associated SFCVs~shall be OPERABLE.

00 APPLICABILITY: MODES 1,2, and 3 except when all MFSVIIMFCVs associated SFCVs~are closedl[and dea3eivated] ýor isolated by a closed manual 00 valveS.

ACTIONS *,lt"*'f'=* MFSV, MFCV, and SFCV r-*

DOC A02 Separate Condition entry is allowed for eachEý 0

CONDITION REQUIRED ACTION COMPLETION TIME 3.6.3.1 (ý Action c AOne MFSVjn morg-flow patlr A.1 Close or isolateRMFSVV R 72Ehours 00 inoperable. AND A.2 VerifyRMFSVgis closed or isolated.

Once per 7 days 0

00

- .t. U 3.7.1.8 ý.n F B.1 Close or isolate BIFCV, [8or 7 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Action ow at s inoperable. AND B.2 Verify /I0FCVqis closed or Once per 7 days 0 isolated.

3.7.1.8 'ý ý.Oe F\&Fi-feýr I

C.1 Close or isolate 1FC4 I

8o'r 72M hours 00 Action inoperable. AND C.2 Verify 0FCVgis closed or Once per 7 days 0 isolated.

BVWOG STS 3.7.3-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 66 of 461

Attachment 1, Volume 12, Rev. 0, Page 67 of 461 CTS

[MFSVs, MFCVs, and Associated SFCVso 3.7.3 0

ACTIONS (continued)

CONDITION REQUIREDACTION COMPLETION TIME 3.7.1.8 Action, D. Two valves in the same D.1 Isolate affected flow path. 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 3.6.3.1 Action c flow path inoperable *for jone or mor flow pathsF 0 3.7.1.8 Action, E. Required Action and E.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 3.6.3.1 Action d associated Completion Time not met. JAND 0 E.2 Be in MODE 4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 00 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.6.3.1.3 SR 3.7.3.1 ----- --

Only required.

/ .....--- NOTE -

be performed in MO S 1 and 2. 0 0

Verify the isolation time of each [AFSV

[isj<_ [7] s condsl Dý In accordance with the Inservice 00 w Testing Program 6 M0ET1 0@

DOC M02 SR 3 .7.3.flý ----------------- ------ --------

Only required

-o --..---...

be performed in MO S 1 and 2.

7 ------ -- -

Verify eachýMFSjV jMFC'VM andgSFCVgactuates.[1 & months to the isolation position on an actual or simulated actuation signal.

BVVOG STS 3.7.3-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 67 of 461

Attachment 1, Volume 12, Rev. 0, Page 68 of 461 CTS 3.7.3 (D INSERT 1 4.7.1.8 SR 3.7.3.2 Verify the isolation time of each MFCV and SFCV is 24 months within limits.

Insert Page 3.7.3-2 Attachment 1, Volume 12, Rev. 0, Page 68 of 461

Attachment 1, Volume 12, Rev. 0, Page 69 of 461 JUSTIFICATION FOR DEVIATIONS ITS 3.7.3, MAIN FEEDWATER STOP VALVES (MFSVs), MAIN FEEDWATER CONTROL VALVES (MFCVs), AND ASSOCIATED STARTUP FEEDWATER CONTROL VALVES (SFCVs)

1. The ISTS 3.7.3 ACTIONS Note has been modified to list the specific valves to which the Note applies (MFSVs, MFCVs, and SFCVs) instead of the generic term "valves."

This is also consistent with similar Specifications in Section 3.7 (e.g., ITS 3.7.1 and ITS 3.7.2).

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

3. Typographical error corrected. The word "or" should be "and," since both MFCVs and their associated SFCVs are required to be OPERABLE.

4. Editorial change made to ISTS 3.7.3 Conditions B and C for consistency with other similar Specifications in Section 3.7 (e.g., ITS 3.7.1 and ITS 3.7.2). Furthermore, the proposed words are consistent with the wording in the ACTIONS Note.

5. The Notes to ISTS SR 3.7.3.1 and SR 3.7.3.2 have been deleted. Davis-Besse normally performs the isolation time tests for the MFSVs, MFCVs, and SFCVs in MODE 4. ISTS SR 3.7.3.2, while not currently required in the Davis-Besse CTS, can also be performed in MODE 4 when the isolation time tests are performed.

Therefore, the allowance to perform the SRs in MODE 3 is not required.

6. ISTS SR 3.7.3.1 requires verification of the isolation times ifthe MFSVs, MFCVs, and SFCVs at a Frequency in accordance with the Inservice Testing (IST) Program.

The Davis-Besse IST Program does not include the MFCVs or SFCVs. Therefore, ITS SR 3.7.3.1 will only require verification of the isolation time of the MFSVs in accordance with the IST Program and new ITS SR 3.7.3.2 will require verification of the isolation times of the MFCVs and SFCVs at a 24 month Frequency. The 24 month Frequency is consistent with the Frequency of CTS 4.3.2.2.3, which is the Surveillance referenced by CTS 4.7.1.8, the current MFCV and SFCV isolation time Surveillance.

Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 69 of 461

Attachment 1, Volume 12, Rev. 0, Page 70 of 461 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 12, Rev. 0, Page 70 of 461

Attachment 1, Volume 12, Rev. 0, Page 71 of 461 I All changes are unless otherwise noted 9 MFSVs, MFCVs, and).ssociated SFCVsjE B 3.7.3 0

B 3.7 PLANT SYSTEMS B 3.7.3 ý Main Feedwater Stop Valves (MFSVs), Main Feedwater Control Valves (MFCVs), and

, ssociated Startup Feedwater Control Valves (SFCVs) 1 0

BASES BACKGROUND The main feedwater isolation valves (MFIVs) for each steam generator consist of the MFSVs, MFCVs, and the SFCVs. The MFIVs isolate main feedwater (MFVV) flow .to the secondary side of the steam generators following a high energy line break (HELB). Closure of the MFIVs terminates flow to 'both steam generators, terminating the event for feedwater line breaks (FWLBs) occurring upstream of the MFIVs. The consequences of events occurring in the main steam lines or in the feedwater lines downstream of the MFIVs will be mitigated by their closure. Closing the MFIVs and associated bypass valves effectively terminates the addition of feedwater to an affected steam generator, limiting the mass and energy release fongteam line breaks ( LBs) or FVVLBs inside containment and reducing the cooldown effects for LBs. M The MFIVs close on receipt of a Steam and Feedwater Rupture Control System (SFRCS) signal generated by eiher~low earngeneatra[]L Main Steam Line Pressure' pressure or stearh generator/feedwater differentiI pressureý The MFIVs or Feedwater/Steam PesLow

[ Generator Differential

[ can also be closed manually.

Prssr - Hig ) The MFIVs and assoc' ted bypass valves close on recei )t for a safety injection - low Tavg c incident with reactor trip or steam generator water level - high high sig al. They may also be actuated nually. In addition to the MFIVs and a sociated bypass valves, a check alve inside containment is av lable to isolate the feedwater line enetrating 0

containment and ensure that the consequences o events do not exceed the capa ity of the containment heat remov I systems.]

IA description of the.MFIVs is found in the FSAR, Segtin [10.4.7] (Ref. 1 ).

APPLICABLE The design basis of the MFIVs is established by the analysis for the Ia e SAFETY SLB. It is also influenced by the accident analysis for the large FVNLB.

ANALYSES Closure of the MFIVs may also be relied on to terminate a steam break

- for core response analysis and excess feedwater event upon the receipt L- of a steam generator water level - high signal.

Failure of an MFIV to close following an LB, FWLB, or excess feedwater event, can result in additional mass and energy being delivered to the steam generators, contributing to cooldown. This failure also results in additional mass and energy releases following an LB or FVVLB event.

The MFIVs satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

BWOG STS B 3.7.3-1 Rev. 3.1, 12/01/05 Attachment 1, Volume 12, Rev. 0, Page 71 of 461

Attachment 1, Volume 12, Rev. 0, Page 72 of 461

[v1FSVs, MFCVs, and ,sociated SFCVsj B 3.7.3 0

BASES LCO This LCO ensures that the .MFIVs will isolate MFM flow to the steam generators following a FRLB or a main steam line break. The* a-es will also isolate the nonsafety related portions fromthe safety related nortions of the system.

EIwc5MFSV4MflFCVsR, gassociated SFCVs are required to be OPERABLE. The MFIVs are considered OPERABLE when the isolation 00 times are within limits and they-close on an isolation actuation signal.

Failure to meet the LCO requirements can result in additional mass and energy being released to containment following an4SLB or FWLB inside containment. Flf SFq/CS on high steam generator)Ievel is relied oin to

-the temnt nexcess fel/dwater flow event, failure to ýneet the LCO may]

Iresult in the introductio# of water into the main stearh lines. 1 0D APPLICABIL ITY The aMFSVsM, MM FCVsj ffassociated SFCVsmmust be OPERABLE-=

whenever there is significant mass and energy in the RCS and steam MSLBrL Q

generators. This ensures that in the event of an lHE'LB, a single failure cannot result in the blowdown of more than one steam generator.

In MODES 1,2, and 3, the[MFSVsM RMFCV4 Faciated required to be OPERABLE in order to limit the amount of available fluid SFCVs~are 0 that could be added to containment in the case of a secondary system pipe break inside containment. When the valves are close they are already performing their safety function. o

[or isoated by a /r closed manualva-lve]ý In MODES 4. 5. and 6, steam generator energy is low. Therefore, the

[jWMFSVZrýMFCV*" associated SFCVszare not required for isolation of (9 potential high energy secondary system pipe breaks in these MODES.

ACTIONS The ACTIONS Table is modified by a Note indicating that separate Condition entry is allowed for each valve.

A.1 and A.2

}0 For -mor-e- ý With oneMMFSo rm e fo 'athsl inoperable, action must be te takento restore thifected valveo OPERABL status or to close or isolate inoperable affected valveW within((8 or]72M hours. When, '

(0

=this valve closed I or isolated, te a performing E0 required safety function. >/s BWVOG STS B 3.7.3-2 Rev. 3.1, 12/01/05 Attachment 1, Volume 12, Rev. 0, Page 72 of 461

Attachment 1, Volume 12, Rev. 0, Page 73 of 461

[fl FSVs, MFCVs, and ,sociated SFCVE 0 B 3.7.3 BASES ACTIONS (continued)

For units with only one MFIV per feedwater line: The [ ] hour Completion Time is reasonable t close the MFIV or its associated bypass valve which includes performing a controlled unit shutdown o MODE 2. The 2 Completion Time is -easonable, based on operating xperience, to reach MODE 2 from full p wer conditions with the MFIVs osed, in an orderly manner and withoot challenging unit systems. ]

The[V721hour Completion Time takes into account the redundancy ()

afforded by the remaining OPERABLE valves and the low probability of an event occurring during this time period that would require isolation of the MFW flow paths. The[7V2hour Completion Time is reasonable, based on operating experience.

B-E Joea~RFV5ta gcoe or isolated, must be verified on a periodic basis thate ar closed or isolated. This is necessary to

(

4e nsure that the assumptions in the safety analysis remain valid. The 7 day Completion Time is reasonable, based on engineering judgment, in view of valve status indications available in the control room, and other administrative controls, to ensure that h se valve* ,closed or isolated.

B.1 and B.2 oe or rTfe flow pathslinoperable, action must be4 takenone/FC~in With to Irestore te a lected valv -u.s s sttusoo or 6A-rL_,

t nl'ak5operable affected valveggwithin X86or 72Whours. When se valvel]leclosed or isolated, r performing FiFJ required safety function. T'F IS

[For units with only o MFIV per feedwater line: The') hour Completion Time is reasonable, ased on operating experience, its associated byp2ss valve. ]

close the MFIV or o TheM72Mhour Completion Time takes into account the redundancy M (D afforded by the remaining OPERABLE v sand the low probability of (

an event occurring during this time period that would require isolation of the MFW flow paths.

--*noperableRMFC\Vdthat closed or isolated must be verified on a Q((

periodic basis tha e closed or isolated. This is necessary to

@ensure that the assumptions in the safety analysis remain valid. The 7 day Completion Time is reasonable, based on engineering judgment, in view of valve status indications available in the control room, and other administrative controls, to ensure that these valves are closed or isolated.

BWOG STS B 3.7.3-3 Rev. 3.1, 12/01/05 Attachment 1, Volume 12, Rev. 0, Page 73 of 461

Attachment 1, Volume 12, Rev. 0, Page 74 of 461

@%A FSVs, MFCVs, and t<ssociated SFCVsE B 3.7.3 03 BASES ACTIONS (continued)

C.1 and C.2 (D o With one or rrpe flow pathsl inoperable, action must be 2 taken to restore theeafTected valvgsi-eP-.AjLE status, or to close or - 4 satenoperable affected valvej]within 8-or]72Ehours. Whent this valveO ]closed or isolated, h performing ý ]required safety JKJ function. "--_L rI For units with only o MFIV per feedwater line: The hour Completion Time is reasonabl , based on operating experience o close the MFIV or its associated by ass valve.]

The M721hour Completion Time takes into account the redundancy Eafforded b the remaining OPERABL va es and the low probability of an event occurring during this time period that would require isolation of the MFW flow paths.

periodic basis tha closed or isolated. This is necessary to ensure that the assumptions in the safety analysis remain valid. The 7 day Completion Time is reasonable, based on engineering judgment, in view of valve status indications available in the control room, and other administrative controls, to ensure that these valves are closed or isolated.

(i.e., an inoperable MFSV and either, D.1 an inoperable MFCV or SFCV) /

With two inoperable valves in the same flow paththere ma b no redundant system to operate automatically and perform the required safety function./Although the co ainment can be isolated/wth the failure to two v es in parallel in the sVme flow path, the doubl /failure can be an ind, ation of a common 100 e failure in the valves of/his flow path and as ch is treated the same -s a loss of the isolation cpability of this flo

_poAh.I Under these conditions, affe ed valves in each flo2& path must bel D4 Irestored to QPERABLE status, o the affected flow path isolated within (

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time is reasonable, based on operating * (D experience, to close the MFIV or otherwise isolate the affected flow path.

BVAOG STS B 3.7.3-4 Rev. 3.1, 12101105 Attachment 1, Volume 12, Rev. 0, Page 74 of 461

Attachment 1, Volume 12, Rev. 0, Page 75 of 461 NM/FSVs, MFCVs, and/.ýsociated SFCVsM (

B 3.7.3 BASES ACTIONS (continued)

.E.1 and E.2 (any Required Action and J Ilfthe [MFSVs],

OPERABLE [MFC ], and [associated SFCVs] 9nnot:be restored to status,- r closed- or isolated within tj~e associated 0,

Completion Time* the unit must be in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in-at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in MODE 4 within 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months s- The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

SURVEILLANCE SR 3.7.3.14--n3.7.3.2 0 REQUIREMENTS These SRs verify that the closure time of eachTMFSVM MIFC\4, and D2 3

a~~~~Mssociated SFCVM is/_7s n./ [ _ 2 "-

r ithin theelimit given in

he [MF i*][MF~C V], an.4 s caed* C s to time M*assu medi ý -* - /*

and s w~h~n he jthe accident lndco~pn-i-ni-enf analyses.,,((B I~relaclnormally **,7- TSTr performed upon returning the unit to operation following a refeling -4 S_/ outage, The[TMFS\A MMFC\A andbssociated SFC~qshould not be m--E

==so v vre h alD've tested at power since even a part stroke exercise increases the risk of a 3 valve closure with the unit generating power. This is consistent with the Inservice Testing Program.

/ ASME Code (Ref. requirements during operation in MODES 1 and 2. @lb This SR is modified y a Note that allows entry it and operation in MODE 3 prior to p/erforming the SR. I The Frequency for M SRtis inaccordance with the Inservice Testing Progra ni ao 3 .i SR 3.7.3. foTR3ý This SR verifies that eachjMFSV, MFCV, and associated SFCV~can close on an actual or simulated actuation signal. This Surveillance is Q

normally performed upon returning the plant to operation following a refueling outage.

The Frequency for this SR is every The month(')

Frequency for testing is based on the refueling cycle. Operating experience has shown that these components usually pass the Surveillance when performed at the 1[T'month Frequency. Therefore, KJ this Frequency is acceptable from a reliability standpoint.

BWOG STS B 3.7.3-5 Rev. 3.1, 12/01/05 Attachment 1, Volume 12, Rev. 0, Page 75 of 461

Attachment 1, Volume 12, Rev. 0, Page 76 of 461

[fIFSVs, MFCVs, and jA/ssociated SFCVsM B 3.7.3 0

BASES REFERENCES 11. FSAR, ction [10.4.7. OTechnical Requirements Manualo

(- (

MASME Code for Operation and Maintenance of Nuclear Power TSW(

Plants.

BWOG STS B 3.7.3-6 Rev. 3.1, 12/01/05 Attachment 1, Volume 12, Rev. 0, Page 76 of 461

Attachment 1, Volume 12, Rev. 0, Page 77 of 461 JUSTIFICATION FOR DEVIATIONS ITS 3.7.3 BASES, MAIN FEEDWATER STOP VALVES (MFSVs), MAIN FEEDWATER CONTROL VALVES (MFCVs), AND ASSOCIATED STARTUP FEEDWATER CONTROL VALVES (SFCVs)

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

2. Changes are made to reflect changes made to the Specification.

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

4. Changes are made to reflect the Specification.

5. Typographical error corrected.

Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 77 of 461

Attachment 1, Volume 12, Rev. 0, Page 78 of 461 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 12, Rev. 0, Page 78 of 461

Attachment 1, Volume 12, Rev. 0, Page 79 of 461 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.7.3, MAIN FEEDWATER STOP VALVES (MFSVs), MAIN FEEDWATER CONTROL VALVES (MFCVs), AND ASSOCIATED STARTUP FEEDWATER CONTROL VALVES (SFCVs)

There are no specific NSHC discussions for this Specification.

Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 79 of 461

, Volume 12, Rev. 0, Page 80 of 461 ATTACHMENT 4 ITS 3.7.4, TURBINE STOP VALVES (TSVs) , Volume 12, Rev. 0, Page 80 of 461

, Volume 12, Rev. 0, Page 81 of 461 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 12, Rev. 0, Page 81 of 461

Attachment 1, Volume 12, Rev. 0, Page 82 of 461 ITS 3.7.4 ITS PLANT SYSTEMS TURBINE STOP VALVES LIMITING CONDITION FOR OPERATION 3.7.4 3.7.1.9 Four Turbine Stop Valves shall be OPERABLE.

except when all TSVs are closed LO1 APPLICABILITY: MODES 1, 2, and 3.

ACTION: j....* Add proposed ACTIONS Note A02 ACTION A ._..With one or more Turbine Stop Valves inoperable, close the inoperable valve(s) within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and Lverify the valve(s) is closed once per 7 days, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ACTION B---- n inH T WN within the f0nowing 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

SURVEILLANCE REQUIREMENTS SR 3.7.4.1 4.7.1.9 Each Turbine Stop Valve shall be demonstrated OPERABLElby performance of Surveillance [ A03 FRequirement 4.3.2.2.3ý Add proposed SR 3.7.4.2 MO1 DAVIS-BESSE, UNIT 1 3/4 7-12e Amendment No. 246 Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 82 of 461

Attachment 1, Volume 12, Rev. 0, Page 83 of 461 DISCUSSION OF CHANGES ITS 3.7.4, TURBINE STOP VALVES (TSVs)

ADMINISTRATIVE CHANGES A01 In the conversion of the Davis-Besse Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1430, Rev. 3.1, "Standard Technical Specifications-Babcock and Wilcox Plants" (ISTS).

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

A02 CTS 3.7.1.9 Action states, in part, that when one or more turbine stop valves (TSVs) are inoperable, close the inoperable valve(s) within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and verify that the valve(s) are closed once per 7 days. ITS 3.7.4 ACTIONS Note states "Separate Condition entry is allowed for each TSV." This changes the CTS by explicitly specifying separate condition entry for each inoperable TSV.

This change is acceptable because it clearly states the current requirement. The CTS considers each TSV to be separate and independent from the others. This change is designated as administrative because it does not result in a technical change to the Specification.

A03 CTS 4.7.1.9 requires each TSV be demonstrated OPERABLE "by performance of Surveillance Requirement 4.3.2.2.3." Specification 3.3.2.2 provides the requirements for the Steam and Feedwater Rupture Control System (SFRCS)

Instrumentation. CTS 4.3.2.2.3 requires a SFRCS RESPONSE TIME test, and footnote *, in part, describes how the TSV closure portion of the SFRCS RESPONSE TIME is to be measured. Thus, the CTS 4.7.1.9 requirement is referencing the TSV closure time requirement. ITS SR 3.7.4.1 requires verification that the isolation time of each TSV is within limits. This changes the CTS by explicitly stating the TSV testing requirement in the TSV Specification.

This change is acceptable because it results in no technical change to the Technical Specifications. The change explicitly states the actual TSV requirement in the TSV Specification, in lieu of providing a cross-reference to the Instrumentation Specification that requires a RESPONSE TIME test. This changeis designated as administrative because it does not result in any technical change to the CTS.

MORE RESTRICTIVE CHANGES M01 CTS 3.7.1.9 does not include a requirement to verify that each TSV actuates to the isolation position on an actual or simulated actuation signal. ITS SR 3.7.4.2 is being added to perform this requirement every 24 months. This changes the CTS by adding an additional Surveillance Requirement.

The purpose of ITS SR 3.7.4.2 is to verify that the TSVs can close on an actual or simulated actuation signal. This change is acceptable because the test is conducted to ensure that the TSVs will perform their safety function. The 24 month Frequency is consistent with CTS 4.7.1.9, which requires the isolation Davis-Besse Page 1 of 2 Attachment 1, Volume 12, Rev. 0, Page 83 of 461

Attachment 1, Volume 12, Rev. 0, Page 84 of 461 DISCUSSION OF CHANGES ITS 3.7.4, TURBINE STOP VALVES (TSVs) time of each TSV to be measured. This change is considered more restrictive because a new Surveillance Requirement is added to the ITS that was not included in the CTS.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES L01 (Category 2- Relaxation of Applicability) CTS 3.7.1.9 is applicable in MODES 1, 2, and 3. ITS LCO 3.7.4 is applicable in MODE 1, and in MODES 2 and 3 except when all TSVs are closed. This changes the CTS by making the Specification not applicable in MODES 2 and 3 when all TSVs are closed.

The purpose of the ITS 3.7.4 Applicability is to ensure that the TSVs are OPERABLE and capable of closing to support the safety analyses. This change is acceptable because the requirements continue to ensure that the structures, systems, components are maintained in the MODES and other specified conditions assumed in the safety analyses and licensing basis. When all the valves are in the closed position, they are in their assumed accident position.

Furthermore, this change is also consistent with the Applicability of ISTS 3.7.2, "Main Steam Isolation Valves (MSIVs)." At Davis-Besse, the TSVs perform a similar function and are required for the main steam line break accident, which is one of the accident scenarios listed for the MSIVs in the ISTS 3.7.2 Bases. This change is designated as less restrictive because the ITS LCO requirements are applicable in fewer operating conditions than in the CTS.

Davis-Besse Page 2 of 2 Attachment 1, Volume 12, Rev. 0, Page 84 of 461

Attachment 1, Volume 12, Rev. 0, Page 85 of 461 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 12, Rev. 0, Page 85 of 461

Attachment 1, Volume 12, Rev. 0, Page 86 of 461 0 TSVs 3.7.4

. CTS 3.7 PLANT SYSTEMS 3.7.4 Turbine Stop Valves (TSVs) 3.7.1.9 LCO 3.7.4 Four TSVs shall be OPERABLE.

APPLICABILITY: MODE 1, MODES 2 and 3 except when all TSVs are closed.

ACTIONS k ..---iT:

C. . .. . . .. . . .. . . . . . . . . . . . . . . .. .. .. . .. .. . .. . .. .. . .. .. .

DOC A02 Separate Condition entry is allowed for each TSV.

CONDITION REQUIRED ACTION COMPLETION TIME Action A. One or more TSVs A.1 Close inoperable TSV. 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months inoperable.

AND A.2 Verify inoperable TSV is Once per 7 days closed.

Action B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND B.2 Be in MODE 4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.7.1.9 SR 3.7.4.1 Verify isolation time of each TSV is within limits. 24 months DOC M01 SR 3.7.4.2 Verify each TSV actuates to the isolation position on 24 months an actual or simulated actuation signal.

3.7.4-1 Attachment 1, Volume 12, Rev. 0, Page 86 of 461

Attachment 1, Volume 12, Rev. 0, Page 87 of 461 JUSTIFICATION FOR DEVIATIONS ITS 3.7.4, TURBINE STOP VALVES (TSVs)

1. This Specification has been added to ensure the OPERABILITY of the Turbine Stop Valves (TSVs). The closure of the TSVs is assumed in the main steam line break accident analysis and TSV requirements are provided in the CTS. Therefore, the Specification is needed to satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 87 of 461

Attachment 1, Volume 12, Rev. 0, Page 88 of 461 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 12, Rev. 0, Page 88 of 461

Attachment 1, Volume 12, Rev. 0, Page 89 of 461 0 TSVs B 3.7.4 B 3.7 PLANT SYSTEMS B 3.7.4 Turbine Stop Valves (TSVs)

BASES BACKGROUND The TSVs are designed to quickly shut off steam flow to the turbine and prevent turbine overspeed under emergency conditions. TSV closure also terminates flow from the unaffected (intact) steam generator following a main steam line break (MSLB).

Four turbine stop valves are located in front and below the turbine unit.

Steam from one steam generator passes through two of the TSVs (in parallel pathways) and steam from the other steam generator passes through the other two TSVs (in parallel pathways). The TSVs are closed on a Steam and Feedwater Rupture Control System (SFRCS) signal generated by either Main Steam Line Pressure - Low or Feedwater/Steam Generator Differential Pressure - High to prevent blowdown of both steam generators during a MSLB.

A description of the turbine stop valves are found in the UFSAR, Section 10.2 (Ref. 1).

APPLICABLE The design basis of the TSVs are established by the accident analysis SAFETY of the MSLB events presented in the UFSAR, Section 15.4 (Ref. 2).

ANALYSES Credit is taken in the MSLB analysis for TSV closure. The TSVs provide a redundant means for main steam line isolation in the event of an MSLB downstream of the MSIVs.

The TSVs satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO This LCO requires all four TSVs to be OPERABLE. The TSVs are considered OPERABLE when the isolation times are within limits and they close on an isolation actuation signal.

This LCO provides assurance that the TSVs will perform their design safety function to mitigate the consequences of accidents that could result in offsite exposures comparable to the 10 CFR 100 limits (Ref. 3).

APPLICABILITY The TSVs must be OPERABLE in MODE 1 and in MODES 2 and 3 with any TSV open, when there is significant mass and energy in the Reactor Coolant System and steam generator; therefore, the TSVs must be OPERABLE or closed. When all the TSVs are closed, they are already performing the safety function.

In MODE 4, the steam generator energy is low. Therefore, the TSVs are not required to be OPERABLE.

B 3.7.4-1 Attachment 1, Volume 12, Rev. 0, Page 89 of 461

Attachment 1, Volume 12, Rev. 0, Page 90 of 461 TSVs B 3.7.4 BASES APPLICABILITY (continued)

In MODES 5 and 6, the steam generators do not contain much energy because their temperature is below the boiling point of water; therefore, the TSVs are not required for isolation of potential high energy secondary system pipe breaks in these MODES.

ACTIONS The ACTIONS Table is modified by a NOTE indicating that separate Condition entry is allowed for each TSV.

A.1 and A.2 With one TSV inoperable, action must be taken to close the inoperable TSV within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time is reasonable, considering the probability of an accident that would require actuation of the TSVs occurring during this time interval. The MSIVs are also available to provide the required isolation for the postulated accidents.

Inoperable TSVs that are closed must be verified on a periodic basis that they are closed. This is necessary to ensure that the assumptions in the safety analysis remain valid. The 7 day Completion Time is reasonable, based on engineering judgment, in view of TSV status indications available in the control room, and other administrative controls, to ensure that these valves are closed.

B.1 and B.2 If any Required Action and associated Completion Time cannot be met, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from MODE 1 conditions in an orderly manner and without challenging unit systems.

SURVEILLANCE SR 3.7.4.1 REQUIREMENTS This SR verifies that the closure time of each TSV is within the limits in Reference 4 and is within that assumed in the accident and containment analyses. This SR is normally performed upon returning the unit to operation following a refueling outage, because the TSVs should not be tested at power since even a part stroke exercise increases the risk of a valve closure with the unit generating power.

The Frequency of TSV testing is every 24 months. The 24 month Frequency for testing is based on the refueling cycle. Operating B 3.7.4-2 Attachment 1, Volume 12, Rev. 0, Page 90 of 461

Attachment 1, Volume 12, Rev. 0, Page 91 of 461 0 TSVs B 3.7.4 BASES SURVEILLANCE REQUIREMENTS (continued) experience has shown that these components usually pass the Surveillance when performed at the 24 month Frequency. Therefore, this Frequency is acceptable from a reliability standpoint.

SR 3.7.4.2 This SR verifies that each TSV can close on an actual or simulated actuation signal. This Surveillance is normally performed upon returning the plant to operation following a refueling outage.

The Frequency of TSV testing is every 24 months. The 24 month Frequency for testing is based on the refueling cycle. Operating experience has shown that these components usually pass the Surveillance when performed at the 24 month Frequency. Therefore, this Frequency is acceptable from a reliability standpoint.

REFERENCES 1. UFSAR, Section 10.2.

2. UFSAR, Section 15.4.

3. 10CFR100.

4. Technical Requirements Manual.

B 3.7.4-3 Attachment 1, Volume 12, Rev. 0, Page 91 of 461

Attachment 1, Volume 12, Rev. 0, Page 92 of 461 JUSTIFICATION FOR DEVIATIONS ITS 3.7.4 BASES, TURBINE STOP VALVES (TSVs)

1. This Specification Bases has been added consistent with the addition of the Specification.

Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 92 of 461

Attachment 1, Volume 12, Rev. 0, Page 93 of 461 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 12, Rev. 0, Page 93 of 461

Attachment 1, Volume 12, Rev. 0, Page 94 of 461 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.7.4, TURBINE STOP VALVES (TSVs)

There are no specific NSHC discussions for this Specification.

Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 94 of 461

, Volume 12, Rev. 0, Page 95 of 461 ATTACHMENT 5 ITS 3.7.5, EMERGENCY FEEDWATER (EFW) , Volume 12, Rev. 0, Page 95 of 461

, Volume 12, Rev. 0, Page 96 of 461 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 12, Rev. 0, Page 96 of 461

Attachment 1, Volume 12, Rev. 0, Page 97 of 461 ITS 3.7.5 ITS PLANT SYSTEMS AUXILIARY FEEDWATER SYSTEM LIMITING CONDITION FOR OPERATION LCO 3.7.5 3.7.1.2 Two trains of auxiliary feedwater, each consistin o an auxilary Pfeedwater pump and aEsociated flow path to-both steam ge./ratorsshall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

Add proposed ACT111]11,JNote A02 ACTION-: L__ Add pro osed! I 11(ý)I, LO 1

a. With one train of auxiliary feedwater inoperable to either or both I ACTION B steam generator(s), restore the inoperable train to OPERABLE status , 0 within 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months sor be in HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . ARequiredActonDA ACTION D

b. With any Auxil' ry Feed Pump Turbine Inlet St/eamrPessure Interlocksl inoperabl~e, ýest 'ore the inoperable interlockst OPERABLE statusi A2 within 7 days or be in HOT SHUTDOWN within ), next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

c. With steam hnerator inlet valve AF 599 or AF 08 closed, re-openl the close. *valve AF 599 or AF 608 within o hhour or be in HOT L*dp~~e L 02, STANDB ithin the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and HOT UTDOWN within the folLAN ing 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . oACI 0 ,

D) M SURVEILLANCE REQUIRENT - AdrooeACONCasendontoofCON 4.7.1.2.1 Each Auxiliary Feedwater train shall be demonstrated OPERABLE:

a. At least once per 92 daysion a STAGGEW TEST BASIS by:* L0G SR 3.7.5.2 I. Verifying the differential pressure of each steam turbine driven pump is greater than or equal to the required differential pressure tne-sDeclrled pt recirculaion flow ine provisions or entry into MODE 3.

When conducting tests of an auxiliary feedwater train in DES 1, 2, and 3 which require local anual realignment of valves that ma the train inoperable, the Mot r Driven Feedwater Pump and its asso iated flow paths shall be OPERABLE er Specification 3.7.1.7 during the erformance of this surveillance. If/the Motor Driven Feedwater Pump or a associated flow path M02 is inoperable, a/dedicated individual shall be statio ed at the realigned auxiliary feedw ter train's valves (in communication with the control room) able to restor the valves to normal system OPERABL status.

DAVIS-BESSE, UNIT 1 3/4' 7-4 Amendment No. 96,122,131,193,200 Page 1 of 6 Attachment 1, Volume 12, Rev. 0, Page 97 of 461

Attachment 1, Volume 12, Rev. 0, Page 98 of 461 ITS 3.7.5 ITS PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

G0

b. At least once per 31 days on a STAGGEJ2i TEST BASIS by:

SR 3.7.5.1 I. Verifying that each valve (power operated or automatic) in that isnot locked.

the flow pathtis in its correct position. sealedorotherwise secured in position

2. Verifying th all manual valves in the auxi iary feedwater pump sucti and discharge lines that aff t the system's L4 capacityy o deliver water to the steam nerator are locked in thei proper position. /

3. Verifyi~ngqt valves CW 196, CW 197, FLA03F, 106 are cosed. -S c At least once each REFUELING INTERVAL by: Add proposed SR 3.7.5.4 Note L0 in the flow path SR 3.7.5.4 1. ý Verifying that each automatic valve actuates to its correct position on a 5ta. n Fee aterL06'1 IRuptu~fi Control S'ystemlIactuation *test signal--'- *_. AO SR 3.7.5.5 2. Verif in that each pump starts automaticall u on receipt of a team a edwat Rupture C roSstewn ac uation M

,actualor test signal. The provis-ions of Specification 4.0.4 are notd a ica e or entr tnODE 3.T L06 SR 3.7.5.6 3. Verifying that there is a flow path from each auxiliary feedwater pump to both steam generators by pumping water from the Condensate Storage Tank with each pump to both steam generators.

The flow paths s all be verified by either eam generator level change or Auxiliary Feedwater Safety rade Flow Indication. erification of the Auxiliar Feedwater System's fl capacity is not required.

d. The Auxiliary feed Pump Turbine Steam Generator/evel Control System shall e demonstrated OPERABLE by performance of a CHANNEL CHECK at le st once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , a CHANNEL F NCTIONAL TEST at IAO least onc5Yper 31 days, and a CHANNEL CALIB TION at least once each REFUELING INTERVAL.

e. The Auxiliary.Feed Pump Suction Pressure Inter10FUs shall be demonstrated/OPERABLE by performance of a CHANEL FUNCTIONAL TEST at least o0 e per 31 days, and a CHANNEL CAL RATION at least once each REFULING INTERVAL.

DAVIS-BESSE, UNIT I 3/4 7-5 Amendment No. 43,63,96,122,131,1)3,216.218 Page 2 of 6 Attachment 1, Volume 12, Rev. 0, Page 98 of 461

Attachment 1, Volume 12, Rev. 0, Page 99 of 461 ITS 3.7.5 ITS SURVEILLANCE REQUIRENENTS fContinued)

f. After any modificat on or repair to the Auxiliary Feedwate, System that could affect the system' capability to deliver water to the s am generator, the affected flow path shall be demonstrated available as fol ows:

1. If the modif tion or repair Is downstream of the t flow line, each auxiliary f pup(s) associated with the affected flow path shall pump water from Condensate Storage Tank to the ste generator(s) associated th the affected flow path; and the fl . path availability will be ver fled by steam generator level change o Auxiliary Feedwater Safety Gra e Flow Indication. e0

2. If the fication or repair is upstream of the est flow line, the auxiliary feed pump shall pump water through the Auxiliary Feedwater System to the test flow line; and the flow path vailability will be verified y flow indication in the test flow li e.*

This Surveil ance Testing shall be performed prior o entering NODE 3 if the modification Is made in NODES 4, 5 or 6. Verificat on of the Auxiliary Feedwater S Stem's flow capacity is not required./

SR 3.7.5.6 g. Following each extended cold shutdown (> 30 days in HODE 5), by:

1. Verifying that there is a flow path from each auxiliary feedwater pump to both stem to bet enerators by pumping Condensate Storage pump stem generators.lThe flow paths shall Tank water with 1:0veriled by each--- LA05*

(either s te*l genera~tor leve.1 chance br .Aux.lf~ag F.ter Safert, GradeI Flo!w Indiiatitn. F ere provisions of Specification .o aenot applicable for entry into VADE 3.

Verification of Auxiliary Feedwter System's. ow capacity isnot ýLAOS required. _~~

4.7.1.2.2 The Auxiliary. eed Pump Turbine Inlet Steam Pressure Interlocks shall be demonstrated OPERABLE *en the steam lIne pressure is greater t, n 275 psig, by performance of a FUNCTIONAL TEST at least once per 31 s, and a CHANNEL CALIBRATION at leas once each REFUELING INTERVAL. The CHANEL FUNCTIONAL TEST shall be performed withi 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after exceeding 275 psig during/each plant startup, if the test has not bee_ /performed within the last 31 days.

When conducting test of an auxiliary feedwater train in HODO 1, 2, and 3 which require local manu realignment of valves that make the tr in inoperable, the Motor Driven Fee$Ater Pump and Its associated flow paths hall be OPERABLE per Specification 3. .1.7 during the performance of this surv illance. If the Motor M0S Driven Feedwate Pump or an associated flow path Is Ino rable, a dedicated Individual sha be stationed at the realigned auxilia feedwater train's valves (in communica ion with the control room) able to resto the valves to normal system OPE LE status.

DAVIS-BESSE, UNIT I 3/4 7-Sa Amendment No. S6 .MI.- 1.,,r 218 Page 3 of 6 Attachment 1, Volume 12, Rev. 0, Page 99 of 461

Attachment 1, Volume 12, Rev. 0, Page 100 of 461 ITS 0 ITS 3.7.5 PLANT SYSTEMS MOTOR DRIVEN FEEDWATER PUMP SYSTEM LIMITING CONDITION FOR OPFRATTAN LIMITING CONDITION FOR OPERATION LCO 3.7.5 3.7.1.7 The Motor Driven Feedwater Pump and associated ow paths to the train LA01 L~uxiliary Fe~edater SystemI shall be OPERABLE.

APPLICABILITY: MODES 1, 2 and 3. Add proposed second Applicability M ACTION: / Add proposed ACTION4 Note j 0 Writh the Motor Drive Feedwater Pumplor its associat dfow paths.to the LA01 ACTION B -uxiliary Fedater System inoperable, restore to OPERABLE status wi tin 72 lhours*o+be in HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . !M0

,* A*Ad__proposed RequiredAction D.1 M02 ACTION D 0 SURVEILLANCE REUIREMENTS s-Add proposed ACTdON Cand second Condition of ACTION DPERAB SAdd proposed 4.7.1.7 The required Motor Driven Feedwater Pump and fow p~aths t~othe ACTIONF M Auxiliary Feedwater System shall be demonstrated OPERABLE:

a. Deleted I

b. At least once per 31 days by:

1. When in MODEE with RATED THERMAL POWER great than 40%,

verifying th t each manual valve in the Moto Driven Feedwater Pump sucti and discharge lines that affe the system's capabilit to deliver water to the steam nerators is locked in its p oper position.

SR 3.7.5.1 2. When in MODE I with RATED THERMAL POWER greater than 40%,

verifying that each power operated valve in the flow path is in its correct position. I that is not locked, sealed, or otherwise secured in position DAVIS-BESSE, UNIT I 3/4 7-12a Amendment No. 403--I043- 200 Page 4 of 6 Attachment 1, Volume 12, Rev. 0, Page 100 of 461

Attachment 1, Volume 12, Rev. 0, Page 101 of 461 ITS 3.7.5 ITS PLANT SYSTEMS that is not locked, sealed, or L04 otherwise secured in position S cIJRVFIIIANCF RFDIJIRFMFNTS (Continuedl SR 3.7.5.1 3. When in MODE I at RATED THERMAL POWER equal to or less than (including Note) 40% or when in MODES 2 or 3, verifying that each valve (manual or power operated)Win the Motor Driven Feedwater Pump flow path is able to be positioned locally for delivering flow to the Auxiliary Feedwater System.

(Ability is demonvirated by verifying the prese ce of handwheelsl for all manual AlIves and the presence of eit br handwheels or available pow l0supply for motor operated v lves.

SR3..53 . tleast once per 92 days Jand prior to etr i~oMDE 3 from MO:DE- ý lqt(ifA not perform d in the past 92 days)I by:*

Verifying pr er operation of each power o ated and

1. automatic alve in the Motor Driven Feed ter Pump flow path to the xiliary Feedwater System.

2. Veri fying*e Motor Driven Feedwater Pu tarts from h Control~oom. **,

3. Verifying proper operation of the Motor Driven Feedwater Pump.**

SR 3.7.5.7 d. At least once each REFUELING INTERVAL by:

1. Verifying that there is a flow path between the Motor Driven Feedwater Pump System and the Auxiliary Feedwater System by pumping water from the Condensate Storage Tanks to the steam A03 generators. The flow path to the steam generators shall beI J veniier Prior to/enteringrODE 3 f~om MODE 41 y either steam g nerator level change or Auxiliary Feed ater Safety Grade low Indication. Verification of Motor riven Feedwa er Pump System flow capacity is not required.

SR3.7.5.3

If the Motor Driven Feedwater Pump cannot be tested within the time period Note specified, due to being aligned to the Main Feedwater System, the Surveillance Requirement shall be met within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after the Motor Driven Feedwater Pump has been aligned to the Auxiliary Feedwater System for I hour.

- When conducting tes s of the Motor Driven Feedwater Pump System in MODE 1 greater than 40% RATE THERMAL POWER which require local m nual realignment of valves that make the system inoperable, both auxiliary fe dwater pumps and their associated fl paths shall be OPERABLE per Specification 3.7.1.2 during the performance of his surveillance. If one auxiliary feedwater pump or flow M02S path is inoperabl , a dedicated individual shall be st tioned at the realigned Motor Driven Fee ater Pump System's valves (in commu ication with the control room) able to r store the valves to normal system OP BLE status.

DAVIS-BESSE, UNIT I 3/4 7-12b Amendment No. 103, 193, 200, 216 Page 5 of 6 Attachment 1, Volume 12, Rev. 0, Page 101 of 461

Attachment 1, Volume 12, Rev. 0, Page 102 of 461 ITS ITS 3.7.5 PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

e. After any modificatog or repair to the Motor Driven Feedwater Pum System that could affect the system's cpablflity to deliver water from the Condensate torage Tanks to the Auxiliary Feedwater System, the affected flow path shall be demo jstrated available as follows:'

1. If the modifcation or repair Is in the Auxiliaryfine Feedwater f ow path downstream of the MotoriDdiven Feedwater Pump test flow tle-4n, theMotor Driven Feedwater Pump shal pump water from the Condensate Storage Tanks to the Awilar Feedwater System and the flow path avallabilnt will be verified by eitherL steam generator level change or Auxiliary Feedwater *afety Grade Flow Indica in./

2. n odification or repair Is upstreamrrven Ifthe of the Motor Feedwater Pump test ow fine tie-in, the Motor Driven Feedwater Purop shall pump water from the A aCory ensate Storage Tanks to the test flow ine a the flow path avalability will Pupshl adteAxlayFeedwate pumpin water from the CondensatStrgTaktohe Syte StorlagFedTank t ehfled by Motor be othe Ssteam a~nd at~t.he Driven Feedwater Pump path flowf flow wilhe vrifiedmbyeitertos tolabl in dcatlion.

stamenerator change or Auxiliary Feedwater level S ,

afety Grade F~lowIncao.tL0)

SR 3.7.5.7 f. Following each extended COLD SHUTDOWN (greater that 30 days in MODE 5), by:

2. Ifte dficatio n rrpi susra ofth Driven Motor fo aaiyiPump o eurd Feedwater

1. Verifying that there is a flow path between the Motor Driven Feedwater System This surveillancesiteng shall be performed prior to entering *3DE 3 from MODE 4 If the modificati is made in MODES 4, 5. or 6. VerficationopL07m the Motor Driven Feedwater flow capacity is not required. Purn DAVIS-BESSE, UNIT 1 3/4 7-12c Amendment No. 103, 193. 261 p

Page 6 of 6 Attachment 1, Volume 12, Rev. 0, Page 102 of 461

Attachment 1, Volume 12, Rev. 0, Page 103 of 461 DISCUSSION OF CHANGES ITS 3.7.5, EMERGENCY FEEDWATER (EFW)

ADMINISTRATIVE CHANGES A01 In the conyersion of the Davis-Besse Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1430, Rev. 3.1, "Standard Technical Specifications-Babcock and Wilcox Plants" (ISTS).

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

A02 The ITS 3.7.5 ACTIONS include a Note that states LCO 3.0.4.b is not applicable when entering MODE 1. CTS 3.7.1.2 and CTS 3.7.1.7 do not include this Note.

This changes the CTS by including the ACTION Note.

The purpose of the ITS 3.7.5 ACTIONS Note is to prohibit entry into MODE 1 with an inoperable EFW train. Currently, CTS 3.7.1.2 and CTS 3.7.1.7 preclude entering MODES 1, 2, and 3 when an AFW train or MDFP train, respectively, are inoperable. ITS LCO 3.0.4 has been added in accordance with the Discussion of Changes for ITS Section 3.0, DOC L01. This LCO allows entry into a MODE or other specified condition in the Applicability under certain conditions when a Technical Specification required component is inoperable. ITS LCO 3.0.4 allows entry into a MODE or other condition in the Applicability of a Specification if a risk assessment is performed, that determines it is acceptable to enter the Applicability, and appropriate risk management actions are established. The addition of this restriction (LCO 3.0.4.b is not applicable) is acceptable because there is an increased risk associated with entering MODE 1 with an inoperable EFW train, and therefore the provisions of LCO 3.0.4.b should not be applied in this circumstance. The change is acceptable because CTS 3.7.1.2 and CTS 3.7.1.7 do not currently allow this option. This change is considered administrative because it does not result in technical changes to the CTS.

A03 CTS 4.7.1.7.c requires performance of a MDFP train functional test (i.e., verify it can be started and properly operated) at least once per 92 days "and prior to entry into MODE 3 from MODE 4 (if not performed in the past 92 days)."

CTS 4.7.1.7.d.1 requires verification at least once each refueling interval (24 months) that there is a flow path between the Motor Driven Feedwater Pump System and the Auxiliary Feedwater System by pumping the water from the Condensate Storage Tanks to the steam generators. It further states it must be performed prior to entering MODE 3 from MODE 4. CTS 4.7.1.7.f requires the same test as CTS 4.7.1.7.d.1 following a COLD SHUTDOWN greater than 30 days, and includes the same stipulation that it must be performed prior to entering MODE 3 from MODE 4. ITS SR 3.7.5.7 requires the same Surveillance test, but does not include the "prior to entering MODE 3 from MODE 4" stipulation. This changes the CTS by deleting the statements "prior to entry into MODE 3 from MODE 4 (if not performed in the past 92 days)" and "prior to entry into MODE 3 from MODE 4."

This change is acceptable because the CTS requirement has not changed.

CTS 4.0.4 states that "entry into an OPERATIONAL MODE or other specified applicability shall not be made unless the Surveillance Requirement(s)

Davis-Besse Page 1 of 14 Attachment 1, Volume 12, Rev. 0, Page 103 of 461

Attachment 1, Volume 12, Rev. 0, Page 104 of 461 DISCUSSION OF CHANGES ITS 3.7.5, EMERGENCY FEEDWATER (EFW) associated with the Limiting Condition for Operation have been performed within the stated surveillance Interval or otherwise specified." This requirement has been maintained in ITS 3.0.4. Therefore, there is no need to restate CTS 4.0.4 (ITS SR 3.0.4). This change is designated as administrative because it does not result in a technical change to the CTS.

MORE RESTRICTIVE CHANGES M01 CTS 3.7.1.2 Action a states that if the inoperable AFW train cannot be restored to OPERABLE status within the allowed time, to be in HOT SHUTDOWN (MODE 4) within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The CTS 3.7.1.7 Action states that if the inoperable MDFP train cannot be restored to OPERABLE status within the allowed time, to be in HOT SHUTDOWN (MODE 4) within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . Under similar conditions, ITS 3.7.2 ACTION D states to be in MODE 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 4 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This changes the CTS by specifying that MODE 3 must be achieved within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

The purpose of the CTS 3.7.1.2 and CTS 3.7.1.7 shutdown actions is to place the unit outside the Applicability of the LCOs. This change is acceptable because a new intermediate MODE must be reached, consistent with the requirements of CTS 3.0.3 and ITS LCO 3.0.3. The proposed Completion Time is sufficient to allow an operator to reduce power to MODE 3 in a controlled manner without challenging unit safety systems. The 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months time provided to reach MODE 3 is consistent with the time provided in similar actions in both the CTS and ITS. This change has been designated as more restrictive because it requires the unit to be placed in MODE 3 within a specific time.

M02 CTS 3.7.1.2 does not provide any actions when both AFW trains are inoperable for reasons other than those provided in CTS 3.7.1.2 Action c (which actually describes a condition in which both AFW trains and the MDFP train is inoperable, as described in DOC L02). Thus, if only two AFW trains are inoperable, CTS 3.0.3 must be entered. CTS 3.0.3 requires a unit shutdown to commence within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , and the unit to be placed in MODE 3 in the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in MODE 4 in the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . CTS 3.7.1.7 provides the requirements for the MDFP train. Since this is a separate Technical Specification that is not part of CTS 3.7.1.2, the AFW train Technical Specification, no actions are provided in either CTS 3.7.1.2 or 3.7.1.7 to cover the condition of one AFW train inoperable concurrent with the MDFP train being inoperable. Thus, if an AFW train and MDFP train are concurrently inoperable, CTS 3.7.1.2 Action a would allow 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to restore the inoperable AFW train to OPERABLE status and the CTS 3.7.1.7 Action would allow 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to restore the inoperable MDFP train to Operable status, prior to requiring a unit shutdown. However, CTS 4.7.1.2.1 .a (the AFW pump flow rate test) and 4.7.1.2.1.f (a post-maintenance flow test) includes a footnote (footnote *) that states if an AFW train is inoperable due to realigning valves for Surveillance testing concurrent with the MDFP train being inoperable, then a dedicated individual (in communication with the control room) shall be stationed at the realigned AFW train valves so that they can be restored to OPERABLE status if required. A similar footnote (footnote **) requiring stationing an individual at the MDFP train valves if one AFW train is inoperable is provided for CTS 4.7.1.7.c.2 and 4.7.1.7.c.3 (the MDFP train flow test). As long Davis-Besse Page 2 of 14 Attachment 1, Volume 12, Rev. 0, Page 104 of 461

Attachment 1, Volume 12, Rev. 0, Page 105 of 461 DISCUSSION OF CHANGES ITS 3.7.5, EMERGENCY FEEDWATER (EFW) as these footnote allowances are followed, the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months restoration times provided in CTS 3.7.1.2 Action a and CTS 3.7.1.7 Action are allowed. ITS 3.7.5 ACTION C will limit the restoration time to 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months if the MDFP train is inoperable concurrent with an AFW train inoperable due to one inoperable steam supply. ITS 3.7.5 Condition D, second Condition, covers the case where any two EFW trains (i.e., two AFW trains or one AFW train and the MDFP train) are inoperable for reasons other than Condition C (the MDFP train inoperable concurrent with an AFW train inoperable due to one inoperable steam supply).

When in this Condition, a unit shutdown to MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is required. This changes the CTS by a) reducing the time the MDFP train can be inoperable concurrent with an AFW train inoperable due to one inoperable steam supply from 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months ; b) reducing the time the MDFP train can be inoperable concurrent with an AFW train being inoperable for reasons other than an inoperable steam supply from 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to no time (i.e., no restoration time is provided); and c) reducing the time to be in MODE 3 from 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 4 from 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months when both AFW trains are inoperable.

The purpose of ITS 3.7.5 ACTION C and ACTION D is to limit the time two EFW trains can be concurrently inoperable. The proposed time in ITS 3.7.5 ACTION C is acceptable since it appropriately limits the time the unit can continue to operate with the MDFP inoperable concurrent with one AFW train inoperable due to an inoperable steam supply. The proposed time in ITS 3.7.5 ACTION D is acceptable since it requires a unit shutdown within a shorter time, without providing any additional time for commencing the shutdown requirements if both AFW trains are inoperable and requires a unit shutdown without providing any restoration time ifthe MDFP train is inoperable concurrent with an AFW train being inoperable for reasons other than one inoperable steam supply. This change is designated as more restrictive since less time is provided to restore inoperable components in the ITS than is provided in the CTS.

M03 CTS 4.7.1.2.1.a.1 requires a flow rate test of the AFW trains. It is modified by an allowance that the provisions of Specification 4.0.4 are not applicable for entry into MODE 3. CTS 4.7.1.2.1.c.2 requires a verification that each AFW pump starts upon receipt of a Steam and Feedwater Rupture Control System actuation test signal. It is also modified by an allowance that the provisions of Specification 4.0.4 are not applicable for entry into MODE 3. Since the Applicability of CTS 3.7.1.2 is MODES 1, 2, and 3, these statements essentially allow the unit to enter MODE 3 without having the two Surveillances performed (current) within the associated Frequency. The two Surveillances must be performed (i.e., current) prior to entering MODE 2. ITS SR 3.7.5.2 and SR 3.7.5.5 require similar Surveillances. However, they are modified by a Note that states the SRs are not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after reaching 800 psig in the steam generators. This changes the CTS by limiting the amount of time the unit can operate in MODE 3 prior to requiring the Surveillances to be performed.

The purpose of the CTS allowances is to provide time to perform the Surveillances under the necessary unit conditions. To perform these Surveillances, adequate steam generator pressure is required. The proposed limit of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after reaching 800 psig in the steam generators is acceptable Davis-Besse Page 3 of 14 Attachment 1, Volume 12, Rev. 0, Page 105 of 461

Attachment 1, Volume 12, Rev. 0, Page 106 of 461 DISCUSSION OF CHANGES ITS 3.7.5, EMERGENCY FEEDWATER (EFW) because it provides adequate time to perform the Surveillances after reaching the necessary unit conditions. This change is designated as more restrictive since less time is being allowed to performed the Surveillances in the ITS than is allowed in the CTS.

M04 The CTS 3.7.1.7 requirements for the MDFP train are applicable in MODES 1, 2, and 3. ITS 3.7.5 requirements for the MDFP train are applicable in MODES 1, 2, and 3, and in addition, MODE 4 when a steam generator is relied upon for heat removal. Consistent with this change in Applicability, a new ACTION (ITS 3.7.5 ACTION F) has been provided when the MDFP train is inoperable in MODE 4, and the new ACTION requires action to be immediately initiated to restore the MDFP train to OPERABLE status. This changes the CTS 3.7.1.7 requirements by requiring the MDFP train to be OPERABLE in MODE 4 when a SG is relied upon for heat removal.

This change is acceptable because the MDFP train may be needed in MODE 4 when the steam generators are used for heat removal until the decay heat removal (DHR) loop has been placed in service. ITS LCO 3.4.6, "RCS Loops -

MODE 4," includes requirements for OPERABLE steam generators, thus a MDFP train must be OPERABLE to ensure the steam generators have a source of feedwater. The change is designated as more restrictive because the MDFP train is now required to be OPERABLE in MODE 4 when a steam generator is relied upon for heat removal.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type I - Removing Details of System Design and System Description, Including Design Limits) CTS LCO 3.7.1.2 requires two trains of auxiliary feedwater, each consisting of an auxiliary feedwater pump and associated flow path to both steam generators, to be OPERABLE. CTS LCO 3.7.1.7 requires the Motor Driven Feedwater Pump and associated flow paths to the Auxiliary Feedwater System to be OPERABLE. ITS LCO 3.7.5 requires three EFW trains to be OPERABLE, consisting of two Auxiliary Feedwater (AFW) trains and the Motor Driven Feedwater Pump (MDFP) train. The ITS does not define the components and associated flow path that comprise an OPERABLE EFW train. This changes the CTS by moving the description of the AFW and MDFP trains to the Bases.

The removal of these details, which are related to system design, from the Technical Specifications, is acceptable because this type of information is not necessary to be included to provide adequate protection of public health and safety. The ITS retains all necessary requirements in the LCO to ensure OPERABILITY of the EFW trains (both AFW and MDFP). Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of Davis-Besse Page 4 of 14 Attachment 1, Volume 12, Rev. 0, Page 106 of 461

Attachment 1, Volume 12, Rev. 0, Page 107 of 461 DISCUSSION OF CHANGES ITS 3.7.5, EMERGENCY FEEDWATER (EFW) changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LA02 (Type 4 - Removal of LCO, SR, or other TS requirementto the TRM, UFSAR, ODCM, QAPM, IST Program, or lIP) CTS 3.7.1.2 Action b provides Action requirements for an inoperable auxiliary feed pump turbine inlet steam pressure interlock which require restoration within 7 days or a unit shutdown.

CTS 4.7.1.2.2 provides the Surveillance Requirement for the auxiliary feed pump turbine inlet steam pressure interlocks and requires a CHANNEL FUNCTIONAL TEST every 31 days and a CHANNEL CALIBRATION every refueling interval (24 months). ITS 3.7.5 does not include these requirements. This changes the CTS by moving these requirements to the Technical Requirements Manual (TRM).

The removal of this Action Requirement and associated Surveillance Requirement from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The purpose of CTS 3.7.1.2 is to ensure the AFW trains are OPERABLE. As stated in the NRC Safety Evaluation for Amendment 131, dated April 25, 1989, the auxiliary feedwater pump turbine inlet steam pressure interlocks are not required for the AFW trains to be OPERABLE. The purpose of the turbine inlet steam pressure interlocks is to close the auxiliary feedwater pump turbine steam supply valves if a low pressure in a steam admission line exists, indicative of a break in a steam admission line. As stated in the CTS 3/4.7.1.2 Bases issued as part of Amendment 131, the OPERABILITY of the auxiliary feed pump turbine inlet pressure interlocks is required only for high energy line break concerns and does not affect AFW System OPERABILITY. Therefore, these requirements are not necessary to be included in the ITS to provide adequate protection of the public health and safety. Also this change is acceptable because the removed requirements will be adequately controlled in the TRM. The TRM is currently incorporated by reference into the UFSAR, thus any changes to the TRM are made under 10 CFR 50.59, which ensures changes are properly evaluated. This change is designated as a less restrictive removal of detail change because Surveillance Requirements are being removed from the Technical Specifications.

LA03 (Type 4 - Removal of LCO, SR, or other TS requirement to the TRM, UFSAR, ODCM, QAPM, IST Program,or 1iP) CTS 4.7.1.2.1.b.3 requires verifying certain turbine plant cooling water valves and the startup feedwater pump suction and discharge valves are closed. ITS 3.7.5 does not include this Surveillance. This changes the CTS by moving this Surveillance Requirement to the Technical Requirements Manual (TRM).

The removal of this Surveillance Requirement from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The purpose of CTS 4.7.1.2.1 .b.3, as stated in the CTS 3/4.7.1.2 Bases, is to address concerns associated with potential pipe failures in the AFW pump rooms that could occur during operation of the startup feedwater pump. The startup feedwater pump was originally used during a unit startup since the main Davis-Besse Page 5 of 14 Attachment 1, Volume 12, Rev. 0, Page 107 of 461

Attachment 1, Volume 12, Rev. 0, Page 108 of 461 DISCUSSION OF CHANGES ITS 3.7.5, EMERGENCY FEEDWATER (EFW) feedwater pumps are steam driven. However, since the addition of the MDFP train, the MDFP train is the feedwater pump normally used during a unit startup.

Furthermore, closure of these valves is not required for the AFW trains to be OPERABLE during a loss of feedwater event or main steam line break event.

Therefore, this Surveillance is not necessary to be included in the ITS to provide adequate protection of the public health and safety. Also this change is acceptable because the removed Surveillance Requirement will be adequately controlled in the TRM. The TRM is currently incorporated by reference into the UFSAR, thus any changes to the TRM are made under 10 CFR 50.59, which ensures changes are properly evaluated. This change is designated as a less restrictive removal of detail change because a Surveillance Requirement is being removed from the Technical Specifications.

LA04 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 4.7.1.2.1 .c.1 and 4.7.1.2.1 .c.2 require verification that each automatic valve in the AFW flow path actuates to its correct position and each AFW pump starts automatically, respectively, on a Steam and Feedwater Rupture Control Systems (SFRCS) actuation test signal. ITS SR 3.7.5.4 and SR 3.7.5.5 do not state the specific type of signal, but only specify an actual or simulated "actuation" signal. This changes CTS by moving the type of actuation signal (i.e., SFRCS) to the Bases. The change to allow an actual signal is discussed in DOC L06.

The removal of these details, which are related to system design, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement to verify that appropriate equipment actuates upon receipt of an actuation signal.

Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5 of the ITS. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Specification.

LA05 (Type 3 - Removing ProceduralDetails for Meeting TS Requirements or Reporting Requirements) CTS 4.7.1.2.1 .a.1 requires verifying the differential pressure of the AFW pumps are greater than or equal to the required differential pressure at the specified recirculation flow rate. CTS 4.7.1.2.1.c.3 and 4.7.1.2.1 .g.1 require verification that there is a flow path from each auxiliary feedwater pump to both steam generators by pumping water from the Condensate Storage Tank with each pump to both steam generators. They further state that the flow path shall be verified by either steam generator level change or Auxiliary Feedwater Safety Grade Flow Indication, and that the verification of the Auxiliary Feedwater System's flow capacity is not required by these Surveillances. CTS 4.7.1.7.d.1 and 4.7.1.7.f.1 require verification that there is a flow path between the Motor Driven Feedwater Pump System and the Auxiliary Feedwater System by pumping the water from the Condensate Storage Tanks to the steam generators. They further state that the flow path to the steam generators shall be verified by either steam generator level change or Auxiliary Davis-Besse Page 6 of 14 Attachment 1, Volume 12, Rev. 0, Page 108 of 461

Attachment 1, Volume 12, Rev. 0, Page 109 of 461 DISCUSSION OF CHANGES ITS 3.7.5, EMERGENCY FEEDWATER (EFW)

Feedwater Safety Grade Flow Indication, and that the verification of the Motor Driven Feedwater Pump System flow capacity is not required by these Surveillances. ITS SR 3.7.5.2 requires a similar AFW pump differential pressure test as required by CTS 4.7.1.2.1 .a.1, but the requirement that the AFW pumps are at the specified recirculation flow rate is not included. ITS SR 3.7.5.6 requires verification of proper alignment of the required AFW flow paths by verifying flow from the condensate storage tanks to each steam generator. ITS SR 3.7.5.7 requires verification of proper alignment of the required MDFP flow paths by verifying flow from the condensate storage tanks to each steam generator. However the CTS 4.7.1.2.c.3, 4.7.1.2.1 .g.1, 4.7.1.7.d.1, and 4.7.1.7.f.1 requirements on the manner to verify flow and that an actual flow capacity check is not required is not included in the ITS. This changes the CTS by moving the requirements to perform the AFW pump differential pressure test at the specified recirculation flow rate, and to verify the flow path by either steam generator level change or Auxiliary Feedwater Safety Grade Flow Indication and that verification of flow capacity is not required to the Bases.

The removal of these details for performing Surveillance Requirements from the Technical Specifications is acceptable because this type of information is not necessary to be included to provide adequate protection of public health and safety. The ITS retains all necessary requirements to perform an AFW pump differential pressure test and to verify the flow path of each EFW train to both steam generators. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LA06 (Type 4 - Removal of LCO, SR, or other TS requirement to the TRM, UFSAR, ODCM, QAPM, IST Program,or 1iP) CTS 4.7.1.2.1.d provides the Surveillance Requirement for the Auxiliary Feed Pump Turbine Steam Generator Level Control System and requires a CHANNEL CHECK every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , a CHANNEL FUNCTIONAL TEST every 31 days, and a CHANNEL CALIBRATION every refueling interval (24 months). ITS 3.7.5 does not include these requirements.

This changes the CTS by moving these requirements to the Technical Requirements Manual (TRM).

The removal of these Surveillance Requirements from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The purpose of CTS 4.7.1.2.1 .d is to ensure the AFW trains can properly control steam generator water level. The ITS Bases states that the AFW System is capable of supplying water to the steam generator to remove decay heat and other residual heat by delivering at least the minimum required flow rate to the steam generators. The ITS Bases also requires the controls to be OPERABLE. Therefore, these requirements are not necessary to be included in the ITS to provide adequate protection of the public health and safety. Also this change is acceptable because the removed requirements will be adequately controlled in the TRM. The TRM is currently incorporated by Davis-Besse Page 7 of 14 Attachment 1, Volume 12, Rev. 0, Page 109 of 461

Attachment 1, Volume 12, Rev. 0, Page 110 of 461 DISCUSSION OF CHANGES ITS 3.7.5, EMERGENCY FEEDWATER (EFW) reference into the UFSAR, thus any changes to the TRM are made under 10 CFR 50.59, which ensures changes are properly evaluated. This change is designated as a less restrictive removal of detail change because Surveillance Requirements are being removed from the Technical Specifications.

LA07 (Type 4 - Removal of LCO, SR, or other TS requirementto the TRM, UFSAR, ODCM, QAPM, /ST Program, orllP) CTS 4.7.1.2.1.e provides the Surveillance Requirement for the auxiliary feed pump suction pressure interlocks and requires a CHANNEL FUNCTIONAL TEST every 31 days and a CHANNEL CALIBRATION every refueling interval (24 months). ITS 3.7.5 does not include these requirements. This changes the CTS by moving these requirements to the Technical Requirements Manual (TRM).

The removal of these Surveillance Requirements from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The purpose of CTS 4.7.1.2.1 .e is to ensure the AFW suction source can be swapped from the condensate storage tanks to the Service Water System on a low suction header pressure (i.e., on low level in the CSTs). However, LCO 3.7.6, "Condensate Storage Tanks (CSTs)," requires a sufficient water level be maintained in the CSTs to meet the safety analysis makeup water requirements. As stated in the ITS 3.7.6 Bases, this required water level (270,300 gallons) provides sufficient water inventory for 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months at MODE 3 steaming to atmosphere, followed by a cooldown to decay heat removal entry conditions at the design cooldown rate. Furthermore, the CSTs are the primary source of water for the AFW trains. Therefore, these requirements are not necessary to be included in the ITS to provide adequate protection of the public health and safety. Also this change is acceptable because the removed requirements will be adequately controlled in the TRM. The TRM is currently incorporated by reference into the UFSAR, thus any changes to the TRM are made under 10 CFR 50.59, which ensures changes are properly evaluated. This change is designated as a less restrictive removal of detail change because Surveillance Requirements are being removed from the Technical Specifications.

LA08 (Type 3 - Removing ProceduralDetails for Meeting TS Requirements or Reporting Requirements) CTS 4.7.1.7.b.3 requires verifying each manual or power operated valve in the MDFP flow path is capable of being repositioned to the correct position when in MODE 1 < 40% RTP and in MODES 2 and 3. It further clarifies that capable of being repositioned is demonstrated by verifying the presence of handwheels for all manual valves and the presence of either a handwheel or an available power supply for power operated valves. ITS SR 3.7.5.1 requires a similar Surveillance, however the manner in which the capability of repositioning the valves is demonstrated is not included. This changes the CTS by moving the details concerning how to demonstrate the capability to reposition the valves to the Bases.

The removal of these details for performing Surveillance Requirements from the Technical Specifications is acceptable because this type of information is not necessary to be included to provide adequate protection of public health and safety. The ITS retains all necessary requirements to verify the valves are in their proper position or can be aligned to their proper position. Also, this change Davis-Besse Page 8 of 14 Attachment 1, Volume 12, Rev. 0, Page 110 of 461

Attachment 1, Volume 12, Rev. 0, Page 111 of 461 DISCUSSION OF CHANGES ITS 3.7.5, EMERGENCY FEEDWATER (EFW) is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LA09 (Type 3 - Removing ProceduralDetails for Meeting TS Requirements or Reporting Requirements) CTS 4.7.1.7.c.1 requires verifying proper operation of each power operated and automatic valve in the MDFP train flow path to the AFW System. CTS 4.7.1.7.c.2 requires verifying the MDFP starts from the control room. ITS SR 3.7.5.3 requires operating the MDFP train. This changes the CTS by moving the details of how the Surveillance is conducted to the Bases.

The removal of these details for performing Surveillance Requirements from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement to periodically operate the MDFP train. Also, this change is acceptable because these types of procedural details will be adequately controlled in the ITS Bases.

Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications.

LA1 0 (Type 4 - Removal of LCO, SR, or other TS requirement to the TRM, UFSAR, ODCM, QAPM, /ST Program,or lIP) CTS 4.7.1.7.d.2 provides the Surveillance Requirement for the MDFP lube oil interlocks and requires verifying proper operation of the interlocks at least once each refueling interval (24 months).

ITS 3.7.5 does not include this Surveillance Requirement. This changes the CTS by moving this requirement to the TRM.

The removal of this Surveillance Requirement from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The purpose of CTS 4.7.1.7.d.2 is to ensure the MDFP lube oil interlock is functioning properly. The MDFP lube oil is provided to ensure the MDFP is not started unless sufficient lube oil pressure is established for pump operation.

ITS SR 3.7.5.3 requires operating the MDFP train every 92 days. In addition, the MDFP train is normally used to provide feedwater to the steam generators during a reactor startup until the reactor is at sufficient power to support the turbine driven main feedwater pumps. Therefore, operation of the MDFP train during this Surveillance and under these routine conditions would provide the opportunity to detect a problem with the MDFP lube oil interlocks that would inadvertently not allow the MDFP to be started. In addition, this interlock is for pump protection only. Therefore, this Surveillance Requirement is not necessary to be included in the ITS to provide adequate protection of the public health and safety. Also this change is acceptable because the removed requirements will be adequately controlled in the TRM. The TRM is currently incorporated by Davis-Besse Page 9 of 14 Attachment 1, Volume 12, Rev. 0, Page 111 of 461

Attachment 1, Volume 12, Rev. 0, Page 112 of 461 DISCUSSION OF CHANGES ITS 3.7.5, EMERGENCY FEEDWATER (EFW) reference into the UFSAR, thus any changes to the TRM are made under 10 CFR 50.59, which ensures changes are properly evaluated. This change is designated as a less restrictive removal of detail change because a Surveillance Requirement is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L01 (Category4 - Relaxation of Required Action) CTS 3.7.1.2 Action a requires an inoperable train of auxiliary feedwater be restored to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for any condition of inoperability. ITS 3.7.5 ACTION A permits 7 days to restore the steam supply valve to an OPERABLE status when an AFW train is inoperable due to one inoperable steam supply valve or if an AFW train is inoperable in MODE 3 following refueling. This changes the CTS by extending the restoration time from 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to 7 days for an inoperable AFW train due to these conditions.

The purpose of CTS 3.7.1.2 Action a is to provide a limit on the length of time the unit may remain in the MODES of Applicability with one AFW train inoperable.

This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified condition, considering the OPERABLE status of redundant systems and features. This includes the capacity and capability of remaining systems and features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the repair period. One steam supply for the inoperable AFW train remains OPERABLE, which will provide the required steam flow for the train to produce the design flow rate and therefore, the capability to mitigate most analyzed accidents is preserved. An inoperable AFW train in MODE 3 following a refueling is acceptable because the remaining AFW train and the MDFP train remain OPERABLE and the decay heat in the Reactor Coolant System is low. The probability of an event occurring during the extended outage time that would require the inoperable steam supply or AFW train to function is low. The ITS ACTION provides adequate assurance that the AFW trains and MDFP trains will continue to meet the assumptions stated in the safety analyses for the EFW to mitigate postulated accidents. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L02 (Category4- Relaxation of RequiredAction) CTS 3.7.1.2 Action c states that if steam generator inlet valve AF 599 or AF 608 is closed, to re-open the closed valve within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or be in HOT STANDBY (MODE 3) within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and HOT SHUTDOWN (MODE 4) within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . When either of these two valves is closed during normal operations, both AFW trains and the MDFP train are inoperable. However, no other conditions describing inoperability of the AFW trains are provided. Thus, if the two AFW trains are inoperable for other reasons, CTS 3.0.3, which requires a unit shutdown to commence within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , must be entered. ITS 3.7.5 ACTION E provides specific actions when all three EFW trains are inoperable, and requires action to be initiated immediately to restore one EFW train to OPERABLE status. In addition, the Note to ITS 3.7.5 Required Davis-Besse Page 10 of 14 Attachment 1, Volume 12, Rev. 0, Page 112 of 461

Attachment 1, Volume 12, Rev. 0, Page 113 of 461 DISCUSSION OF CHANGES ITS 3.7.5, EMERGENCY FEEDWATER (EFW)

Action E.1 states that LCO 3.0.3 and all other LCO Required Actions requiring MODE changes are suspended until one EFW train is restored to OPERABLE status. This changes the CTS by providing an Action to maintain the unit in the current MODE when both AFW trains and the MDFP train are inoperable, and require actions to be immediately initiated to restore one of the EFW trains to OPERABLE status, in lieu of requiring a unit shutdown within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

The purpose of the CTS 3.7.1.2 Actions is to place the unit in a MODE in which the LCO is not applicable when both AFW trains are inoperable. However, ifthe MDFP train is also inoperable, no EFW is available. In this situation, the unit is in a seriously degraded condition with no safety related means for conducting a cooldown, and only limited means for conducting a cooldown with non-safety grade equipment. In such a condition, the unit should not be perturbed by any action, including a power change, which might result in a trip. Thus, Required Action E.1 is modified by a Note indicating that LCO 3.0.3 and all LCO Required Action requiring MODE changes are suspended until at least one EFW train is restored to OPERABLE status. Furthermore, the seriousness of this condition requires that action be started immediately to restore at least one EFW train to OPERABLE status. Therefore, the ITS 3.7.5 Required Action E.1 provides the appropriate compensatory measures when three EFW trains are inoperable and are considered acceptable. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L03 (Category 7- Relaxation Of Surveillance Frequency, Non-24 Month Type Change) CTS 4.7.1.2.1.a.1 states that each AFW train shall be demonstrated OPERABLE at least once every 92 days "on a STAGGERED TEST BASIS" by verifying the differential pressure of each AFW pump is greater than or equal to the required differential pressure at the specified recirculation flow rate.

CTS 4.7.1.2.1 .b.1 requires verifying each AFW train valve (power operated or automatic) in the flow path is in its correct position at least once per 31 days "on a STAGGERED TEST BASIS." ITS SR 3.7.5.2 and SR 3.7.5.1 require similar tests every 92 days and every 31 days, respectively, but do not include the "STAGGERED TEST BASIS" requirement. This changes the CTS by deleting the requirement to test on a STAGGERED TEST BASIS.

The purpose of CTS 4.7.1.2.1 .a.1 and 4.7.1.2.1 .b.1 is to demonstrate the OPERABILITY of the AFW trains. This change is acceptable because the new Surveillance Frequencies provide an acceptable level of equipment reliability.

This change deletes the requirement to perform CTS 4.7.1.2.1 .a.1 and 4.7.1.2.1.b.1 on a STAGGERED TEST BASIS. The intent of a requirement for staggered testing is to increase reliability of the component/system being tested.

A number of studies have been performed that demonstrate that staggered testing has negligible impact on component reliability. These analytical and subjective analyses have determined that staggered testing 1) is operationally difficult, 2) has negligible impact on component reliability, 3) has no impact on failure frequency, 4) introduces additional stress on components potentially causing increased component failures rates and component wearout, 5) results in reduced redundancy during testing, and 6) increases likelihood of human error by increasing testing intervals. Therefore, the AFW trains staggered testing requirements have been deleted. This change is designated as less restrictive Davis-Besse Page 11 of 14 Attachment 1, Volume 12, Rev. 0, Page 113 of 461

Attachment 1, Volume 12, Rev. 0, Page 114 of 461 DISCUSSION OF CHANGES ITS 3.7.5, EMERGENCY FEEDWATER (EFW) because the intervals between performances of the Surveillances for the two AFW trains can be larger or smaller under the ITS than under the CTS.

L04 (Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria)

CTS 4.7.1.2.1 .b.1 requires the verification that each power operated or automatic valve in the AFW flow path is in its correct position. CTS 4.7.1.2.1 .b.2 requires the verification that all manual valves in the auxiliary feedwater pump suction and discharge lines that affect the system's capacity to deliver water to the steam generator are locked in their proper position. CTS 4.7.1.7.b.1 requires the verification that all manual valves in the Motor Driven Feedwater Pump suction and discharge lines that affect the system's capacity to deliver water to the steam generator are locked in their proper position. CTS 4.7.1.7.b.2 requires the verification that each power operated valve in the Motor Driven Feedwater Pump flow path is in its correct position when > 40% RTP. CTS 4.7.1.7.b.3 requires verifying each manual or power operated valve in the MDFP flow path is capable of being repositioned to the correct position when in MODE 1 < 40% RTP and in MODES 2 and 3. ITS SR 3.7.5.1 requires verifying that each EFW manual, power operated, and automatic valve in each water flow path and in both steam supply flow paths to the AFW pumps, that is not locked, sealed, or otherwise secured in position, is in the correct position (or can be aligned as allowed by the Note to SR 3.7.5.1). This changes the CTS by only requiring the verification of EFW valves that are not locked, sealed or otherwise secured in position.

The purpose of CTS 4.7.1.2.1.b.1, 4.7.1.2.1.b.2, 4.7.1.7.b.1, 4.7.1.7.b.2, and 4.7.1.7.b.3 is to verify that the automatic, power operated, and manual valves in the AFW and MDFP flow paths are aligned to the correct position (or can be aligned under certain conditions). This change is acceptable because the relaxed Surveillance Requirement acceptance criteria are not necessary for verification that the equipment used to meet the LCO can perform its required functions. The verification of valves that are aligned and secured into the required safety position is unnecessary. Valves secured in the safety position will satisfy the safety analyses assumptions for the mitigation of analyzed accidents. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

L05 (Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria)

CTS 4.7.1.2.1.c.1 requires that each AFW automatic valve in the flow path actuate to the correct position on an SFRCS actuation signal. ITS SR 3.7.5.4 requires a similar Surveillance. However, it is modified by a Note that states the SR is not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after reaching 800 psig in the steam generators. This changes the CTS by providing an allowance to delay the performance of required testing without requiring the associated AFW train to be declared inoperable.

The purpose of CTS 4.7.1.2.1 .c.1 is to ensure the AFW train is OPERABLE in MODES 1, 2, and 3. The allowance provides for entry into MODE 3 before requiring the testing of the automatic valves. This change is acceptable because the relaxed Surveillance Requirement acceptance criteria are not necessary for verification that the equipment used to meet the LCO can perform its required functions. This change is necessary because the steam generator pressure may Davis-Besse Page 12 of 14 Attachment 1, Volume 12, Rev. 0, Page 114 of 461

Attachment 1, Volume 12, Rev. 0, Page 115 of 461 DISCUSSION OF CHANGES ITS 3.7.5, EMERGENCY FEEDWATER (EFW) be insufficient in MODE 4 to properly test the AFW train. One manner of performing this SR would be to combine this test with the test required by CTS 4.7.1.2.1 .c.2, which tests the automatic start of the AFW pump using the same signal as is required to test the automatic valves. The majority of SRs demonstrate equipment is, in fact, OPERABLE when the tests are performed.

Inconsistent testing results may result if testing of the AFW train is required before establishing a sufficient steam generator pressure. The allowance will permit the establishment of stable unit conditions and sufficient steam generator pressure to test the AFW pump and valves and will allow an accurate and consistent method for the testing. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

L06 (Category6 - Relaxation Of Surveillance Requirement Acceptance Criteria)

CTS 4.7.1.2.1 .c.1 and 4.7.1.2.1 .c.2 require verification that each automatic valve in the AFW flow path actuates to its correct position and each AFW pump starts automatically, respectively, on an SFRCS actuation test signal. ITS SR 3.7.12.3, which performs a similar test, specifies that the signal may be from either an "actual" or simulated (i.e., test) signal. This changes the CTS by explicitly allowing the use of either an actual or simulated signal for the test.

The purpose of CTS 4.7.1.2.1 .c.1 and 4.7.1.2.1 .c.2 is to ensure the AFW trains actuate upon receipt of an actuation signal. This change is acceptable because the relaxed Surveillance Requirement acceptance criteria are not necessary for verification that the equipment used to meet the LCO can perform its required functions. Equipment cannot discriminate between an "actual," "simulated," or "test" signal and, therefore, the results of the testing are unaffected by the type of signal used to initiate the test. This change allows taking credit for unplanned actuation if sufficient information is collected to satisfy the Surveillance test requirements. The change also allows a simulated signal to be used, if necessary. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

L07 (Category5- Deletion of Surveillance Requirement) CTS 4.7.1.2.f and 4.7.1.7.e (including footnote *) describe tests that must be performed following modification or repairs to the AFW trains and MDFP trains, respectively.

ITS 3.7.5 does not include these testing requirements. This changes the CTS by deleting these post-maintenance Surveillance Requirements.

The purpose of CTS 4.7.1.2.f and 4.7.1.7.e is to verify the OPERABILITY of the AFW trains and MDFP train following completion of modifications to the AFW or MDFP trains that may alter the flow characteristics. This change is acceptable because the deleted Surveillance Requirements are not needed to verify that the equipment used to meet the LCO can perform its required functions. Thus, appropriate equipment continues to be tested in a manner and at a frequency necessary to give confidence that the equipment can perform its assumed safety function. Any time the OPERABILITY of a system or component has been affected by repair, maintenance, modification, or replacement of a component, post-maintenance testing is required to demonstrate the OPERABILITY of the system or component. This is described in the Bases for ITS SR 3.0.1 and Davis-Besse Page 13 of 14 Attachment 1, Volume 12, Rev. 0, Page 115 of 461

Attachment 1, Volume 12, Rev. 0, Page 116 of 461 DISCUSSION OF CHANGES ITS 3.7.5, EMERGENCY FEEDWATER (EFW) required under ITS SR 3.0.1. The OPERABILITY requirements for the AFW System and MDFP train are described in the Bases for ITS 3.7.5. Post-maintenance testing will continue to be performed and an explicit requirement in the Technical Specifications is not necessary. This change is designated as less restrictive because Surveillances which are required in the CTS will not be required in the ITS.

L08 (Category 5 - Deletion of Surveillance Requirement) CTS 4.7.1.7.d.3 requires verifying, at least once each refueling interval (i.e., 24 months), proper operation of manual valves by shifting the MDFP between the Main Feedwater System and the AFW System. ITS 3.7.5 does not include this specific Surveillance Requirement. This changes the CTS by deleting a Surveillance Requirement.

The purpose of CTS 4.7.1.7.d.3 is to demonstrate the capability of shifting the discharge flow path of the MDFP from the Main Feedwater System to the AFW System. The OPERABILITY of the MDFP train, as described in the ITS 3.7.5 Bases, requires it to be capable of providing flow to the AFW System flow path, since this is the flow path for the emergency feedwater mode. This change is acceptable because this capability is already demonstrated at least once every 24 months through routine operation of the MDFP train. The MDFP train is normally used to supply feedwater flow through the Main Feedwater System flow path during a reactor startup until reactor power is sufficient to support operation of the turbine driven Main Feedwater pumps. At that time, the MDFP is realigned to provide flow to the AFW System. ITS SR 3.7.5.1 requires the MDFP train valves to be in their correct position when in MODE 1 > 40% RTP. Prior to that point, the Note to the SR allows the valves to be in the non-correct position provided they are capable of being realigned to the correct position. Thus, following a reactor startup the valves will be required to be repositioned from the Main Feedwater System to the AFW System in order to meet ITS SR 3.7.5.1.

Therefore, it is unnecessary to specify an additional Surveillance Requirement to prove this capability. This change is designated as less restrictive because a specific Surveillance Requirement in the CTS is not included in the ITS.

Davis-Besse Page 14 of 14 Attachment 1, Volume 12, Rev. 0, Page 116 of 461

Attachment 1, Volume 12, Rev. 0, Page 117 of 461 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 12, Rev. 0, Page 117 of 461

Attachment 1, Volume 12, Rev. 0, Page 118 of 461 CTS EFWe 37.5 0

3.7 PLANT SYSTEMS wo Auxiliary Feedwater (AFW) trains; and he Motor Driven Feedwater Pump (MDFP) train. 0 3.7.5 Emergency Feedwater (EFVW rn r ,F traisting of:b

'lhree* EFW trains shall be OPERABLF.*

3.7.1.2, 3.7.1.7 LCO 3.7.5 00 DOC M04 the MDFP train Only ne EFW tair, which includes a be OPERABLE in MODE 4.

driven Kur is required to 0

APPLICABILITY: MODES 1, 2, and 3, MODE 4 when steam generator is relied upon for heat removal.

ACTIONS S- L 3- - -NOTE-1.

DOC A02 LCO 3.0.4.b is not applicable when entering MODE 1.

0 CONDITION REQUIRED ACTION COMPLETION TIME 4

t DOC L01 A. One stea supply to A.1/ Restore laffected 94iuipmentI

[turbine driv,6n EF__J oeto OPERABLE status.

1pump ino rable I~l~urbine d rain Sinoperable due to one ORT inoperable steam supply

--- NOTE----

Only applicable if MODE 2 has not been entered following refueling.

One turbine d*ren EFW p inoperable in 0

MODE 3 following refueling.

L _______________________________ L BVVOG STS 3.7.5-1 Rev. 3.1, 12/01/05 Attachment 1, Volume 12, Rev. 0, Page 118 of 461

Attachment 1, Volume 12, Rev. 0, Page 119 of 461 CTS EFW tern 3.7:5 0 ACTIONS (continued)

CONDITION REQUIRED ACTION { COMPLETION TIME 3.7.1.2 Action a. B. One EFVNtrain B.1 Restore EFVV train to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 3.7.1.7 Action inoperable gfor reasons other than Condition A1 OPERABLE status.

0 in MODE 1,2, or 3. NSERT

)

3.7.1.2 Action a, L*Required Action and 1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 3.7.1.7 Action. associated Completion DOC M02 Time of Condition A AND D Mff nmet.

.2 Be in MODE 4.

[71]

O TSTF

-12 Two E-FVV trains for reasons other than Condition C inoperable in MODE 1, 2, or 3. 0 DOC L02 j MThreeM EFW trains inoperable in MODE 1, 2, or 3.

1 NOTE -..........

LCO 3.0.3 and all other LCO Required Actions requiring MODE changes

.----- TSTF

-42 are suspended until one EFVN train is restored to OPERABLE status.

Initiate action to restore Immediately one EFVVtrain to OPERABLE status.

DOC M04 Required train f Initiate action to restore Immediately 4-1TSTFQ inoperable in MODE 4. E train to OPERABLE Fstatus.

BWOG STS 3.7.5-2 Rev. 3.1, 12/01/05 Attachment 1, Volume 12, Rev. 0, Page 119 of 461

Attachment 1, Volume 12, Rev. 0, Page 120 of 461 3.7.5 CTS

-2 INSERT 1 i

DOC M02 C. Onelturbine dven EFWItrain inoperable due to one C.1 Restore the steam supply to the tur me

[2o 48M hours 00 inoperable steam supply. [ 0 train to Aý 0 OPERABLE status.

AND MDFP OR FMotor dr en EFW train MFP 0 inoperable. C.2 Restore the o Fdrive'EFW train to

[2 o 48R hours 00 OPERABLE status.

Insert Page 3.7.5-2 Attachment 1, Volume 12, Rev. 0, Page 120 of 461

Attachment 1, Volume 12, Rev. 0, Page 121 of 461 CTS EFW t-rn 3.7.5 0

SURVEILLANCE REQUIREMENTS SURVEILLANCE 1 FREQUENCY 4.7.1.2.1.b.1, SR 3.7.5.1 Verify each EFW manual, power operated, and 31 days 0 4.7.1.7.b.2, 4.7.1.7.b.3 INSRT 2 E :

automatic valve in each water flow path and in both steam supply flow paths to thelsteam turne driven -

0 pumps, that is not locked, sealed, or otherwise secured in position, is in the correct position.

7_

4.7.1.2.1.a.1 SR 3.7.5.2 ------------------------...... NOTE -.-.---------------

Not required to be performedfor the, u e drivenj EF'V mps,I until M24M hours after reaching J80OM] psig in the steam generators. (DO)

Verify the developed head of each IEFN pump at the flow test point is greater than or equal to the acrd nce

- ththe service 00, required developed head. tTesting rogram

- +

~T3 4.7.1.2.1.c.1 SR S----- - - --- NOTF_ --.... ..............

[ Not required to be performed until 641 hours0.00742 days 0.178 hours 0.00106 weeks 2.439005e-4 months after reaching OO*]psig in the steam generators.

0

12. Not required tso-de met in MODE 4.1 (D

0D(

Verify each Iautomatic valve that is not locked, [gmonths sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal.

4.7.1.2.1.c.2 SR 3.7.5._.

W

---- . -........ NOTE---

Not required to be performed until [24Jhours after reaching PQ00psig in the steam 00 D generators.

12. Not required je met in MODE 4.1 0G Verify each mpum* p starts automatically on an gmonths actual or simulated actuation signal.

BWOG STS 3.7.5-3 Rev. 3.1, 12/01/05 Attachment 1, Volume 12, Rev. 0, Page 121 of 461

Attachment 1, Volume 12, Rev. 0, Page 122 of 461 3.7.5 INSERT 2 0

4.7.1.7.b.3

NOTE ------------

In MODE 1 < 40% RTP and MODES 2, 3, and 4, the MDFP train valves are allowed to be in the non-correct position, provided the valves are capable of being locally realigned to the correct position.

0 INSERT 3 4.7.1.7.c SR 3.7.5.3 ------------------------- NOTE ------------

Not required to be performed until 73 hours8.449074e-4 days 0.0203 hours 1.207011e-4 weeks 2.77765e-5 months after MDFP train is aligned to the AFW System.

Operate the MDFP train. 92 days Insert Page 3.7.5-3 Attachment 1, Volume 12, Rev. 0, Page 122 of 461

Attachment 1, Volume 12, Rev. 0, Page 123 of 461 CTS EFWt 3.7.5 0

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY 4.7.1.2.1.c.3, Verify proper alignment of the required WEF/Wflow S R 3.7.51~

4.7.1.2.1.g.1 paths by verifying l[valve anmennlovlfrom the

_j condensate storage tanlto each steam generator. whenever plant has been in MODE 5, MODE 6, or defueled for a cumulative period of > 30 days SR 3.7.5.6 [Pe rm a CHANNEL FUNCTIONAL TEST for the 31 days]

pump suction pressure interlocks.

0 SR 3.7.5.7 /Perform a CHANNEL CALIBRATION for the FW [18] months]

pump suction pressure interlocks.

INSERT 4 0 BWOG STS 3.7.5-4 Rev. 3.1, 12/01/05 Attachment 1, Volume 12, Rev. 0, Page 123 of 461

Attachment 1, Volume 12, Rev. 0, Page 124 of 461 3.7.5 CTS INSERT 4 0

4.7.1.7.d.1, SR 3.7.5.7 Verfiy proper alignment of the required Prior to entering 4.7.1.7.f.1 MDFP flow paths by verifying flow from the MODE 3 following condensate storage tanks to each steam refueling or generator. whenever plant has been in MODE 5, MODE 6, or defueled for a cumulative period of > 30 days Insert Page 3.7.5-4 Attachment 1, Volume 12, Rev. 0, Page 124 of 461

Attachment 1, Volume 12, Rev. 0, Page 125 of 461 JUSTIFICATION FOR DEVIATIONS ITS 3.7.5, EMERGENCY FEEDWATER (EFW)

1. The Davis-Besse design for Emergency Feedwater includes the Auxiliary Feedwater (AFW) System and the Motor Driven Feedwater Pump (MDFP); there is no "Emergency Feedwater System." The AFW System consists of two turbine driven pumps; the AFW System does not include any motor driven pumps. Therefore, the LCO title has been changed to delete the word "System" and the LCO has been modified to include both types of Emergency Feedwater trains, the AFW trains and the MDFP train. This is consistent with the current licensing basis. Furthermore, since the AFW System includes only turbine driven pumps, any reference to "turbine driven EFW," "turbine driven EFW pump," or "steam turbine driven" has been deleted and replaced with the term "AFW train" or "AFW," as applicable. Also, the term "motor driven EFW" has been replaced with "MDFP" consistent with the Davis-Besse terminology. Due to the above described change, the words in the LCO Note describing an EFW train have been modified to clearly state the described EFW train is the MDFP train and the term EFW train in ISTS ACTION F has been changed to MDFP train.

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

3. These bracketed Surveillances have not been included in the Davis-Besse ITS, as described in the Discussion of Changes for ITS 3.7.5.

4. The Davis-Besse design includes two turbine driven AFW pumps. Therefore, the number "One" has been added to the first Condition of ISTS 3.7.5 Condition A for clarity.

5. The term "affected equipment" in ISTS 3.7.5 Required Action A.1 has been changed to "AFW train" for clarity since the affected equipment in this ACTION is the AFW train.

6. ISTS SR 3.7.5.1 has been modified by the addition of a Note. The Note applies to the MDFP train, and is consistent with the current licensing basis. At Davis-Besse, the MDFP train is also used during a unit startup to supply feedwater until the turbine driven main feedwater pumps can be put in service. When operating in this mode, the MDFP is aligned to the Main Feedwater System, not the AFW System (the emergency feedwater alignment).

7. ISTS SR 3.7.5.2 provides the testing requirements for the EFW pumps. This Surveillance has been modified to only apply to the AFW pumps (the turbine driven pumps) and new SR 3.7.5.3 has been added to provide the Davis-Besse specific Surveillance for the MDFP. Due to this addition, the term "for the turbine driven EFW pumps," in the SR 3.7.5.2 Note is not needed and has been deleted. Subsequent SRs have been renumbered.

8. The proper Davis-Besse Surveillance Frequency has been provided.

9. The MDFP train is not an automatically actuated train; it is manually actuated.

Therefore, ISTS SR 3.7.5.3 and SR 3.7.5.4 have been modified to only apply to the AFW trains (which are automatically actuated), consistent with current licensing basis. In addition, since the AFW trains are not required to be OPERABLE in MODE 4, the Notes to the two SRs exempting the SRs in MODE 4 (ITS SR 3.7.5.4 Davis-Besse Page 1 of 2 Attachment 1, Volume 12, Rev. 0, Page 125 of 461

Attachment 1, Volume 12, Rev. 0, Page 126 of 461 JUSTIFICATION FOR DEVIATIONS ITS 3.7.5, EMERGENCY FEEDWATER (EFW)

Note 2 and ITS SR 3.7.5.5 Note 2) are unnecessary and have been deleted. Due to these deletions, the Note number assigned to the remaining Note in each of the SRs has been deleted, consistent with the format of the ISTS.

10. The Frequency for performing ISTS SR 3.7.5.5 is different for the AFW trains and the MDFP trains. The MDFP train can be tested in MODE 4, thus the allowance to not test the MDFP until after entering MODE 3 is not needed. Therefore, the Surveillance has been modified to only apply to the AFW trains and new ITS SR 3.7.5.7 has been added to provide the Davis-Besse specific Surveillance Frequency for the MDFP. In addition, Davis-Besse is also required to perform these Surveillances every refueling interval (24 months). This Frequency has been maintained in the ITS (through the use of the term "following refueling") since the ISTS Frequency may not ensure a test is performed every 24 months. (The Frequency only requires performance if the unit has been in MODE 5 or 6 or defueled for a cumulative time period of greater than 30 days, and it is possible for Davis-Besse to complete a refueling outage in less time than 30 days.)

11. Changes made to be consistent with changes made to another Specification (i.e.,

Davis-Besse has two condensate storage tanks).

Davis-Besse Page 2 of 2 Attachment 1, Volume 12, Rev. 0, Page 126 of 461

Attachment 1, Volume 12, Rev. 0, Page 127 of 461 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 12, Rev. 0, Page 127 of 461

Attachment 1, Volume 12, Rev. 0, Page 128 of 461 All changes are u n le s s ot h e rw is e n o t edPE FW t 3 . .

B 3.7.5 B 3.7 PLANT SYSTEMS B 3.7.5 Emergency Feedwater (EFW) tr 0 BASES INSERT 1 -----

BACKGROUND The EFW Sstem auto tically supplies feed ter to the sfeamr Iigenerato to remove 0ecay heat from the eactor Cook(nt System (RCS) pon the 1o of normal feedwate upl I.The pumps take suction Ithrougn 5eparate and i epen ent iction lineslfrom the condensate storage tanKk(CST (LCO 3.7.6, "Condensate Storage Tank CS )"), and pump to the steam generator secondary side through the

~jJ-.r-EAnozzles. The steam generators function as a heat sink for core decay heat. The heat load is dissipated by releasing steam to the atmosphere from the steam generators via the main steam safety valves (MSSVs) (LCO 3.7.1, "Main Steam Safety Valves (MSSVs)"), or atmospheric vent valvesl(AVVs) (LCO 3.7.4. "Atmosphefic Vent Valvesl A s)". e main condenser s available, steam mayb/ released via efh--Turbin)6 Bypass System an recirculated to the CST.

I[The following *ystem description is provided -s an example. Acul AFW Isystem descrotion should be provided by thwspecific unit.. The E provides sa a nominal ystem consis o 100% WO turbine capacityl, nriverandErvWNpumps, each of which o oenonsatety~rade moto~fl~n MOWFE pum . The-steam turbine drivenEWpumps receive steam from F either of the two main steam headers, upstream of the main steam wate-ter via two isolation valves (MSIVs). The E ystem supplies corn neaaer lheaders, capable of feeding either or steam generatoru. The 100% capacity each is sufficient to remove decay heat and cool the unit to $ecay Ieat Femoval Eyste (DH+R entry conditions. The [E!yýstem normally receives a supply of water from the CSJ. A safety grade source of water is also supplied by 5 the Service Water System (SWS). Automatic valves on the supply piping open on low pressure in the supply piping to transfer the water supply from the CST to the SWS. A third source of water can be supplied byAFW E[ manuay aigning the fire protection header to the ump suction.D Thus, the requir ments for diversity iymotive power sou s for the EFW System are t.

eEFW

is capable of supplying feedwater to the steam generators during normal unit startup, shutdown, and hot standby conditions.

M EFW t is designed to supply sufficient water to cool the unit to L IV ntry conditions with steam being released through the/AD s on COnsdnser.

MSSVs or atmospheric vent valves BWOG STS B 3.7.5-1 Rev. 3.1, 12/01/05 Attachment 1, Volume 12, Rev. 0, Page 128 of 461

Attachment 1, Volume 12, Rev. 0, Page 129 of 461 B 3.7.5 0 INSERT 1 Emergency Feedwater (EFW) consists of two Auxiliary Feedwater (AFW) trains and the Motor Driven Feedwater Pump (MDFP) train.

0 INSERT 2 The AFW System provides a safety related source of feedwater to the secondary side of the steam generators in the event of a loss of normal feedwater flow to remove reactor decay heat.

0 INSERT 3 The MDFP train provides feedwater to the steam generators during normal plant startup and shutdown. The MDFP train is also designed to provide a backup supply of feedwater to the steam generators in the event of a total loss of both AFW and main feedwater (MFW). The MDFP train can be aligned to take suction from the condensate storage tanks, deaerator storage tanks, or the SWS. The MDFP discharge can be aligned to either the AFW System or the MFW System. During plant operation when reactor power is > 40% RTP, the MDFP train is aligned as an EFW train and is capable of delivering water to both steam generators. In addition, since the MDFP uses the AFW flowpaths to discharge to the steam generators, the position of the steam generator inlet valves affects the MDFP in addition to the AFW pumps.

The MDFP train is non-safety related and provides a diverse means of supplying emergency feedwater to the steam generators.

Insert Page B 3.7.5-1 Attachment 1, Volume 12, Rev. 0, Page 129 of 461

Attachment 1, Volume 12, Rev. 0, Page 130 of 461 I

All changes are unless otherwise noted 9 EFW tr 0

B 3.7.5 BASES BACKG ROUND (continued) AFW System TThe Eti'ctuates automatically on/low steam gouierator level, low steamj generator press , or loss of four reactor coo ant pumps.

M EFW is discussed in thefSAAR, Sections 19.2.71MandR*9.2.8M (Refs. 1 and 2, respectively).

0 APPLICABLE The

/normal System mitigates the consequences of any event with a loss of feedwater.

SAFETY ANALYSES The design basis of the System is to supplywater to the steam

_generator to remove decay heat and other residual heat by delivering at A least the minimum required flow rate to the steam generators at pressures corresponding to the lowest stearr4enerator safety valve set pressure plus 3%.

In addition, the System must supply enough makeup water to replace steam generator seconda inventory being lost as steam as the unit cools to MODE 4 conditions. Ifficient EFW flow must als be_

availa e to account~for flow loss such as pump recirculatior/an li 0 Ibre s.

The limiting Design Basis Accidents (DBAs) and transients for the U System are as follows:

a line break ( and

b. Loss of main feedwater.

In addition, the minimum available [E*flow and system characteristics are serious considerations in the analysis of a small break loss of coolant accident.

FAW SThe *e System design is such that it can perform its function following a loss of the turbine driven main feedwater pumps or an k, combined 0 loss of Inormal opraserve electria power INSERT 5 \.lffItýt The [-I-System satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii)o]

rand the MDFP train satisfies Criterion 4 of 10 CFR 50.36(c)(2)(ii).

BVWOG STS B 3.7.5-2 Rev. 3.1, 12/01/05 Attachment 1, Volume 12, Rev. 0, Page 130 of 461

Attachment 1, Volume 12, Rev. 0, Page 131 of 461 B 3.7.5 0 INSERT 4 a Steam and Feedwater Rupture Control System (SFRCS) actuation signal (i.e., Main Steam Line Pressure - Low, Feedwater/Steam Generator Differential Pressure - High, Steam Generator Level - Low, and Loss of RCPs).

0 INSERT 5 The MDFP train is not credited in any accident analysis; however in the event of a line break in the steam supply piping of one AFW pump turbine and a single failure in the redundant AFW train, the MDFP train is capable of providing emergency feedwater to the steam generators.

Insert Page B 3.7.5-2 Attachment 1, Volume 12, Rev. 0, Page 131 of 461

Attachment 1, Volume 12, Rev. 0, Page 132 of 461 All changes are unless otherwise noted 9 EFW 0

B 3.7.5 BASES LCO This LCO provides assurance that f] EFVV will perform its design safety function to mitigate the consequences of accidents that (consisting of two could result in overpressurization of the reactor coolant pressure *the and ,tria WMDFP train) boundary.. frhreenM enEFW pumps-rtwo d iverse train e* thM trin required to be OPERABLE to ensure the availability of eat removal capability for all events accompanied by a loss of offsite power and a single failure. lT'his is accomplished by powering twopumps by steam driven turbines supplied with steam from a source not isolated by the closure of the MSIVs, and onekump from a power source that, in the event of loss of offsite power, supplied by emergency diesel mdriven generator.m a ea EFWVV is considered to be OPERABLE when the components and flow paths required to provide EFW flow to the steam generators are OPERABLE. This requires that'thepwo lturbine- EFVV pumpH be OPERABLE with redundant steam supplies from each of the main st 0

ieptherabe steam generator lines upstream of the MSIVs ancroapable of supplying EFW flow to i e MDFP i when a (except is i eand ssted) isolated) of theLf* steam generatorsP, The Inonsafety grademoE pu and [t ] associated flow path]to the j7,System~are[jalso 0@

required to be OPERABL . The piping, valves, instrumentation, and controls in the required flow paths shall also be OPERABLE. The primary LAFWJ o0 and capable of supplying flow to and secondary sources of water to F EFW t are required to be both steam generators (except OPERABLE. The associated flow paths from E EFW t primary when a steam generator is and secondary sources of water to all EFW pumps also are required to be inoperable and isotated)

MOPERABLE.

The LCO is modified by a Note indicating that EH -ta include a motordriven EF-V pumprn is required in MODE 4. This is c-h-]

0 because of reduced heat removal requirement, the short duration of MODE 4 in which feedwater is required, and the insufficient steam supply available in MODE 4 to power the lturbine*driven pump.-W - VEE APPLICABILITY In MODES 1, 2, and 3, Wt EFW tis required to be OPERABLE and to function in the event that the main feedwater is lost. In addition, e EFW eis required to supply enough makeup water to replace the steam generator secondary inventory lost as the unit cools to MODE 4 conditions.

In MODE 4, Mwh RCS temperature above [7,42]7, thel EFW be used for heat removal via the steam generators. In MODE 4, the t may 0

steam generators are used for heat removal until the DHR System is in operation-In MODES 5 and 6, the steam generators are not used forF'T andft e 0 EFW t is not required. hemovIJ-.

BWOG STS B 3.7.5-3 Rev. 3.1, 12/01/05 Attachment 1, Volume 12, Rev. 0, Page 132 of 461

Attachment 1, Volume 12, Rev. 0, Page 133 of 461 I

All changes are EFW t B 3.7.5 0

BASES ACTIONS A Note prohibits the application of LCO 3.0.4.b to an inoperable EFW train when entering MODE 1. There is an increased risk associated with entering MODE 1 with EFVV inoperable and the.provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

dteo to one inoperable due a inoperabilityo"lof Z For theth/7dy steam supply the 7 day Comple redundant steam supply AFW train i postulated events an b. For the inoperability o urbine d umr while in MODE 3 immediately subsequent to a refueling, the 7 day Completion Time is 5 addn freasonable .... due to the minimal decay heat levels in this situation. eeithertai In or--- tditon the]

or c. the inoperability of a steam* m*uto t-e-ur i-e river an AFW train!

du, o one!i.no .pera...

b., . ,=,,,7 7to oniopraan Pd.u.e inoperable [turbine Z'ur ile in MODE 3 steam supply immediately following refueling, the 7 day Completion Time is 4 reasonable due to the availability of redundant OPERABLE EFW pumpi and due to the low probability of an event t, a requiring the use of th*,ri " n PUMP- AFW for an inoera Condition A is modified by a Note which limits the applicability of the pumpin-Mi-OE 3 Condition to when the unit has not entered MODE 2 following a refueling.

Condition A allows one i nto be inoperable for 7 days vice the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time in Condition B. This longer Completion Time is based on the reduced decay heat following refueling and prior to the reactor being critical. 0 BVOG STS B 3.7.5-4 Rev. 3.1, 12/01/05 Attachment 1, Volume 12, Rev. 0, Page 133 of 461

Attachment 1, Volume 12, Rev. 0, Page 134 of 461 I 0 All changes are EFW t B 3.7.5 BASES ACTIONS (cnntinued*

in MODE 1, 2, or 3@for B.1 reasons other than Condition Am 0 When one of the[ EFWtrains (pump or flow path) is inoperable, 0 action must be taken to restore the train to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This Condition includes the loss of two steam supply lines to fne tulurn The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time Is

[

reasonable, based on the redundant capabilities afforded by -WEFW

, time needed for repairs, and the low probability of a DBA occurring during this time period.

0 11 C[. 1, or C .2 M 0

When Fe Required Action A.r Reu ction B.l annot be completed within the required Completion Time, or when two EFW trains for reasons other than Condition C are inoperableon MODE 1. 2, or 3ijthe unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be 0 placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in MODE 4 within (Kafhours.

The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

the In MODE 4, with two1*trains inoperable, operation is allowed to continue because onlylone motb-driVen EFWltrain is required in 0 accordance with the Note that modifies the LCO. Although not required.

the unit may continue to cool down and initiate DHR.

Required A M.1 is modified by a Note indicating that all required MODE changes or poW ction are suspended until at least one EFW train is restored to OPERABLE status.

Withb*alleEFWtrains inoperable in MODE 1,2, or 3, the unit is in a seriously degraded condition with no safety related means for conducting 0

a cooldown, and only limited means for conducting a cooldown with nonsafety grade equipment. In such a condition, the unit should not be perturbed by any action, including a power change, that might result in a trip. The seriousness of this condition requires that action be started immediately to restore at least one EFW train to OPERABLE status.

LCO 3.0.3 is not applicable, as it could force the units into a less safe condition.

BWOG STS B 3.7.5-5 Rev. 3.1, 12/01/05 Attachment 1, Volume 12, Rev. 0, Page 134 of 461

Attachment 1, Volume 12, Rev. 0, Page 135 of 461 I

All changes are B 3.7.5 INSERT 6 C.1 and C.2 With the l otorre train (pump or flow path) inoperable and one C SofHth-trin nnEFWtrains inoperable due to one inoperable steam supply, action must be taken to restore the affected equipment to OPERABLE status within j48M hours. Assuming no single active failures when in this condition, 0

AW _the accident (a MSLB could result in the loss of the remaining steam Fsteamr supply to the inoperable t&urbin ý e eEF pump due to the faulted In this generator 0

stea generators condition, the EFW the

may no longer be able to meet the required flow assumed in the safety analysis,j [either due to the analysis ,6quiring flow to 0

from two EFW pumps or d o the remaining EFW pump havingO feed a faulted SG]. 7 / 0D

REVIEWER'S NOTE. ----------------

Licensees should adopt the appropriate Completion me based on their plant 0

design. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is applica to plants that can no longer meet the safety analysis requirement of 100% FW flow to the SG(s) assuming no single active failure and a FLB or MSLB esulting in the loss of the remaining steam supply to the inoperable turbine ven EFW pump. The 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months Completion Time is applicable to plats that can still meet the safety analysis requirement of 100% EFW flow t e SG(s) assuming no single active failure and a FLB or MSLB resulting ' the loss of the remaining steam supply to the turbine driven EFW pump.

[The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is reasonable based e remaining OPERABLE steam supply to the affected tur availability of the remaining OPERAB driven EFW pump, the rbine driven EFW pump, and the low 0 probability of an event occurrin at would require the inoperable steam supply to be available for the a ed turbine driven EFW pump]

0-[The 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months Completion Time is reasonable based on the fact that the remaining Iturbuiv rFW train is capable of providing 100 % of the EFW flow requirements, and the low probability of an event occurring that would challenge 0(D the EFW M

-. 0 Insert Page B 3.7.5-5 Attachment 1, Volume 12, Rev. 0, Page 135 of 461

Attachment 1, Volume 12, Rev. 0, Page 136 of 461 B 3.7.5 BASES ACTIONS (continued)

In MODE 4, either the steam generator loops or the DHR loops can be used to provide heat removal, which is addressed in LCO 3.4.6, "RCS the required Loops - MODE 4." With. train inoperable, action must beL-t-t- ("a'),-

MFP [] immediatelyýestore the inoperable train to OPERABLE status.

SURVEILLANCE SR 3.7.5.1 tod REQUIREMENTS Verifying the correct alignment for manual, power operated, and automatic valves in the EFW water and steam supply flow paths provides assurance that the proper flow paths exist for EFW operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since those valves are verified to be in the correct position prior to locking, sealing, or securing. This SR also does not apply to valves that cannot be inadvertently misaligned, such as check valves. This Surveillance does not require any testing or valve manipulation; rather, it involves verification that those valves capable of potentially being mispositioned are in the correct position.

The 31 day Frequency is based on engineering judgment, is consistent with the procedural controls governing valve operation, and ensures correct valve positions.

SR 3.7.5.2 Verifying that each E pump's developed head at the flow test point is Q greater than or equal to the required developed head ensures that pump performance has not degraded during the cycle. Flow and differential head are normal tests of pump performance required by the ASME Code (Ref. 3). Because it is undesirable to introduce cold FM into the steam generators while they are operating, this test is performed on recirculation flow.

This test confirms one point on the pump design curve and is indicative of overall performance. Such inservice tests confirm component OPERABILITY, trend performance, and detect incipient failures by indicating abnormal performance. Performance of inservice testing in the ASME Code (Ref- 3), at 3 month intervals, satisfies this requirement-BVVOG STS B 3.7.5-6 Rev. 3.1, 12/01/05 Attachment 1, Volume 12, Rev. 0, Page 136 of 461

Attachment 1, Volume 12, Rev. 0, Page 137 of 461 B 3.7.5 O INSERT 7 A Note has been added that allows the MDFP train valves to be in the non-correct position (aligned in the Main Feedwater mode) when in MODE 1 < 40% RTP or in MODE 2, 3, or 4, provided the valves are capable of being locally realigned to the correct position (i.e., aligned in the AFW mode). The capability of the valves to be locally realigned to the correct position is met if a handwheel is present for each manual valve and either a handwheel is present or a power supply is available for each power operated valve. This Note is necessary because the MDFP train is normally aligned to the Main Feedwater System during a reactor startup.

The allowance is acceptable since the MDFP train is a manually actuated train.

Insert Page B 3.7.5-6 Attachment 1, Volume 12, Rev. 0, Page 137 of 461

Attachment 1, Volume 12, Rev. 0, Page 138 of 461 B 3.7.5 BASES SURVEILLANCE REQUIREMENTS (continued)

This SR is modified by a Note indicating that the SR should be deferred until suitable test conditions are established. This deferral is required because there is insufficient steam pressure to perform the test.

SR 3.7.5.0 This SR verifies that E nbedelivered to the appropriate steam generator in the event of any accident or transient that generates a earn land Feedwate -ýPture Control System SFRCSjE signal by Q

[A*J demonstrating that each automatic valve in the flow path actuates to its correct position on an actual or simulated actuation signal. This SR is not 0

required for valves that are locked, sealed, or otherwise secured in position under administrative controls. The I[V8]F~rmonth Frequency is based on the need to perform this Surveillance under the conditions that apply during a unit outage and the potential for an unplanned transient if

[J..the Surveillance were performed with the reactor at power. The also acceptable on based 10E operatingbyexperience

s* and month Im

..... ~~~that states Frequency reliability design the ofisthe SR ýi~not to be me n ýSR equipment.[This required .InMDa Note is r'pdified 4 h /

Fi traini' is already aligqned and operý ng. Ff--h- - mdfe E.. by a Note s]. o in ica es that the SR be deferred until (

indicating suitable tes conditions are established. This deferral is required because there is insufficient steam pressure to perform the testj] [The] Note [2]

states that the SR is not required to be met in MODE 4. [In MODE 4, the required pump is already operating and the autostart function is not Q required.] [In MODE 4, the heat removal requirements would be less providing more time for operator action to manually start the required EW pump.]

SR 3.7.5.9*--E F This SR verifies that the a-= Wpumps start in the event of any accident or transient that generates an SFRCS signal by AF demonstrating that each Iturbine.4i- F *Pumpstarts automatically on 24 an actual or simulated actuation signal. These u re uired in M The 8 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a unit outage and the potential for an unplanned transient if the Surveillance were performed Swith the reactor at power. This SR is modified by @aEý Notefl))

ote indticate that the SR be deferred until suitable test conditions are established. This deferral is required because there is insufficient steam BWAOG STS B 3.7.5-7 Rev. 3.1, 12/01/05 Attachment 1, Volume 12, Rev. 0, Page 138 of 461

Attachment 1, Volume 12, Rev. 0, Page 139 of 461 B 3.7.5 OINSERT 8 SR 3.7.5.3 This SR verifies the ability of the MDFP train to operate in the emergency feedwater mode. This SR verifies the proper operation of each power operated and automatic valve in the MDFP train flow path to the AFW System, and that the MDFP can be started and operated from the control room.

As noted, the SR is not required to be performed until 73 hours8.449074e-4 days 0.0203 hours 1.207011e-4 weeks 2.77765e-5 months after the MDFP train is aligned to the AFW System. This Note is necessary because the MDFP train is normally aligned to the Main Feedwater System during a reactor startup. This allowance is acceptable since any inoperabilities with the MDFP train would likely be discovered during the reactor startup when it is being used in the main feedwater mode.

The 92 day Frequency is acceptable based on engineering judgment and corresponds to the testing requirements for pumps as contained in the ASME Code (Ref. 3).

Insert Page B 3.7.5-7 Attachment 1, Volume 12, Rev. 0, Page 139 of 461

Attachment 1, Volume 12, Rev. 0, Page 140 of 461 I EFW- em All changes are 0 1 unless otherwise noted B 3.7.5 BASES SURVEILLANCE REQUIREMENTS (continued) pressure to perform the test.h [The] Note [2] states thaYthe SR is not required to be met in MO 4. [In MODE 4, the req red pump is already operating and the aut art function is not required. [In MODE 4, the heat removal requi ments would be less providir more time for operator action manually start the required A/; V*pump.]

I i T

--- ------- REVIEWEEIý'S NOTE---------.

Some plants -aynot routinely use tlfe AFWfor~heat ren The second j tification is provided for plants that use a pump rather ian AFW for startup aýd shutdown.

0 (for SR 3.7.5.6) and MODE 3 SR 3.7.5. - 6 and SR 3.7.5.7 (for SR 3.7.5.7), following refueling or This SR ensures that We EFW em is properly aligned by verifying the flow paths to each steam generator prior to entering MODE 2after more than 30 days in any combination of MODE 5 or 6, or defueled.

OPERABILITY of EFW flow paths must be demonstrated before sufficient core heat is generated that would require the operation of-fij- EFW INSERT 9

~during a subsequent shutdown.hThe Frequency is reasonable, based on engineering judgment, in view of other administrative controls to 0 ensure that the flow paths are OPERABLE. To further ensure EFVV Salignment, flow path OPERABILITY is verified, following extended outages to determine no misalignment of valves has occurred. This SR Eensures that thelow path from the CS to the steam generator is properly aligned. r(Ts SR is not required by tho)6 units that use EFW for 0 Inormal startup a%_shutdown.)

SR 37 3.7.5.66 and nd SR R 3 .5.7 57 t h facility, For this a ci ty th thee HAN HANNEL FUNCTIONAL TEST and CH E NEL IB A CALIBRATIONf N S the 3e EFAN pump suction A EFVV pressure eL and interloc n aareasa follows:

w Asuccessfu estof the required contact(s) of TE a chann relaymaybe performed f y the f verification r of the change of state a single contact of

'5 the relay.

S This a clarifies what is an acceptable pr CH NEL FUNCTIONAL C TEST o a relay. 0II This is acceptable because all f the other C required loc conta s of the i relay are verified by other Tech ical Specifications and non-10Lrsechnical T Specifications tests at least o per refueling r interval with a iicable extensions.

BVWOG STS B 3.7.5-8 Rev. 3.1, 12/01/05 Attachment 1, Volume 12, Rev. 0, Page 140 of 461

Attachment 1, Volume 12, Rev. 0, Page 141 of 461 B 3.7.5 O INSERT 9 The flow paths shall be verified by either steam generator level change or AFW safety grade flow indication (e.g., the Post Accident Monitoring AFW Flow Rate indicators). Verification of actual AFW flow capacity is not required by this SR.

Insert Page B 3.7.5-8 Attachment 1, Volume 12, Rev. 0, Page 141 of 461

Attachment 1, Volume 12, Rev. 0, Page 142 of 461 EFW t B 3.7.5 0 BASES REFERENCES 1. FSAR, SectionR9.2.74 00 00 2)< FSAR, SectionR9.2.81

3. ASME Code for Operation and Maintenance of Nuclear Power Plants.

BVVOG STS B 3.7.5-9 Rev. 3.1, 12/01/05 Attachment 1, Volume 12, Rev. 0, Page 142 of 461

Attachment 1, Volume 12, Rev. 0, Page 143 of 461 JUSTIFICATION FOR DEVIATIONS ITS 3.7.5 BASES, EMERGENCY FEEDWATER (EFW)

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

2. Changes are made to reflect changes made to another Specification (AVVs are not in the Davis-Besse ITS).

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

4. Changes made to reflect changes made to the Specification.

5. Changes are made to reflect the Specification.

6. Editorial change made for consistency.

7. The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed in to what is needed to meet this requirement. This is not meant to be retained in the final version of the plant specific submittal.

Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 143 of 461

Attachment 1, Volume 12, Rev. 0, Page 144 of 461 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 12, Rev. 0, Page 144 of 461

Attachment 1, Volume 12, Rev. 0, Page 145 of 461 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.7.5, EMERGENCY FEEDWATER (EFW)

There are no specific NSHC discussions for this Specification.

Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 145 of 461

Attachment 1, Volume 12, Rev. 0, Page 146 of 461 ATTACHMENT 6 ITS 3.7.6, CONDENSATE STORAGE TANKS (CSTs)

Attachment 1, Volume 12, Rev. 0, Page 146 of 461

, Volume 12, Rev. 0, Page 147 of 461 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 12, Rev. 0, Page 147 of 461

Attachment 1, Volume 12, Rev. 0, Page 148 of 461 ITS 3.7.6 ITS PLANT SYSTEMS CONDENSATE STORAGE TANKS LIMITING CONDITION FOR OPERATION LC03.7.6--F.7.1.3 The condensate storage tanks shall be OPERABLE with a minimum SR3.7.6.1 on ine volume o F o water _ 7.0 usable APPLICABILITY: MODES , Add proposed second Applicability ACTION:A0 With the condensate storage tanks inoperable, within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months either:MEt hours L ACTIONA. -des ore e con ens rage tanks to OPERABLE stasr rei nn-ACTION B -- SHUTDOWNtwithin the ,(ext 12Lhours, or ____witout reliance on steam generator for heat removal

b. Verif by administrative means the OPERABILITY of thelserv ce wateri-4 tssteas a ac up supply to th auxiliar eedwater systmye yM yr LA1 01 once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter, and restore the condensate storage tanks to OPERABLE status within 7 days or be in HOT SHUTDOWN within ACTIONBB hours. for

- 24

without reliance on steam generator for heat removal MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months SURVEILLANCE REQUIREMENTS usable A0 SR3.7.6.1 4.7.1.3.1 The condensate storage tanks shall be demonstrated OPERABLE at z least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months by verifying the Iionine water volume to be within its limitslwhvh the tanks are the suppR source for the auxili ty feedwater puTn s./

DAVIS-BESSE, UNIT I 3/4 7-6 Amendment No. 444-, 200 Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 148 of 461

Attachment 1, Volume 12, Rev. 0, Page 149 of 461 DISCUSSION OF CHANGES ITS 3.7.6, CONDENSATE STORAGE TANKS (CSTs)

ADMINISTRATIVE CHANGES A01 In the conversion of the Davis-Besse Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1430, Rev. 3.1, "Standard Technical Specifications-Babcock and Wilcox Plants" (ISTS).

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

A02 The CTS 3.7.1.3 Actions provide two compensatory actions for when the CSTs are found to be inoperable. CTS 3.7.1.3 Action a allows four hours to restore the CSTs to OPERABLE status or be in MODE 4 within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

CTS 3.7.1.3 Action b alternatively allows 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to demonstrate the OPERABILITY of the Service Water System as a backup supply to the Auxiliary Feedwater System and restore the CSTs to OPERABLE status within 7 days or be in MODE 4 within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . ITS 3.7.6 Required Action A.1 requires the verification by administrative means of an OPERABLE backup water supply at a Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter and Required Action A.2 requires the CSTs to be restored to OPERABLE status within 7 days.

This changes the CTS by deleting the alternative requirement in CTS 3.7.1.3 Action a to restore the CSTs to OPERABLE status within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

This change is acceptable because the requirements have not changed. Davis-Besse always has the opportunity to restore the equipment to OPERABLE status. ITS LCO 3.0.2 states that upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met. If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required unless otherwise stated. Therefore based on ITS LCO 3.0.2 restoration is always an option. This change is considered administrative because the technical requirements have not changed.

A03 CTS 4.7.1.3.1 states that the CSTs shall be demonstrated OPERABLE at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months by verifying the water level is within its limits when the tank is the supply source for the Auxiliary Feedwater System. ITS SR 3.7.6.1 states that the usable volume in the CSTs must be verified to be > 270,300 gallons. This changes the CTS by deleting detail that the Surveillance must be performed when the CSTs are the supply source for the Auxiliary Feedwater System.

The purpose of CTS 4.7.1.3.1 is to ensure the CSTs are OPERABLE when they are the supply source for the Auxiliary Feedwater System. CTS 4.0.3 states, in part, "Surveillance requirements do not have to be performed on inoperable equipment." ITS SR 3.0.1 states "Surveillances do not have to be performed on inoperable equipment or variables outside specified limits." If the CSTs are not capable of supplying the Auxiliary Feedwater System, the CSTs are considered inoperable and the ITS 3.7.6 ACTION A must be entered. Since inoperable equipment does not have to be tested, the removal of the phrase "when the tanks are the supply source for the auxiliary feedwater pumps" is acceptable. This Davis-Besse Page 1 of 3 Attachment 1, Volume 12, Rev. 0, Page 149 of 461

Attachment 1, Volume 12, Rev. 0, Page 150 of 461 DISCUSSION OF CHANGES ITS 3.7.6, CONDENSATE STORAGE TANKS (CSTs) change is designated as administrative because it does not result in technical changes to the CTS.

A04 This change to CTS 3.7.1.3 is provided in the Davis-Besse ITS consistent with License Amendment Request No. 05-0007, submitted to the USNRC for approval in FENOC letter Serial Number 3198, from Mark B. Bezilla (FENOC) to USNRC, dated April 12, 2007. As such, this change is administrative.

MORE RESTRICTIVE CHANGES M01 The CTS requirements on the CSTs are applicable in MODES 1, 2, and 3.

ITS 3.7.6 is applicable in MODES 1, 2, and 3, and in addition, MODE 4 when a steam generator is relied upon for heat removal. Consistent with this change in Applicability, the requirement to be in MODE 4 "without reliance on steam generator for heat removal" is added as indicated in ITS 3.7.6 Required Action B.2. This changes the CTS requirements by requiring the CSTs to be OPERABLE in MODE 4 when a SG is relied upon for heat removal.

This change is acceptable because the CSTs may be needed in MODE 4 ifa decay heat removal (DHR) loop has not yet been placed in service. If offsite power were to be lost when the DHR loop is not yet in service, the steam generators, fed from an emergency feedwater pump with the CSTs providing the suction source, would be relied upon for decay heat removal. The change is designated as more restrictive because the CSTs are now required to be OPERABLE in MODE 4 when a steam generator is relied upon for heat removal.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.7.1.3 Action b requires the Service Water System to be demonstrated as a backup supply to the Auxiliary Feedwater System at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months by verifying that the Service Water System is OPERABLE whenever the Service Water System is the supply source for the Auxiliary Feedwater System. ITS 3.7.6 Required Action A.1 requires the verification of OPERABILITY of a backup water supply. This changes the CTS by moving the detail that the Service Water System provides the backup supply for the Auxiliary Feedwater System from the CTS to the Bases.

The removal of these details, which are related to system design, from the Technical Specifications, is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement to verify by administrative means OPERABILITY of a backup water supply when the CSTs are found to be inoperable. Also, this change is acceptable because the Davis-Besse Page 2 of 3 Attachment 1, Volume 12, Rev. 0, Page 150 of 461

Attachment 1, Volume 12, Rev. 0, Page 151 of 461 DISCUSSION OF CHANGES ITS 3.7.6, CONDENSATE STORAGE TANKS (CSTs) removed information will be adequately controlled in ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L01 (Category3 - Relaxation of Completion Time) With the CSTs inoperable, CTS 3.7.1.3 Action a requires restoration of the CSTs within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months or be in MODE 4 within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , while CTS 3.7.1.3 Action b requires demonstration of OPERABILITY of the backup supply within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and restoration of the CSTs to OPERABLE status within 7 days or be in MODE 4 within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . ITS 3.7.6 Required Action A.1 requires the verification of OPERABILITY of the backup water supply within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and Required Action A.2 requires the CSTs to be restored to OPERABLE status within 7 days.

If any of these Required Actions are not met within the associated Completion Time, ITS 3.7.6 ACTION B requires the unit to be in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in MODE 4 without reliance on steam generator for heat removal within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

This changes the time to be in MODE 4 without reliance on the steam generators for heat removal from 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and adds an additional requirement to be in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

The purpose of CTS 3.7.13 Actions a and b is to place the unit in a condition in which it does not rely on the steam generators for heat removal when the CSTs are inoperable. This change is acceptable because the Completion Time is consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the allowed Completion Time. Allowing 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to be in MODE 4 without reliance on the steam generators for heat removal recognizes that additional time is required from the time MODE 4 is entered until the steam generators are not relied upon for heat removal. The new requirement that the unit be in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ensures a unit shutdown is commenced within a reasonable period of time upon failure to restore the CSTs to OPERABLE status within the allowed Completion Time. This change is designated as less restrictive because additional time is allowed to restore parameters to within the LCO limits than was allowed in the CTS.

Davis-Besse Page 3 of 3 Attachment 1, Volume 12, Rev. 0, Page 151 of 461

Attachment 1, Volume 12, Rev. 0, Page 152 of 461 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 12, Rev. 0, Page 152 of 461

Attachment 1, Volume 12, Rev. 0, Page 153 of 461 CTS CSTA-(O 3.7.6 0

3.7 PLANT SYSTEMS 0 3.7.6 Condensate Storage Tan (CS 3.7.1.3 LCO 3.7.6 The *--- CSrT[sýshall be OPERABLE. 0 APPLICABILITY: MODES 1,2, and 3, MODE 4 when steam generator is relied upon for heat removal.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME Action a, A. The P '11C s A.1 Verify by administrative 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Action b inoperabe. means OPERABILITY of backup water supply. AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter AND A.2 Restore CSTsto 7 days OPERABLE status.

Action a, B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Action b associated Completion Time not met. AND B.2 Be in MODE 4 without M24Mhours reliance on steam generator for heat removal.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.7.1.3.1 SR 3.7.6.1 VerifyICS e e is j[25,0]gal. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 000 usable volume in the BWOG STS 3.7.6-1 Rev. 3.0, 03/31104 Attachment 1, Volume 12, Rev. 0, Page 153 of 461

Attachment 1, Volume 12, Rev. 0, Page 154 of 461 JUSTIFICATION FOR DEVIATIONS ITS 3.7.6, CONDENSATE STORAGE TANKS (CSTs)

1. Changes are made to the ISTS Specification which reflect the plant specific nomenclature, number as designed and built.

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

3. This is an editorial change for clarity.

Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 154 of 461

Attachment 1, Volume 12, Rev. 0, Page 155 of 461 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 12, Rev. 0, Page 155 of 461

Attachment 1, Volume 12, Rev. 0, Page 156 of 461 All changes are unless otherwise noted 9 B 3.7.6 B 3.7 PLANT SYSTEMS B 3.7.6 Condensate Storage Tan CS andtheMotrDriven o cp _- the primary aligned to the AFW mode BASES BACKGROUND The'CS providej s source of water to the steam generators s for removing decay and sensible heat from the Reactor Coolant System (RCS). The CST providej a passive flow of water, by gravity, to the Ernee FýFeedwater (EFW)y Feedwater (FW) System (LCO 3.7.5, "Emergency

'). The steam produced is released to the

-- atmosphere by the main steam safety valves (MSSVs) or the atmospheric 0

vent valves.

When the main stean isolation valves ar open. the preferred eans of heat removal is todscharge to the cne nonsafe grade path of the turbin bypass valves.

condensed steam i returned to the CST by the ondensate pump. This has the advantal of conserving condensate wole minimizing releoes to the environmet.

Because the C T is a principal compone in removing residual eat from RCS, it isesigned gthe to withstand ea quakes and other na ral IINSERT 1 1phenomenaas well as missiles that ight be generated by tural phenomen . The CST is designed Seismic Category I ensure availabili of the feedwater suppi . Feedwater is also av ilable from an alternatq source(s)./-

Adescription of the CS;isfound in 'Le FSAR, Section 19.2.6NJ(Ref. 1). 2 source of APPLICABLE ŽJThe-CSi'provide n water to Iremove d ea a cool down System SAFETY n*toll ing a events in tWe acci ent ana ysis, aý iscusse in ANALYSES e R Chapters [6] and V5] (Refs. 2 and 3. resp- ctive or CSTs design the RCS in the anticipated operational occurrences and accidents that do not affect the provides sufficient event of a loss of OPERABILITY of the steam generators, the lanalysi,* sumption water invent fo offsite power generafly'30 minutesl at MODE 3, steaming Ptroug 1 e :s, owed by a cooldown to decay heat removal (DHR) entry conditions at the to atmosphere 13ors design cooldown rate.

The limiting ev nt for the condensat* volume is the larg/ feedwater line break coincid ht with a loss of offsie power. Single fatures that also affect this ev nt include the foI owi g..

BW*OG STS B 3.7.6-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 156 of 461

Attachment 1, Volume 12, Rev. 0, Page 157 of 461 B 3.7.6 0 INSERT 1 The CSTs are the preferred choice for makeup water to the steam generators because they meet secondary water chemistry requirements. The CSTs are Seismic Class I1.

The Service Water System (SWS) is the Safety Grade source of water in the event of an earthquake. In the event of a reduction in the inventory of the CSTs (i.e., a low level in the CSTs as sensed by Auxiliary Feedwater pump low suction pressure), the Auxiliary Feedwater System supply will automatically switch from the CSTs to the Service Water System.

Insert Page B 3.7.6-1 Attachment 1, Volume 12, Rev. 0, Page 157 of 461

Attachment 1, Volume 12, Rev. 0, Page 158 of 461 I 0 All changes are unless otherwise noted 9 CSTP B 3.7.6 BASES APPLICABLE SAFETY ANALYSES (continued)

a. Failure of th diesel generator po ering the motor dri en EFW pump to the unaff cted steam generato (requiring addition I steam to drive the remain hg EFW pump turbin and

b. Failure of he steam driven E pump (requiring a I nger time for cooldown using only one motor riven EFW pump).

These are no usually the limiting fa lures in terms of co sequences for Ithese events y

W The CST satisý Criteria 2 and 3 of 10 CFR 50.36(c)(2)(ii).

design considerations To satisfy laccident a.-sis assumptionsh therrW CSTs must contain sufficient cooling water to remove decay heat for 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months following a 0 with steam discharge to the atmosphere reactor trip nom 12"No RM and then to cool down the RCS to DHR System entry conditionsl assuming a cOpciden loss0ot of oste power an Imost adv..ise sinqle faur. While so doing, the CSTs must retain sufficient water to ensure adequate net positive suction head for the;-

pump~s during the cooldown, to account for any losses from the steam P--

0 IEIW drivegFWV pumplinturbine, Q6 roken . as well as lossRis-mcurred betore isolat in L-C smutcontain Clevel T requiretis ýeuiva~lent toI a usable volume of 2 0gallons, which is based on holding the unit in MODE 3for 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months , followed by a 00 cooldown to DHR System entry conditions. usbl The OPERABILITY of the CSfiT'determined by maintaining the tank at or above the minimum required ýJ-oirne 0(D APPLICABILITY In MODES 1, 2, 3, and in MODE 4owhenksteam generator is being relied upon for heat removal, the CST required to be OPERABLE.

sa-rel In MODES 5 and 6, the CSTL not required because the System is not required. ; r BWOG STS B 3.7.6-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 158 of 461

Attachment 1, Volume 12, Rev. 0, Page 159 of 461 CST B 3.7.6 2

0 BASES ACTIONS A.1 and A.2 (the__Service (the Service Water System)

____As an alternative to unit shutdown, the OPERABILITY of the backup water supplyshould be verified within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and once every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 0 thereafter. The OPERABILITY of the backup feedwater supply must include verification, by administrative means, of the OPERABILITY of flow paths from the bac up supply to the E pumpsland avajla ilit) of the required volume o r in the backup suppl . The C must be s restored to OPERABLE status within 7 days because the backup supply is not the preferred source of Y may e erforming this fu n addition to its n rmal functions. The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time is reasonable, based on operating experience, to 0

water add this(i.e., it is not backup preferred source to of water verify the OPERABILITY of the backup water supply. Additionally, to the steam generators) verfying the backup water supply every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is adequate to ensure

.6 backup

_L-thewater supply continues to be available. The 7 day Completion Time is reasonable, based on an OPERABLE backup water supply being available, and the low probability of an event occurring during this time period, requiring the use of the water from the CSTIs1.

B.1 and B.2 f any Required Action and I 0

If the CST cannot be ret to OPERABLE status in thel associated Completion Time, the unit must be placed in a MODE in which the LCO does not a-pp y-,1th the DHR System in operation. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in 00 MODE 4, without reliance on steam generators for heat removal, within hours. This all an additiona 6 ho System to be Iplaced in service fter entering MODE 4/

The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

SURVEILLANCE SR 3.7.6.1 usabl REQUIREMENTS This SR verifies that the CSTjJcontain! the required olume of cooling 00 water. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency is based on operating experience and the need for operator awareness of unit evolutions that may affect the CST.-FJ 0 inventory between checks. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency is considered adequate in view of other indications in the control room, including alarms, to alert the operator to abnormal deviations in CST levels.

BWOG STS B 3.7.6-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 159 of 461

Attachment 1, Volume 12, Rev. 0, Page 160 of 461 CST B 3.7.6 2

0 BASES REFERENCES 1>..FSAR, Section~ .2.6g 00

[2 *Rh a[pte[

3. ZFSR,ýhapt:r[15].! 0 BWOG STS B 3.7.6-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 160 of 461

Attachment 1, Volume 12, Rev. 0, Page 161 of 461 JUSTIFICATION FOR DEVIATIONS ITS 3.7.6 BASES, CONDENSATE STORAGE TANKS (CSTs)

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

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

3. Changes are made to reflect changes made to the Specification.

4. Changes made to be consistent with the Specification.

5. The Service Water System is supplied by the Ultimate Heat Sink (UHS), which is required by ITS 3.7.9. A periodic verification of UHS is not needed.

6. Typographical/grammatical error corrected.

Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 161 of 461

Attachment 1, Volume 12, Rev. 0, Page 162 of 461 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 12, Rev. 0, Page 162 of 461

Attachment 1, Volume 12, Rev. 0, Page 163 of 461 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.7.6, CONDENSATE STORAGE TANKS (CSTs)

There are no specific NSHC discussions for this Specification.

Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 163 of 461

Attachment 1, Volume 12, Rev. 0, Page 164 of 461 ATTACHMENT 7 ITS 3.7.7, COMPONENT COOLING WATER (CCW) SYSTEM Attachment 1, Volume 12, Rev. 0, Page 164 of 461

, Volume 12, Rev. 0, Page 165 of 461 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 12, Rev. 0, Page 165 of 461

Attachment 1, Volume 12, Rev. 0, Page 166 of 461 ITS Q ITS 3.7.7 PLANT SYSTEMS 3/4.7.3 COMPONENT COOLING WATER SYSTEM LIMITING CONDITION FOR OPERATION LAO 1 LCO3.7.7 3.7.3.1 Two indepndentlcomponent cooling water loops shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3 and 4.

ACTION:---- Add proposed Required ActionA.1 Notes (M ý ACTIONA -[i-Wt'one component cooling water loop inoperable, restore the inoperable loop Ito OPERABLE status within 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months sior be in at least HOT STANDBY within the ACTION B -next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

SURVEILLANCE REQUIREMENTS 4.7.3.1 Each component cooling water loop shall be demonstrated OPERABLE:

Add proposed SIR 3.7.7.1 Note 1_ _

once p[

Akt least SR 3.7.7.1 a. A least once per 31 days by verifying that each valve (manual, intheflowpath power operated or automatic)kservicing safety related equipment that is not locked, sealed or otherwise secured in position, is in A03 its correct position.

b. At least once each REFUELING INTERVAL, by:

SR 3.7.7.2

1. Verifying that each automatic valve in the flow path_-

actuates to its correct position on an S Sest signal.

Sthatýisnot locked, sealed, or otherwised secured in positict, SR 3.7.7.3

2. Veriryngnat eacn component cooling wa*tr emergency-I starts automatically on an FS-F-ASktest signal.

DAVIS-BESSE, UNIT I 3/4 7-14 Amendment No. 216 Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 166 of 461

Attachment 1, Volume 12, Rev. 0, Page 167 of 461 DISCUSSION OF CHANGES ITS 3.7.7, COMPONENT COOLING WATER (CCW) SYSTEM ADMINISTRATIVE CHANGES A01 In the conversion of the Davis-Besse Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1430, Rev. 3.1, "Standard Technical Specifications-Babcock and Wilcox Plants" (ISTS).

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

A02 CTS 4.7.3.1 does not contain an explicit reference to isolating CCW flow to individual components. ITS SR 3.7.7.1 contains a Note which states, "Isolation of CCW flow to individual components does not render CCW System inoperable."

This changes CTS by adding an allowance that is not explicitly stated in the CTS.

The purpose of the CCW System Technical Specification is to provide assurance that CCW is available to the appropriate plant components. This change is acceptable because by current use and application of the CTS, isolation of a component supplied with CCW does not necessarily result in the CCW System being considered inoperable, but the respective component may be declared inoperable for its system. This change clarifies this application. This change is designated as administrative because it does not result in technical changes to the CTS.

A03 CTS 4.7.3.1.a requires verification that each CCW valve (manual, power operated, or automatic) servicing safety related equipment that is not locked, sealed, or otherwise secured in position, is in its correct position. ITS SR 3.7.7.1 requires verification that each CCW manual, power operated, and automatic valve in the flow path servicing safety related equipment that is not locked, sealed, or otherwise secured in position, is in the correct position. This changes the CTS by adding the words "in the flow path" to CTS 4.7.3.1.a.

The purpose of CTS 4.7.3.1 .a is to ensure all valves in the CCW flow path are in the correct position. The addition of the words "in the flow path" does not change the intent of the Surveillance Requirement. Each manual, power operated, and automatic valve servicing safety related equipment that is not locked, sealed, or otherwise secured in position will continue to be verified to be in the correct position. Each CCW automatic valve in the flow path that is not locked, sealed or otherwise secured in position, will still be checked to ensure it actuates to the correct position on an actual or simulated actuation signal. This change is designated as administrative because it does not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES M01 The Action for CTS 3.7.3.1 allows 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to restore an inoperable CCW loop to OPERABLE status. ITS 3.7.7 ACTION A has this same requirement, however two Notes have been included. The ITS 3.7.7 Required Action A.1 Note 1 requires entry into the applicable Conditions and Required Actions of LCO 3.8.1, Davis-Besse Page 1 of 4 Attachment 1, Volume 12, Rev. 0, Page 167 of 461

Attachment 1, Volume 12, Rev. 0, Page 168 of 461 DISCUSSION OF CHANGES ITS 3.7.7, COMPONENT COOLING WATER (CCW) SYSTEM "AC Sources- Operating," for an emergency diesel generator made inoperable by CCW. The ITS 3.7.7 Required Action A.1 Note 2 requires entry into the applicable Conditions and Required Actions of LCO 3.4.6, "RCS Loops -

MODE 4," for decay heat removal loop made inoperable by CCW. This changes the CTS by explicitly specifying the applicable Conditions and Required Actions of ITS LCO 3.4.6 must be entered.

The purpose of the Action for CTS 3.7.3.1 is to ensure the inoperable CCW loop is restored to OPERABLE status within a reasonable time. This change is acceptable because it provides additional assurance that the appropriate compensatory actions are taken for an inoperable emergency diesel generator or decay heat removal loop that results from a loss of a CCW loop. This change is designated as more restrictive because it adds the explicit cascading requirement.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type I - Removing Details of System Design and System Description, Including Design Limits) CTS 3.7.3.1 states that two "independent" CCW loops shall be OPERABLE. ITS 3.7.7 requires two CCW loops to be OPERABLE, but does not contain the detail that the loops must be independent. This changes the CTS by moving the detail that the CCW loops are independent to the Bases.

The removal of these details, which are related to system design, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement for two CCW loops to be OPERABLE. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LA02 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 4.7.3.1 .b.1 and 4.7.3.1 .b.2 require verification of the automatic actuation of CCW components on an "SFAS" test signal. ITS SR 3.7.7.2 and SR 3.7.7.3 do not state the specific type of signal, but only specify an actual or simulated "actuation" signal. This changes CTS by moving the type of actuation signal (i.e., SFAS) to the Bases.

The removal of these details, which are related to system design, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate Davis-Besse Page 2 of 4 Attachment 1, Volume 12, Rev. 0, Page 168 of 461

Attachment 1, Volume 12, Rev. 0, Page 169 of 461 DISCUSSION OF CHANGES ITS 3.7.7, COMPONENT COOLING WATER (CCW) SYSTEM protection of public health and safety. The ITS still retains the requirement to verify that appropriate equipment actuates upon receipt of an actuation signal.

Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5 of the ITS. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Specification.

LESS RESTRICTIVE CHANGES L01 (Category6- Relaxation Of Surveillance Requirement Acceptance Criteria)

CTS 4.7.3.1 .b.1 and 4.7.3.1 .b.2 require verification of the automatic actuation of component cooling water components on an SFAS "test" signal. ITS SR 3.7.7.2 and SR 3.7.7.3 specify that the signal may be from either an "actual" or simulated (i.e., test) signal. This changes the CTS by explicitly allowing the use of either an actual or simulated signal for the test.

The purpose of CTS 4.7.3.1 .b.1 and 4.7.3.1 .b.2 is to ensure the CCW components operate correctly upon receipt of an actuation signal. This change is acceptable because the relaxed Surveillance Requirement acceptance criteria are not necessary for verification that the equipment used to meet the LCO can perform its required functions. Equipment cannot discriminate between an "actual," "simulated," or "test" signal and, therefore, the results of the testing are unaffected by the type of signal used to initiate the test. This change allows taking credit for unplanned actuation if sufficient information is collected to satisfy the Surveillance test requirements. The change also allows a simulated signal to be used, if necessary. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

L02 (Category5 - Deletion of Surveillance Requirement) CTS 4.7.3.1 .b.1 requires verification that each CCW automatic valve in the flow path actuates to its correct position. ITS SR 3.7.7.2 requires verification that each CCW automatic valve in the flow path "that is not locked, sealed, or otherwise secured in position" actuates to the correct position. This changes the CTS by excluding those valves that are locked, sealed, or otherwise secured in position from the verification.

The purpose of CTS 4.7.3.1.b.1 is to provide assurance that if an event occurred requiring CCW valves to be in their correct position, then those requiring automatic actuation would actuate to their correct position. This change is acceptable because the deleted Surveillance is not necessary to verify that the equipment used to meet the LCO can perform its required functions. Thus, appropriate equipment continues to be tested to in a manner and at a Frequency necessary to provide confidence that the equipment can perform its assumed safety function. Those automatic valves that are locked, sealed, or otherwise secured in position are not required to actuate on a component cooling water actuation .signal in order to perform their safety function because they are already Davis-Besse Page 3 of 4 Attachment 1, Volume 12, Rev. 0, Page 169 of 461

Attachment 1, Volume 12, Rev. 0, Page 170 of 461 DISCUSSION OF CHANGES ITS 3.7.7, COMPONENT COOLING WATER (CCW) SYSTEM in the required position. Testing such valves would not provide any additional assurance of OPERABILITY. Valves that are required to actuate will continue to be tested. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

Davis-Besse Page 4 of 4 Attachment 1, Volume 12, Rev. 0, Page 170 of 461

Attachment 1, Volume 12, Rev. 0, Page 171 of 461 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 12, Rev. 0, Page 171 of 461

Attachment 1, Volume 12, Rev. 0, Page 172 of 461 CTS CCW System 3.7.7 3.7 PLANT SYSTEMS 3.7.7 Component Cooling Water (CCW) System 3.7.3.1 LCO 3.7.7 Two CCWIshall be OPERABLE. 0 APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME Action A. One CCWEDAO inoperable.

A.1 -----------.NOTES --------..

1. Enter applicable 0

Conditions and Required Actions of LCO 3.8.1, "AC Sources -

Operating," for emergency diesel generator made inoperable by CCW.

2. Enter applicable Conditions and Required Actions of LCO 3.4.6, "RCS Loops

- MODE 4," for heat removalae loo 0

inoperable by CCW.

Restore CCWETglto 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 0

OPERABLE status.

Action B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time ion not AND 0 met.

B.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months BWOG STS 3.7.7-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 172 of 461

Attachment 1, Volume 12, Rev. 0, Page 173 of 461 CTS CCW System 3.7.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.7.3.1.a SR 3.7.7.1 NOTE Isolation of CCW flow to individual components does not render CCW System inoperable.

Verify each CCW manual, power operated, and 31 days automatic valve in the flow path servicing safety related equipment, that is not locked, sealed, or otherwise secured in position, is in the correct position.

4.7.3.1.b.1 SR 3.7.7.2 Verify each CCW automatic valve in the flow path that is not locked, sealed, or otherwise secured in months 0

position, actuates to the correct position on an actual or simulated actuation signal.

4.7.3.1.b.2 SR 3.7.7.3 SWared Verify ea'chiCCW pump starts automatically on an []months 00 actual or simulated actuation signal.'24 BWOG STS 3.7.7-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 173 of 461

Attachment 1, Volume 12, Rev. 0, Page 174 of 461 JUSTIFICATION FOR DEVIATIONS ITS 3.7.7, COMPONENT COOLING WATER (CCW) SYSTEM

1. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant specific nomenclature.

2. Editorial changes made for clarity and to be consistent with the terminology in ITS 3.4.6.

3. Since Condition B applies to all Conditions in the ACTIONS Table, the term "of Condition A" is not necessary. This is consistent with the Writer's Guide for the Improved Standard Technical Specifications, TSTF-GG-05-01, Section 4.1.6.i.5.ii.

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

5. The Davis-Besse design includes a spare CCW pump and heat exchanger that can be substituted for one of the normal CCW pumps and its associated heat exchanger.

Therefore SR 3.7.7.3 has been modified to only require the "required" CCW pumps to be tested. This is consistent with the use of the word required in the ITS, as discussed the Writer's Guide for the Improved Standard Technical Specifications, TSTF-GG-05-01, Section 4.1.3.

Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 174 of 461

Attachment 1, Volume 12, Rev. 0, Page 175 of 461 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 12, Rev. 0, Page 175 of 461

Attachment 1, Volume 12, Rev. 0, Page 176 of 461 I

All changes are unless otherwise noted 9 CCW System B 3.7.7 B 3.7 PLANT SYSTEMS B 3.7.7 Component Cooling Water (CCW\o System BASES BACKGROUND The CCW System provides a heat sink for the removal of process and operating heat from safety related components during a Design Basis Accident (DBA) or transient. During normal operation, the CCW System also provides this function for various nonessential components, as well as the spent fuel pool. The CCW System serves as a barrier to the release of radioactive byproducts between potentially radioactive systems and the Service Water System, and thus to the environment.

CCW System is arranged as two independent full capaci cooling loops, and has isolatable nonsafety related components./Fach\

.I~~~safety reltiýltrain includes a ful capacity pump, surge tank, heaf._

71exchanger piping, valves, and ihstrumentation. Each safety re ted train\

^.

is pow ire/rom a separatie bu .l A surge tank in the system provides

The surge tank is dividdedt sufficient net positive suction head i or each pump and isolation of internally into two sep compartments by a ceenter nonessential components on a low tank level signal.'The pump in each baffle approximately Inalf the M_T is automatically started on receipt of a safety featurectuation height of the tank. Ea ch signal, and all nonessential components are isolated.

compartment serves a separate loop. This e nsures that if a leak on one Ioop Additional information on the design and operation of the CCW System occurs, water remains along with a list of the components served, is presented in the'FSAR, available to the other ler Section [P.2.21j(Ref. 1). The principal safety related function of the CCW S stem is the removal of decay heat from the reactor via the [jiecay heat 0

removal (DHR heat chan e This may utilize the DHR System during a normal or post accident cool own and shutdown, or during the recirculation phase following a loss of coolant accident.

APPLICABLE The design basis of the CCW System is to provide cooling water to the SAFETY Emergency Core Cooling Systerr and lemergencye.ese7 -eneratorsI ANALYSES [EDGs during DBA conditions. The CCW System also supplies cooling componentsj water to EDGs during a loss of offsite power.

The CCW System is designed to perform its function with a single failure of any active component assuming a loss of offsite power.

MODE4 The CCW System also functions to cool the unit fromDHl.entry condition (TCod < F) to MODE 5 (Trad <C200jF' during normal and post accident operations. The time required to coo from I20T F is a function of the number of CCW and DH¶ qin;oe*rating. 0

@ ne C rCi is sufficient to remove decay heat during subsequent loops operations with Tcold < 2Q00F.

The CCW System satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).

BWOG STS B 3.7.7-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 176 of 461

Attachment 1, Volume 12, Rev. 0, Page 177 of 461 B 3.7.7 O INSERT 1 The CCW System consists of three pumps, three heat exchangers, a surge tank and two closed cooling loops. Each closed cooling loop is capable of serving one train of Emergency Core Cooling System (ECCS) components and the associated emergency diesel generator (EDG). Each closed cooling loop is supplied by one of the three pumps. Three pumps and heat exchangers are provided so any one of the pump-heat exchanger units can be removed from service for maintenance or repair without reducing the capability or redundancy of the CCW System. Two of the CCW pumps are powered from the associated essential bus. The third CCW pump can be powered from either essential bus through interlocked supply breakers and can manually be aligned to supply either CCW loop.

Insert Page B 3.7.7-1 Attachment 1, Volume 12, Rev. 0, Page 177 of 461

Attachment 1, Volume 12, Rev. 0, Page 178 of 461 I All changes are unless otherwise noted 9 CCW System B 3.7.7 BASES LCO EE The C:CWHn are independent-of each other to the degree that each .lV has separate controls and power supplies and the operation of one does not depend on the other. In the event of a DBA, one r f CCW is required to provide the minimum heat removal capability assumed in the safety anal sis for s stem*nto which it supplies cooling water. To ensure;hlo is is met, two CCWrin must be OPERABLE. At least one CCW r _

will operate assuming the worst case single active failure occurs coincident with loss of offsite power.

is considered OPERABLE when: portion of the

a. It has an OPERABLE pump and associatedsurge tankand n 0

b. The associated piping, valves, heat exchanger, and instrumentation and controls required to perform the safety related function are OPERABLE.

individua The isolation of CCW from other components or systems not required for safety may render th *components or systems inoperable, but does not affect the OPERABILITY of the CCW System. 0 APPLICABILITY In MODES 1, 2, 3, and 4, the CCW System is a normally operating system that must be prepared to perform its post accident safety functions primarily Reactor Coolant System heat removal, by cooling the eat chan e.

In MODES 5 and 6, the OPERABILITY requirements of the CCW System are determined by the systems it supports.

ACTIONS A.1 Required Action A.1 is modified by a Note indicating that the applicable Conditions and Required Actions of LCO 3.8.1, "AC Sources - Operating,"

and LCO 3.4.6, "RCS Loops - MODE 4," should be entered if an inoperable CCWiý results in an inoperable EDG or DHR loop. This is an exception to LCO 3.0.6 and ensures the proper actions are taken for these components.

lop If one CC riis inoperable, action must be taken to restore OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . In this Oondition, the remaining 0 OPERABLE CC Vi r is adequate to perform the heat removal function.

The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is reasonable, based on the redundant capabilities afforded by the OPERABLE i,, and the low probability of a DBA occurring during this period.

BWOG STS B 3.7.7-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 178 of 461

Attachment 1, Volume 12, Rev. 0, Page 179 of 461 B 3.7.7 0 INSERT 2 Furthermore, the spare CCW pump and associated heat exchanger can be substituted for a normal CCW pump and heat exchanger, provided the power supply for the pump is aligned to the same essential bus as the pump it is replacing.

Insert Page B 3.7.7-2 Attachment 1, Volume 12, Rev. 0, Page 179 of 461

Attachment 1, Volume 12, Rev. 0, Page 180 of 461 All changes are unless otherwise noted 9 CCW System B 3.7.7 BASES ACTIONS (continued)

B.1 and B.2 If the CCV i cannot be restored to OPERABLE status in the associated Completion Time, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

SURVEILLANCE SR 3.7.7.1 REQUIREMENTS This SR is modified by a Note indicating that the isolation of the CCW flow to individual components may render those components inoperable, but does not affect the OPERABILITY of the CCW System.

Verifying the correct alignment for manual, power operated, and automatic valves in the CCW flow path provides assurance that the proper flow paths exist for CCW operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since they are verified to be in the correct position prior to locking, sealing, or securing. This SR also does not apply to valves which cannot be inadvertently misaligned, such as check valves. This Surveillance does not require any testing or valve manipulation; rather, it involves verification that those valves capable of potentially being mispositioned are in their correct position.

The 31 day Frequency is based on engineering judgment, is consistent with the procedural controls governing valve operation, and ensures correct valve positions.

SR 3.7.7.2 (i.e., SFAS) This SR verifies proper automatic operation of the CCW valves on an actual or simulated actuation'signal. The CCW System is a normally operating system that cannot be fully actuated as part of routine testing during normal operation. This SR is not required for valves that are locked, sealed, or otherwise secured in position under administrative BWOG STS B 3.7.7-3 Rev. 3.0, 03/31104 Attachment 1, Volume 12, Rev. 0, Page 180 of 461

Attachment 1, Volume 12, Rev. 0, Page 181 of 461 CCW System B 3.7.7 BASES SURVEILLANCE REQUIREMENTS (continued) controls. The8 month Frequency is based on the need to perform this 4

Surveillance under the conditions that apply during a plant outage and the Q

potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience'has shown that these omponents usually pass the Surveillance when performed at the 8!month Frequency. Therefore, the Frequency is acceptable from a 0 reliability standpoint.

SR 3.7.7.3 (eSFAS)

(,..

This SR verifies proper automatic operation of the CCW pumps on an actual or simulated actuatior signal. The CCW System is a normally 0 24 operating system that cannot be fully actuated as part of routine testing during normal operation. The6I[M8] month Frequency is based on the need 0 to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown that these components usually pass the Surveillance when performed at the [ 8] month Frequency. Therefore, the Frequency is 0 acceptable from a reliability standpoint.

REFERENCES LT.h FSAR, Section[9.2.2$

00 BWOG STS B 3.7.7-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 181 of 461

Attachment 1, Volume 12, Rev. 0, Page 182 of 461 JUSTIFICATION FOR DEVIATIONS ITS 3.7.7 BASES, COMPONENT COOLING WATER (CCW) SYSTEM

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

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

3. These punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, TSTF-GG-05-01, Section 5.1.3.

4. Typographical error corrected.

5. Grammatical error corrected.

Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 182 of 461

Attachment 1, Volume 12, Rev. 0, Page 183 of 461 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 12, Rev. 0, Page 183 of 461

Attachment 1, Volume 12, Rev. 0, Page 184 of 461 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.7.7, COMPONENT COOLING WATER (CCW) SYSTEM There are no specific NSHC discussions for this Specification.

Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 184 of 461

, Volume 12, Rev. 0, Page 185 of 461 ATTACHMENT 8 ITS 3.7.8, SERVICE WATER SYSTEM (SWS) , Volume 12, Rev. 0, Page 185 of 461

, Volume 12, Rev. 0, Page 186 of 461 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 12, Rev. 0, Page 186 of 461

Attachment 1, Volume 12, Rev. 0, Page 187 of 461 ITS Q ITS 3.7.8 PLANT SYSTEMS 3/4.7.4 SERVICE WATER SYSTEM LIMITING CONDITION FOR OPERATION LAO01 LC03.7.8 3.7.4.1 Two e service water loops shall-be OPERABLE.

APPLICABILITY: MODES 1, 2, 3 and 4.

ACTION:

[Add proposed Required Accion A. 1 Notes ACTIONA _Tth one service water loop inoperable, restore the inoperable loop to PERABLE status within 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months sFo-r be in at least HOT STANDBY within the next ACTIONB 6hours and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

SURVEILLANCE REQUIREMENTS 4.7.4.1 Each service water loop shall be demonstrated OPERABLE:

J[Add~propOsed SR 3 .7.8 .1Note _ _

SR3.7.8.1 a. t least once per 31 days by verifying at each valve (manual, nthefowpath power operated or automatic) servicing safety related equipment that is not locked, sealed or otherwise secured in position, is in its correct position.

b. At least once each REFUELING INTERVAL, by:

SR 3.7.8.2

1. Verifying that each automatic valve in the flow path _{ actualor L01 actuates to its correct position on an pFASftest signal. LA0

..- *that is not locked, sealed, or otherwised secured in position, actuation

A0 SR 3.7.8.3

2. 2. Veritying automatically hat oneachan service water emergency pump s ar*s tstsinl.L0 L0 1 actuation LA02 DAVIS-BESSE, UNIT I 3/4 7-15 Amendment No. 216 Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 187 of 461

Attachment 1, Volume 12, Rev. 0, Page 188 of 461 DISCUSSION OF CHANGES ITS 3.7.8, SERVICE WATER SYSTEM (SWS)

ADMINISTRATIVE CHANGES A01 In the conversion of the Davis-Besse Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1430, Rev. 3.1, "Standard Technical Specifications-Babcock and Wilcox Plants" (ISTS).

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

A02 CTS 4.7.4.1 does not contain an explicit reference to isolating SWS flow to individual components. ITS SR 3.7.8.1 contains a Note which states, "Isolation of SWS flow to individual components does not render the SWS inoperable."

This changes CTS by adding an allowance that is not explicitly stated in the CTS.

The purpose of the SWS Technical Specification is to provide assurance that service water is available to the appropriate plant components. This change is acceptable because by current use and application of the CTS, isolation of a component supplied with service water does not necessarily result in the SWS being considered inoperable, but the respective component may be declared inoperable for its system. This change clarifies this application. This change is designated as administrative because it does not result in technical changes to the CTS.

A03 CTS 4.7.4.1.a requires verification that each SWS valve (manual, power operated, or automatic) servicing safety related equipment that is not locked, sealed, or otherwise secured in position, is in its correct position. ITS SR 3.7.8.1 requires verification that each SWS manual, power operated, and automatic valve in the flow path servicing safety related equipment that is not locked, sealed, or otherwise secured in position, is in the correct position. This changes the CTS by adding the words "in the flow path" to CTS 4.7.4.1.a.

The purpose of CTS 4.7.4.1 .a is to ensure all valves in the SWS flow path are in the correct position. The addition of the words "in the flow path" does not change the intent of the Surveillance Requirement. Each manual, power operated, and automatic valve servicing safety related equipment that is not locked, sealed, or otherwise secured in position will continue to be verified to be in the correct position. Each SWS automatic valve in the flow path that is not locked, sealed or otherwise secured in position, will still be checked to ensure it actuates to the correct position on an actual or simulated actuation signal. This change is designated as administrative because it does not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES M01 The Action for CTS 3.7.4.1 allows 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to restore an inoperable SWS loop to OPERABLE status. ITS 3.7.8 ACTION A has this same requirement, however two Notes have been included. The ITS 3.7.8 Required Action A.1 Note 1 requires entry into the applicable Conditions and Required Actions of LCO 3.8.1, Davis-Besse Page 1 of 4 Attachment 1, Volume 12, Rev. 0, Page 188 of 461

Attachment 1, Volume 12, Rev. 0, Page 189 of 461 DISCUSSION OF CHANGES ITS 3.7.8, SERVICE WATER SYSTEM (SWS)

"AC Sources- Operating," for emergency diesel generator made inoperable by SWS. The ITS 3.7.8 Required Action A.1 Note 2 requires entry into the applicable Conditions and Required Actions of LCO 3.4.6, "RCS Loops -

MODE 4," for decay heat removal loop made inoperable by SWS. This changes the CTS by explicitly specifying the applicable Conditions and Required Actions of ITS LCO 3.4.6 must be entered.

The purpose of the Action for CTS 3.7.4.1 is to ensure the inoperable SWS loop is restored to OPERABLE status within a reasonable time. This change is acceptable because it provides additional assurance that the appropriate compensatory actions are taken for an inoperable emergency diesel generator or decay heat removal loop that result from a loss of an SWS loop. This change is designated as more restrictive because it adds the explicit cascading requirement.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type I - Removing Details of System Design and System Description, Including Design Limits) CTS 3.7.4.1 states that two "independent" SWS loops shall be OPERABLE. ITS 3.7.8 requires two SWS loops to be OPERABLE, but does not contain the detail that the loops must be independent. This changes the CTS by moving the detail that the SWS loops are independent to the Bases.

The removal of these details, which are related to system design, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement for two SWS loops to be OPERABLE. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LA02 (Type I - Removing Details of System Design and System Description, Including Design Limits) CTS 4.7.4.1.b.1 and 4.7.4.1.b.2 require verification of the automatic actuation of SWS components on an "SFAS" test signal. ITS SR 3.7.8.2 and SR 3.7.8.3 do not state the specific type of signal, but only specify an actual or simulated "actuation" signal. This changes CTS by moving the type of actuation signal (i.e., SFAS) to the Bases.

The removal of these details, which are related to system design, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate Davis-Besse Page 2 of 4 Attachment 1, Volume 12, Rev. 0, Page 189 of 461

Attachment 1, Volume 12, Rev. 0, Page 190 of 461 DISCUSSION OF CHANGES ITS 3.7.8, SERVICE WATER SYSTEM (SWS) protection of public health and safety. The ITS still retains the requirement to verify that appropriate equipment actuates upon receipt of an actuation signal.

Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5 of the ITS. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L01 (Category 6- Relaxation Of Surveillance Requirement Acceptance Criteria)

CTS 4.7.4.1 .b.1 and 4.7.4.1 .b.2 require verification of the automatic actuation of SWS components on an SFAS "test" signal. ITS SR 3.7.8.2 and SR 3.7.8.3 specify that the signal may be from either an "actual" or simulated (i.e., test) signal. This changes the CTS by explicitly allowing the use of either an actual or simulated signal for the test.

The purpose of CTS 4.7.4.1 .b.1 and 4.7.4.1 .b.2 is to ensure the SWS components operate correctly upon receipt of an actuation signal. This change is acceptable because it has been determined that the relaxed Surveillance Requirement acceptance criteria are not necessary for verification that the equipment used to meet the LCO can perform its required functions. Equipment cannot discriminate between an "actual," "simulated," or "test" signal and, therefore, the results of the testing are unaffected by the type of signal used to initiate the test. This change allows taking credit for unplanned actuation if sufficient information is collected to satisfy the Surveillance test requirements.

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

L02 (Category5 - Deletion of Surveillance Requirement) CTS 4.7.4.1 .b.1 requires verification that each SWS automatic valve in the flow path actuates to its correct position. ITS SR 3.7.8.2 requires verification that each SWS automatic valve in the flow path "that is not locked, sealed, or otherwise secured in position" actuates to the correct position. This changes the CTS by excluding those SWS automatic valves that are locked, sealed, or otherwise secured in position from the verification.

The purpose of CTS 4.7.4.1 .b.1 is to provide assurance that if an event occurred requiring the SWS valves to be in their correct position, then those requiring automatic actuation would actuate to their correct position. This change is acceptable because the deleted Surveillance Requirement is not necessary to verify that the equipment used to meet the LCO can perform its required functions. Thus, appropriate equipment continues to be tested to in a manner and at a Frequency necessary to provide confidence that the equipment can perform its assumed safety function. Those automatic valves that are locked, sealed, or otherwise secured in position are not required to actuate on an SWS actuation signal in order to perform their safety function because they are already Davis-Besse Page 3 of 4 Attachment 1, Volume 12, Rev. 0, Page 190 of 461

Attachment 1, Volume 12, Rev. 0, Page 191 of 461 DISCUSSION OF CHANGES ITS 3.7.8, SERVICE WATER SYSTEM (SWS) in the required position. Testing such valves would not provide any additional assurance of OPERABILITY. Valves that are required to actuate will continue to be tested. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

Davis-Besse Page 4 of 4 Attachment 1, Volume 12, Rev. 0, Page 191 of 461

Attachment 1, Volume 12, Rev. 0, Page 192 of 461 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 12, Rev. 0, Page 192 of 461

Attachment 1, Volume 12, Rev. 0, Page 193 of 461 CTS SWS 3.7.8 3.7 PLANT SYSTEMS 3.7.8 Service Water.System (SWS) 3.7.4.1 LCO 3.7.8 Two SWS F shall be OPERABLE. 0 APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME Action

-4 1~ 0 A. One sWS A.1 ----------- NOTES------------

inoperable. 1. MEnter applicable Conditions and 0

Required Actions of LCO 3.8.1, "AC Sources - Operating,"

for emergency diesel generator made inoperable by SWS.

2. MEnter (pplicable 00 Conditions and Required Actions of LCO 3.4.6, "RCS Loops

- MODE 4," for decay heat removal -

inoperable by SWS.

- 0 1 11 Restore SWS OE50 OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 0 Action B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time o met.

on not AND 0

B.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months BWOG STS 3.7.8-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 193 of 461

Attachment 1, Volume 12, Rev. 0, Page 194 of 461 CTS SWS 3_7 8 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.7.4.1.a SR 3.7.8.1 -........-------.------ . NOTE-Isolation of SWS flow to individual components does not render.the SMV inoperable.

Verify each SWS manual, power operated, and 31 days automatic valve in the flow path servicing safety related equipment, that is not locked, sealed, or otherwise secured in position, is in the correct position.

4.7.4.1.b.1 SR 3.7.8.2 Verify each SMS automatic valve in the flow path that is not locked, sealed, or otherwise secured in

[8] months 24 0

position, actuates to the correct position on an actual or simulated actuation signal.

Fre~qrdý 00 4.7.4.1.b.2 SR 3.7.8.3 er each WS pump starts automatically on an 8] months actual or simulated actuation signal. 24 "k;?

BWOG STS 3.7.8-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 194 of 461

Attachment 1, Volume 12, Rev. 0, Page 195 of 461 JUSTIFICATION FOR DEVIATIONS ITS 3.7.8, SERVICE WATER SYSTEM (SWS)

1. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant specific nomenclature.

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

3. Editorial changes made for clarity and to be consistent with the terminology in ITS 3.4.6.

4. Since Condition B applies to all Conditions in the ACTIONS Table, the term "of Condition A" is not necessary. This is consistent with the writer's guide for the Improved Standard Technical Specifications, TSTF-GG-05-01, Section 4.1.6.i.5.ii.

5. The Davis-Besse design includes a spare SWS pump that can be substituted for one of the normal SWS pumps. Therefore SR 3.7.8.3 has been modified to only require the "required" SWS pumps to be tested. This is consistent with the use of the word required in the ITS, as discussed the Improved Standard Technical Specifications, TSTF-GG-05-01, Section 4.1.3.

6. Typographical error corrected.

Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 195 of 461

Attachment 1, Volume 12, Rev. 0, Page 196 of 461 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 12, Rev. 0, Page 196 of 461

Attachment 1, Volume 12, Rev. 0, Page 197 of 461 I All changes are unless otherwise noted E

SwS B 3.7.8 B 3.7 PLANT SYSTEMS B 3.7.8 Service Water System (SWS)

BASES BACKGROUND The SWS provides a heat sink for the removal of process and operating heat from safety related components during a t Accident (DBA) or transient. During normal operation and normal Design Basis 0

shutdown, the SWS also provides this function for various safety related and nonsafety related components. The safety related covered by this LCO.

jis 0

[ INSET 1 ]waterý traiZs Each train consiists f a 100% capacity pump, one

,An SC omnnt coolingofwater cFnits (CCV heat two separate, exchanger,

'O0% capacity piping, valving,cooling/

safety rela4ted and/

instruryenltation.j The pumps and valves are remote manually aligned except in the unlikely event of a loss of coolant accident (LOCA). The and.....

pumps are automatically started upon receipt of a safety featurectuation non-essential signal, and all essential valves are aligned to their post accident positions.#' loads are isolated The SWSas provides cooling i to the Control Room Emergency Ventilation System water cooled condensing unit, the Emergency Core s Cooling System (ECCS) pump room coolers, containment air coolerrand Component Cooling Water System heat exchangers ur me riven coo)fng water7sstems[pump also a sourceo water to the IThe system pro 'des cooling and is and the eergency feedwater 0

__________________________pumps, apl can provide a urce of makeup wate to the cooling tower.

The SWS provides a backup source of water to the Auxiliary Additional information about the design and operation of the SWS, along [

Feedwater System and the Motor .

Driven Feedwater Pump. with a list of the components served, is presented in the SAR, Section N9.2.1 *(Ref. 1). The principal safety related function of the SWS 2 Systern.

is the removarof decay heat from the reactor via the TCCW APPLICAE3LE The design basis of the SWS is for one SWS UHin conjunction with the l SAFETY CCW System and a 100% capacity containment cooling system, ANALYSE .S (containment spray, containment air coolers, or a combination) to remove J core decay heat following a design basis LOCA, as discussed in the

' FSAR, SectionMS.2M (Ref. 2). This provides for a gradual reduction in the temperature of this fluid, as it is supplied to the Reactor Coolant System 0 (RCS) by the afetnjection pumps.

The SWS is designed to perform its function with a single failure of any active component, assuming loss of offsite power.

BWOG STS B 3.7.8-1 Rev. 3.0, 03131104 Attachment 1, Volume 12, Rev. 0, Page 197 of 461

Attachment 1, Volume 12, Rev. 0, Page 198 of 461 B 3.7.8 0 INSERT 1 The SWS consists of three pumps and two independent essential load cooling loops.

Each essential load cooling loop is supplied by one of three pumps. One pump normally supplies the essential loads for its associated loop, and the second pump supplies the essential loads for its associated loop and all the non-essential loads.

Three pumps are provided so that any one of the pumps can be removed from service for maintenance or repair without reducing the capability or redundancy of the SWS.

Two of the SWS pumps are powered from the associated essential bus. The third SWS pump can be powered from either essential bus through interlocked supply breakers and can manually be aligned to supply either SWS loop.

Insert Page B 3.7.8-1 Attachment 1, Volume 12, Rev. 0, Page 198 of 461

Attachment 1, Volume 12, Rev. 0, Page 199 of 461 I

All changes are unless otherwise noted 9 SWS B 3.7.8 BASES APPLICABLE SAFETY ANALYSES (continued)

The SWS, in conjunction with the CCW System, also cools the unit from Decay Heat Removal (DHR) as discussed in the' Section 1M.3E (Ref. :3) Jentry conditions to MODE 5 (luring normal a-nd po-s-t laccident fopeatn-The time required for this evolution is a function 2 _ýofp the number of CCW and DHR System 2fthat are operating. One SWS train is sufficient to remove decay heat during subsequent ainitial with Tcod < 200°F operation in MO temperature of r S 5 and 61 This assumesaWS F occurring simultaneously with maximum heat loads 0 on the system. 0 The SWS is also required when needed to support CCW in the removal of heat from the emergency diesel generators (EDGs) or reactor auxiliaries.

The SWS satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO Two SWS rin are required to be OPERABLE to provide the required redundancy to ensure that the system functions to remove post accident heat loads, assuming the worst case single active failure occurs coincident with the loss of offsite power.

EKAnS ý is considered OPERABLE when:

a. It has an OPERABLE pump6-'d-i 0

b. The associated piping, valves, 1heat chang and instrumentation and controls required to perform the safety related function are 1

OPERABLE.

APPLICABILITY In MODES 1, 2, 3, and 4, the SWS is a normally operating system that is required to support the OPERABILITY of the equipment serviced by the SWS and required to be OPERABLE in these MODES.

In MODES 5 and 6, the OPERABILITY requirements of the SWS are determined by the systems it supports.

ACTIONS A.1 Zone sw ris inoperable, action must be taken to restore l OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . In this Pondition, the remaining OPERABLE S r i is adequate to perform the heat removal function-00 However, the overall reliability is reduced because a single failure in the BWOG STS B 3.7.8-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 199 of 461

Attachment 1, Volume 12, Rev. 0, Page 200 of 461 B 3.7.8 0 INSERT 2 Furthermore, the spare SWS pump can be substituted for a normal SWS pump, provided the power supply for the pump is aligned to the same essential bus as the pump it is replacing.

Insert Page B 3.7.8-2 Attachment 1, Volume 12, Rev. 0, Page 200 of 461

Attachment 1, Volume 12, Rev. 0, Page 201 of 461 B 3.7.8 SWS B 3.7.8 BASES ACTIONS (continued)

OPERABLE in could result in loss of SWS function. Required Action A.1 is modified by two Notes. The first Note indicates that the applicable Conditions and Required Actions of LCO 3.8.1 "AC Sources -

Operating," should be entered if an inoperable SWS trl_.re-sults in an inoperable EDG. The second Note indicates that the applicable Conditions and Required Actions of LCO 3.4.6, "RCS Loops - MODE 4,"

should be entered if an inoperable SWS r results in an inoperable l tr inThe 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is based on the redundant capabilities afforded by the OPERABLE in and the low probability of a DBA occurring during this period. -'

B.1 and B.2 Ifthe SWS cannot be restored to OPERABLE status within the associated Completion Time, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

SURVEILLANCE SR 3.7.8.1 REQUIREMENTS Verifying the correct alignment for manual, power operated, and automatic valves in the SWS flow path provides assurance that the proper flow paths exist for SWS operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since they are verified to be in the correct position prior to locking, sealing, or securing. This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of potentially being mispositioned are in the correct position. This SR also does not apply to valves that cannot be inadvertently misaligned, such as check valves.

The 31 day Frequency is based on engineering judgment, is consistent with the procedural controls governing valve operation, and ensures correct valve positions.

This SR is modified by a Note indicating that the isolation of the SWS components or systems may render those components inoperable but does not affect the OPERABILITY of the SWS.

BWOG STS B 3.7.8-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 201 of 461

Attachment 1, Volume 12, Rev. 0, Page 202 of 461 SWS B 3.7.8 BASES SURVEILLANCE REQUIREMENTS (continued) on an actual or simulated actuation (i.e., SFAS) signal C'D -270' The SR verifies proper automatic operation of the SWS valves/The SWS is a normally operating system that cannot be fully actuated as part of the 00 normal testing. This SR is not required for valves that are locked, sealed, or otherwise secured in position under administrative controls. The 8] month Frequency is based on the need to perform this Surveillance 0

udr the conditions that apply during a unit outage and the potential for an unplanned transient if the Surveillance were performed with the 24 reactor at power. Operating experience has shown that these components usually pass the Surveillance when performed at the M month Frequency. Therefore, the Frequency is acceptable from a 0 reliability standpoint.

SR 3.7.8.3 The SR verifies proper automatic operation of the SWS pumps on an

( actual or simulatedjctuation signal. The SWS is a normally operating 0

system that cannot be fully actuated as part of normal testing during normal operation. Tht 8]month Frequency is based on the need to 0

24 perform this Surveillance under the conditions that apply during a unit outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown that these components usually pass the Surveillance when performed at a 18 month Frequency. Therefore, the Frequency is 0

acceptable from a reliability standpoint.

REFERENCES r*I.FFSAR, Section P.2. IM 2.'*FSAR, SectionN6.21 00 3'* FSAR, Section [

BWOG STS B 3.7.8-4 Rev. 3,0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 202 of 461

Attachment 1, Volume 12, Rev. 0, Page 203 of 461 JUSTIFICATION FOR DEVIATIONS ITS 3.7.8 BASES, SERVICE WATER SYSTEM (SWS)

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

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

3. These punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, TSTF-GG-05-01, Section 5.1.3.

4. Changes made to reflect changes made to the Specification.

5. Typographical error corrected.

6. Changes made to be consistent with the Specification.

7. While the SWS does provide a source of water to the cooling tower, it is not required for OPERABILITY of the SWS. Therefore, the description has been deleted.

8. Change made to be consistent with the CCW System Bases.

Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 203 of 461

Attachment 1, Volume 12, Rev. 0, Page 204 of 461 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 12, Rev. 0, Page 204 of 461

Attachment 1, Volume 12, Rev. 0, Page 205 of 461 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.7.8, SERVICE WATER SYSTEM (SWS)

There are no specific NSHC discussions for this Specification.

Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 205 of 461

, Volume 12, Rev. 0, Page 206 of 461 ATTACHMENT 9 ITS 3.7.9, ULTIMATE HEAT SINK (UHS) , Volume 12, Rev. 0, Page 206 of 461

, Volume 12, Rev. 0, Page 207 of 461 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 12, Rev. 0, Page 207 of 461

Attachment 1, Volume 12, Rev. 0, Page 208 of 461 ITS 3.7.9 ITS PLANT SYSTEMS 3/4.7.5 ULTIMATE BEAT SINK LIMITING CONDITION FOR OPERATION LCO 3.7.9 3.7.5.1 The ultimate heat sink shall be OPERABLE with:

SR 3.7.9.1 a. A minimum water level at or above elevation 562;0 feet International Great Lakes Datum, and SR 3.7.9.2 b. An average water temperature of < 900 F. I APPLICABILITY: MODES 1, 2, 3 and 4.

ACTION:

ACTION A With the requirements of the above specification not satisfied, be in at least HOT STANDBY within .5hours and in COLD SHUTDOWN within the f,1wing 30[hours.

S~

SURVEILLANCE REQUIREMENTS SR 3.7.9.1, 4.7.5.1 The ultimate heat sink shall be determined OPERABLE at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months by SR 3.7.9.2 verifying the average water temperature and water level to be within their limits.

DAVIS-BESSE, UNIT I 3/4 7-16 Amendment No. 242 Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 208 of 461

Attachment 1, Volume 12, Rev. 0, Page 209 of 461 DISCUSSION OF CHANGES ITS 3.7.9, ULTIMATE HEAT SINK (UHS)

ADMINISTRATIVE CHANGES A01 In the conversion of the Davis-Besse Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1430, Rev. 3.1, "Standard Technical Specifications-Babcock and Wilcox Plants" (ISTS).

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

MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES L01 (Category 1 - Relaxation of LCO Requirements) The CTS 3.7.5.1 Action states to be in HOT STANDBY in 2.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months and in COLD SHUTDOWN in the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months when the UHS is inoperable. ITS 3.7.9 ACTION A states to be in MODE 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in MODE 5 in 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months when the UHS is inoperable.

This changes the CTS by providing an additional 3.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months to be in MODE 3 and in MODE 5.

The purpose of the CTS 3.7.5.1 Action time limit to reach MODE 3 and MODE 5 is to provide an appropriate amount of time for the unit to be cooled down to MODE 5 conditions, via MODE 3, in a controlled manner. This change is acceptable because the proposed time is still limited, and provides additional time to reach MODES 3 and 5 in an orderly manner and without challenging plant systems. Furthermore, the proposed time is consistent with the time normally provided to reach MODE 3 from MODE 1 and MODE 5 from MODE 4 in other CTS Specifications, such as CTS 3.0.3. This change is designated as less restrictive since more time is provided in the ITS to reach MODE 5 than is provided in the CTS.

Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 209 of 461

Attachment 1, Volume 12, Rev. 0, Page 210 of 461 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 12, Rev. 0, Page 210 of 461

Attachment 1, Volume 12, Rev. 0, Page 211 of 461 CTS UHS 3.7.9 3.7 PLANT SYSTEMS 3.7.9 Ultimate Heat Sink (UHS) 3.7.5.1 LCO 3.7.9 'The UHS shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. [One or mor cooling A.1 estore cooling towe 7 days]

towers with )ne cooling tower fan i operable.

fan(s) to OPERABL status. 0

,orI/ __ I i -1 REVIEWER'S OTE ----- B.1 The [ ]°F is the ma imum Verio water temperature of the HS is [90]aF O Once per hour] 0 allowed U HS temprature aver ged over the previous value and is base on 24 ur period.

temperature limita ions of the equipment tha is relied upon for accident itigation and safe shutdo of the unit.

B. [ Water temr erature of 0

the UHS>[ Of Fand t[]F ACTION [Required Actio/and associated Co pletion

.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 00 Time of Con ion A or B AND not met.

2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months OR] /

UHS inoperable r[-

reaso)s other tl.nj Condition A or/B]

BWOG STS 3.7.9-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 211 of 461

Attachment 1, Volume 12, Rev. 0, Page 212 of 461 CTS UHS 3.7.9 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 3.7.5.1.a.

4.7.5.1 SR 3.7.9.1 Verify water level of UHS is _>562*jft m 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months sm 0 MeLIl* ." FInternational Great Lakes Datum r 3.7.5.1.b, 4.7.5.1 SR 3.7.9.2 @Verify average water temperature of UHS is 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 0 ISR 3.7.9.3 [Operate each cooling-tower fan for> [15] rr*utes.

S--.....-..-.....

J 31 I..

days]7 0 BWOG STS 3.7.9-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 212 of 461

Attachment 1, Volume 12, Rev. 0, Page 213 of 461 JUSTIFICATION FOR DEVIATIONS ITS 3.7.9, ULTIMATE HEAT SINK (UHS)

1. The Davis-Besse cooling tower is not part of the Ultimate Heat Sink. Therefore, this ACTION and Surveillance Requirement are not included in the Davis-Besse ITS.

Subsequent ACTIONS have been renumbered due to this deletion, and the first Condition of ISTS 3.7.9 Condition C has been deleted and the second condition of ISTS 3.7.9 Condition C has been modified.

2. The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed in to what is needed to meet this requirement. This is not meant to be retained in the final version of the plant specific submittal. In addition, the Davis-Besse Ultimate Heat Sink (UHS) analysis does not provide for averaging the UHS (intake temperature) over a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period. The analysis assumes the initial intake temperature is - 90°F. Therefore the ACTION to verify UHS temperature averaged over 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is not included in the Davis-Besse ITS. Subsequent ACTIONS have been renumbered due to this deletion, and the first Condition of ISTS 3.7.9 Condition C has been deleted and the second condition of ISTS 3.7.9 Condition C has been modified.

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

Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 213 of 461

Attachment 1, Volume 12, Rev. 0, Page 214 of 461 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 12, Rev. 0, Page 214 of 461

Attachment 1, Volume 12, Rev. 0, Page 215 of 461 UHS B 3.7.9 B 3.7 PLANT SYSTEMS B 3.7.9 Ultimate Heat Sink (UHS)

BASES BACKGROUND The UHS provides a heat sink for process and operating heat from safety related components during a transient or accident as well as during normal operation. This is done utilizing the Service Water System (SWS).

The U HS has been defined as that complex of water sources, including necessary retaining structures (e.g., a pond with its dam, or a river with its dam), and the canals or conduits connecting the sources with, but not r

~'FSAR, including, the cooling water system intake structures, as discussed in the Sectionp.2.5 (Ref. 1). /If coo ig towers or portions teeo thej required to acco.,yplish the UHS sa,,t y functions, they hudle are 00 same requirerr)6nts as thM in. Teto principal functions of the IUHS 0 are the dissipation of residual heat after a reactor shutdown, and dissipation of residual heat after an accident.

A variety of co plexes is used to mee the requirements f r a UHS. A INSERT 1

lake or an ocea may qualify as a sin le source. Ifthe coirnplex includes a water source ontained by a structure, it is likely that a *econd source 0 The basic perf rmance requirements are that a 30 day s pply of water be available, and hat the design basis t mperatures of safe related equipment not be exceeded. Basins of cooling towers g nerally include less than a 30 day supply of water, t pically 7 days or le s. A 30 day supply would e dependent on anot er source(s) and a akeup system(s) for eplenishing the sourc in the cooling tow r basin. For smaller basin sources, which may b1 as small as a 1 d supply, the systems for r plenishing the basin nd the backup sour e(s) become of sufficient imp rtance that the make p system itself mar be required to meet the sa e design criteria as a Engineered Safety Feature (e.g.,

single failure considerations and m Itiple makeup wate sources may be re uired .

Additional information on the design and operation of the system, along with a list of components served, can be found in Reference 1.

BWOG STS B 3.7.9-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 215 of 461

Attachment 1, Volume 12, Rev. 0, Page 216 of 461 B 3.7.9 0 INSERT 1 The ultimate heat sink is Lake Erie, and is the source of cooling water for the Service Water System. This is the single source for the ultimate heat sink, and the most severe natural phenomenon that can occur does not prevent a safe shutdown of the reactor. The Seismic Class I portion of the intake forebay provides adequate storage that is capable of providing sufficient cooling for at least 30 days. Procedures for ensuring a continued capability after this time are available. The ultimate heat sink provides adequate cooling for at least 30 days. An earthquake, which may result in loss of the source of lake water to the intake forebay, is the most severe event. This occurrence does not cause loss of the ultimate heat sink safety functions. The occurrence of extremely low lake level, which reduces the quantity of available water in the forebay, in conjunction with loss of the canal, was considered. The lowest level was assumed for the analysis, and this condition does not preclude the ultimate heat sink from performing its safety functions. The collapse of the intake pipe or complete closure of the canal was postulated for the analysis. It is demonstrated that additional sources of water are not required since the stored water in the forebay is adequate for safe shutdown. With regards to the amount of conservatism available for dissipating heat loads, the design of the ultimate heat sink is also consistent with the recommendations of Regulatory Guide 1.27, Revision 1 (Ref. 2).

Insert Page B 3.7.9-1 Attachment 1, Volume 12, Rev. 0, Page 216 of 461

Attachment 1, Volume 12, Rev. 0, Page 217 of 461 UHS B 3.7.9 BASES APPLICABLE The UHS is the sink for heat removal from the reactor core following all SAFETY accidents and anticipated operational occurrences in which the unit is at ANALYSES swapover to the containment cooled down and placed on Mecay heat removal Its maximum post accident

ý heat load occurs-approxi0y 20 minuteslafter a design basis Q20 emergency sump lossof coolant accident (LOCA). JNear is trmeahe unit switches from injection to recirculation and the containment cooling systems are-This i wheJn required to remove the core decay heat.

The operating limits are based on conservative heat transfer analyses for the worst case LOCA. Reference 1 provides the details of the assumptions used in the analysis. These assumptions include: worst expected meteorological conditions, conservative uncertainties when calculating decay heat, and the worst case failure (e.g., single failure of a manmade structure). The UHS is designedlin ac9rdance with " consistent Regulatory Guide 1.27 (Ref. 2), which requires a 30 day supply of cooling I

0 water in the UHS.

The U HS satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO The UHS is required to be OPERABLE and is considered OPERABLE if

[it contains a sufficient volume of water at or below the maximum temperature~that would allow the SVtS to operate for at least 3b days 0

following the design basis LOCA without the loss of net positive suction head (NPSH), and without exceeding the maximum design temperature of the equipment served by the SWS. To meet this condition, the UHS 0 International Great Lakes Datum temperature should not exceed[9drF, and the level should not fall below R562M ft J[mear ea leve]l during normal unit operation. 0 APPLICABILITY In MODES 1, 2, 3, and 4, the UHS is a normally operating system that is required to support the OPERABILITY of the equipment serviced by the UHS and is required to be OPERABLE in these MODES.

In MODES 5 and 6, the OPERABILITY requirements of the UHS are determined by the systems it supports.

ACTIONS [ A.1 If one or more oling towers have o e fan inoperable (i., up to one fan per cooling to r inoperable), action ust be taken to re tore the 0

inoperable coo ing tower fan(s) to 0 ERABLE status wit in 7 days.

The 7 day Co pletion Time is reas nable, based on th low probability of an accident o urring during the 7 ys that one coolin tower fan is inoperable in ne or more cooling t wers, the number o available systems, an the time required to mplete the Requir d Action.]

BWOG STS B 3.7.9-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 217 of 461

Attachment 1, Volume 12, Rev. 0, Page 218 of 461 UHS B 3.7.9 BASES ACTIONS (continued)

B.1 REVIEWE 'S NOTE-The [ ]°F is th maximum allowed U S temperature valu and is based on temperatur limitations of the equ pment that is relied pon for 0

accident mitig ion and safe shutdo of the unit.

With water te perature of the UHS [90]'F, the design asis assumption associated wi initial UHS tempera re is bounded prov ed the temperature o the UHS averaged o er the previous 24 our period is

> [90] 0F. Wit the water temperatur of the UHS > [901 , long term cooling capa ility of the ECCS load and DGs may be a ected.

Therefore, to nsure long term cool ng capability is prov ded to the ECCS loads when ' ter temperature of th UHS is> [90]°F, quired Action B.1 is provid, d to more frequently nitor the water te nperature of the UHS and ver the temperature is [90]°F when avera ed over the previous 24 our period. The once per hour Completio Time takes into consideratio UHS temperature va iations and the incr ased monitoring frequency n eded to ensure desig basis assumptions nd equipment limitations a not exceeded in this condition. Ifthe wa er temperature of the UHS ex eds [90]'F when ave aged over the previ us 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period or the water temperature of the U S exceeds [ ]*F, C ndition C must be entered im diately.]

00 Ifthe *equired Actions and Compl tion Time of Condition [A o B] are not met

_orithe UHS is inoperable [foy'reasons other than Condit'6n A or B]T the unit must be placed in a MODE in which the LCO does not apply. To 0

achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. *1 0)

SURVEILLANCE REQUIREMENTS rSR 3.7.9.1 0

This SR verifies that adequate long term (30 days) cooling can be maintained. The level specified also ensures NPSH is available for operating the SV\S pumps. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency is based on operating experience related to the trending of the parameter variations during the applicable MODES. This SR verifies that the UHS water level is - ftl[mear ea leve]rT 0

z6 International Great Lakes Datum BWOG STS B 3.7.9-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 218 of 461

Attachment 1, Volume 12, Rev. 0, Page 219 of 461 UHS B 3.7.9 BASES SURVEILLANCE REQUIREMENTS (continued)

TSR 3.7.9.2 0 This SR verifies that the SWS can cool the CCW S stem to at least its maximum design temperature within the maximum accident or normal 0 heat loads for 30 days following a Design Basis Accident. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency is based on operating experience related to the trending of the parameter variations during the applicable MODES. This SR verifies that the UHS average water temperature is _<N9IF.[j 0

[SR 3.7.9.33 Operating ea cooling tower fan fo Z[15] minutes ens res that all fans 0 are OPERAB E and that all associ- ted controls are fun ioning properly.

It also ensure that fan or motor fail re, or excessive vi ration, can be detected for rrective action. The/31 day Frequency i based on operating ex erience, known relia tility of the fan units, the redundancy available, a d the low probability 4f significant degrad tion of the UHS coolina tow r fans occurrina between surveillances. 1 REFERENCES 1 Sectiond19.2.5 Re gulFSAR, '

00

2. Regulatory Guide .7 0

BWOG STS B 3.7.9-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 219 of 461

Attachment 1, Volume 12, Rev. 0, Page 220 of 461 JUSTIFICATION FOR DEVIATIONS ITS 3.7.9 BASES, ULTIMATE HEAT SINK (UHS)

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

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

3. Changes are made to reflect changes made to the Specification.

Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 220 of 461

Attachment 1, Volume 12, Rev. 0, Page 221 of 461 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 12, Rev. 0, Page 221 of 461

Attachment 1, Volume 12, Rev. 0, Page 222 of 461 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.7.9, ULTIMATE HEAT SINK (UHS)

There are no specific NSHC discussions for this Specification.

Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 222 of 461

Attachment 1, Volume 12, Rev. 0, Page 223 of 461 ATTACHMENT 10 ITS 3.7.10, CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS)

Attachment 1, Volume 12, Rev. 0, Page 223 of 461

, Volume 12, Rev. 0, Page 224 of 461 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 12, Rev. 0, Page 224 of 461

Attachment 1, Volume 12, Rev. 0, Page 225 of 461 IITS 3.7.10 PLANT SYSTEMS 3/4.7.6 CONTROL ROOM EMERGENCY VENTILATION SYSTEM LIMITING CONDITION FOR OPERATION LCO 3.7.10 3.7.6.1 Two [indep0'ndent control room emergency ventilation systems shall be OPERABLE. (D LA01 111 Add proposed LC0 Note 1 APPLICABILITY: MODES , 2, 3 and propose ApdlicabiNtey for reasons other than Condition B L-*

L ACTION A a. WVith one control room emergency ventilation system inoperable, restore the inoperable Asstem to OPERABLE status within 7 days oFr be in at least HOT STANDBY within the ACTION C [next-6 hours and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

[Add proposed ACTION EB3 0

b. With one channel of Station Vent Normal Range Radiation Monitoring instrumentation inoperable, restore the inoperable channel to OPERABLE status, or isolate the control room normal ventilation system and place at least one control room emergency ventilation system train in operation within 7 days. See.ITS 3.3.16

c. With inoperable, within I of both channels Station hour, Vent Normal Range Radiation Monitoring instrumentation isolate the control room normal ventilation system and place at 0 I least one control room emergency ventilation system train in operation.

- -[~~Add proposedAC I,OC D}7Ad proose A ,O SURVEILLANCE REQUIREMENTS Add proposed ACTION1 4.7.6.1 Each control room emergency ventilation system shall be demonstrated OPERABLE:

a. At least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months by verifying that the control room air temperature is less than-or equal to 11 0IF when the control room emergency ventilation ýystem is operating. I *

[ se3I.S ]

SR 3.7.10.1 b. At least once per 31 days on a STAGGE D TEST BASIS Py i itiating, from the-..........-- "

[c-ontrol room, flow tl'rough the HEPA filters and charcoal adsorl~ers and Fer~fthat' A0 the system operates for at least 15 minutes.

SR 3.7.10.2 c. At least once each REFUELING INTERVAL and in accordance with the Ventilation Filter Testing Program (VFTP).

DAVIS-BESSE, UNIT 1 3/4 7-17 Amendment No. 135, 155,217,227, 244, Page 1 of 3 Attachment 1, Volume 12, Rev. 0, Page 225 of 461

Attachment 1, Volume 12, Rev. 0, Page 226 of 461 FS 3.7.10 ITS PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

1. [Deleted]

2. [Deleted]

3. [Deleted]

d. [Deleted]

e. At least once each REFUELING INTERVAL by:

I. [Deleted] 7J77.. E tution SR 3.7.10.3 2. Verifying that the control room normal ventilation system is isolated by a SF S est signal and a Station Vent Normal &eRadiation Monitoring est signal; and DAVIS-BESSE, UNIT I 3/4 7-18 Amendment No. 134, 135, 155, 209, 217,227, 244, Page 2 of 3 Attachment 1, Volume 12, Rev. 0, Page 226 of 461

Attachment 1, Volume 12, Rev. 0, Page 227 of 461 ITS 3.7.10 ITS PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

SR 3.7.10.5 3. Verifying that the makeup flow of the system is 300 cfm +/- 10% when supplying the control room with outside air.

f. [Deleted] I

g. [Deleted]

Addprposed SR371 -LO I

DAVIS-BESSE, UNIT I 3/4 7-19 Amendment No. 155, 244, Page 3 of 3 Attachment 1, Volume 12, Rev. 0, Page 227 of 461

Attachment 1, Volume 12, Rev. 0, Page 228 of 461 DISCUSSION OF CHANGES ITS 3.7.10, CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS)

ADMINISTRATIVE CHANGES A01 In the conversion of the Davis-Besse Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1430, Rev. 3.1, "Standard Technical Specifications-Babcock and Wilcox Plants" (ISTS).

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

A02 CTS 3.7.6.1 does not provide an Action for two CREVS trains inoperable. Thus, CTS LCO 3.0.3 would be required to be entered. ITS 3.7.10 ACTION E requires immediate entry into ITS LCO 3.0.3 when two CREVS trains are inoperable in MODE 1, 2, 3, or 4 for reasons other than Condition B. Condition B covers the inoperability of one or more CREVS trains due to an inoperable control room envelope (CRE) boundary in MODE 1, 2, 3, or 4. This changes the CTS by providing a specific ACTION for two inoperable CREVS trains for reasons other than due to an inoperable CRE boundary. The change to allow one or more CREVS trains to be inoperable due to a CRE boundary is discussed in DOC L01.

The purpose of ITS 3.7.10 ACTION E is to require immediate entry into ITS LCO 3.0.3 when two CREVS trains are inoperable for reasons other than due to an inoperable CRE boundary. If two CREVS trains were inoperable in MODE 1, 2, 3, or 4, then CTS LCO 3.0.3 would be entered because there is no other Action in CTS 3.7.6.1 that fits this condition. This change is acceptable because this same action is required in the CTS (except for the change discussed in DOC L01). This change is designated as administrative because it does not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES M01 The CTS does not have any requirements for the Control Room Emergency Ventilation System during movement of irradiated fuel assemblies. ITS 3.7.10 Applicability includes "During movement of irradiated fuel assemblies." ITS 3.7.10 LCO Note 2 clarifies that only the CRE boundary is required to be OPERABLE during this new Applicability. ITS 3.7.10 ACTION D provides compensatory measures when the CRE boundary is inoperable during movement of irradiated fuel assemblies. This changes the CTS by adding additional Applicability criteria and an associated ACTION.

The purpose of ITS 3.7.10 is to provide assurance that the CREVS is OPERABLE when required to perform its function. Only the CRE boundary portion of the CREVS is required during movement of irradiated fuel assemblies.

The fuel handling accident analyses assumes only the control room is isolated; the CREVS trains are not assumed. This change is acceptable because it provides this Applicability with an associated ACTION to provide additional assurance that the CRE boundary is available to perform its function when required. This change is designated as more restrictive because it adds a new Applicability for the CRE boundary with an associated ACTION.

Davis-Besse Page 1 of 6 Attachment 1, Volume 12, Rev. 0, Page 228 of 461

Attachment 1, Volume 12, Rev. 0, Page 229 of 461 DISCUSSION OF CHANGES ITS 3.7.10, CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS)

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.7.6.1 states that two "independent" control room emergency ventilation systems shall be OPERABLE. ITS LCO 3.7.10 states that two CREVS trains shall be OPERABLE. This changes the CTS by moving the details that the CREVS trains are "independent" from the CTS to the Bases.

The removal of these details, which are related to system design, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement that two CREVS trains be OPERABLE. The details concerning the independence of the trains do not need to appear in the Specification in order for the requirement to apply. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LA02 (Type 3 - Removing ProceduralDetails for Meeting TS Requirements or Reporting Requirements) CTS 4.7.6.1 .b states that each CREVS train shall be demonstrated OPERABLE by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that the train operates for a least 15 minutes. ITS SR 3.7.10.1 states to operate each CREVS train for

> 15 minutes. This changes the CTS by moving the details of how the Surveillance is conducted to the Bases.

The removal of these details for performing Surveillance Requirements from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement to periodically operate the CREVS trains. Also, this change is acceptable because these types of procedural details will be adequately controlled in the ITS Bases.

Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications.

LA03 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 4.7.6.1 .e.2 requires verification of the automatic isolation of the Control Room Normal Ventilation System on an "SFAS" test signal and a Davis-Besse Page 2 of 6 Attachment 1, Volume 12, Rev. 0, Page 229 of 461

Attachment 1, Volume 12, Rev. 0, Page 230 of 461 DISCUSSION OF CHANGES ITS 3.7.10, CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS)

"Station Vent Normal Range Radiation monitoring" test signal. ITS SR 3.7.10.3 does not state the specific type of signal, but only specifies an actual or simulated "actuation" signal. This changes CTS by moving the type of actuation signal (i.e., SFAS and Station Vent Normal Range Radiation Monitoring) to the Bases.

The removal of these details, which are related to system design, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement to verify that appropriate equipment isolates upon receipt of an actuation signal.

Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5 of the ITS. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Specification.

LESS RESTRICTIVE CHANGES L01 (Category 4 - Relaxation of Required Action) CTS 3.7.6.1 requires two CREVS trains to be OPERABLE. Included as part of the OPERABILITY of the CREVS trains is the control room envelope (CRE) boundary. CTS 3.7.6.1 Action a provides the actions for when one CREVS train is inoperable, however no actions are provided when both trains are inoperable, such as when the CRE boundary is inoperable. In this situation, CTS 3.0.3 must be entered, which requires a unit shutdown. In addition, CTS 3.7.6.1 does not address the CRE boundary being opened intermittently (such as for routine entry and exit) under administrative controls. ITS LCO 3.7.10 also requires the two CREVS trains to be OPERABLE, however Note 1 to the LCO is included that allows the control room envelope (CRE) boundary to be opened intermittently under administrative controls. ITS 3.7.10 ACTION B provides actions for when the CRE boundary is inoperable in MODE 1, 2, 3, or 4. The action allows up to 90 days to restore the CRE boundary before requiring a unit shutdown. Also, ITS SR 3.7.10.4 is added to verify the OPERABILITY of the CRE boundary by testing for unfiltered air inleakage past the CRE boundary and into the CRE, in accordance with the Control Room Envelope Habitability Program. The program details are discussed in the Discussion of Changes for ITS 5.5. This changes the CTS by allowing the CRE boundary to be opened intermittently under administrative controls and not consider both CREVS trains to be inoperable and provides time to restore an inoperable CRE boundary prior to requiring a unit shutdown.

The purpose of CTS 3.7.6.1 is to ensure the CREVS remains OPERABLE to support the safety analyses. Davis-Besse proposes to establish new ACTION requirements in ITS 3.7.10 for an inoperable CRE boundary. Currently, if one CREVS train is determined to be inoperable due to an inoperable CRE boundary, CTS 3.7.6.1 Action a would apply and require restoring the train (and the CRE boundary) to OPERABLE status in 7 days. If two trains are determined to be inoperable due to an inoperable CRE boundary, no CTS 3.7.6.1 Actions are Davis-Besse Page 3 of 6 Attachment 1, Volume 12, Rev. 0, Page 230 of 461

Attachment 1, Volume 12, Rev. 0, Page 231 of 461 DISCUSSION OF CHANGES ITS 3.7.10, CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS) provided, thus immediate entry into the shutdown actions of CTS 3.0.3 is required. These existing Actions are more restrictive than would be appropriate in situations for which implementation of compensatory measures or mitigating actions would temporarily afford adequate CRE occupant protection from postulated airborne hazards. To account for such situations, Davis-Besse proposes to revise the action requirements to add ITS 3.7.10 ACTION B, whose entry condition is "One or more CREVS trains inoperable due to inoperable CRE boundary in MODE 1, 2, 3, or 4." ITS 3.7.10 Required Action B.3 would allow 90 days to restore the inoperable CRE boundary (and consequently, the affected CREVS trains) to OPERABLE status, provided that mitigating actions are immediately implemented (ITS 3.7.10 Required Action B.1) and within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months are verified to ensure, that in the event of a DBA, CRE occupant radiological exposures will not exceed the calculated dose of the licensing basis analyses of DBA consequences, and that CRE occupants are protected from hazardous chemicals and smoke (ITS 3.7.10 Required Action B.2). The 24-hour Completion Time of ITS 3.7.10 Required Action B.2 is reasonable based on the low probability of a DBA occurring during this time period, and the use of mitigating actions. The 90-day Completion Time of ITS 3.7.10 Required Action B.3 is reasonable based on the determination that the mitigating actions will ensure protection of CRE occupants within analyzed limits while limiting the probability that CRE occupants will have to implement protective measures that may adversely affect their ability to control the reactor and maintain it in a safe shutdown condition in the event of a DBA. The 90-day Completion Time of ITS 3.7.10 Required Action B.3 is also a reasonable time to diagnose, plan and possibly repair, and test most anticipated problems with the CRE boundary.

Therefore, the addition of ITS 3.7.10 ACTION B is acceptable.

To distinguish ITS 3.7.10 Condition B from the existing condition for one CREVS train inoperable, CTS 3.7.6.1 Action a is revised as shown in ITS 3.7.10 Condition A to state One CREVS train inoperable "for reasons other than Condition B." To distinguish ITS 3.7.10 Condition B from ITS 3.7.10 Condition E, which was added as described in DOC A02, ITS 3.7.10 Condition E states Two CREVS trains inoperable in MODE 1, 2, 3, or 4 "for reasons other than Condition B." The changes to CTS 3.7.6.1 Action a and CTS 3.0.3 (which is the action to enter when both CREVS trains are inoperable) are less restrictive because these Actions will no longer apply in the event one or two CREVS trains are inoperable due to an inoperable CRE boundary. This is acceptable because ITS 3.7.10 ACTION B establishes adequate remedial measures in this condition.

Davis-Besse also proposes to modify CTS 3.7.6.1 by adding a Note (ITS LCO 3.7.10 Note 1) allowing the CRE boundary to be opened intermittently under administrative controls. As stated in the ITS 3.7.10 LCO Bases, this Note "only applies to openings in the CRE boundary that can be rapidly restored to the design condition, such as doors, hatches, floor plugs, and access panels. For entry and exit through doors, the administrative control of the opening is performed by the person(s) entering or exiting the area. For other openings, these controls should be proceduralized and consist of stationing a dedicated individual at the opening who is in continuous communication with operators in the CRE. This individual will have a method to rapidly close the opening and to restore the CRE boundary to a condition equivalent to the design condition when a need for CRE isolation is indicated." The allowance of this Note is acceptable Davis-Besse Page 4 of 6 Attachment 1, Volume 12, Rev. 0, Page 231 of 461

Attachment 1, Volume 12, Rev. 0, Page 232 of 461 DISCUSSION OF CHANGES ITS 3.7.10, CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS) because the administrative controls will ensure that the opening will be quickly sealed to maintain the validity of the licensing basis analyses of DBA consequences.

Furthermore, to support the above changes, a new Surveillance Requirement has been added. ITS SR 3.7.10.4 requires performance of required CRE unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program. ITS Section 5.5 includes the details for the program. This addition is acceptable because the proposed SR will ensure that the unfiltered air inleakage into the CRE is no greater than the flow rate assumed in the licensing basis analyses of DBA consequences.

These changes are consistent with NUREG-1430, Rev. 3, as modified by TSTF-448, Rev. 3, which has been approved by the NRC using the Consolidated Line Item Improvement Process and documented in the Federal Register notice dated January 17, 2007 (pages 2022 through 2033). This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L02 (Category 7- Relaxation Of Surveillance Frequency, Non-24 Month Type Change) CTS 4.7.6.1 .b states that each CREVS train shall be demonstrated OPERABLE at least once every 31 days "on a STAGGERED TEST BASIS" by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that the train operates for a least 15 minutes.

ITS SR 3.7.10.1 requires a similar test every 31 days, but does not include the "STAGGERED TEST BASIS" requirement. This changes the CTS by deleting the requirement to test on a STAGGERED TEST BASIS.

The purpose of CTS 4.7.6.1 .b is to demonstrate the OPERABILITY of the CREVS trains. This change is acceptable because the new Surveillance Frequency provides an acceptable level of equipment reliability. This change deletes the requirement to perform CTS 4.7.6.1 .b on a STAGGERED TEST BASIS. The intent of a requirement for staggered testing is to increase reliability of the component/system being tested. A number of studies have been performed that demonstrate that staggered testing has negligible impact on component reliability. These analytical and subjective analyses have determined that staggered testing 1) is operationally difficult, 2) has negligible impact on component reliability, 3) has no impact on failure frequency, 4) introduces additional stress on components potentially causing increased component failures rates and component wearout, 5) results in reduced redundancy during testing, and 6) increases likelihood of human error by increasing testing intervals.

Therefore, the CREVS staggered testing requirements have been deleted. This change is designated as less restrictive because the intervals between performances of the Surveillances for the two CREVS trains can be larger or smaller under the ITS than under the CTS.

L03 (Category 6 - Relaxation Of Surveillance Requirement Acceptance Criteria)

CTS 4.7.6.1.e.2 requires verification of the automatic isolation of the Control Room Normal Ventilation System on an "SFAS" test signal and a "Station Vent Normal Range Radiation monitoring" test signal. ITS SR 3.7.12.3 specifies that the signal may be from either an "actual" or simulated (i.e., test) signal. This Davis-Besse Page 5 of 6 Attachment 1, Volume 12, Rev. 0, Page 232 of 461

Attachment 1, Volume 12, Rev. 0, Page 233 of 461 DISCUSSION OF CHANGES ITS 3.7.10, CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS) changes the CTS by explicitly allowing the use of either an actual or simulated signal for the test.

The purpose of CTS 4.7.6.1 .e.2 is to ensure the Control Room Normal Ventilation System isolates upon receipt of an actuation signal. This change is acceptable because it has been determined that the relaxed Surveillance Requirement acceptance criteria are not necessary for verification that the equipment used to meet the LCO can perform its required functions. Equipment cannot discriminate between an "actual," "simulated," or "test" signal and, therefore, the results of the testing are unaffected by the type of signal used to initiate the test. This change allows taking credit for unplanned actuation if sufficient information is collected to satisfy the Surveillance test requirements.

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

Davis-Besse Page 6 of 6 Attachment 1, Volume 12, Rev. 0, Page 233 of 461

Attachment 1, Volume 12, Rev. 0, Page 234 of 461 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 12, Rev. 0, Page 234 of 461

Attachment 1, Volume 12, Rev. 0, Page 235 of 461 I All changes are CTS unless otherwise notedog CREVS 3.7.10 3.7 PLANT SYSTEMS 3.7.10 Control Room Emergency Ventilation System (CREVS) 3.7.6.1 LCO 3.7.10 Two CREVS trains shall be OPERABLE.

r--envelope (CRE) N TJ ctI I

CT'q.. ~ . ... ....~-n. ... e .. .NO TEk ' ý--- ----........

DOC L01 The control room oundary may be opened intermittently under administrative control.

DOC M01 f ...........

2. Only the CRE boundary is required to be OPERABLEJ TSTF during movement of irradiat ed fuel assemblies. ,P and APPLICABILITY: MODES 1, 2,3, NDuring movement of d4*-54d, irradiated fuel assembliesO.

C1D0 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME Action a A. One CREVS train A.1 Restore CREVS train to 7 days for reasons other inoperable OPERABLE status.

than Condition B

2INSERT DOC L01 B. o[CREVS trains f{1 B. Restore contr room -

One or more inoperable due to -- boundary to OPERABLE

' inoperable lcontrQ"room I status.

boundary in MODE 1, 2, 3, or 4.

Action a C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A or B AND not met in MODE 1, 2, 3, or 4. C-2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months BWOG STS 3.7.10-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 235 of 461

Attachment 1, Volume 12, Rev. 0, Page 236 of 461 3.7.10 CTS

(ýD INSERT 1 DOC L01 B.1 Initiate action to implement Immediately mitigating actions.

AND B.2 Verify mitigating actions 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ensure CRE occupant exposures to radiological, chemical, and smoke hazards will not exceed limits.

AND Insert Page 3.7.10-1 Attachment 1, Volume 12, Rev. 0, Page 236 of 461

Attachment 1, Volume 12, Rev. 0, Page 237 of 461 CTS CREVS 3710 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

.4 4-D. [ Required Action and D.1 ----- NOTE--.-.----- -

TSTF-448 associated Completion Place in emergency mode if changes not Time of Condition A no automatic transfer to shown ___0 met during movement f emergency mode

[recently] irradiated fu I inoperable.

assemblies.

Place OPERABLE CRE Immediately train in emergency mod, OR D.2 Suspend movement #f Immediately]

[recently] irradiated f el assemblies. /

DOC M01 I- ~l 1 Suspend movement of Immediately[ LTSTF-448 changes not(

inoperable during a irradiated fuel shown movement of fý ýJ assemblies.

irradiated fuel assemblies.

DOC A02 Two CREVS trains Enter LCO 3.0.3. Immediately inoperable f MODE 1, 2, 3, or 4 for I1 ~-448) reasons other than Condition B.

SURVEILLANCE REQUIREMENTS SURVEILLANCE j FREQUENCY 4.7.6.1 .b SR 3.7.10.1 Operate each CREVS train for [_ 10 c ntinuous 31 days 0) hours with te heaters operating or (fo system without heoters !! 15 minutes4 0) 9TSTF-4 BWOG STS 3.7.10-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 237 of 461

Attachment 1, Volume 12, Rev. 0, Page 238 of 461 CTS CREVS 3.7.10 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY 4.7.6.1.c SR 3.7.10.2 Perform required CREVS filter testing in accordance In accordance with the MVentilation Filter Testing Program (VFTP)ý with the D/FTF*

0 4.7.6.1.e.2 SR 3.7.10.3 VeriM[eac CREVS train actuate or the control [U]months Iroom isola es] on an actual or simulated actuation signal. Control Room Normal Ventilation System isolates DOC L01 SR 3.7.10.4 Verify one CREVS tr n can maintain a positive [18] months on a pressure of > [0.125 inches water gauge relative t STAGGERED -448 INSERT 2 the adjacent [area/during the [pressurization] me e TEST BASIS

~~~of operation ataafow rate of!_<[3300] cfm. /

4.7.6.1.e.3 SR 3.7.10.5 MVerify the system makeup flow rate is _270S ]1 )monthsM

_M30Mcfm when supplying the E control room &t with outside air. T 7

}00 BWOG STS 3.7.10-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 238 of 461

Attachment 1, Volume 12, Rev. 0, Page 239 of 461 3.7.10 9 INSERT 2 Perform required CRE unfiltered air In accordance inleakage testing in accordance with the with the Control Control Room Envelope Habitability Room Envelope Program. Habitability Program Insert Page 3.7.10-3 Attachment 1, Volume 12, Rev. 0, Page 239 of 461

Attachment 1, Volume 12, Rev. 0, Page 240 of 461 JUSTIFICATION FOR DEVIATIONS ITS 3.7.10, CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS)

1. The Davis-Besse fuel handling accident analyses (both inside and outside containment) and waste gas decay tank rupture analysis do not assume the CREVS operates to provide airborne radiological protection for the control room envelope (CRE) occupants. The above analyses only assume the CRE is isolated. However, further analysis of the waste gas decay tank rupture event demonstrates acceptable accident results without a CRE isolation. Therefore, the MODES 5 and 6 Applicabilities have not been included in ITS 3.7.10 and LCO Note 2 has been added to state that only the CRE boundary is required to be OPERABLE during movement of irradiated fuel assemblies. Due to this deletion, ISTS 3.7.10 ACTION D has been deleted and ISTS 3.7.10 Condition E has been modified to clearly identify the Condition (i.e., CRE boundary inoperable). Subsequent ACTIONS have been renumbered due to the deletion.

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

3. Typographical error corrected.

Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 240 of 461

Attachment 1, Volume 12, Rev. 0, Page 241 of 461 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 12, Rev. 0, Page 241 of 461

Attachment 1, Volume 12, Rev. 0, Page 242 of 461 All changes are unless otherwise notedg ]

CREVS B 3.7.10 B 3.7 PLANT SYSTEMS B 3.7.10 Control Room Emergency Ventilation System (CREVS)

BASES BACKGROUND The CREVS provides a protected environment fromwhich ) -rstano control the unit following an uncontrolled release of radioactivityt chemi , or toxic as hazardous chemicals, or smoke The CREVS consists of two independent, redundanfaieut assemblies]. EacI*iII~ train consists of a a igh eiclency ORE VS particulate air (H EPA) filter, r a charoal.

The CREVS is an emergency system. Upon receipt of the activating Contro Room l E- - -,h ignal(s), the rma con room lentilation ýystem is automatically[s u (approximately 300 cfm of isolated whch wn and the CREVS can be manually started. The roughing filters 5 outside air and 3000 cfm isolates the CRE water ensin units remove any large particles in the aira of re rculation air) is.'.s..boundary,' lentrae drople resen ,to prevent excessive loading of the Foperating at a flow rate of < 3300Mcfm HEPA and charcoal filters.

DRESA singlehrainill pressurize the ýcontrol room, th-a 1.5 ftf LEAKAGE ORED D DFa eato about 1/8 inch water gauge.4The CREVS operation is discussed in *e ESAR,,Section 9 ] (Ref. 1). relative to external areas adjacent to the CRE boundary (D

~

941 a habitable environment in The C REVS is designed to maintainihe on om oor 30 days of continuous occupancy after a Design Basis Accident (DBA), without exceeding body, a15I rem whole toaefetvd or its equivalent to any part of the body dose euven(TD)

APPLICABLE The CREVS components are arranged in redundant safety related SAFETY ventilation trains. The location of componentsiand ucting within the the ANALYSES O controO ye ope ensures an adequate supply of filtered air to all CRE occupant]

areas requiring access. The CREVS provides airborne radiological OCREoccupants protection for th$ control eratorslas demonstrated by the cowo roo edose analyses for the most limiting design basis loss of coolant accident fission product release presented in thFSAR, Section 15.4.6 Cha (Ref. 2). i F INSERT3ý S iTheworst case single active failure of a CREVS component, assuming a loss of offsite power, does not impair the ability of the system to perform its design function.

[For this unit, th e are no sources of toic gases or chemic ls that could be released to/affect control room ho6itability. ]\

The CREVS satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).

BWOG STS B 3.7.10-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 242 of 461

Attachment 1, Volume 12, Rev. 0, Page 243 of 461 B 3.7.10 48 INSERT 1 trains that recirculate and filter the air in the control room envelope (CRE) and a CRE boundary that limits the inleakage of unfiltered air 44 INSERT 2 for removal of gaseous activity (principally iodines), and a fan. Ductwork, valves or dampers, doors, barriers, and instrumentation also form part of the system.

The CRE is the area within the confines of the CRE boundary that contains the spaces that control room occupants inhabit to control the unit during normal and es accident conditions. This area encompasses the control room, and* (T encompas other non-critical areas to which frequent personnel access or LaiY continuous occupancy is not necessary in the event of an accident. The CRE is protected during normal operation, natural events, and accident conditions. The CRE boundary is the combination of walls, floor, roof, ducting, doors, penetrations and equipment that physically form the CRE. The OPERABILITY of the CRE boundary must be maintained to ensure that the inleakage of unfiltered air into the CRE will not exceed the inleakage assumed in the licensing basis analysis of design basis accident (DBA) consequences to CRE occupants. The CRE and its boundary are defined in the Control Room Envelope Habitability Program.

INSERT 3 The CREVS provides protection from smoke and hazardous chemicals to the CRE occupants. The analysis of hazardous chemical releases demonstrates that the toxicity limits are not exceeded in the CRE following a hazardous TSTF-chemical release (Ref. 3). The evaluation of a smoke challenge demonstrates that it will not result in the inability of the CRE occupants to control the reactor either from the control room or from the remote shutdown panels (Re . 4 -d Furthermore, the fuel handling accident, both inside and outside containment, assumes the control room is isolated (Ref. 5).

Insert Page B 3.7.10-1 Attachment 1, Volume 12, Rev. 0, Page 243 of 461

Attachment 1, Volume 12, Rev. 0, Page 244 of 461 I All changes are unless otherwise noted rTSTF \

J CREVS B 3.7.10 BASES , such as from a loss of both ventilation trains or from an inoperable CRE boundary, LCO Two independent and redundant CREVS trains are required to be active OPERABLE to ensure that at least one is available if a. single4ailure (whole body or its e any disables the other train. Total system failure*could result in exceeding a toDuivalent pdE dose o rero thelcontrol .rm operat in the event of a large 0 radioactive release. C

ý} CRE c idered OPERABLE when the individual components R

pntcrnecessary p CREVS train ist considered OPERABLE exposure are when OPERABLE n the associated: A

a. Fan is OPERABLkj--Q 0

b. HEPA filter and charcoal absorber are not excessively restricting flow, and are capable of performing their filtration functionsm and 0

c. Heatrer misterJ Auctwork, valves, and dampers are OPERABLE, and air circulation can be maintained.

0 In addition, floors, the/Control cailinqg, ductwork, room andboundary/.including accesp'doors, mustthe beintegfity mintained of the ithn wells,/

Ithe assumnitions of the design analysis.1 INET4 The LCO is modified by a Not allowing the[co ro boundary to be opened intermittently under administrative controls.gFor entry and exit INET through doors, the administrative control of the opening is performed by the person(s) entering or exiting the area. For other openings, these should be proceduralized and controls~consist of stationing a dedicated individual at the opening who is and to restore the CRE boundary to a,) in continuous communication with the Icontirdl roor. This individual will operators inthe GRE condition equivalent to the design condition have a method o0rapidy ose e opening hen a need for con roo r--R isolation is indicated. INSERT 5A 1 j APPLICABILITY In MODES 1,2.3. ý3 ,d the CREVS must be OPERABLE to ensure that 5nd F l ýconArl roomiwill remain habitable during and following a DBA. durng mgr n MODES I and6, -RE _- boundary as.E the CREVS i required to During movement or irradiated fuel assemblies, the irass cope with /e release must be OPERABLE to cope with a release due to a fuel h BVWOG STS B 3.7.10-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 244 of 461

Attachment 1, Volume 12, Rev. 0, Page 245 of 461 B 3.7.10 INSERT 4 In order for the CREVS trains to be considered OPERABLE, the CRE boundary must be maintained such that the CRE occupant dose from a large radioactive TSTF-448 release does not exceed the calculated dose in the licensing basis consequence analyses for DBAs, and that CRE occupants are protected from hazardous chemicals and smoke. Maintaining the CRE boundary OPERABLE includes the capability to isolate the Control Room Normal Ventilation System.

TSFINSERT 5 This Note only applies to openings in the CRE boundary that can be rapidly restored to the design condition, such as doors, hatches, floor plugs, and access panels.

OINSERT 5A The LCO is modified by a second Note (Note 2) indicating that only the CRE boundary is required during movement of irradiated fuel assemblies. This is because the fuel handling accident analyses (Ref. 5) does not assume CREVS operation, only that the control room is isolated.

Insert Page B 3.7.10-2 Attachment 1, Volume 12, Rev. 0, Page 245 of 461

Attachment 1, Volume 12, Rev. 0, Page 246 of 461 I All changes are unless otherwise noted TTF]

CREVS B 3.7.10 BASES ACTIONS A.1 for reasons other than an inoperable CRE boundary, With one CREVS train inoperabi action must be taken to restore the inoperable CREVS train to

OPERABLE status within 7 days. In this Oondition, the remaining OPERABLE CREVS train is adequate to perform thelcon room 00 CRE occupantý a protection function. However, the overall reliability is-reduced because a failure in the OPERABLE CREVS train could result in loss of CREVS function. The 7 day Completion Time is based on the low probability of a DBA occurring during this time period, and ability of the remaining train to provide the required capability.

B.1 -- B.2. a~nd B.3 NOTE ---.--------- --...............

-REVIEWE

'S--

Adoption of Co dition B is dependen on a commitment f om the licensee to have writte procedures available describing compen atory measures to be taken in he event of an intenti nal or unintentiona entry into Condition B.

Ifthe control roqm boundary is inope ble in MODE 1,2, 3, or 4, the I*NSERT 6

CREVS trains c innot perform their intended functions. ctions must be taken to restorq an OPERABLE cont ol room boundary *thin 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

During the pern d that the control roo m boundary is inop=rable, appropriate co pensatory measure (consistent with th intent of GDC

19) should be tilized to protect con ol room operators rom potential hazards such ýs radioactive conta ination, toxic chemi Is, smoke, temperature a hd relative humidity, nd physical secunt . Preplanned measures sh Id be available to a ress these concer s for intentional and unintenti nal entry into the con ition. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is reasonable based on the low pro ability of a DBA o urring during this time period, nd the use of compe satory measures, he 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion ime is a typically rea onable time to diag ose, plan and possibly rep ir, and test most pro ems with the contr I room boundary.

ifayRqurdAtinadC.1 and C.2 !e R h t e associated Completion:Time aof.t 1, 2, 3, or4,if In MODE car/not loundary the inopeDable be restored to /ERABLE CR5 VSsatus t *tin or Ti owed -

thereuired Condition Aor Bcannot be met I the L MO

")-*Completion tirme/. the unit must be placed inunit a MODE lin whipHl y! To achieve this status, the must be placed in at least

[tatn~ninie2ccident risk - does fot app The allowed

' * - MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

Completion Times are reasonable, based on operating experience, to inwhich the LCO does not appiy reach the required unit conditions from full power conditions in an orderly 2manner and without challenging unit systems. 4/1 BWOG STS B 3.7.10-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 246 of 461

Attachment 1, Volume 12, Rev. 0, Page 247 of 461 B 3.7.10 48 INSERT 6 If the unfiltered inleakage of potentially contaminated air past the CRE boundary and into the CRE can result in CRE occupant radiological dose greater than the calculated dose of the licensing basis analyses of DBA consequences (allowed to be up to R5 rem whole body or its equivalent to any part of the bod] (e

, or inadequate protection of CRE occupants from hazardous chemicals or smoke, the CRE boundary is inoperable. Actions must be taken to restore an OPERABLE CRE boundary within 90 days.

During the period that the CRE boundary is considered inoperable, action must L' etY- .initiatedto implement mitigating actions to lessen the effect on CRE occupants from the potential hazards of a radiological or chemical event or a challenge from smoke. Actions must be taken within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to verify that in the event of a DBA, the mitigating actions will ensure that CRE occupant radiological exposures will not exceed the calculated dose of the licensing basis analyses of DBA consequences, and that CRE occupants are protected from hazardous 8 chemicals and smoke. These mitigating actions (i.e., actions that are taken to offset the consequences of the inoperable CRE boundary) should be preplanned Insert from Insert for implementation upon entry into the condition, regardless of whether entry is of Requied Page B3.7.10-5 intentional or unintentional., The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time4s reasonable based Action8.2 of equired on the low probability of a DBA occurring during this time period, and the use of mitigating actions. The 90 day Completion Timeis reasonable based on the determination that the mitigating actions will ensure protection of CRE occupants within analyzed limits while limiting the probability that CRE occupants will have to implement protective measures that may adversely affect their ability to control the reactor and maintain it in a safe shutdown condition in the event of a DBA. In addition, the 90 day Completion Time is a reasonable time to diagnose, plan and possibly repair, and test most problems with the CRE boundary.

Insert Page B 3.7.10-3 Attachment 1, Volume 12, Rev. 0, Page 247 of 461

Attachment 1, Volume 12, Rev. 0, Page 248 of 461 CREVS B 3.7.10 BASES ACTIONS (continued)

[D.1 and D.2 TST--4481 changes not In MODE 5 or 6, or] d ing movement of [recently] irradiat d fuel shown assemblies, if the ino. rable CREVS train cannot be rest red to OPERABLE status wi in the required Completion Time, he OPERABLE CREVS train must im ndiately be placed in the emnerger cy mode. This action ensures that t" e*remaining train is OPERABLE, tt *t no failures preventing automatic actuation will occur, and that any a *-tve failure will be readily detected. Required Action D.1 is modified by a Note indicating to place the system* the emergency mode if automnati( transfer to emergency mode is inoperable.

An alternative to R*quired Action D.1 is to immediately suspend activities that could release I }dioactivity that might require isola ,on of the control room. This places ~he unit in a condition that minimize s the accident risk.

This does not preclude the movement of fuel to a safe position. ]

1019, luring movement 4 if the CRE assembiieS",m " "n,'. ,

boundary is immediately to suspend activities that inable might require isolation of the condition that minimizes the accident r TSTF448 changes not shown movement of fuel to a safe position. 1Q D

If both CREVS trains are inoperable in MODE 1, 2, 3, or 4 for reasons TSTF other than an inoperable n-rtroom-boundary (i.e., Condition B), the .448 SCREVS may not be capable of performing the intended function and the unit is in a condition outside the accident analysis. Therefore, LCO 3.0.3 must be entered immediately.

BWOG STS B 3.7.10-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 248 of 461

Attachment 1, Volume 12, Rev. 0, Page 249 of 461 Atl changes are ("T 7' unless otherwise noted -- CREVS B 3.7.10 BASES SURVEILLANCE SR 3.7.10.1 REQUIREMENTS Standby systems should be checked periodically to ensure that they function properly. As the environment and normal operatingdry conditions ouy'any I "

on this system are not severe, system. Monthly testing eachheate train 'operations once every month adequately checks this / -('

}becausefr of huI Jin the 1/ntinuous as accumul tel in themust w h heaters be/op~erated charco the ambien air.

moisture/tat [Systems be ] "

SInitiating each train from

without heaters redonly wih lorom conro trogh *jhors*vth the heaters *nergized. Syster 00 adforbers, and operating oper ed for Z 15 minutes Mdemonstrat thefunction of train Iae The 31 day Frequency is based on the known reliability of the equipment and the two train redundancy available. s SR 3.7.10.2 This SR verifies that the required CREVS testing is performed in accordance with the Ventilation Filter Testing Program (VFTP)ý The

[VFTP*Jincludes testing HEPA filter performance, charcoal absorber efficiency, mini um system flow rate, and the physical properties of the )

activated charcoal. Specific test frequencies and additional information are discussed in detail in the RVFTFP 0 C2 Control Room Normal Ventilation System SIR 3.7.10.3 (i.e., SFAS and Station Tst Vent Normal Range "Ths SR verifies that [each CREVSin s tae"con room2 Radiation Monitoring) isolate an o rates on an actual or simulated actual-ionsignal. The Frequency of [18] rpnths is consistent with thay specified in Reference 3\ __

I [

The Frequency of[]months is based oin f operating 1 SR 3.7.10.4 experience and is consitenwith the typical refueling cycle.

This SR verifies the integrity of the co trol room enclosur and the assumed inleak ge rates of the poten ially contaminated ir. The control INSERT 7 room positive p essure, with respect potentially conta mated adjacent areas, is periodlically tested to verify at the CREVS is f ctioning properly. Dunrig the emergency mo e of operation, the REVS is designed to pr ssurize the control ro m - [0.125] inches water gauge positive press re. with respect to adjacent areas, to pre ent unfiltered inleakage. T CREVS is designed to maintain this po tive pressure with one train at a flow rate of _ [33 0] cfm. This value ncludes [300] cfm of outside air The Frequency of [1 ] months on a STA GERED TEST BASIS is co istent with industry p actice and other filt ation SRs.

INSERT 8 11-BWOG STS B 3.7.10-5 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 249 of 461

Attachment 1, Volume 12, Rev. 0, Page 250 of 461 B 3.7.10 S INSERT 7 This SR verifies the OPERABILITY of the CRE boundary by testing for unfiltered air inleakage past the CRE boundary and into the CRE. The details of the testing are specified in the Control Room Envelope Habitability Program.

The CRE is considered habitable when the radiological dose to CRE occupants calculated in the licensing basis analyses of DBA consequences is no more than P rem whole body or its equivalent to any part of the body] [5 ren EDE] and the CRE occupants are protected from hazardous chemicals and smoke. This SR 0

verifies that the unfiltered air inleakage into the CRE is no greater than the flow rate assumed in the licensing basis analyses of DBA consequences. When unfiltered air inleakage is greater than the assumed flow rate9 Condition B must ae entered.d Required A ion B.3 allows time toresur the CRE boundary to mtERABLE status pre qied mitigating actions can enBure that the CRE remains Move to Insert __ within the licensinqbasi haitability limits for the occ* pants following an Page B 3.7.10-3 Laccident.J Compensatory measures are discussed in Regulatory Guide 1. 196,

.Section C.2.7.3. (Ref.S) w~hich endorses, with exceptions, NEI 99-03, Section 8.4{*

6 and Appendix F (R-ef.A'). These compensatory measures maylal1,d be ýused a 7 mitigating actions as required by Required Action B.2. Temporary analytical methods may also be used as compensatory measures to restore OPERABILITY

-o 8

(Ref.MZ). Options for restoring the CRE boundary to OPERABLE status include changing the licensing basis DBA consequence analysis, repairing the CRE boundary, or a combination of these actions. Depending upon the nature of the problem and the corrective action, a full scope inleakage test may not be necessary to establish that the CRE boundary has been restored to OPERABLE status.

TSF INSERT 8 SR 3.7.10.5 This SR verifies the CREVS can supply the CRE with outside air to meet the design requirement. The Frequency of*Fi7months is consistent with industry practice and other filtration SRs.

0 Insert Page B 3.7.10-5 Attachment 1, Volume 12, Rev. 0, Page 250 of 461

Attachment 1, Volume 12, Rev. 0, Page 251 of 461 I

All changes are I unless otherwise noted CREVS B 3.7.10 BASES REFERENCES

-* I F

FSAR, Section .4J 00

3. ýFSAR, Section M6.4 UI, Sectpoe 00 U4 FSAR, Section M9.5 MSAR, *

Regulatory.Guide :15/e~v.

[2]

00 7 NEI 99-03, "Control Room Habitability Assessment," June 2001. 5. UFSAR. Section 15.4.7. (

Letter January 30, Eric from J. Leeds 2004, (NRC)

"NEI Draft to James W. Davis (NEI) dated White Paper, Use of Generic Letter 91-18I Process and Alternative Source Terms in the Context of Control Rooml Habitability" (ADAMS Accession No. ML-040300694).

BWOG STS B 3.7.10-6 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 251 of 461

Attachment 1, Volume 12, Rev. 0, Page 252 of 461 JUSTIFICATION FOR DEVIATIONS ITS 3.7.10 BASES, CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS)

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

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

3. These punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, TSTF-GG-05-01, Section 5.1.3.

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

5. Typographical error corrected.

6. Changes made to be consistent with the Specification. The ACTIONS B.1, B.2 and B.3 discussion is an immediate action and the ACTIONS C.1 and C.2 discussion is not correct since not meeting restoration actions are not the only actions that could result in Condition C being entered (i.e., Required Action B.1 or B.2 could not be met).

7. Editorial change for clarity.

8. This information provided in the SR 3.7.10.4 Bases is discussing how to meet the requirements of ACTION B; not how to meet the SR requirements. Therefore, this information has been moved, as appropriate, to the ACTIONS B.1, B.2, and B.3 section of the Bases, where it properly belongs.

9. Changes are made to reflect the Specification.

Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 252 of 461

Attachment 1, Volume 12, Rev. 0, Page 253 of 461 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 12, Rev. 0, Page 253 of 461

Attachment 1, Volume 12, Rev. 0, Page 254 of 461 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.7.10, CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS)

There are no specific NSHC discussions for this Specification.

Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 254 of 461

Attachment 1, Volume 12, Rev. 0, Page 255 of 461 ATTACHMENT 11 ITS 3.7.11, CONTROL ROOM EMERGENCY AIR TEMPERATURE CONTROL SYSTEM (CREATCS)

Attachment 1, Volume 12, Rev. 0, Page 255 of 461

, Volume 12, Rev. 0, Page 256 of 461 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 12, Rev. 0, Page 256 of 461

Attachment 1, Volume 12, Rev. 0, Page 257 of 461 ITS 0 ITS 3.7.11 PLANT SYSTEMS 3/4.7.6 CONTROL ROOM EMERGENCY VENTILATION SYSTEM LIMITING CONDITION FOR OPERATION

.ýn, LCO 3.7.11 3.7.6..1 Two indep ndent control room emergency venti ation systems shall be OPERABLE.

APPLICABILITY: MODES 1, 2,3 and 4. / {Air Temperature Control A0 ACTION:

_a. inoperable, restore the inoperableh With one control room emergency [ventoation system tlatHTSADYwti ACTION A -- -- ~~e o-ei sLstem to OPERABLE status within 06ays oobe in at least HOT STANDBY within the K

ACTION B Lnext ours an in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

b. With one channel of Station Vent Normal Range Radiation Monitoring instrumentation inoperable, restore the inoperable channel to OPERABLE status, or isolate the control room normal ventilation system and place at least one control room emergency See ITS ventilation system train in operation within 7 days. 3.3.16 ]

c. With both channels of Station Vent Normal Range Radiation Monitoring instrumentation inoperable, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , isolate the control room normal ventilation system and place at least one control room emergency ventilation system train in operation.

Air Temperature Control A02 SURVEILLANCE REQUIREMENTS 4.7.6.1 Each control room emergency venti ation system shall be demonstrated OPERABLE:

a. At least once per 12 ours by verifying that the control room air mperature is less than L02 or equal to 110,Uwhen the control room emergency ventil tn sýystem is operating.

b. At least once per 31 days on a STAGGERED TEST BASIS by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that the system operates for at least 15 minutes. See ITS 1 3.7.10 ]

c. At least once each REFUELING INTERVAL and in accordance with the Ventilation Filter Testing Program (VFTP).

Add proposed SR 3.7.11.1 G0 DAVIS-BESSE, UNIT I 3/4 7-17 Amendment No. 135, 155,217,227, 244, Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 257 of 461

Attachment 1, Volume 12, Rev. 0, Page 258 of 461 DISCUSSION OF CHANGES ITS 3.7.11, CONTROL ROOM EMERGENCY AIR TEMPERATURE CONTROL SYSTEM (CREATCS)

ADMINISTRATIVE CHANGES A01 In the conversion of the Davis-Besse Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1430, Rev. 3.1, "Standard Technical Specifications-Babcock and Wilcox Plants" (ISTS).

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

A02 CTS 3.7.6.1 states that two control room emergency ventilation systems shall be OPERABLE. CTS 4.7.6.1 .a requires verification that the control room air temperature is < 11 0°F every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months when the CREVS is operating. Thus, the CTS 3.7.6.1 statement that two CREVS shall be OPERABLE and the CTS 4.7.6.1 statement that each CREVS train shall be demonstrated OPERABLE includes the air temperature control portion of the CREVS. In the ITS, the requirements have been split into separate Technical Specifications; ITS 3.7.10, "Control Room Emergency Ventilation System (CREVS)," for the filtration and control room envelope boundary requirements and ITS 3.7.11, "Control Room Emergency Air Temperature Control System (CREATCS)," for the control room envelope air conditioning requirements. Therefore, the ITS 3.7.11 LCO, ACTIONS, and Surveillance Requirement refers to the CREATCS. This changes the CTS by providing a separate Technical Specification for the CREATCS.

This change is designated as administrative and is acceptable because it does not result in any technical changes, except as justified by another Discussion of Change.

MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.7.6.1 states that two "independent" control room emergency ventilation systems shall be OPERABLE. ITS LCO 3.7.10 states that two Control Room Emergency Air Temperature Control System (CREATCS) trains shall be OPERABLE. This changes the CTS by moving the details that the CREATCS trains are "independent" from the CTS to the Bases. The change from CREVS to CREATCS is discussed in DOC A02.

Davis-Besse Page 1 of 3 Attachment 1, Volume 12, Rev. 0, Page 258 of 461

Attachment 1, Volume 12, Rev. 0, Page 259 of 461 DISCUSSION OF CHANGES ITS 3.7.11, CONTROL ROOM EMERGENCY AIR TEMPERATURE CONTROL SYSTEM (CREATCS)

The removal of these details, which are related to system design, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement that two CREATCS trains be OPERABLE. The details concerning the independence of the trains do not need to appear in the Specification in order for the requirement to apply. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L01 (Category 3- Relaxation of Completion Time) CTS 3.7.6.1 Action a allows 7 days to restore an inoperable CREVS train to OPERABLE status. ITS 3.7.11 ACTION A allows 30 days to restore an inoperable CREATCS train to OPERABLE status. This changes the CTS by increasing the time allowed to restore the inoperable components from 7 days to 30 days. The change from CREVS to CREATCS is discussed in DOC A02.

The purpose of CTS 3.7.6.1, in part, is to provide a degree of assurance that the CREATCS can provide cooling when required. This change is acceptable because the Completion Time is consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the allowed Completion Time. The CREATCS is still required to be restored to OPERABLE status, and can perform its function without one air conditioning train. Furthermore, alternate non-safety related cooling means are available. This change is designated as less restrictive because additional time is allowed in the ITS to restore parameters to within the LCO limits than was allowed in the CTS.

L02 (Category 5- Deletion of Surveillance Requirement) CTS 4.7.6.1 .a requires verification every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months that the control room air temperature is < 11 0°F when the CREVS is operating. ITS 3.7.11 does not include this requirement.

However, ITS SR 3.7.11.1 requires verification that each CREATCS train has the capability to remove the assumed heat load every 24 months. This changes the CTS by eliminating the Surveillance Requirement to verify control room air temperature every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and adding a Surveillance Requirement to verify each CREATCS train has the capability to remove the assumed heat load every 24 months.

The purpose of CTS 4.6.7.1 .a is to ensure the continuous duty rating for the instrumentation and equipment cooled by this system is not exceeded. This change is acceptable because the deleted Surveillance Requirement is not Davis-Besse Page 2 of 3 Attachment 1, Volume 12, Rev. 0, Page 259 of 461

Attachment 1, Volume 12, Rev. 0, Page 260 of 461 DISCUSSION OF CHANGES ITS 3.7.11, CONTROL ROOM EMERGENCY AIR TEMPERATURE CONTROL SYSTEM (CREATCS) necessary to ensure the CREATCS can perform its safety function and ITS SR 3.7.11.1 has been added to verify each control room ventilation subsystem has the capability to remove the assumed heat load. This new SR will ensure the CREATCS can perform its safety function. Temperature is not always the appropriate method to verify the system capability to remove its design basis heat load because the conditions in the control room envelope boundary do not always reflect the assumptions of the accident (e.g., personnel assumed to be in the control room envelope boundary during an accident, the system does not normally operate in the pressurization mode of operation). ITS SR 3.7.11.1 will ensure each CREATCS train has sufficient cooling capability to meet the safety analyses assumptions. This change is designated as less restrictive because a Surveillance that is required in the CTS will not be required in the ITS.

Davis-Besse Page 3 of 3 Attachment 1, Volume 12, Rev. 0, Page 260 of 461

Attachment 1, Volume 12, Rev. 0, Page 261 of 461 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 12, Rev. 0, Page 261 of 461

Attachment 1, Volume 12, Rev. 0, Page 262 of 461 CTS CREATCS 3.7.11 3.7 PLANT SYSTEMS 3.7.11 Control Room Emergency Air Temperature Control System (CREATCS) 3.7.6.1 LCO 3.7.11 Two CREATCS trains shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4a~ d6],

I[During movement of [recegjtyjtlradiated fuel assembliesj. I ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME Action a A. One CREATCS train A.1 Restore CREATCS train to 30 days inoperable. OPERABLE status.

Action b B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time oC tionAnot AND met lin MODE 1, 2,3,1 o B.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months 0

C. [ Required Action and C.1 Place OPERABLE I mediately associated Completio CREATCS train in Time of Condition A n t operation.

met during movemen of

[recently] irradiated f el OR assemblies. I C.2 Suspend movement of i Immediately ]

[recently] irradiated fuel /

assemblies.

D. [Two CREATC trains D.1 Suspend movement of Immediately ]

0 inoperable duri g [recently] irradiated fuel movement of [r cently] assemblies.

irradiated fuel assemblies./

BVWOG STS 3.7.11-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 262 of 461

Attachment 1, Volume 12, Rev. 0, Page 263 of 461 CTS CREATCS 3711 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Two CREATCS train E.1 Enter LCO 3.0.3. /mmediately inoperable during/

MODE 1, 2, 3, or 0 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY DOC L02 SR 3.7.11.1 Verify each CREATCS train has the capability to months 0 remove the assumed heat load.

BWOG STS 3.7.11-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 263 of 461

Attachment 1, Volume 12, Rev. 0, Page 264 of 461 JUSTIFICATION FOR DEVIATIONS ITS 3.7.11, CONTROL ROOM EMERGENCY AIR TEMPERATURE CONTROL SYSTEM (CREATCS)

1. The Davis-Besse fuel handling accident analyses (both inside and outside containment) and waste gas decay tank rupture analysis do not assume the CREATCS operates to provide air conditioning for the control room envelope (CRE).

Due to this deletion, the reference to MODES 1, 2, 3, and 4 in ISTS 3.7.11 Condition B and ISTS 3.7.10 ACTIONS C and D have been deleted. Since ISTS 3.7.11 ACTIONS C and D have been deleted, there is no need for ISTS 3.7.11 ACTION E, which requires entry in LCO 3.0.3 when two CREATCS trains are inoperable in MODE 1, 2, 3, or 4. This ACTION was included only because of ISTS 3.7.11 ACTION D. Subsequent ACTIONS have been renumbered due to these deletions.

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

Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 264 of 461

Attachment 1, Volume 12, Rev. 0, Page 265 of 461 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 12, Rev. 0, Page 265 of 461

Attachment 1, Volume 12, Rev. 0, Page 266 of 461 I All changes are unless otherwise noted 9 CREATCS B 3.7.11 B 3.7 PLANT SYSTEMS B 3.7.11 Control Room Emergency Air Temperature Control System (CREATCS)

BASES BACKGROUND The CREATCS provides temperature control for the control room following isolation of the control room.

The CREATCS consists of two independent and redundant trains that provide cooling of recirculated control room air. A cooling coil and a water cooled condensing unit are provided for each system to provide suitable temperature conditions in the control room for operating personnel and safety related control equipment. Ductwork, valves or dampers, and instrumentation also form part of the system. Two redundant air cooled condensing units are provided as a backup to the water cooled condensing unit. Both the water cooled and air cooled condensing units must be OPERABLE for the CREATCS to be OPERABLE. During emergency operation, the CREATCS maintains the

-110°F in the control rom } temDeratur~lbetweenL*f°F and 85 F1. The CREATCS is a subsystem providing air temperature control for the control room. Operation of the CREMVS is required for a Safety Features Actuation The CREATCS is an emergency system. On detection of high CREATCS to be System (SFAS) signal or a can essure or radiat low

" Reactor Cool t System in operation.

high radiation signal from one -containment bu'dlng pr of the Station Vent Normal -pressure, or I h noble gas radioactivA in the station vent, the Range Radiation Monitors Oontrol fornlentilation $ystem is automatically shut down, and the Normalontrol oom Emergency Ventilation Systerr1can be manually started. A single train will provide the required temperature control. The CREATCS operation to maintain

[*Sectionffl(Ref. 1).* control room temperature is discussed in the 4FSAR, APPLICABLE The design basis of the CREATCS is to maintain control room SAFETY temperature for 30 days of continuous occupancy.

ANALYSES The CREATCS components are arranged in redundant, safety related trains. During emergency operation, the CREATCS maintains the 11F in the control roo rtemperaturbetween and .A single active failure of a CREATCS component does not impair the ability of the system to perform 0

as designed. The CREATCS is designed in accordance with Seismic Category I requirements. The CREATCS is capable of removing sensible and latent heat loads from the control room, including consideration of equipment heat loads and personnel occupancy requirements, to ensure equipment OPERABILITY.

The CREATCS satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).

BVVOG STS B 3.7.11-1 Rev. 3.0, 03131104 Attachment 1, Volume 12, Rev. 0, Page 266 of 461

Attachment 1, Volume 12, Rev. 0, Page 267 of 461 CREATCS B 3.7.11 BASES LCO Two independent and redundant trains of the CREATCS are required to be OPERABLE to ensure that at least one is available, assuming a single failure disables the other train. Total system failure could result in the equipment operating temperature exceeding limits in the event of an accident.

Te-*

TC R EATCSV ere OPERABLE when the individual components that are necessary to maintain control room temperature are 0

[3 OPERABLEi.

itýýe These components include the cooling coils, oled condensing units, and associated temperature control Vtrain (7(

nstrumentaton. In addition,- JCREATCSi nust be OPERABLE to t2 extent that air circulation can be maintained.

APPLICABILITY In MODES 1, 2, 3,44, [5, and 6,] an during movement/of [recently]

lirradiated fu I assemblies [i.e., fuel/that has occupied part of a critical 0 0 ireactor cor* within the previous [X/ days)], t-he CREATCS must be OPERABLE to ensure that the control room temperature will not exceed equipment OPERABILITY requirements following isolation of the control room.

ACTIONS A.1 the inoperable CREATCS train to With one CREATCS train inoperable, action must be taken to restor OPERABLE status within 30 days. In this Oondition, the remaining OPERABLE CREATCS train is adequate to maintain the control room temperature within limits. However, the overall reliability is reduced because a failure in the OPERABLE CREATCS train could result in a loss of CREATCS function. The 30 day Completion Time is based on the low probability of an event occurring requiring control room isolation, the consideration that the remaining train can provide the required capabilities, and the alternate s that are available.

nonsafety related cooling means 0 Concurrent failure,0two CREATCS trains would rest in the loss of function capab y; therefore, LCO 3.0.3 must be, ntered immediately.

B.1 and B.2 lIn MODE) 23, , or 4,1ft the inoperable CREATCS train cannot be restored to OPERABLE status within the required Completion Time, the 0

unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner without challenging unit systems.

BWOG STS B 3.7.11-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 267 of 461

Attachment 1, Volume 12, Rev. 0, Page 268 of 461 CREATCS B 3.7.11 BASES ACTIONS (continued)

C.1 and C.2

[In MODE 5 or 6, or] during movement of [recently] irrad ated fuel, if the inoperable CR EAT train cannot be restored to OPE ABLE status within the required ompletion Time, the OPERABLE REATCS train must be placed in o eration immediately. This action e sures that the remaining train is PERABLE, that no failures preventi g automatic actuation will occur and that any active failure will be r adily detected.

An alternative to R quired Action C.1 is to immediatel suspend activities that could release adioactivity that might require the i olation ofthe control room. Thi places the unit in a condition that inimizes accident risk. This does n t preclude the movement of fuel to safe position.]

D.1

[In MODE 5 or 6 or] during movement of [recently] i radiated fuel assemblies, wi two CREATCS trains inoperable, ction must be taken to immediately uspend activities that could release radioactivity that might require is lation of the control room. This pla es the unit in a condition that inimizes accident risk- This does n t preclude the movement of f el to a safe position.

E.1 If both CREA CS trains are inoperable in MODE , 2, 3, or 4, the CREATCS m y not be capable of performing the intended function and the unit is in condition outside the accident ana yses. Therefore, LCO 3.0.3 m st be entered immediately..

SURVEILLANCE SR 3.7.11.1 REQUIREMENTS This SR verifies that the heat removal capability of the system is sufficient to remove the heat load assumed in the safety analysesl This SR consists of a combination of testing and calculations. A onth 24 0 Frequency is appropriate, as significant degradation of the CREATCS is slow and is not expected over this time period.

REFERENCES 1. Sectionev .FSAR, 0 0 BWJG STS B 3.7.11-3 Rev. 3.0, 03/31104 Attachment 1, Volume 12, Rev. 0, Page 268 of 461

Attachment 1, Volume 12, Rev. 0, Page 269 of 461 JUSTIFICATION FOR DEVIATIONS ITS 3.7.11 BASES, CONTROL ROOM EMERGENCY AIR TEMPERATURE CONTROL SYSTEM (CREATCS)

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

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

3. Changes are made to reflect the Specification.

4. Typographical error corrected.

5. Editorial change to be consistent with similar discussions in other Bases. This discussion concerns one inoperable CREATCS, not both.

6. Changes are made to reflect changes made to the Specification.

7. Editorial changes for consistency with similar discussions in other Bases.

Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 269 of 461

Attachment 1, Volume 12, Rev. 0, Page 270 of 461 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 12, Rev. 0, Page 270 of 461

Attachment 1, Volume 12, Rev. 0, Page 271 of 461 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.7.11, CONTROL ROOM EMERGENCY AIR TEMPERATURE CONTROL SYSTEM (CREATCS)

There are no specific NSHC discussions for this Specification.

Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 271 of 461

Attachment 1, Volume 12, Rev. 0, Page 272 of 461 ATTACHMENT 12 ITS 3.7.12, STATION EMERGENCY VENTILATION SYSTEM (EVS)

Attachment 1, Volume 12, Rev. 0, Page 272 of 461

, Volume 12, Rev. 0, Page 273 of 461 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 12, Rev. 0, Page 273 of 461

Attachment 1, Volume 12, Rev. 0, Page 274 of 461 ITS 3.7.12 ITS CONTAINMENT SYSTEMS 3/4.6.5 SHIELD BUILDING EMERGENCY VENTILATION SYSTEMI LIMITING CONDITI ON FOR OPERATION 0LAO1 LCO 3.7.12 3.6.5.1 Two *E nt emergency ventilation systems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3 and 4.

ACTION:

ACTION A With one emergency ventilation system inoperable, restore the inoperable system to OPERABLE Istatus within 7 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD ACTION C HUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

SURVEILLANCE REQUIREMENTS 4.6.5.1 Each emergency ventilation system shall be demonstrated OPERABLE:

SR 3.7.12.1 a. At least once per 31 days on a STA GERE TEST ASIS by inirtiati , from the:

F.-onrol room, flow/thouah the HEPA filters Od charcoal a*dsorbers- d d/,nifying

-- ' -- ---- (,2 that the system operates for at least 15 minutes.

SR 3.7.12.2 b. At least once each REFUELING INTERVAL and in accordance with the Ventilation Filter Testing Program (VFTP).

DAVIS-BESSE, UNIT I 314 6-28 Amendment No. 155,217, 24 4.

Page 1 of 4 Attachment 1, Volume 12, Rev. 0, Page 274 of 461

Attachment 1, Volume 12, Rev. 0, Page 275 of 461 ITS 0 ITS 3.7.12 CONTAINMENT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

1. [Deleted]

2. [Deleted]

3. [Deleted]

c. [Deleted]

d. At least once each REFUELING INTERVAL by:

1. [Deleted] a ti SR 3.7.12.3 2. Verifying that the system starts automatically on any containw nt isolationRtest signal; and SR 3.7.12.5 3. Verif~ying that the filter cooling bypass valves can be manually opened.

DAVIS-BESSE, UNIT I 3/4 6-29 Amendment No. 43,135,155,209.217,233, 244, Page 2 of 4 Attachment 1, Volume 12, Rev. 0, Page 275 of 461

Attachment 1, Volume 12, Rev. 0, Page 276 of 461 ITS 3.7.12 ITS CONTAINMENT SYSTEMS SHIELD BUILDING INTEGRITY LIMITING CONDITION FOR OPERATION LA01 I

LCO 3.7.12 3.6.5.2 ýhield bVdding integrio shall be ryintaine APPLICABILITY: MODES 1, 2, 3 and 4 ACTION:

ACTION B Without shield building integrity, restore shield building integrity within 24 urs or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD ACTION C - _HUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

SURVEILLANCE REQUIREMENTS (L03 4...21Shi e'd bui~lding integrib/shall be demonstrate6d at least once pper/

131 days b/verifyingl that airtigf~i doors and the bloycout panels listedn

ýTable 4*IaeclosedJ except when the airtight doors are being used for/ L04 LCO NOTE normal transit entry and exit.1 SR 3.7.12.4 4.6.5.2.2 Shield building integrity shall be demonstrated at least once per j IREFUELING INTERVAL by verifying that leach Emergency Ventilation System I train produces a negative pressure of greater than or equal to 0.25 inches Water Gauge in the annulus within 4 seconds after the fan attains a flow rate of 8000 cfm t 10%. This test is t be performed witlythe flow path LA02 established prigf to starting the EV fan, and the other dampers I lassociated wth the negative prssure boundary clo ed. F DAVIS-BESSE, UNIT I 3/4 6-31 Amendment No.233 Page 3 of 4 Attachment 1, Volume 12, Rev. 0, Page 276 of 461

Attachment 1, Volume 12, Rev. 0, Page 277 of 461 ITS 3.7.12 TABLE. .6-1 ACCESS OPENINGS RE UIRED TO BE CLOSED TO ENSURE SHIELD UILDING INTEGRITY LAS AIR TIGHT DOORS DOOR NO. ESCRIPTION ELEVATION 100 Access Door from he No. 1 ECCS Pump Room 545' (Room 105) to Pip Tunnel 101 1/04A Access Door fro Stair AB-3 to the No. 555' ECCS Pump Roo (Room 105) 105 Access Door fro Passage 11 OA to the area above 555' the Decoy Heat Coolers 107 Access Door fro the No. 2 ECCS Pump Room 555' (Room 115) tot e Miscellaneous Waste Monitor Tank and Pum Room (Room 114) 108 Access Door fr m the No. 2 ECCS Pump Room 555' (Room 115) to he Detergent Waste Drain Tank and Pump Ro m (Room 125) 201 -A Access Door rom Corridor 209 to the No. 1 565' Mechanical enetration Room (Room 208) 204 Access Doo from Passage 227 to the Makeup 565' Pump Room (Room 225) 205 Access Do r from Passage 227 to the No. 2 565' Mechanic I Penetration Room (Room 236) 307 Access Do r from Corridor 304 to the No. 3 585' Mechanic I Penetration Room (Room 303) 308 Access D or from Corridor 304 to the No. 4 585' Mechani al Penetration Room (Room 314)

11. BLOWOUT PANELS TOTAL NO. LOCATION ELEVATION 1 No. 2 M chanical Penetration Room 565" (Room 36) 6 No. 3 echanical Penetration Room 585' (Room 303) 6 No. 4 echanical Penetration Room 585' (Roo 314)

DAVIS-BESSE, UNIT 1 3/4 6-33 Amendment No. 233 Page 4 of 4 Attachment 1, Volume 12, Rev. 0, Page 277 of 461

Attachment 1, Volume 12, Rev. 0, Page 278 of 461 DISCUSSION OF CHANGES ITS 3.7.12, STATION EMERGENCY VENTILATION SYSTEM (EVS)

ADMINISTRATIVE CHANGES A01 In the conversion of the Davis-Besse Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1430, Rev. 3.1, "Standard Technical Specifications-Babcock and Wilcox Plants" (ISTS).

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

MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type I - Removing Details of System Design and System Description, Including Design Limits) CTS 3.6.5.1 states that two "independent" emergency ventilation systems shall be OPERABLE. CTS 3.6.5.2 states that the shield building integrity shall be maintained. ITS LCO 3.7.12 states that two Station EVS trains shall be OPERABLE. This changes the CTS by moving the details that the Station EVS trains are "independent" and that the "shield building integrity" must be maintained from the CTS to the Bases.

The removal of these details, which are related to system design, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement that two Station EVS trains be OPERABLE. The details concerning the independence of the trains do not need to appear in the Specification in order for the requirement to apply. The details concerning the shield building integrity are considered part of the OPERABILITY requirements for the Station EVS trains.

ITS SR 3.7.12.4 ensures that each Station EVS train can drawdown the shield building area negative pressure boundary, and ITS 3.7.12 ACTION B provides actions for when both Station EVS trains are inoperable due to an inoperable shield building area negative pressure boundary. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases.

Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

Davis-Besse Page 1 of 6 Attachment 1, Volume 12, Rev. 0, Page 278 of 461

Attachment 1, Volume 12, Rev. 0, Page 279 of 461 DISCUSSION OF CHANGES ITS 3.7.12, STATION EMERGENCY VENTILATION SYSTEM (EVS)

LA02 (Type 3 - Removing ProceduralDetails for Meeting TS Requirements or Reporting Requirements) CTS 4.6.5.1 .a states that each EVS train shall be demonstrated OPERABLE by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that the train operates for a least 15 minutes. CTS 4.6.5.2.2 requires the shield building area negative pressure boundary drawdown test to be "performed with the flow path established prior to starting the EVS fan, and the other dampers associated with the shield building area negative pressure boundary closed." ITS SR 3.7.12.1 states to operate the each Station EVS train for > 15 minutes. ITS SR 3.7.12.4 performs the shield building area negative pressure boundary drawdown test, but does not include the prerequisites (described above) of CTS 4.6.5.2.2. This changes the CTS by moving the details of how the Surveillances are conducted to the Bases.

The removal of these details for performing Surveillance Requirements from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement to periodically operate the Station EVS trains and perform a drawdown test of the shield building area negative pressure boundary. Also, this change is acceptable because these types of procedural details will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications.

LA03 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 4.6.5.1 .d.2 requires verification of the automatic actuation of the Station EVS trains on a "containment isolation" test signal. ITS SR 3.7.12.3 does not state the specific type of signal, but only specifies an actual or simulated "actuation" signal. This changes CTS by moving the type of actuation signal (i.e., containment isolation) to the Bases.

The removal of these details, which are related to system design, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement to verify that appropriate equipment actuates upon receipt of an actuation signal.

Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5 of the ITS. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Specification.

LA04 (Type I - Removing Details of System Design and System Description, Including Design Limits) CTS Table 4.6-1 contains a list of the shield building area negative pressure boundary airtight doors and blowout panels. ITS 3.7.12 does Davis-Besse Page 2 of 6 Attachment 1, Volume 12, Rev. 0, Page 279 of 461

Attachment 1, Volume 12, Rev. 0, Page 280 of 461 DISCUSSION OF CHANGES ITS 3.7.12, STATION EMERGENCY VENTILATION SYSTEM (EVS) not contain this list. This changes the CTS by relocating the list of the shield building area negative pressure boundary airtight doors and blowout panels to the Technical Requirements Manual (TRM).

The removal of these details, which are related to system design, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. ITS 3.7.12 still requires the shield building area negative pressure boundary to be intact, and ITS SR 3.7.12.4 requires periodic Surveillances to verify the integrity of the boundary. It is not necessary for the list of the shield building area negative pressure boundary airtight doors and blowout panels to be in the Technical Specifications in order to ensure that the shield building area negative pressure boundary is intact. Other lists of components, such as containment isolation valves and equipment response times, have been relocated from the Technical Specification to licensee-controlled documents while retaining the requirements on these components in Technical Specifications. Also, this change is acceptable because the removed information will be adequately controlled in the TRM. The TRM is currently incorporated by reference into the UFSAR, thus any changes to the TRM are made under 10 CFR 50.59, which ensures changes are properly evaluated. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L01 (Category 7- Relaxation Of Surveillance Frequency, Non-24 Month Type Change) CTS 4.6.5.1.a states that each Station EVS train shall be demonstrated OPERABLE at least once every 31 days "on a STAGGERED TEST BASIS" by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that the train operates for a least 15 minutes. ITS SR 3.7.12.1 requires a similar test every 31 days, but does not include the "STAGGERED TEST BASIS" requirement. This changes the CTS by deleting the requirement to test on a STAGGERED TEST BASIS.

The purpose of CTS 4.6.5.1 .a is to demonstrate the OPERABILITY of the EVS trains. This change is acceptable because the new Surveillance Frequency provides an acceptable level of equipment reliability. This change deletes the requirement to perform CTS 4.6.5.1 .a on a STAGGERED TEST BASIS. The intent of a requirement for staggered testing is to increase reliability of the component/system being tested. A number of studies have been performed that demonstrate that staggered testing has negligible impact on component reliability. These analytical and subjective analyses have determined that staggered testing 1) is operationally difficult, 2) has negligible impact on component reliability, 3) has no impact on failure frequency, 4) introduces additional stress on components potentially causing increased component failures rates and component wearout, 5) results in reduced redundancy testing, and 6) increases likelihood of human error by increasing testing intervals.

Therefore, the EVS staggered testing requirements have been deleted. This change is designated as less restrictive because the intervals between Davis-Besse Page 3 of 6 Attachment 1, Volume 12, Rev. 0, Page 280 of 461

Attachment 1, Volume 12, Rev. 0, Page 281 of 461 DISCUSSION OF CHANGES ITS 3.7.12, STATION EMERGENCY VENTILATION SYSTEM (EVS) performances of the Surveillances for the two EVS trains can be larger or smaller under the ITS than under the CTS.

L02 (Category 6 - Relaxation Of Surveillance Requirement Acceptance Criteria)

CTS 4.6.5.1 .d.2 requires verification of the automatic actuation of the Station EVS trains on a containment isolation "test" signal. ITS SR 3.7.12.3 specifies that the signal may be from either an "actual" or simulated (i.e., test) signal. This changes the CTS by explicitly allowing the use of either an actual or simulated signal for the test.

The purpose of CTS 4.6.5.1 .d.2 is to ensure the Station EVS trains operate correctly upon receipt of an actuation signal. This change is acceptable because it has been determined that the relaxed Surveillance Requirement acceptance criteria are not necessary for verification that the equipment used to meet the LCO can perform its required functions. Equipment cannot discriminate between an "actual," "simulated," or "test"signal and, therefore, the results of the testing are unaffected by the type of signal used to initiate the test. This change allows taking credit for unplanned actuation if sufficient information is collected to satisfy the Surveillance test requirements. The change also allows a simulated signal to be used, if necessary. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

L03 (Category5 - Deletion Of Surveillance Requirement) CTS 4.6.5.2.1 requires the shield building area negative pressure boundary airtight doors and blowout panel to be verified closed once per 31 days. ITS 3.7.12 does not include this Surveillance. This changes the CTS by deleting this specific Surveillance.

The purpose of CTS 4.6.5.2.1 is to help ensure the shield building area negative pressure boundary is intact. This change is acceptable since this specific Surveillance is not required to ensure the shield building area negative pressure boundary is intact. The airtight doors are routinely accessed by station personnel for entry and exit into the shield building area negative pressure boundary.

Station practices and procedures require these doors to be closed immediately after use. Therefore, a specific Surveillance verifying the doors are closed is not needed: they are checked closed after use by the individuals using the doors.

Furthermore, if a door was left open by an individual, it would be found by the next individual who used the door and properly closed. Also, some of the doors will provide a security alarm if the door is left open for an extended time. The blowout panels are part of the building walls. They are not access points for entry or exit into the shield building area negative pressure boundary. Any problem with the blowout panels that affects the shield building area negative pressure boundary integrity would be identified during the drawdown test (ITS SR 3.7.12.4), similar to other problems with the boundary (e.g., a penetration leaking excessively such that it impacted the drawdown test). Furthermore, any positive pressure event that could negatively impact the blowout panels would be readily obvious to plant personnel. Thus, if the overpressure event negatively affected the blowout panels, it would not go undetected. This change is designated as less restrictive because a Surveillance Requirement required by the CTS is not required in the ITS.

Davis-Besse Page 4 of 6 Attachment 1, Volume 12, Rev. 0, Page 281 of 461

Attachment 1, Volume 12, Rev. 0, Page 282 of 461 DISCUSSION OF CHANGES ITS 3.7.12, STATION EMERGENCY VENTILATION SYSTEM (EVS)

L04 (Category I - Relaxation of LCO Requirements) CTS 4.6.5.2.1, in part, specifies that doors in the shield building area negative pressure boundary may be opened during normal transit entry and exit. ITS 3.7.12 includes this allowance in an LCO Note, which states that the shield building area negative pressure boundary may be opened intermittently under administrative control. This changes the CTS by allowing the shield building area negative pressure boundary to be opened for more reasons than is specified in the CTS.

The purpose of the CTS 4.6.5.2.1 allowance is to allow the shield building area negative pressure boundary to be opened under administrative control. This change is acceptable because the LCO requirements continue to ensure that the structures, systems, and components are maintained consistent with the safety analyses and licensing basis. The CTS allows doors in the shield building area negative pressure boundary to be opened during normal transit entry and exit.

The ITS allows these doors to be opened, but in addition will allow other portions of the boundary to be opened. This change is acceptable since administrative controls must be in place in order to open the boundary. The administrative controls required are described in the Bases. For entry and exit through doors the administrative control of the opening is performed by the person(s) entering or exiting the area. For other openings, these controls consist of stationing a dedicated individual at the opening who is in continuous communication with the control room. This individual will have a method to rapidly close the opening when a need for shield building area negative pressure boundary isolation is indicated. This change is designated as less restrictive because less stringent LCO requirements are being applied in the ITS than were applied in the CTS.

L05 (Category 7- Relaxation Of Surveillance Frequency, Non-24 Month Type Change) CTS 4.6.5.2.2 requires verification that each EVS train can drawdown the shield building area to a negative pressure of_> 0.25 inches water gauge in the annulus within 4 seconds after the fan attains a flow rate > 7200 cfm and

< 8800 cfm at least once per Refueling Interval (i.e., 24 months). ITS SR 3.7.12.4 requires this same test, however it is required to be performed using one Station EVS train every 24 months "on a STAGGERED TEST BASIS." This changes the CTS by requiring the test to be performed using each Station EVS train at least once per 48 months.

The purpose of the CTS 4.6.5.2.2 is to ensure the integrity of the shield building area negative pressure boundary. This change is acceptable because the new Surveillance Frequency provides an acceptable level of equipment reliability. The change is acceptable since the proposed Surveillance Frequency will continue to require performance of the test every 24 months. This will ensure the shield building area negative pressure boundary integrity is maintained. The status of the integrity of the shield building area negative pressure boundary can be determined with either Station EVS train. ITS SR 3.7.12.3 requires the performance of a test to ensure each Station EVS train actuates on an actual or simulated initiation signal. Therefore, each subsystem will continue to be tested to ensure it can be automatically aligned to the correct mode of operation, however the verification that the shield building area negative pressure boundary can be maintained at the proper negative pressure will only be required with one train in operation. This change is designated as less restrictive because the Davis-Besse Page 5 of 6 Attachment 1, Volume 12, Rev. 0, Page 282 of 461

Attachment 1, Volume 12, Rev. 0, Page 283 of 461 DISCUSSION OF CHANGES ITS 3.7.12, STATION EMERGENCY VENTILATION SYSTEM (EVS)

Surveillance will only be required to be performed on one Station EVS train each Surveillance interval instead of on both Station EVS trains.

Davis-Besse Page 6 of 6 Attachment 1, Volume 12, Rev. 0, Page 283 of 461

Attachment 1, Volume 12, Rev. 0, Page 284 of 461 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 12, Rev. 0, Page 284 of 461

Attachment 1, Volume 12, Rev. 0, Page 285 of 461 I

CTS All changes are unless otherwise noted 9 Station EVS 3.7.12 3.7 PLANT SYSTEMS Station 3.7.12 mergency Ventilation System (EVS)

Station 3.6.5.1, LCO 3.7.12 Two VS trains shall be OPERABLE.

3.6.5.2 iel h-------------- lin- e --- ve---NT -----------

NOTE --------------.-.-.-----.................-

4.6.5.2.1 The ~ buildinghegative pressure-'*] boundary may be opened intermittently under administrative control.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME 3.6.5.1 Action A. One EVS train A.1 Restore EVS train to 7 days inoperable. OPERABLE status.

3.6.5.2 Action B. Two;EVS trains -ttion B.1 Restore u a building 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months inoperable due to shied negative pressure i&ý inoperable a boundary to OPERABLE buildingiegative status.

pressure re-a] boundary.

3.6.5.1 Action, C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 3.6.5.2 Action associated Completion Time not met. AND C.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months BWOG STS 3.7.12-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 285 of 461

Attachment 1, Volume 12, Rev. 0, Page 286 of 461 CTS on EVS 3.7.12 0

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY Ston SR 3.7.12.1 Operate eachVStrin forl[ 10 conYnuous hours] 31 days 00 4.6.5.1.a 1with thXheaters operatin or (for sy 'tems without

Ž_hears)

.15 minutesj 4.6.5.1.b SR 3.7.12.2 Perform requiredVS filter testng in accordance with the *Ventilation Filter Testing Program (VFTP)ý In accordance with the Mi/FTPM 00

- -- on at ra]

4.6.5.1.d.2 SR 3.7.12.3 Verify each+EVS train actuates on an actual or simulated actuation signal.

F months (D00

[station attain negative 420 4.6.5.2.2 SR 3.7.12.4 ininches VSa pressure water gauge relative6 atmospheric prssureI

[ months on a STAGGERED 000 4second after the durin the3staccidentrodeofoperatio ata TEST BASIS wfooratea M

[is ? 7200 cfm and <- 8 4.6.5.1.d.3 SR 3.7.12.5 MVerify each be opened.

-cooling bypass damper can months M (00 BWOG STS 3.7.12-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 286 of 461

Attachment 1, Volume 12, Rev. 0, Page 287 of 461 JUSTIFICATION FOR DEVIATIONS ITS 3.7.12, STATION EMERGENCY VENTILATION SYSTEM (EVS)

1. Changes are made to the ISTS Specification which reflect plant specific nomenclature.

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

3. ISTS SR 3.7.12.4 has been modified consistent with the Davis-Besse current licensing basis and design basis. The Station EVS trains are assumed to drawdown the shield building area boundary to a negative pressure in the annulus within 4 seconds after the flow rate is > 7200 cfm and < 8800 cfm.

Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 287 of 461

Attachment 1, Volume 12, Rev. 0, Page 288 of 461 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 12, Rev. 0, Page 288 of 461

Attachment 1, Volume 12, Rev. 0, Page 289 of 461 All changes are unless otherwise noted 9 EVS B 3.7.12 B 3.7 PLANT SYSTEMS B3.7.12Emergency Ventilation System,(EVS)

BASES BACKGROUND The EVS fi s air from the a of the active emer ncy Core Cooling System (ECCScornponents dug the recirculatio phý eofalss of coolant acc~ident. CA). I TeEVS consists of two independent, redundant trains. Each train consists of a prefilter, a high efficiency particulate air (HEPA) filter, an activated charcoal.adsorber section for removal of gaseous activity (principally iodines), and a fan. Ductwork, valves or dampers, and instrumentation also form part of the system. The syste initiates filtered ventilat n of the Auxiliary B3bling negative essure area lowing receipt ofasafety features act tion signal (S S).

The E is a stand system. Duri emergency operat ns, the EVS IN 2 damperslre realigne , and fans are s rted to begin filtrati . Upon receipt of e SFAS si al(s), normal ai discharges from the egative pressure aria are isolat and the strea of ventilation air dis arqes through the system filter tins.1 The prefters remove aný\arge particles o an te air, lodn any entraineq h "1P d'rbr.in water droplets',poresent, fles 'dchrol to prevent excessive e EVS is discussed in the FSAR, Sectionsg6.2.3k9.4.f, and 15.4.6]

(Refs. 1,2, and 3, respectively).

APPLICABLE The design basis of the*EVS is established by the large break LOCA.

SAFETY The system evaluation assumes a passive failure of the ECCS outside ANALYSES containment, such as an ECCS pump seal failure during the recirculation mode. In such a case, the system limits radioactive release to within 10 CFR 100 (Ref. 4) requirements. The analysis of the effects and consequences of a large break LOCA is presented in Reference 3. he EVSso actuates following a mall break LOCA, in tho cases where the unit es into the recirculatio mode of long term cooli and to cleanup re ses of smaller leaks, uch as from valve stem p cking.

BWAOG STS B 3.7.12-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 289 of 461

Attachment 1, Volume 12, Rev. 0, Page 290 of 461 B 3.7.12 O INSERT I The function of the Station Emergency Ventilation System (EVS) is to collect and process potential leakage from the containment vessel to minimize environmental activity levels resulting from all sources of containment leakage following a loss of coolant accident (LOCA).

The Station EVS is required to:

a. Maintain a negative pressure (minimum of 1/4 inch water gauge), with respect to outside atmosphere, within the annular space between the shield building and the containment vessel and in the penetration rooms following a LOCA; and

b. Provide a filtered exhaust path from the shield building annulus and the penetration and pump rooms following a LOCA.

O INSERT 2 Normally, the Station EVS is idle during normal plant operations. Following a LOCA, an Incident Level 1 Safety Features Actuation System (SFAS) signal (Containment Pressure - High or Reactor Coolant System Pressure - Low) will start both fans and then the Station EVS suction dampers and the discharge dampers to the station vent stack will open. The recirculating dampers remain closed until the annulus differential pressure reaches the setpoint.

Interconnecting dampers CV5024 and CV5025 will be automatically closed (if they are open) by the SFAS signal in the event of a LOCA. The Level 1 SFAS signal will also isolate the area being serviced by the Station EVS by closing the Containment Purge and Exhaust System valves and the ECCS pump room isolation valves to ensure that the Station EVS can draw down the shield building area to the required negative pressure.

O INSERT 3 Prefilters are provided to remove coarse airborne particles to prolong HEPA filter life. HEPA filters are provided to remove fine airborne particulates that penetrate the prefilter. The activated charcoal adsorbers are impregnated to remove methyl iodide as well as elemental iodine contaminants resulting from a LOCA.

Insert B 3.7.12-1 Attachment 1, Volume 12, Rev. 0, Page 290 of 461

Attachment 1, Volume 12, Rev. 0, Page 291 of 461 I

All changes are EVS unless otherwise noted 9 B 3.7.12 BASES APPLICABLE SAFETY ANALYSES (continued) f sst Two types of system failures r n"ered in the accident analysi complete loss of function, and excessive;[EAKAGE- Either type of failure may result in a lower efficiency of removal of any gaseous and particulate 0

activity released to the ECCS pump rooms following a LOCA.

Jon Following a LOCA, an EJSFAS signal starts theEVS fans and opens the NSERT4 dampe ted in the tration room t4 ductwork. The gSFAS signal closes all containment isolation valves [an turge s'ystem'ylves].

The purge system fans, if running, are shut down automatically.

The EVS satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO S Two independent and redundant trains of the*EVS are required to be OPERABLE to ensure that at least one is available, assuming that a single failure disables the other train coincident with loss of offsite power.

Total system failure could result in atmospheric release from the negative pressure area boundary exceeding Reference 4 limits in the event of a Design Basis Accident (DBA).

The EVS is considered OPERABLE when the individual components Si necessary to inmaintain OP.*ERABLE the negative pressure area boundary filtration are both trains.

VS train is considered OPERABLE when its associated:

a. Fan is OPERABLE_

,--8 0

b. HEPA filter and charcoal adsorber are not excessively restricting flow, and are capable of performing their filtration functions]and 03

c. I [He er, 35eister,]e u ctwork, valves, and dampers are OPERABLE, and air circulation can be maintained. 0 The LCO is modified by a Note allowing the 7 Vuilding egative pressure 'ai-] boundary to be opened intermittently under administrative 0

controls. For entry and exit through doors, the administrative control of the opening is performed by the person(s) entering or exiting the area.

For other openings, these controls consist of stationing a dedicated 0

individual at the opening who is in continuous communication with the control room. This individual will have a method to rapidly close the opening when a need for Ouildinginegative pressur-e isolation is indicated.

BWOG STS B 3.7.12-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 291 of 461

Attachment 1, Volume 12, Rev. 0, Page 292 of 461 B 3.7.12 O INSERT 4 Station EVS suction dampers and the discharge dampers to the station vent stack O INSERT4A mechanical penetration room dampers, Purge and Exhaust System valves, and the connection between the Emergency Ventilation System and the spent fuel pool area O INSERT 4B Furthermore, the list of access openings required to be closed to ensure the shield building area negative pressure boundary is intact is provided in Reference 5.

Insert B 3.7.12-2 Attachment 1, Volume 12, Rev. 0, Page 292 of 461

Attachment 1, Volume 12, Rev. 0, Page 293 of 461 r All changes are E'EQ. EVS unless otherwise noted B 3.7.12 BASES Sio APPLICABILITY In MODES 1, 2, 3, and 4, th*EVS is required to be OPERABLE consistent with the OPERABILITY requirements of the ECCS.

In MODES 5 and6 theEVS is not required to be OPERABLE since the ECCS is not required to be OPERABLE.

ACTIONS A.1 the inoperable Station Staion EVS train to )

With one-EVS train inoperable, action must be taken to restoreý OPERABLE status within 7 days. During this time, the remaining Station OPERABLE train is adequate to perform the EVS safety function.

However, the overall reliability is reduced because a Single failure in the OPERABLE EVS train could result in loss of EVS function.

The 7 day Completion Time is appropriate because the risk contribution is less than that of the ECCS (72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time), and this system is not a direct support system for the ECCS. The 7 day Completion Time is based on the low probability of a DBA occurring during this time period, and ability of the remaining train to provide the required capability.

B.1

. . R EVIEW E 'S NOTE ------- ------ .............--------

Adoption of Co dition B is dependent on a commitment fr m the licensee to have written/procedures available escribing compen tory measures to be taken in he event of an intenti nal or unintentional entry into 0

Condition B.

Etaon ýl ftheu iary uildinginegative pressureigara boundary is inoperable, the EVS trains cannot perform their intended functions. Actions must be 0

taken to restor PABL uildinginegative pressure ar(a(

tOOPERABLE L Jbounday within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . During the period that the Auilding status - negative pressurelaledi compensatory boundary is inoperable, appropriate shield measureslýositnt*th the intent, as/ picable, ofl JGDC 19,63, 4 and 10 CFR Part 1 0]ishould be utilized to protect plant personnel from potential hazards such as radioactive contamina'tion, toxic chemicals, smoke, temperature and relative humidity, and physical security. Preplanned measures should be available to address these concerns for intentional and unintentional entry into the condition. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is reasonable based on the low probability of a DBA occurring during this time period, and the use of compensatory measures. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is a typically reasonable time to diagnose, plan and possibly repair, and test most problems with the sVuilding iegative pressurerý boundary.

BVVOG STS B 3.7.12-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 293 of 461

Attachment 1, Volume 12, Rev. 0, Page 294 of 461 All changes are 1 unless otherwise noted J EVS B 3.7.12 BASES ACTIONS (continued)

CA1 and C.2 If the train or the eVS u uilding*inegative E' pressur aoe e boundary cannot be -restored to OPERABLE status within the associated Completion Time, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in-an orderly manner and without challenging unit systems.

SURVEILLANCE SR 3.7.12.1 REQUIREMENTS Standby systems should be checked periodically to ensure that they function properly. Since the environment and normal operating conditions on this system are not severe, testing each train once a month provides an adequate check on this system.I Mont' heater oper ns dry out nitiating each train from the oisture that may h e accumulated in e charcoal fro umidity in control room, with flow throughI the arrient air. [Systems i heaters must b ,operated:ý 10 ti*nuous the HEPA filters and charcoal L'*hours wi* the heaters energiz . Systems witho't heaters. need on, be

asrbr, n oeatn *) oerated for -_15 minutes N]demonstrate the function of t_-'h-tysi The 31 day Frequency is based on knownreliability of equipmentand the two train redundancy available.

SR 3.7.12.2 This SR verifies that the require VS testing is performed in accordance with the *Ventilation Filter Testing Program (VFTP)a The *VFT includes 2 m0nm testing HEPA filter performance, charcoal adsorber efficiency, system flow rate, and the physical properties of the activated charcoal (general use and following specific operations). Specific test frequencies and additional information are discussed in detail in thefVFTFj SR 3.7.12.3 This SR verifies that eac4EVS train starts and operates on an actual or (i.e., containment isolation)

Bc Ihtkspecified simulated actuatiorn renrce 5.

i'pe signal.

Th'* *8] month Frequen is consistent with 0 rOperating experience has shown that these Icomponents usually pass the Surveillance Iwhen performed at the 24 month Frequency.

ITherefore, the Frequency is acceptable from*

La reliability standpoint.

BWOG STS B 3.7.12-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 294 of 461

Attachment 1, Volume 12, Rev. 0, Page 295 of 461 All changes are I

unless otherwise noted 9 O EVS B 3.7.12 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.7.12.4

-- -- [(shield building area }L(

This SR verifies the integrity of thetnegative pressure boundary '*. f"inthe annulus The ability of theEVS tm aa negative pressurel, vftý resct to" tent -ontaminate ~cent areas4 is periodicall tested to verify sieldbuig Station roper unctioning o EVS. During the post accidenrmode of peration, t EVS is designed to maintain a slight nega ive pressure in 0

ýIthe negative pressure boundary r*-ia-with respect to adjacent areas to leakage prevent unfiltereSE. TheEVS is designed to maEia - Station ahin0 pressure at a flow rate of m from theCiegalive pressure The Surveillance is performed with the flow' boundaryr i~I-The Frequency of months on a STAGGERED TEST 2 path established prior to starting the Station BASIS is consistent with industry ractice and er filtra s EVS fan, and the other dampers associated t , and 5 ,8 \

with the shield building area negative 24 - 7200 ctm and - 8800

,pressure boundary closed.

rISR 37.12.5 _ shield building area necessary to ensure that LITY of thetVS §filteri REFERENCES 1. FSAR, Section~ M52 .

perating experience has shown that these components usually pass the Surveillance

2. FSAR, SectionM9.4 j2. when performed at the 24 month requency. Therefore, the Frequency is acceptable from a reliability standpoint.

3. FSAR, Section M1 5.4.1

4. 10CFR100.11.

Rev. 2 .- Technical

5. IReg latory (uide 1. 0 BWOG STS B 3.7.12-5 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 295 of 461

Attachment 1, Volume 12, Rev. 0, Page 296 of 461 JUSTIFICATION FOR DEVIATIONS ITS 3.7.12 BASES, STATION EMERGENCY VENTILATION SYSTEM (EVS)

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

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

3. These punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, TSTF-GG-05-01, Section 5.1.3.

4. Changes are made to reflect changes made to the Specification.

5. The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed in to what is needed to meet this requirement. This is not meant to be retained in the final version of the plant specific submittal. In addition, the ISTS ACTION described in these Bases is currently allowed by the Davis-Besse CTS.

6. Changes are made to reflect the Specification.

7. Typographical error corrected.

Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 296 of 461

Attachment 1, Volume 12, Rev. 0, Page 297 of 461 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 12, Rev. 0, Page 297 of 461

Attachment 1, Volume 12, Rev. 0, Page 298 of 461 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.7.12, STATION EMERGENCY VENTILATION SYSTEM (EVS)

There are no specific NSHC discussions for this Specification.

Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 298 of 461

Attachment 1, Volume 12, Rev. 0, Page 299 of 461 ATTACHMENT 13 ITS 3.7.13, SPENT FUEL POOL AREA EMERGENCY VENTILATION SYSTEM (EVS)

Attachment 1, Volume 12, Rev. 0, Page 299 of 461

, Volume 12, Rev. 0, Page 300 of 461 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 12, Rev. 0, Page 300 of 461

Attachment 1, Volume 12, Rev. 0, Page 301 of 461 ITS 3.7.13 ITS REFUELING OPERATIONS STORAGE POOL VENTILATION LIMITING CONDITION FOR OPERATION storage p LCO 3.7.13 3-.9.12 Two inde~endentlemergency ventilation systems servicing the

-OPERABLE \When an emergency ventilationsystem servicing the storage po I e acceptance criteria of Surveillance Requirement 4.9.12.1 solely becauselthc LCO 3.7.13 hatcn*,Aopen andi both doors of the containment personnel air lock are open, it Note OPERA.BLE/provied that at least one personnel #r lock door is capable ofbe lindividual is avai ble immediately outside the pzrsonnel air lock to close the d ACTION: Add propose ATOA LU04 ACTION B a. With one emergency ventilation system servicing the storage pool area inoperable,[ fuel movement within the spent fuel pool Jor crane ogEration with lo, s ovcr the spx-nt fue pooi may procee provided the OPERABLE emergency ventilation system servicing the storage pool area is in LA02 operationland dischargin*,- trough at least one t ofHEPA filters andcharcoal adsorbers*

b. With one emergency ve ilation system servicing the storage pool areai operable, CORE ALTERATIONS and uel movement within containment may procee provided either the OPERABLE emer cy ventilation system servicing the storage p I area is in operation and L0, discharging throu at least one train of HEPA filters and charco adsorbers or the containment ACTION C c. With no emergency ventilation system scivicing the storare ool area OPERABLEE susLend (ALTEP-A TIONS and all operations involving movement of1 Within the cottainment orlspent fuel L0,5*J pool, Jor crane oaration with loos over the sunt ue oo until at least one system is restored to OPERABLE statu~s. J CORE A.TERATONS and fuel movement wit n containment may proceedL0

]provided the containment eqi~pment hatch cover is closed and held *h l'lace by a minimum of four:

A02 ACTIONS 1

d. The provisions ofISpecifications 3.O31anY3_0.4 are not applicable.

NOTE SURVEILLANCE REQUIREMENTS SR 3.7.13.4 4.9.12.1 The above required emergency ventilation system servicing the storage pool area shall be demonst-ated OPERABLE per the applicable Surveillance Requirements of 4.6.5.1, and at least once each REFUELING INTERVAL y verifying that the emergency ventilation system 'ervicing the storage pool area maintains the storage pool area at a negative pressure of> 1/8 inches Water Gauge relative to the outside atmosphere during system operation. I on a STAGGERED TEST 8 SR 3.7.13.3 4.9.12.2 The normal storage pool ventilation system shall be demonstrated OPERABLE at least once each REFUELING INTERVAL by verifying that the systemlfans stor automaticoly and th actual or lautomatica ldivert flow into e emergency v.e ilation sy'ste i on a fuel s trage arT4 high-rdiatiol test L07 signal.

actuates atainLO DAVIS-BESSE, UNIT I 3149-12 Amendment No. 135,217,237, 247,251, Page 1 of 3 Attachment 1, Volume 12, Rev. 0, Page 301 of 461

Attachment 1, Volume 12, Rev. 0, Page 302 of 461 ITS 3.7.13 ITS CONTAINMENT SYSTEMS 3/4.6.5 SHIELD BUILDING EMERGENCY VENTILATION SYSTEM See ITS]

LIMITING CONDITION FOR OPERATION 3.6.5.1 Two independent emergency ventilation systems shall be OPERAkBLE.

APPLICABILITY: MODES 1, 2, 3 and 4.

ACTION:

With one emergency ventilation system inoperable, restore the inoperable system to OPERABLE status within 7 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

SURVEILLANCE REQUIREMENTS 4.6.5.1 Each emergency ventilation system shall be demonstrated OPERABLE:

SR 3.7.13.1 a. At least once per 31 days on a r3TAGGEY TEST BA by initiatinvtrom the jcontrol room. ilow tI'rough the HEPA filters and/charcoal adsorbers 4,n,,ia, verif'ying that the system operates for at leat 15 minutes. L0 SR 3.7.13.2 b. At least once each REFUELING INTERVAL and in accordance with the Ventilation Filter Testing Program (VFTP).

DAVIS-BESSE, UNIT I 3/4 6-28 A-mendment No. 155,217, 24, Page 2 of 3 Attachment 1, Volume 12, Rev. 0, Page 302 of 461

Attachment 1, Volume 12, Rev. 0, Page 303 of 461 ITS 0 ITS 3.7.13 CONTAINMENT SYSTEMS SURVEILLANCE REOUIREMENTS (Continued)

I. [Deleted]

2. [Deleted] {See ITS]

3. [Deleted]

c. [Deleted]

d. At least once each REFUELING INTERVAL by:

I. [Deleted]

2. Verifying that the system starts automatically on any containment isolation test signal; and SR 3.7.13.5 3. Verifying that the filter cooling bypass valves can be manually opened.

DAVIS-BESSE, UNIT I 3/4 6-29 Amendment No. 43,135,155,209,217,233, 244, Page 3 of 3 Attachment 1, Volume 12, Rev. 0, Page 303 of 461

Attachment 1, Volume 12, Rev. 0, Page 304 of 461 DISCUSSION OF CHANGES ITS 3.7.13, SPENT FUEL POOL AREA EMERGENCY VENTILATION SYSTEM (EVS)

ADMINISTRATIVE CHANGES A01 In the conversion of the Davis-Besse Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1430, Rev. 3.1, "Standard Technical Specifications-Babcock and Wilcox Plants" (ISTS).

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

A02 CTS 3.9.12 Action d states, in part, that the provisions of Specification 3.0.4 are not applicable. ITS 3.7.13 does not include this exception. This changes the CTS by deleting the specific exception to Specification 3.0.4.

This change is acceptable because it results in no technical change to the Technical Specifications. CTS 3.0.4 provides requirements to preclude changing MODES with inoperable equipment. However, ITS LCO 3.0.4 has been modified to allow MODE changes under certain circumstances. This is justified in the Discussion of Changes for ITS Section 3.0. Therefore, this specific exception to CTS 3.0.4 is not needed in the ITS. This change is designated as administrative because it does not result in a technical change to the CTS.

MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.9.12 states that two "independent" emergency ventilation systems servicing the storage pool area shall be OPERABLE. ITS LCO 3.7.13 states that two Spent Fuel Pool Area EVS trains shall be OPERABLE. This changes the CTS by moving the details that the Spent Fuel Pool Area EVS trains are "independent" from the CTS to the Bases.

The removal of these details, which are related to system design, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement that two Spent Fuel Pool Area EVS trains be OPERABLE. The details concerning the independence of the trains do not need to appear in the Specification in order for the requirement to apply. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Davis-Besse Page 1 of 8 Attachment 1, Volume 12, Rev. 0, Page 304 of 461

Attachment 1, Volume 12, Rev. 0, Page 305 of 461 DISCUSSION OF CHANGES ITS 3.7.13, SPENT FUEL POOL AREA EMERGENCY VENTILATION SYSTEM (EVS)

Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LA02 (Type 3 - Removing ProceduralDetails for Meeting TS Requirements or Reporting Requirements) CTS 3.9.12 Actions a and b, under certain conditions, requires the OPERABLE Spent Fuel Pool Area EVS train to be in operation and "discharging through at least one train of HEPA filters and charcoal adsorbers."

Under similar conditions, ITS 3.7.13 Required Action B.1 requires the OPERABLE Spent Fuel Pool EVS train to be placed in operation. This changes the CTS by moving the details of what placing the train in operation entails to the Bases.

The removal of these details for meeting a Technical Specification requirement is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirements to place the OPERABLE Spent Fuel Pool Area EVS train in operation. Also, this change is acceptable because these types of procedural details will be adequately controlled in the ITS Bases.

Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications.

LA03 (Type 3 - Removing ProceduralDetails for Meeting TS Requirements or Reporting Requirements) CTS 3.9.12, in part, allows CTS 4.9.12.1 not to be met due to both doors of the personnel air lock being open, provided at least one personnel air lock door is capable of being closed and a designated individual is available immediately outside the personnel air lock to close the door. The Note to ITS LCO 3.7.13 also allows the Spent Fuel Pool Area EVS trains to be inoperable due to opening of the boundary under administrative control, but does not include these specific provisions of the allowance. This changes the CTS by moving the details of controlling the open air lock doors (i.e., one is capable of being closed and a designated individual is available immediately outside the personnel air lock to close the door) to the Bases.

The removal of these details for meeting a Technical Specification requirement is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the LCO Note allowance to open the boundary under administrative control. Also, this change is acceptable because these types of details will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5.

This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because details for meeting Technical Specification requirements are being removed from the Technical Specifications.

Davis-Besse Page 2 of 8 Attachment 1, Volume 12, Rev. 0, Page 305 of 461

Attachment 1, Volume 12, Rev. 0, Page 306 of 461 DISCUSSION OF CHANGES ITS 3.7.13, SPENT FUEL POOL AREA EMERGENCY VENTILATION SYSTEM (EVS)

LA04 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 4.9.12.2 requires verification that the system "fans stop automatically" and "that dampers automatically divert flow into the emergency ventilation system" on a "fuel storage area high radiation" test signal. ITS SR 3.7.13.3 does not state the specific automatic actions or the specific type of signal, but only specifies the Spent Fuel Pool Area EVS "actuates" on an actual or simulated "actuation" signal. This changes CTS by moving the actions when the system actuates and the type of actuation signal to the Bases. The change to replace "test" with "simulated" and allow both "actual or simulated" actuation signals to be used for these SRs is discussed in DOC L07.

The removal of these details, which are related to system design, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement to verify that appropriate equipment actuates upon receipt of an actuation signal.

Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5 of the ITS. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LA05 (Type 3 - Removing ProceduralDetails for Meeting TS Requirements or Reporting Requirements) CTS 4.6.5.1 .a states that each EVS train shall be demonstrated OPERABLE by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that the train operates for a least 15 minutes. ITS SR 3.7.13.1 states to operate each Spent Fuel Pool Area EVS train for_> 15 minutes. This changes the CTS by moving the details of how the Surveillance is conducted to the Bases.

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

LESS RESTRICTIVE CHANGES L01 (Category I - Relaxation of LCO Requirements) CTS 3.9.12, in part, specifies that both doors of the containment personnel air lock may be opened under administrative control (a designated individual who can close the door when Davis-Besse Page 3 of 8 Attachment 1, Volume 12, Rev. 0, Page 306 of 461

Attachment 1, Volume 12, Rev. 0, Page 307 of 461 DISCUSSION OF CHANGES ITS 3.7.13, SPENT FUEL POOL AREA EMERGENCY VENTILATION SYSTEM (EVS) needed). ITS 3.7.13 includes this allowance in an LCO Note, which states that the spent fuel pool area negative pressure boundary may be opened under administrative control. This changes the CTS by allowing the spent fuel pool area negative pressure boundary to be opened for more reasons than is specified in the CTS.

The purpose of the CTS 3.9.12 allowance is to allow the boundary to be opened under administrative control. This change is acceptable because the LCO requirements continue to ensure that the structures, systems, and components are maintained consistent with the safety analyses and licensing basis. The CTS allows both doors of the personnel air lock to be opened under administrative control. The ITS allows these doors to be opened, but in addition will allow other portions of the boundary to be opened. This change is acceptable since administrative controls must be in place in order to open the boundary. The administrative controls required are described in the Bases. For entry and exit through doors the administrative control of the opening is performed by the person(s) entering or exiting the area. For other openings, these controls consist of stationing a dedicated individual at the opening who is in continuous communication with the control room. This individual will have a method to rapidly close the opening when a need for spent fuel pool area negative pressure boundary isolation is indicated. This change is designated as less restrictive because less stringent LCO requirements are being applied in the ITS than were applied in the CTS.

L02 (Category 2 - Relaxation of Applicability) CTS 3.9.12 states, in part, that the requirements for the Spent Fuel Pool Area EVS trains are applicable "Whenever irradiated fuel assemblies is in the spent fuel pool." ITS 3.7.13 is applicable "During movement of irradiated fuel assemblies in the spent fuel pool." This changes the CTS by restricting the Applicability to only when there is a potential for a fuel handling accident in the spent fuel pool, i.e., during the movement of irradiated fuel assemblies in the spent fuel pool.

The purpose of CTS 3.9.12 is to ensure that any releases of radioactivity from a fuel handling accident are within the limits of the fuel handling accident analysis.

This change is acceptable because the requirements continue to ensure that the structures, systems, and components are maintained in the MODES and other specified conditions assumed in the safety analyses and licensing basis. The fuel handling accident analysis (outside containment) assumes that a single fuel assembly is damaged. A fuel handling accident is only assumed to occur when an irradiated fuel assembly is being moved. Therefore, the ITS imposes the controls on the Spent Fuel Pool Area EVS during the movement of irradiated fuel in the spent fuel pool. This change is designated as less restrictive because the LCO requirements are applicable in fewer operating conditions than in the CTS.

L03 (Category2 - Relaxation of Applicability) CTS 3.9.12, in part, allows the acceptance criteria of CTS 4.9.12.1 to not be met solely due to the containment equipment hatch being open in combination with both doors of the personnel airlock being open. The Applicability of CTS 3.9.12 includes CORE ALTERATIONS or movement of irradiated fuel within the containment with the containment equipment hatch open. CTS 3.9.12 Action b provides the actions when one Spent Fuel Pool Area EVS train is inoperable during CORE Davis-Besse Page 4 of 8 Attachment 1, Volume 12, Rev. 0, Page 307 of 461

Attachment 1, Volume 12, Rev. 0, Page 308 of 461 DISCUSSION OF CHANGES ITS 3.7,13, SPENT FUEL POOL AREA EMERGENCY VENTILATION SYSTEM (EVS)

ALTERATIONS or movement of irradiated fuel within the containment with the containment equipment hatch open. CTS 3.9.12 Action c, in part, provides the actions when both Spent Fuel Pool Area EVS trains are inoperable during CORE ALTERATIONS or movement of irradiated fuel within the containment with the containment equipment hatch open. ITS 3.7.13 does not include Spent Fuel Pool EVS requirements during CORE ALTERATIONS or movement of irradiated fuel within the containment with the containment equipment hatch open. This changes the CTS by deleting the requirements for the Spent Fuel Pool EVS to be OPERABLE during CORE ALTERATIONS or movement of irradiated fuel within the containment with the containment equipment hatch open.

The purpose of the allowance in CTS 3.9.12 is to allow both doors of the personnel air lock to be open, as allowed in CTS 3.9.4 (ITS 3.9.3), and not require declaring both Spent Fuel Pool Area EVS trains inoperable due to the inability to meet CTS 4.9.12.1, the Surveillance that ensures the boundary is capable of maintaining a negative pressure. This allowance was added to the CTS by License Amendment 251, approved by the NRC on February 14, 2002.

All of the above described CTS requirements were added as part of this amendment. However, the allowance can only be used after the reactor has been shutdown for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , since CTS 3.9.3 does not allow any irradiated fuel movement until the reactor has been shutdown for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . CTS 3.9.4 provides the requirements for containment penetrations during movement of irradiated fuel assemblies in the containment, and the equipment hatch and air lock doors are covered by CTS 3.9.4. However, as part of this ITS conversion, the Applicability of CTS 3.9.4 has been changed (as shown in ITS 3.9.3) to only include "recently" irradiated fuel assembly movement in thecontainment. As described in the ITS 3.9.3 Bases, the term "recently" means fuel that has occupied part of a critical reactor core within the previous 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . Thus, after the reactor has been shutdown for > 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , ITS 3.9.3 is no longer applicable and the containment equipment hatch and air lock doors can be opened. The justification for the CTS 3.9.4 (ITS 3.9.3) Applicability change is described in ITS 3.9.3 DOC L01. If the containment equipment hatch or air lock doors are opened anytime after the reactor has been shutdown for > 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , the spent fuel pool area negative pressure boundary extends to include the inside of the containment pressure vessel. The Note to ITS LCO 3.7.13 provides adequate administrative controls to ensure that in this case (i.e., the containment equipment hatch and air lock doors opened), the negative pressure boundary can be properly restored. Therefore, this change is considered acceptable. This change is designated as less restrictive because the ITS LCO requirements are applicable in fewer operating conditions than in the CTS.

L04 (Category 4 - Relaxation of Required Action) When a Spent Fuel Pool Area EVS train is inoperable, CTS 3.9.12 Action a allows fuel movement in the spent fuel pool to continue, provided the OPERABLE Spent Fuel Pool Area EVS train is in operation. No time is provided to restore the inoperable train prior to requiring the OPERABLE train to be in operation. ITS 3.7.13 ACTION A allows 7 days to restore an inoperable Spent Fuel Pool Area EVS train prior to requiring the OPERABLE train to be placed in operation. This changes the CTS by allowing 7 days to restore an inoperable Spent Fuel Pool Area EVS train prior to placing the OPERABLE train in operation.

Davis-Besse Page 5 of 8 Attachment 1, Volume 12, Rev. 0, Page 308 of 461

Attachment 1, Volume 12, Rev. 0, Page 309 of 461 DISCUSSION OF CHANGES ITS 3.7.13, SPENT FUEL POOL AREA EMERGENCY VENTILATION SYSTEM (EVS)

The purpose of CTS 3.9.12 Action a is to place the Spent Fuel Pool Area EVS in the condition assumed in the accident analysis. This change is acceptable because the requirements continue to ensure that the structures, systems, and components are maintained in the MODES and other specified conditions assumed in the safety analyses and licensing basis. During this additional 7 day period, one train of the Spent Fuel Pool Area EVS remains OPERABLE and capable of performing its assumed safety function. Furthermore, this 7 day time is consistent with the time allowed for other ventilation system Technical Specifications when one ventilation train is inoperable (e.g., CTS 3.6.5.1 and ITS 3.7.12). This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L05 (Category 4 - Relaxation of RequiredAction) CTS 3.9.12 Actions a and c provide an option that when one or both Spent Fuel Pool Area EVS trains are inoperable, to immediately suspend fuel movement and crane operations with loads over the spent fuel pool. Under similar conditions, ITS 3.7.13 Required Actions B.2 and C.1 require immediate suspension of movement of irradiated fuel assemblies in the spent fuel pool. This changes the CTS by deleting the requirement to suspend non-irradiated fuel assembly movement and to suspend crane operations over the spent fuel pool.

The purpose of CTS 3.9.12 Actions a and c is to preclude a fuel handling accident from occurring when the initial conditions for that accident are not met.

This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The only initiator to a fuel handling accident assumed in the accident analysis is the damaging of a single irradiated fuel assembly.

Damaging a fuel assembly which has not been irradiated has no significant radiological effects and is not assumed in the fuel handling accident analysis.

Therefore, stopping the handling of fuel assemblies which have not been irradiated is not required. The dropping of loads onto fuel assemblies in the spent fuel pool is not an initiator that is assumed in the fuel handling accident analysis. The movement of heavy loads is addressed by the Davis-Besse response to NUREG 0612, "Control of Heavy Loads at Nuclear Power Plants,"

and Generic Letter 81-07. Therefore, these activities are not restricted in the Technical Specifications. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L06 (Category 7- Relaxation Of Surveillance Frequency, Non-24 Month Type Change) CTS 4.9.12.1 requires verification that each Spent Fuel Pool Area EVS train can maintain > 0.125 inches vacuum water gauge relative to the outside atmosphere at least once per Refueling Interval (i.e., 24 months). ITS SR 3.7.13.4 requires this same test, however it is required to be performed every 24 months "on a STAGGERED TEST BASIS." This changes the CTS by requiring the test to be performed using each Spent Fuel Pool Area EVS train at least once per 48 months.

The purpose of the CTS 4.9.12.1 is to ensure the integrity of the spent fuel pool area boundary. This change is acceptable because the new Surveillance Davis-Besse Page 6 of 8 Attachment 1, Volume 12, Rev. 0, Page 309 of 461

Attachment 1, Volume 12, Rev. 0, Page 310 of 461 DISCUSSION OF CHANGES ITS 3.7.13, SPENT FUEL POOL AREA EMERGENCY VENTILATION SYSTEM (EVS)

Frequency provides an acceptable level of equipment reliability. The change is acceptable since the proposed Surveillance Frequency will continue to require performance of the test every 24 months. This will ensure the spent fuel pool area boundary integrity is maintained. The status of the integrity of the spent fuel pool area boundary can be determined with either Spent Fuel Pool Area EVS train. ITS SR 3.7.13.3 requires the performance of a test to ensure each Spent Fuel Pool Area EVS train actuates on an actual or simulated initiation signal.

Therefore, each subsystem will continue to be tested to ensure it can be automatically aligned to the correct mode of operation, however the verification that the Spent Fuel Pool Area can be maintained at the proper negative pressure will only be required with one train in operation. This change is designated as less restrictive because the Surveillance will only be required to be performed on one Spent Fuel Pool Area EVS train each Surveillance interval instead of on both Spent Fuel Pool Area EVS trains.

L07 (Category 6 - Relaxation Of Surveillance Requirement Acceptance Criteria)

CTS 4.9.12.2 requires verification of the automatic actuation of the Spent Fuel Pool Area EVS trains on a fuel storage area high radiation "test" signal. ITS SR 3.7.13.3 specify that the signal may be from either an actual or simulated (i.e., test) signal. This changes the CTS by explicitly allowing the use of either an actual or simulated signal for the test. The change to remove the specific type of actuation signal (i.e., fuel storage area high radiation) to be used for this SR is discussed in DOC LA04.

The purpose of CTS 4.9.12.2 is to ensure that the Spent Fuel Pool Area EVS trains operate correctly upon receipt of an actuation signal. This change is acceptable because it has been determined that the relaxed Surveillance Requirement acceptance criteria are not necessary for verification that the equipment used to meet the LCO can perform its required functions. Equipment cannot discriminate between an "actual," "simulated," or "test" signal and, therefore, the results of the testing are unaffected by the type of signal used to initiate the test. This change allows taking credit for unplanned actuation if sufficient information is collected to satisfy the Surveillance test requirements.

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

L08 (Category 7- Relaxation Of Surveillance Frequency, Non-24 Month Type Change) CTS 4.6.5.1 .a states that each EVS train shall be demonstrated OPERABLE at least once every 31 days "on a STAGGERED TEST BASIS" by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that the train operates for a least 15 minutes. ITS SR 3.7.13.1 requires a similar test every 31 days, but does not include the "STAGGERED TEST BASIS" requirement. This changes the CTS by deleting the requirement to test on a STAGGERED TEST BASIS.

The purpose of CTS 4.6.5.1 .a is to demonstrate the OPERABILITY of the EVS trains. This change is acceptable because the new Surveillance Frequency provides an acceptable level of equipment reliability. This change deletes the requirement to perform CTS 4.6.5.1 .a on a STAGGERED TEST BASIS. The intent of a requirement for staggered testing is to increase reliability of the Davis-Besse Page 7 of 8 Attachment 1, Volume 12, Rev. 0, Page 310 of 461

Attachment 1, Volume 12, Rev. 0, Page 311 of 461 DISCUSSION OF CHANGES ITS 3.7.13, SPENT FUEL POOL AREA EMERGENCY VENTILATION SYSTEM (EVS) component/system being tested. A number of studies have been performed that demonstrate that staggered testing has negligible impact on component reliability. These analytical and subjective analyses have determined that staggered testing 1) is operationally difficult, 2) has negligible impact on component reliability, 3) has no impact on failure frequency, 4) introduces additional stress on components potentially causing increased component failures rates and component wearout, 5) results in reduced redundancy testing, and 6) increases likelihood of human error by increasing testing intervals.

Therefore, the EVS staggered testing requirements have been deleted. This change is designated as less restrictive because the intervals between performances of the Surveillances for the two EVS trains can be larger or smaller under the ITS than under the CTS.

Davis-Besse Page 8 of 8 Attachment 1, Volume 12, Rev. 0, Page 311 of 461

Attachment 1, Volume 12, Rev. 0, Page 312 of 461 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 12, Rev. 0, Page 312 of 461

Attachment 1, Volume 12, Rev. 0, Page 313 of 461 CTS Spent Fuel Pool Area EVS F V 3.7.13 0

3.7 PLANT SYSTEMS uArea Emergency -EVSI 3.7.13 Fuel St a ePool eentilation System

[Spent Fuel Pool Area EVS]

3.9.12 LCO 3.7.13 JTwo VStrains shall be OPERABLE.

00 spent fuel pool area ----- -------- -- NOTE ---------......................-------

negative pressure The fuel uilding boundary may be opened inter ittently under administrative control.

APPLICABILITY: kMO ES 1,P, T3, d4, spent 03 During movement of re irradiated fuel assemblies in th fuel 00 ACTIONS

.. . ... .. . . . . . . .NOT E-.-... . ... . .... . . . . . . .. . . . . . . . ...... .... . .

Action d LCO 3.0.3 is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME AreaFuel Spent EVSPool DOC L04 A. One *YVtrain inoperable.

A.1 Restore F VS train to OPERABLE status.

7 days 0 B. Two FSPVS trains B.1 Res re fuel building 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months inoperable du 'to inoperable fu I building bosu dary to OPERABLE sta us. 0 boundary in NODE 1,2, 3, or 4.

BWOG STS 3.7.13-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 313 of 461

Attachment 1, Volume 12, Rev. 0, Page 314 of 461 CTS Spent Fuel Pool Area EVS F VS 3.7.13 0

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. [ Required Act on and C.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated C repletion Time of Cond ion A or B AND 0

not met in M DE 1,2, 3, or 4. C.2 in MODE 5. 36 hour4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months s]

OR Two FSPVs trains inoperable i MODE 1, 2, 3, or 4 fo reasons other than ondition B.

I _ _ _ _ _ _ _ _ _ _ _

Action a, Required Action and associated Completion 1 Place OPERABLE train in operation. I Immediately Spent Fuel Pool Area EVS 00 Action b Time of Condition A not m dur-ng! movent of reenty] irradiat fuel assc blies in th fuel OR 2 Suspend movement of r irradiated fuel Immediately 0© assemblies inthe~fue spent Fuel P 0olArea EVS rains . Suspend movement of Immediately 0

(D Action c inoperable uring r irradiated fuel move nt of [rec ntly] IL assemblies in the fuel irradi ed fuel ass mblies in e fuel bu din.

00 SURVEILLANCE REQUIREMENTS TO SURVEILLANCE j FREQUENCY 4.6.5.1.a SR 3.7.13.1 jOperate each F VS train for [_ 10ý ontinuous 31 days*

Spent Fuel Pool hours wvith/e heaters opera in or for systemsI Area EVS I without r6aters)/> 15 minutesM BWVOG STS 3.7.13-2 Rev. 3.0, 03/31104 Attachment 1, Volume 12, Rev. 0, Page 314 of 461

Attachment 1, Volume 12, Rev. 0, Page 315 of 461 CTS Spent Fuel Pool Area EVS F 3.7.13 0

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE 1 FREQUENCY 4.6.5.1.b SR 3.7.13.2 / Perform required filtertesting in In accordance EVSPool SAreaFuel Spent accordance Prga with the Ventilation Filter Testing

-/TA with the [VFTFO 00 4.9.12.2 SR 3.7.13.3 MVerify eachF train actuates on an actual or simulated actuation signal.

[monthsM 24 00 Spent Fuel Pool Area EVS f.ape$-/

4.9.12.1 SR 3.7.13.4 Verify one F VS train can naintain a pressure [ months on a a0 125 [- inches water gauge with respe t to STAGGERED Fatmospneric p essure during the [p6st accident] TEST BASIS 5<4'30001 cfm.

[relative to outside' -- mode ofoperAtion at a flow rate 0

4.6.5.1.d.3 SR 3.7.13.5 MVerify each F opened.

VS filte y damper can be iSpent Fuel Pool Area EVS ]

D nmonths*

00 BWCOG STS 3.7.13-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 315 of 461

Attachment 1, Volume 12, Rev. 0, Page 316 of 461 JUSTIFICATION FOR DEVIATIONS ITS 3.7.13, SPENT FUEL POOL AREA EMERGENCY VENTILATION SYSTEM (EVS)

1. Changes are made to the ISTS Specification which reflect plant specific nomenclature.

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

3. The Spent Fuel Pool Area Emergency Ventilation System (EVS) is not used to provide fission product removal associated with ECCS leaks due to a loss of coolant accident. The Station EVS is used for this function, as described in ITS 3.7.12.

Therefore, the bracketed MODES 1, 2, 3, and 4 requirements have been deleted and subsequent ACTIONS renumbered. Furthermore, due to this deletion, the words in the Conditions concerning movement of fuel is not necessary and has been deleted.

4. ISTS LCO 3.7.13 Note allows the fuel building boundary to be opened "intermittently" under administrative control. This Note is described in the LCO Bases, and includes actions to be taken if the boundary is opened for reasons other than entry and exit through doors. When the boundary is opened for these reasons (i.e., for reasons other than entry and exit through doors), it is not necessarily being opened "intermittently." The reasons could include opening a penetration or creating a new penetration through a wall, and this might not be considered "intermittent."

Furthermore, Davis-Besse current licensing basis allows the air lock doors to both be opened and maintained open, provided one of the doors is capable of being closed and a designated individual is assigned to close the door if necessary. When using this allowance, Davis-Besse might not meet the "intermittent" requirement since the doors could be opened for an extended time period. The ITS Bases clearly describes the conditions that must be met to use the Note allowance. Therefore, the term "intermittently" is unnecessary and has been deleted.

Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 316 of 461

Attachment 1, Volume 12, Rev. 0, Page 317 of 461 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 12, Rev. 0, Page 317 of 461

Attachment 1, Volume 12, Rev. 0, Page 318 of 461 All changes are unless otherwise noted 9

( Spent Fuel Pool Area EVS B 3.7.13 B 3.7 PLANT SYSTEMS Spent Fuel Pool Area Emergency Ventilation System (EVS) 0 B 3.7.13 IFuel Sto fijiEPool Vetilation Syst-4 nFSPVS)-ýJ BASES BACKGROUND The provides negative pressure in thelfue ae[rea, and filters airborne radioactive particulates from the area of the fuel pool Se following a fuel handling accident. spent fuel pool With the containment Area EVS The F S consists of portions of the normal Fuel Handling Area equipment hatch Ventilation System (FHAVS), the Aation Emergency Ventilation System open, the spent fuel (EVS), ductwork bypasses, and dampers. The portion of the normal pool area negative y t Sec s opressure boundary FHAVS used by the* consists of ducting between the spent fuel Iextends to include the pool and the normal FHAVS exhaust fans or dampers, and redundant inside of the radiation detectors installed close to the suction end of the FHAVS containment pressure i exhaust fan ducting. The portion of the EVS used by the S consists vesel of two independent, redundant trains. Each train consists of a prefilter, gg high efficiency particulate air (HEPA) filter, activated charcoal adsorber section for removal of gaseous activity (principally iodines), and d fan. Ductwork, valves or dampers, and instrumentation also form part of the system. Tw iso vyes are installed in series in the ductwork between the FHAVS and the+EVS to provide isolation of the-'FVS from the FHAVS on an Safety Featurei~lctuation fignal. Th -esela dmpr r~~~

. ar oened prioikt-o fugelha-hidlinq operatio'qs finvolviný14;~andlinq retej.ntly I nomlty open areI..tl n l oeirradia d fuel]ý Th EVS is the subject of LCO 3.7.12, 'Emergency Stn entiaton *System (EVS)," and is fully described in theFSAR, (Ref 1) Section M6.2_ l e A ductwork bypass with redundant t dampers connects the FHAVS to the#FEVS.

During normal operation, the exhaust from the fuel handling area is passed through the FHAVS exhaust filter and is discharged through the station vent stack. In the event of a fuel handling accident, the radiation detectors (one per Jtrain), located at the suction of the FHAVS exhaust fan ducting, send signals to isolate the FHAVS supply and exhaust fans and ductwork, open the redundant dampers in the bypass Statin ductwork, and start the EVS fans. The EVS fans pull the air from the fuel handling area, creating a negative pressure, and discharge the filtered air T_71, to the station vent.

The F AVS is discussed in tFSAR, Sections [6.2. , [9.4.2],

and [15. .7] (Refs. 1, 2, and 3, espectively), because i may be used for normal a well as post accident, tmospheric cleanup fu ions.

BWOG STS B 3.7.13-1 Rev. 3.0, 03131/04 Attachment 1, Volume 12, Rev. 0, Page 318 of 461

Attachment 1, Volume 12, Rev. 0, Page 319 of 461 B 3.7.13 O) INSERT I Specifically, when the Fuel Handling Exhaust - High Radiation instrumentation detects a radiation level in excess of the high radiation setpoint, a signal from the applicable radiation monitor is sent to the logic for the FHAVS and the Spent Fuel Pool Area EVS. The FHAVS supply and exhaust fans will trip and their respective inlet and outlet dampers will isolate. The Fuel Handling Area to Emergency Ventilation dampers open and the Station EVS fans start.

This will maintain a negative pressure in the Spent Fuel Pool Area and filter the exhaust through charcoal filters and HEPA filters. Filtration of the exhaust ensures the accident dose at the site boundary will be well below the 10 CFR 100 limits and the control room dose will be within the 10 CFR 50, GDC 19 limits.

Insert Page B 3.7.13-1 Attachment 1, Volume 12, Rev. 0, Page 319 of 461

Attachment 1, Volume 12, Rev. 0, Page 320 of 461 I

All changes are unless otherwise noted .J Se uePlAr

{ Spent Fuel Poo:l Are.a ES B371 Q BASES APPLICABLE The S design basis is established by the consequences of the SAFETY ANALYSES / limiting 4involvinq Design 'Basis

" Accident (DBA), fuel].

t~ irradliatedt which The is a analysis fuel handlingof theaccident fuel Spent Fuel Pool Area EVS

/

handling accident, given in Reference assumes a a certain number of fuel rods in an assembly are damaged..The DBA analysis of the fuel 0

[(outside containment) ]---/ hand~ling accidentl[inovg handln den involving -ue-Trsme raiae the Spent Fuel Pool Area that o y one rain o th* is un i nal due to a sirte failure that EVS actuation aligns the ventilation flow path through the HEPA andto isa I the other train. he accident ana sis accounts fo the reduction n airbo e radioactive maa rial provided by he remaining onb train of this filtration steT. These assumptions and the analysis follow the 0

discharging to the station guidance provided in Regulatory Guide 1.25 (Ref. ).

" vent -

The ý

Spent Fuel Pool Area EVS satsfieirito

-H f 10 CFR 50.36(c)(2)(ii).

[Spent Fuel Pool]

. Area EVS LCO NjTwc[N independent and redundant trains of the F OPERABLE to ensure that at least one is available, assuming a single are required to be 0 failure that disables the other train coinci enolffsite power.

Total system failure could result in the atmospheric release from the fuel handling area exceeding 10 CFR 100 (Ref.L9 limits in the event of a fuel W handling accident [involving Spent Fuel Pool r--*

irradiated fuel.

Area -v*e\1 The S is considered OPERABLE when the individual components ensure offaitelimits room dose l

exceeded control and ar~enot necessary tolcontrol OPERABLE in both trains. Ai operpdr *. exposure in the fuelbah.l-lling train is considered OPERABLE building Iare 0 when its associated: "-Spent Fuel Pool]

Area EVS J Fan is OPERABLEIa (Z 0 HEPA filter and charcoal adsorber are not excessively restricting flow, and are capable of performing their filtration functionsaid 7

)

U

--M. jHeate;ernister,u uctwork, valves, and dampers are OPERABLE, C ) 0 and air circulation can be maintained. [ sent ulpoolara

-negative pressure The LCO is modified by a Note allowing the fe n boundary to be opened ttentlYlunder administrative controls. For entry and exit through doors, the administrative control of the opening is performed by the person(s) entering or exiting the area. For other openings, these controls consist of stationing a dedicated individual at the opening who is in continuous communication with the control room. This individual will have a method to rapidly close the opening when a need for fueding isolation is indicated.

INSERT 1A }spent fuel pool area negative pressure boundary BWOG STS B 3.7.13-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 320 of 461

Attachment 1, Volume 12, Rev. 0, Page 321 of 461 B 3.7.13 (O INSERT 1A In addition, when the spent fuel pool area negative pressure boundary includes the containment (i.e., when the containment equipment hatch is open - hatch not closed and held in place by four bolts) and the boundary is open due to both containment personnel air lock doors being open, then the administrative controls also include ensuring at least one of the air lock doors is capable of being closed and the above described dedicated individual must be immediately outside the personnel air lock.

Insert Page B 3.7.13-2 Attachment 1, Volume 12, Rev. 0, Page 321 of 461

Attachment 1, Volume 12, Rev. 0, Page 322 of 461 All changes are unless otherwise noted 9 Spent Fuel Pool Area EVS B 3.7.13 0 BASES APPLICABILITY [In [I DES 1, 2, 3, and 4,flt.FSPVS is required to be OP ABLE to provide fi *on product removal as!ciated with ECCS leaks due o a loss of coolant ac ent (refer to LCO 3.7.12 r"units that use this syste as 0

part of their EVS" spent fuel pool During movement of r an area, the irradiated fuel assemblies in therff-[

always required to be OPERABLE to 00 mitigate the consequences of a fuel handling accident.1 Spent Fuel Pool Area EVS In M0'5&5 and 6, the FS the ECCS is*required to be OPER not required to be OPE 0D ACTIONS LCO 3.0.3 is not applicable while in MODE 5 or 6. However, since irradiated fuel assembly movement can occur in MODE 1, 2, 3, or 4, the ACTIONS have been modified by a Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the fuel movement is independent of reactor operations. Entering LCO 3.0.3, while in MODE 1, 2, 3, or 4 would require the unit to be shutdown unnecessarily.

A.1 the inoperable Spent Fuel]

Pool Area EVS train to >

With on F S train inoperable, action must be taken to restore W(

OPERABLE status within 7 days. During this time period, the remaining

[Spent Fuel Pool Area EVS j OPERABLE train is adequate to perform thel I SW function. However, 7 % the overall reliability is reduced because a single failure in the OPERABL train could result in a loss o FSSfunctiorn[J The 7 day Completion Time is based on the risk from an event occurring requiring the inoperable-" train, and ability of the remaining train so provide the requirea protecuon.

B.1

....... . ........................REVII WER'S----

S NOTE-------------------------

NOT. -

0 Adoption o Condition B is depen dnt on a commitment fro he licensee to have wri n procedures available escribing compensatory easures to be taken in he even of an intention or unintentional entry int Condition B.

BWOG STS B 3.7.13-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 322 of 461

Attachment 1, Volume 12, Rev. 0, Page 323 of 461 I All changes are unless otherwise noted 9 Spent Fuel Pool Area EVS B 3.7.13 0 BASES ACTIONS (continued)

If the fuel b building bounda is inoperable n e ble in MODE 2, 3, or 4, the FSP trains nu cannot perfor their intendedd functions. Actions mustbe taken restore aan OPERAB fuel building i boundary 'thin 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

During n re 05i0 that the fuel uilding e period r boundary is inope ble, c,e0 p appropri te compensatory mea res [consistent with the i tent, as applicabl ica of GDC 19, 0ý, 61 61 1 64 and 10 CFR 100] sho Id be utilized to protecte lant personr p 6 , f rorý, po ntial hazards such Ias s ra active contarninat n, 'd toxic t0 chemicals, sm64ke, temperature a nd r ati e a nd measures should humidity, it 'atan physical security. Pre lanned ui 10 g

\ ct toa ntdress available x these'ica . co concerns fu

' , sm ke Is r. temp I nc intentional f [consis and unintenti al entry resntiabou haz.

It ion into the condi *on. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Compl Time I is reasonable ba ed on the low probab ity of a DBA of compensato measures.

r etII fu r

I mea from

\eb AB s t i ui'ding I po iIn d ring this time period, and t e use eoccurring dn The 24 hou Completion Time is a typi Ily Q

reasonable bme o diagnose, plan and po s ibly repair, and test most

ýj C.1 d C.22 InMO El,2,3,or4,whenR 3 uiredActionA.1orB.1 nnot be complet d within t n the associate te I ompletion Time, or whe bothbeFSPVS trains are t for reasons ther than an inoperable fnnot I building boundary cC PI e., Condition B), 3 the uni u must u t bbe placed Binnaa MO 0 E in 1 which w

t n LCO)7do the L s nott' apply. To achiev this r than i 'io' st status, 10 m s E nplaced the ruinitit =S-t pla hc -t et otu .SPVS iI mMin atstt M DE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , an tjleast m in i MODE M( 5 within i 36 ho rable T The Comple:tion Ti -s are reasonable, bas d on operating experience, f I bui to Iding reach tthe req uj cd unit conditions c it from f I power conditions iti iin an or erly 1ý manner and with 1 ut challenging unit syste s.

9 ~~S'pent Fuel If the inoperable Fr S train cannot be restored to OPERABLE status Pool Are within the required Completion Time, Idur-in ;;;;

irradiate - " he fuel bu-idinq the OPERABLE Or.recen y (2 train must be started immediately or[ irradiated fuel movement 3 suspended. This action ensures that the remaining train is OPERABLE, that no undetected failures preventing system operation will occur, and that any active failures will be readily detected.

inthe spent fuel pool If the system is not placed in operation, this action requires suspension of III-J i irradiated fuel movemen*, which precludes a fuel handling accident [invo lyi andlinc!

Mt-ectly irra el] This action does not 2o preclude the movement of fuel assemblies to a safe position.

BWOG STS B 3.7.13-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 323 of 461

Attachment 1, Volume 12, Rev. 0, Page 324 of 461 I

All changes are unless otherwise noted P

Pool Area EVS B 3.7.13 0

BASES ACTIONS (continued)

Spent Fuel Pool Area EVS 0 When two trains of the [

[recently] frr .

are inoperable jdurine9nt n tthe tuelut idflmcl ofl the unit must be 00 s

placed in a condition in which the LCO does not apply. This LCO involves immediately suspending movement of jf=*t irradiated fuel 00 assemblies in the4 uel .Thris does not preclude the movement of fuel to a safe position. _

SURVEILLANCE REQUIREMENTS MSR 3.7.13.1 0

Standby systems should be checked periodically to ensure that they function properly. As the environment and normal operating conditions on this system are not severe, testing each train once every month provides an adequate check on this system. fM-onthly heat er operation dries out a *moisture accumulatedoin the charcoal from huridity in the\ 0

~hours

~ambient air. kSystems with heaters r~ust be operated for a- 10 ontinuous/

with the heaters energized. Sy~ems without heaters nee' only be goerated for a 15 minutes[] Ndemonstrate the function of the-e5.[e 0

. The 31 day Frequency is based on the known reliability of the equif----e-t and the two train redundancy available. 0 0

@SR 3.7.13.2 Spent Fuel Pool Area EVS This SR verifies that the required FOS testing is performed in accordance with the JPentilation Filter Testing Program (VFTP) The MVFTPFincludes testing HEPA filter performance, charcoal adsorber efficiency, mum system flow rate, and the physical properties of the 00 activated charcoal (general use and following specific operations).

Specific test frequencies and additional information are discussed in 0 detail in the E/FTI 0]

0 ISR 3.7.13.3 Spent Fuel Pool Area EVS ' a 0

(i. e., Fuel Handling Exhaust This SR verifies that each -- train startsates on an actual

(

- High Radiation) or simulated actuation signal. The 18 moy th Frequency is c nsistent with/

at specified i eference 6.

INSERT 3 BWOG STS B 3.7.13-5 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 324 of 461

Attachment 1, Volume 12, Rev. 0, Page 325 of 461 B 3.7.13 O INSERT 2 Initiating each train from the control room, with flow through the HEPA filters and charcoal adsorbers, and operating O INSERT 3 This test includes ensuring the FHAVS supply and exhaust fans trip and their respective inlet and outlet dampers close, the Fuel Handling Area to Emergency Ventilation dampers open, and the Station EVS fans start.

Operating experience has shown that these components usually pass the Surveillance when performed at the 24 month Frequency. Therefore, the Frequency is acceptable from a reliability standpoint.

Insert Page B 3.7.13-5 Attachment 1, Volume 12, Rev. 0, Page 325 of 461

Attachment 1, Volume 12, Rev. 0, Page 326 of 461 I

All changes are unless otherwise noted 9 Spent Fuel Pool Area EVS B 3.7.13 0 BASES SURVEILLANCE REQUIREMENTS (continued) rspent fuel pool area R 3 7.1 4ve pressure spent fuel pool area negative S ... . 4 boundary pressure boundary (which includes the containment if the containment equipment hatch is open) , This SR verifies the integrity of the fuel areal. The ability of the

. .outside atmosphere fue a narea to maintain a negative pressure, with respect to Spent Fuel Pool ]'proper Area EVS otentia y function of thde*'

operation, the acent areas is periodically tested to verify 1 During the Npost aocidentjmode of S is designed to maintin a slight negative pressure 0

spent fuelpa n u lamg areto prevent unfiltereareaEKAGE. FSPVS is negative pressure esigned to intam this negativk pressure at a flow rate of - 000] cfm boundary o the fuel ha linq area.jThe Frequency ofr[f8l months on a STAGGERED TEST BASIS is consistent with industry practice2

1* *cooling (i.e., EVS fans cross tie dampers, SR 3.7.13.5 CV5056 and CV5057) each Spent Fuel I I Pool Area EVS J

Operating the-. VSfiltebypass dampei*s necessary to ensure that [Spent Fuel Pool

- the system functions properly. The OPERABILITY of the F S ilter Area EVS y *y...Jcooling -bypass damper is verified if it can be opened. reency od INSERT4 months*s specified in Refere ,ce 6.

REFERENCES 1. FSAR, Sectionwc.2.

0

. F n.-*9.4.21. 0 E- FSAR, Sectional15.4.7% 0 J. Regulatory Guide 1.25.

6.10 CFR 100.11.

16. Regu " 2 Rev. [2].I BWOG STS B 3.7.13-6 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 326 of 461

Attachment 1, Volume 12, Rev. 0, Page 327 of 461 B 3.7.13 O INSERT 4 Operating experience has shown that these components usually pass the Surveillance when performed at the 24 month Frequency. Therefore, the Frequency is acceptable from a reliability standpoint.

Insert Page B 3.7.13-6 Attachment 1, Volume 12, Rev. 0, Page 327 of 461

Attachment 1, Volume 12, Rev. 0, Page 328 of 461 JUSTIFICATION FOR DEVIATIONS ITS 3.7.13 BASES, SPENT FUEL POOL AREA EMERGENCY VENTILATION SYSTEM (EVS)

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

2. Changes are made to reflect changes made to the Specification.

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

4. These punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, TSTF-GG-05-01, Section 5.1.3.

5. Typographical error corrected.

6. Changes made to reflect the Specification.

7. Changes made to be consistent with other Specifications.

Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 328 of 461

Attachment 1, Volume 12, Rev. 0, Page 329 of 461 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 12, Rev. 0, Page 329 of 461

Attachment 1, Volume 12, Rev. 0, Page 330 of 461 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.7.13, SPENT FUEL POOL AREA EMERGENCY VENTILATION SYSTEM (EVS)

There are no specific NSHC discussions for this Specification.

Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 330 of 461

, Volume 12, Rev. 0, Page 331 of 461 ATTACHMENT 14 ITS 3.7.14, SPENT FUEL POOL WATER LEVEL , Volume 12, Rev. 0, Page 331 of 461

, Volume 12, Rev. 0, Page 332 of 461 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 12, Rev. 0, Page 332 of 461

Attachment 1, Volume 12, Rev. 0, Page 333 of 461 ITS 3.7.14 ITS REFUELING OPERATIONS STORAGE POOL WATER LEVEL LIMITING CONDITION FOR OPERATION LCO 3.7.14 3.9.11 As a minimum, 23 feet of water shall be maintained over the to of irradiated fuel assemblies seated in the storage racks in the spent fuel pool. During movement of irradiated fuel i thetn asse n fuel storage pool Weeef PLCBLT APPLICABTLITY: lWhenever ig'*diated fuel asseyd'blies are in thc/&'penl fuel poclý /L ACTION:

ACTION A With the requirement orthe 0operatioa's with !oadsA the 14 Xour Ibe provisions of Speci SURVEILLANCE REQUIREMENTS SR 3.7.14.1 4.9.11 The water level in the spent fuel pool shall be determined to be at least ius minimum required depth at least once per 7 days Fhen irradjted fuel asem tes ýarin the ent fuel ool L01 DAVIS-BESSE, UNIT I 3/4 9-I I Arnendm'ent No. 237, 247 , 266 Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 333 of 461

Attachment 1, Volume 12, Rev. 0, Page 334 of 461 DISCUSSION OF CHANGES ITS 3.7.14, SPENT FUEL POOL WATER LEVEL ADMINISTRATIVE CHANGES A01 In the conversion of the Davis-Besse Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1430, Rev. 3.1, "Standard Technical Specifications-Babcock and Wilcox Plants" (ISTS).

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

A02 CTS 3.9.11 Action states that with the requirement of the Specification not satisfied, suspend all movement of fuel. ITS 3.7.14 Required Action A.1 requires the immediate suspension of movement of irradiated fuel assemblies in the fuel storage pool. This changes the CTS by explicitly specifying that the compensatory action to suspend all movement of fuel assemblies requires an immediate response. Other changes to this CTS Action are discussed in DOCs L01 and L02.

The purpose of the CTS 3.9.11 Action to suspend all movement of fuel assemblies is to help ensure the assumptions of a fuel handling accident are met. The current action does not specify a time; however it implies that the action is immediate. This change is acceptable because it only provides clarification that the compensatory action requires an immediate response. This change is designated as administrative because it does not result in a technical change to the CTS.

MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES L01 (Category 2 - Relaxation of Applicability) CTS 3.9.11 states that the requirements on storage pool water level are applicable "Whenever irradiated fuel assemblies are in the spent fuel pool." CTS 4.9.11 requires the water level in the spent fuel pool to be verified every 7 days "when irradiated fuel assemblies are in the spent fuel pool." ITS 3.7.14 is applicable "During movement of irradiated fuel assemblies in the spent fuel pool." ITS SR 3.7.14.1 requires Davis-Besse Page 1 of 3 Attachment 1, Volume 12, Rev. 0, Page 334 of 461

Attachment 1, Volume 12, Rev. 0, Page 335 of 461 DISCUSSION OF CHANGES ITS 3.7.14, SPENT FUEL POOL WATER LEVEL verification of the spent fuel pool water level every 7 days. This changes the CTS by restricting the Applicability of the spent fuel pool water level Specification and performance of the Surveillance to only when there is a potential for a fuel handling accident, i.e., during the movement of irradiated fuel assemblies in the fuel storage pool. In addition, since the Applicability is now limited to when irradiated fuel is being moved, the CTS Action to restore water level to within its limit within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after movement of fuel has been suspended has also been deleted.

The purpose of CTS 3.9.11 is to ensure that the minimum fuel storage pool water level assumption in the fuel handling accident analysis is met. This change is acceptable because the requirements continue to ensure that the structures, systems, and components are maintained in the MODES and other specified conditions assumed in the safety analyses and licensing basis. The fuel handling accident analysis (outside containment) assumes that a single fuel assembly is damaged. A key assumption in the analysis is that there is ->23 feet of water over the damaged assembly, as this depth is directly related to the clean up of the fission products before release to the spent fuel pool area atmosphere. A fuel handling accident is only assumed to occur when an irradiated fuel assembly is being moved. Therefore, the ITS imposes the controls on minimum spent fuel pool water level during the movement of irradiated fuel in the spent fuel pool.

This change is designated as less restrictive because the LCO requirements are applicable in fewer operating conditions than in the CTS.

L02 (Category 4 - Relaxation of Required Action) CTS 3.9.11 Action states that when the spent fuel pool water level is not met, suspend all movement of fuel and crane operations with loads in the spent fuel pool area. ITS 3.7.14 Required Action A.1 states that when spent fuel pool water level is not within limit, immediately suspend movement of irradiated fuel assemblies in the spent fuel pool. This changes the CTS by deleting the requirement to suspend non-irradiated fuel assembly movement and to suspend crane operations over the spent fuel pool.

The purpose of the CTS 3.9.11 Action is to preclude a fuel handling accident from occurring when the initial conditions for that accident are not met. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The only initiator to a fuel handling accident assumed in the accident analysis is the damaging of a single irradiated fuel assembly.

Damaging a fuel assembly which has not been irradiated has no significant radiological effects and is not assumed in the fuel handling accident analysis.

Therefore, stopping the handling of fuel assemblies which have not been irradiated when the spent fuel pool water level is less than the limit is not required. The dropping of loads onto fuel assemblies in the spent fuel pool is not an initiator that is assumed in the fuel handling accident analysis. The movement of heavy loads is addressed by the Davis-Besse response to NUREG 0612, "Control of Heavy Loads at Nuclear Power Plants," and Generic Letter 81-07.

Therefore, these activities are not restricted in the Technical Specifications when the spent fuel pool water level is not within limit. This change is designated as Davis-Besse Page 2 of 3 Attachment 1, Volume 12, Rev. 0, Page 335 of 461

Attachment 1, Volume 12, Rev. 0, Page 336 of 461 DISCUSSION OF CHANGES ITS 3.7.14, SPENT FUEL POOL WATER LEVEL less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

Davis-Besse Page 3 of 3 Attachment 1, Volume 12, Rev. 0, Page 336 of 461

Attachment 1, Volume 12, Rev. 0, Page 337 of 461 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 12, Rev. 0, Page 337 of 461

Attachment 1, Volume 12, Rev. 0, Page 338 of 461 I

All changes are CTS unless otherwise noted 9 Fuel t Pool Water Level ffE 3.7.14 3.7 PLANT SYSTEMS 3.7.14 Fuel t Pool Water Level Th fuel pool water level shall be > 23 ft over the top of irradiated 3.9.11 LCO 3.7.14 fuel assemblies seated in the storage racks.

APPLICABILITY: During movement of irradiated fuel assemblies in fuel pool.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME Action A tuel pool water A.1 NOTE ------- --------------

E level not within limit. LCO 3.0.3 is not applicable.

Suspend movement of Immediately irradiated fuel assemblies in s fuel a pool.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.9.11 SR 3.7.14.1 Verify fuelst age pool water level is > 23 ft 7 days above the top of irradiated fuel assemblies seated in the storage racks.

BWOG STS 3.7.14-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 338 of 461

Attachment 1, Volume 12, Rev. 0, Page 339 of 461 JUSTIFICATION FOR DEVIATIONS ITS 3.7.14, SPENT FUEL POOL WATER LEVEL

1. Changes are made to the ISTS Specification which reflect plant specific nomenclature.

Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 339 of 461

Attachment 1, Volume 12, Rev. 0, Page 340 of 461 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 12, Rev. 0, Page 340 of 461

Attachment 1, Volume 12, Rev. 0, Page 341 of 461 All changes are L unless otherwise noted 9

)Fuel t Pool Water Level B 3.7.14 0

B 3.7 PLANT SYSTEMS B 3 714 Fuel t Pool Water Level 0 BASES BACKGROUND The minimum water level in th~efuel pool meets the assumption of iodine decontamination factors following a fuel handling accident. The specified water level shields and minimizes the general area dose when the storage racks are filled to their maximum capacity. The water also provides shielding during the movement of spent fuel.

A general descriptioln ofthe uel s pool design is given in the SAR, Sectionp.12LReference 1 1. The Spent Fuel Pool Cooling and Cleanup Sys em is given in th FSAR, Section 9..311 (Ref. 2). The assumptions of the fuel handling accident are given in thelFSAR, Section15.4.7 (Ref. 3). L. 0 APPLICABLE The minimum water level in thelfuelt pool meets the assumptions SAFETY of the fuel handling accident described in Regulatory Guide 1.25 (Ref. 4).

ANALYSES The resultant 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months thyroid dose to a person at the exclusion area boundary is below 10 CFR 100 (Ref. 5) guidelines.

According to Reference 4, there is 23 ft of water between the top of the damaged fuel bundle and the fuel pool surface for a fuel handling accident. With 23 ft, the assumptions of Reference 4 can be used directly. In practice, the LCO preserves this assumption for the bulk of the fuel in the storage racks. In the case of a single bundle dropped and lying horizontally on top of the spent fuel rack, however, there may be

< 23 ft above the top of the fuel bundle and the surface, by the width of the bundle./To offset this smal no/conservatism, the */alysis assumes/

tha al ful ros filalthughtheanalysis shows that *)ly the first [f!w]

' ' Irows fail/from a hypothetical ma imum drop. .

T nfuelrs ag pool water level satisfies Criteria 2 and 3 of 10 CFR 50.36(c)(2)(ii).

0 LCO The specified water level preserves the assumptions of the fuel handling accident analysis (Ref. 3). As such, it is the minimum required for4fe r .adited stor ean movement within the uel s pool. f )

APPLICABILITY This LCO applies during movement of irradiated fuel assemblies in the fuels pool since the potential for a release of fission products exists.

BWOG STS B 3.7.14-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 341 of 461

Attachment 1, Volume 12, Rev. 0, Page 342 of 461 B 3.7.14 0 INSERT 1 The fuel handling accident assumes the entire outer row of fuel rods in the assembly, 56 fuel rods out of 208 total fuel rods, suffer mechanical damage to the cladding.

Insert Page B 3.7.14-1 Attachment 1, Volume 12, Rev. 0, Page 342 of 461

Attachment 1, Volume 12, Rev. 0, Page 343 of 461 Spe Fuel a Pool Water Level B 3.7.14 0

BASES ACTIONS A.1 SRequired Action A.1 is modified by a Note indicating that LCO 3.0.3 does 0

Inot apply.

When the initial conditions for an accident cannot be met, immediate action must be taken to preclude the occurrence of an accident. Vith the E fuel* pool at less than the required level, the movement ofýuel~iradiated EEýý ýassemblies in thZfuel s pool is immediately suspended. This &D effectively precludes the occurrence of a fuel handling accident. In such 0

a case, unit procedures control the movement of loads over the spent fuel. This does not preclude movement of a fuel assembly to a safe position.

If moving irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODES 1, 2, 3, and 4, the fuel movement is independent of reactor operations. Therefore, in either case, inability to suspend movement of irradiated fuel assemblies is not sufficient reason to require a reactor shutdown.

SURVEILLANCE SR 3.7.14.1 REQUIREMENTS This SR verifies that sufficien pool water is available in the event of a fuel handling accident. The water level in the e pool guel spent 0501 must be checked periodically. The 7 day Frequency is appropriate because the volume in the pool is normally stable. Water level changes are controlled by unit procedures and are acceptable, based on operating experience.

During refueling operations, the level in thuel pool is at equilibrium with that in the refueling canal, and the level in the refueling 0D canal is checked daily in accordance with SR 3.9.6.1.

REFERENCES 1. FSAReSectionr9.1.25.

2. FSAR, Section19.1.3M

3. FSAR, Sectiong'15.4.7MJ 00

4. Regulatory Guide 1.25.

5. 10OCFR 100.11.

BWOG STS B 3.7.14-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 343 of 461

Attachment 1, Volume 12, Rev. 0, Page 344 of 461 JUSTIFICATION FOR DEVIATIONS ITS 3.7.14 BASES, SPENT FUEL POOL WATER LEVEL

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

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

3. Changes made to be consistent with the Specification.

4. Editorial changes for clarity. The first paragraph, which describes the addition of the Note, has been combined with the paragraph describing the reason for the Note.

5. Changes made to reflect changes made to the Specification.

Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 344 of 461

Attachment 1, Volume 12, Rev. 0, Page 345 of 461 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 12, Rev. 0, Page 345 of 461

Attachment 1, Volume 12, Rev. 0, Page 346 of 461 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.7.14, SPENT FUEL POOL WATER LEVEL There are no specific NSHC discussions for this Specification.

Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 346 of 461

Attachment 1, Volume 12, Rev. 0, Page 347 of 461 ATTACHMENT 15 ITS 3.7.15, SPENT FUEL POOL BORON CONCENTRATION Attachment 1, Volume 12, Rev. 0, Page 347 of 461

, Volume 12, Rev. 0, Page 348 of 461 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 12, Rev. 0, Page 348 of 461

Attachment 1, Volume 12, Rev. 0, Page 349 of 461 ITS 3.7.15 ITS Add proposed ITS 3.7.15 1 Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 349 of 461

Attachment 1, Volume 12, Rev. 0, Page 350 of 461 DISCUSSION OF CHANGES ITS 3.7.15, SPENT FUEL POOL BORON CONCENTRATION ADMINISTRATIVE CHANGES None MORE RESTRICTIVE CHANGES M01 The CTS does not have any requirements for the spent fuel pool boron concentration when fuel assemblies are stored in the spent fuel storage pool.

ITS 3.7.15 requires the spent fuel pool boron concentration to be > 630 ppm when fuel assemblies are stored in the spent fuel pool and a spent fuel pool verification has not been performed since the last movement of fuel assemblies in the spent fuel pool. An appropriate ACTION and Surveillance Requirement have also been added. This changes the CTS by incorporating the requirements of ITS 3.7.15.

The purpose of ITS 3.7.15 is to ensure the accident analysis assumptions concerning the boron concentration in the spent fuel pool are met. A fuel assembly could be inadvertently loaded into a spent fuel rack location not allowed by LCO 3.7.16 (e.g., an unirradiated fuel assembly or an insufficiently depleted fuel assembly). This accident is analyzed assuming the case of loading an unirradiated assembly of the highest permissible enrichment into one of the storage cells intended for burned fuel, or in an empty cell between other fresh assemblies in the checkerboard pattern. This change is acceptable since the minimum boron concentration required by this LCO will ensure that keff will not exceed 0.95 if a fuel assembly is misloaded as described above. This change is designated as more restrictive because it adds new requirements to the CTS.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES None Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 350 of 461

Attachment 1, Volume 12, Rev. 0, Page 351 of 461 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 12, Rev. 0, Page 351 of 461

Attachment 1, Volume 12, Rev. 0, Page 352 of 461 CTS MSpent Fuel Pool Boron ConcentrationEJ 3.7.15 0 3.7 PLANT SYSTEMS 3.7.15 MSpent Fuel Pool Boron Concentration 0 DOC M01 LCO 3.7.15 The spent fuel pool boron concentration shall be Ž[5X] _> ppm.

0 APPLICABILITY: When fuel assemblies are stored in the spent fuel pool and a spent fuel pool verification has not been performed since the last movement of fuel assemblies in the spent fuel pool.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME DOC M01 A. Spent fuel pool boron ---.- - NOTE -...............

concentration not within LCO 3.0.3 is not applicable.

limit. - -------------------------------- .

A.1 Suspend movement of fuel Immediately assemblies in the spent fuel pool.

AND A.2.1 Initiate action to restore Immediately spent fuel pool boron concentration to within limit.

OR A.2.2 Initiate action to perform a Immediately fuel storage pool verification.

BVVOG STS 3.7.15-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 352 of 461

Attachment 1, Volume 12, Rev. 0, Page 353 of 461 CTS Ppent Fuel Pool Boron Concentratiorl 3.7.15 0

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY DOC M01 SR 3.7.15.1 Verify the spent fuel pool boron concentration is 7 days within limit.

BWOG STS 3.7.15-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 353 of 461

Attachment 1, Volume 12, Rev. 0, Page 354 of 461 JUSTIFICATION FOR DEVIATIONS ITS 3.7.15, SPENT FUEL POOL BORON CONCENTRATION)

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

Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 354 of 461

Attachment 1, Volume 12, Rev. 0, Page 355 of 461 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 12, Rev. 0, Page 355 of 461

Attachment 1, Volume 12, Rev. 0, Page 356 of 461 MSpent Fuel Pool Boron Concentrationr

-B 3.7.15 0 B 3.7 PLANT SYSTEMS B 3.7.15 MSpent Fuel Pool Boron Concentration M BASES BACKGROUND As described in

LCO 3.7-16, "Spent Fuellsrly, SMixed Zone Three* Storage," fuel assemblies are stored in the spent fuel pool rackslin a

(

0 0

[Region, Checkerboard, or-.

SHomogenous Loading ý

,,che f~~ardl enrichmne"nt S5e6 pattern~in accordance with criteria based on*]initia-an*j disý_.har*

qej burnulj [Although the *v)6ter in the'speptfuel 0 y rpool y normally bgrated to ->[500]/jppm, the c~ritera that limit the. torage

~~of a/fuel assemb)Jy to specific raklction r/econsrvtivelIdeveloped with~lout takina dredit fo bo r on/ /n osev /~

0 APPLICABLE A fuel assembly could be mina bertently loaded into*spent fuel rack SAFETY location not allowed by LC 3.7.16 (e.g., an unir diated fuel assemb ANALYSES or an insufficiently depl d fuel assembly). ,is accident is anal d assuming the extre case of completely'ading the spent fue ool racks with unirrad' ed assemblies of imum enrichment. other INSRT type of postulatd accident is associ ed with a fuel asse ly that is dropped on the fully loaded spe fuel pool storage r . Either incident could ha a positive reactivit ect, decreasing th margin to criticality.

Howe r, the negative rea ity effect of the sol e boron compensates for e increased reactivi caused by either o of the two postulated cident scenarios.

The concentration of dissolved boron in thefuel pool satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii). spent 0

LCO 6 The specified concentratiiorl (S 0] pprrj]of dissolved boron in thef t pool preserves the assumption used in the analyses of the potential accident scenarios described above. This concentration of dissolved boron is the minimum required concentration for fuel assembly storage and movement within the uel pool.

0 APPLICABILITY This LCO applies whenever fuel assemblies are stored in the spent fuel pool, until a ete~spent fuel pool verification has been performed following the last movement of fuel assemblies in the spent fuel pool. 0 This LCO does not apply following the verification since the verification would confirm that there are no misloaded fuel assemblies. With no further fuel assembly movement in progress, there is no potential for a misloaded fuel assembly or a dropped fuel assembly.

BWVG STS B 3.7.15-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 356 of 461

Attachment 1, Volume 12, Rev. 0, Page 357 of 461 B 3.7.15 O* INSERT 1 The high density spent fuel pool storage racks in the Spent Fuel Pool (SFP) are designed to assure that the effective neutron multiplication factor, keff, is < 0.95 with the racks fully loaded with fuel of the highest anticipated reactivity and flooded with unborated water.

O INSERT 2 Reactivity effects of abnormal and accident conditions have been evaluated to assure that under credible abnormal and accident conditions, the reactivity will not exceed 0.95, with credit for soluble boron in the pool water. Assuring the presence of soluble poison during fuel handling operations precludes the possibility of the simultaneous occurrence of two independent accident conditions.

Three potential accident scenarios, misloaded fresh fuel assembly, mislocated fresh fuel assembly, and a dropped fuel assembly, were analyzed to determine the effect the accidents would have on the effective neutron multiplication factor, kerr. The results of the analysis determined that a minimum boron concentration of 630 ppm in the SFP water is required to maintain keff at 0.945 for the worst-case accident scenario (i.e., a 5.05 weight percent enriched fresh fuel assembly misloaded in a Checkerboard pattern) (Ref. 1). The minimum boron concentration value of 630 ppm bounds all analyzed potential accident scenarios discussed below.

A misloaded fresh fuel assembly accident scenario analyzed misloading the assembly in the following five different locations: 1) misloading in the Mixed Zone Three Region (MZTR) inner rack 10x9; 2) misloading in the MZTR inner rack 10x9 (different location of a fresh assembly); 3) misloading in the MZTR side rack 1 0x8; 4) misloading in Homogeneous (45 BU) inner rack 10x9, and; 5) misloading in Checkerboard inner rack 10x9. The worst case scenario, misloading in Checkerboard inner rack 10x9, requires a minimum boron concentration of 627 ppm to assure that keff does not exceed 0.945.

The second potential accident scenario considers the mislocation of a fresh fuel assembly outside of a storage rack adjacent to other fuel assemblies. The worst case would be an assembly mislocated in a corner on the west side of the pool (next to MZTR outer rack 10x8 - 7xl). This scenario requires a minimum boron concentration of 448 ppm to assure that keff does not exceed 0.945.

The dropped fuel assembly accident considers three different scenarios: a dropped fuel assembly coming to rest horizontally on top of the rack; a dropped fuel assembly came to rest vertically into a location occupied by another assembly, and; dropping the fuel assembly into an unoccupied cell. In all cases, a minimum boron concentration of 53 ppm is adequate to assure that keff does not exceed 0.945.

Insert Page B 3.7.15-1 Attachment 1, Volume 12, Rev. 0, Page 357 of 461

Attachment 1, Volume 12, Rev. 0, Page 358 of 461 ESpent Fuel Pool Boron Concentration] (0 B 3.7.15 BASES ACTIONS A.1, A.2.1, and A.2.2 The Required Actions are modified by a Note indicating that LCO 3.0.3 does not apply. d0 When the concentration of boron in thehfuel

pool is less than spn Q*

(D be taken to preclude the occurrence of required, immediate ac~tion must of an accident in progress.

an accident or to mitigate the consequences suspending the by immediately This is most efficiently achieved not preclude movement of a assemblies. This does movement of the fuel The concentration of boron is restored fuel assembly to a safe position. of the fuel assemblies.

simultaneously with suspending movement beginning a verification of the spent fuel pool locations, to Alternatively, to can be performed. However, prior ensure proper locations of the fuel, of boron must the concentration resuming movement of fuel assemblies, while in MODE 5 or 6, LCO 3.0.3 If moving irradiated fuel assemblies irradiated fuel assemblies while in would not specify any action. If moving is independent of reactor MODE 1, 2, 3, or 4, the fuel movement movement of fuel assemblies is operation. Therefore, inability to suspend not a sufficient reason to require a reactor This SR verifies that the concentration shutdown.

of boron in the*'f7ue Ypools~n

Q SURVEILLANCE met, the analyzed required limit. As long as this SR is REQUIREMENTSI is within the is appropriate The 7 day Frequency

}*

[SR3.715. incidents are fully addressed. of pool water is expected to take place 3..15 1 SR because no major replenishment of time.

over a short period E.UFSAR. Section 9.1.2 .1.

0 REFERENCES tJ~.

Rev. 3.0, 03/31/04 B 3.7.15-2 BWO~G STS Attachment 1, Volume 12, Rev. 0, Page 358 of 461

Attachment 1, Volume 12, Rev. 0, Page 359 of 461 JUSTIFICATION FOR DEVIATIONS ITS 3.7.15 BASES, SPENT FUEL POOL BORON CONCENTRATION

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

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

3. Editorial changes for clarity. The first paragraph, which describes the addition of the Note, has been combined with the paragraph describing the reason for the Note.

4. Changes made to be consistent with the Specification.

5. Change made to be consistent with the format of the ISTS Bases.

Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 359 of 461

Attachment 1, Volume 12, Rev. 0, Page 360 of 461 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 12, Rev. 0, Page 360 of 461

Attachment 1, Volume 12, Rev. 0, Page 361 of 461 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.7.15, SPENT FUEL POOL BORON CONCENTRATION There are no specific NSHC discussions for this Specification.

Davis-Besse Page 1 of 1 -

Attachment 1, Volume 12, Rev. 0, Page 361 of 461

, Volume 12, Rev. 0, Page 362 of 461 ATTACHMENT 16 ITS 3.7.16, SPENT FUEL POOL STORAGE , Volume 12, Rev. 0, Page 362 of 461

, Volume 12, Rev. 0, Page 363 of 461 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 12, Rev. 0, Page 363 of 461

Attachment 1, Volume 12, Rev. 0, Page 364 of 461 ITS 3.7.16 ITS REFUELING OPERATIONS SPENT FUEL ASSEMBLY STORAGE LIMITING CONDITION FOR OPERATION LCO 3.7.16 3.9.13 Fuel assemblies stored in the spent fuel pool shall be placed in the spent fuel storage racks in accordance with the criteria shown in Figure 3.9-1.

APPLICABILITY: Whenever fuel assemblies are in the spent fuel pool.

ACTION:.*

With the requirt'ments of the above specification not satisfied, sseda5 e fuel move-m~ent J ACTION A vwithin the..Wnt, fuel. pool, and[FQo..ve the non-complying._ . fuel. assemblies to allov,'.abie locations. in I*Il"'aeimaae. .

accordance with Figure .3.9- 1. The -provisionsof Specifications 3.0.3 n 704are not applicable. I atction to A02 SR 3.7.16.1 4.9.13.1 Prior to storing a fuel assembly in the spent fuel pool, verif' by admin-stmtive means that the initial enrichment and burnup of the fuel assembly are in accordance with Figure 3.9-1.

DAVIS-BESSE, UNIT I 3/4 9-13 Amendment No. !30, 181, 237, 247, 263 Page 1 of 2 Attachment 1, Volume 12, Rev. 0, Page 364 of 461

Attachment 1, Volume 12, Rev. 0, Page 365 of 461 ITS 3.7.16 ITS Figure 3.9-1 Burnup vs Enrichment Curves For the Davis-Besse High Density Spent Fuel Pool Storage Racks Figure 3.7.16-1 04* . b11 2.00 2.50 3.00 3.50 . 4.00 4.50 5.00 5.50 Initial Enrichment (wt% U-235)

Notes: Fuel assemblies with initial enrichments less than 2 wr0 /, U-235 will conservatively be required to meet the burnup requirements of 2.0 wt% U-235 assemblies.

Loading pattern considerations applicable to Category "A", "B", and "C" assemblies are described in the Bases DAVIS-BESSE, UNIT I 3/4 9-14 Amendment No. 247, Page 2 of 2 Attachment 1, Volume 12, Rev. 0, Page 365 of 461

Attachment 1, Volume 12, Rev. 0, Page 366 of 461 DISCUSSION OF CHANGES ITS 3.7.16, SPENT FUEL POOL STORAGE ADMINISTRATIVE CHANGES A01 In the conversion of the Davis-Besse Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1430, Rev. 3.1, "Standard Technical Specifications-Babcock and Wilcox Plants" (ISTS).

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

A02 The CTS 3.9.13 Action, in part, states to suspend all other fuel movement within the spent fuel pool when the requirements of the Specification are not met.

ITS 3.7.16 ACTION A does not require this action. This changes the CTS by deleting the action to suspend all other fuel movement within the spent fuel pool.

This change is acceptable because the ITS 3.7.16 ACTION A requirement to immediately initiate action to move the non-complying fuel assembly infers that no other fuel movement can be in progress. Only one fuel assembly is moved at a time in the spent fuel storage pool. Therefore this change is considered administrative since it does not result in any technical changes to the CTS.

A03 CTS 3.9.13 Action, in part, states that with the requirements of the Specification not satisfied, to move the non-complying fuel assemblies to allowable locations in accordance with Figure 3.9-1. ITS 3.7.16 Required Action A.1 requires action to be immediately initiated to move the noncomplying fuel assembly to an allowable location. This changes the CTS by explicitly specifying that the compensatory action to move non-complying fuel assemblies to allowable locations requires an immediate response.

The purpose of the CTS 3.9.13 Action to move non-complying fuel assemblies to allowable locations is to help ensure the assumptions of the spent fuel pool storage analysis is met. The current action does not specify a time; however it implies that the action is immediate. This change is acceptable because it only provides clarification that the compensatory action requires an immediate response. This change is designated as administrative because it does not result in a technical change to the CTS.

A04 The CTS 3.9.13 Action, in part, states that the provisions of Specification 3.0.4 are not applicable. ITS 3.7.16 ACTION A does not include a Note similar to the exception in the CTS 3.9.13 Action. This changes the CTS by deleting the explicit exception from Specification 3.0.4 in CTS 3.9.13 Action.

This change is acceptable because it results in no technical change to the Technical Specifications. CTS 3.0.4 provides requirements to preclude changing MODES with inoperable equipment. However, ITS LCO 3.0.4 has been modified to allow MODE changes under certain circumstances. This is justified in the Discussion of Changes for ITS Section 3.0. Therefore, this specific exception to CTS 3.0.4 is not needed in the ITS. This change is designated as administrative because it does not result in a technical change to the CTS.

Davis-Besse Page 1 of 2 Attachment 1, Volume 12, Rev. 0, Page 366 of 461

Attachment 1, Volume 12, Rev. 0, Page 367 of 461 DISCUSSION OF CHANGES ITS 3.7.16, SPENT FUEL POOL STORAGE MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES None Davis-Besse Page 2 of 2 Attachment 1, Volume 12, Rev. 0, Page 367 of 461

Attachment 1, Volume 12, Rev. 0, Page 368 of 461 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs).

Attachment 1, Volume 12, Rev. 0, Page 368 of 461

Attachment 1, Volume 12, Rev. 0, Page 369 of 461 CTS 5Spent Fuel Pool StorageS1 3.7.16 0 3.7 PLANT SYSTEMS 3.7.16 MSpent Fuel Pool Storage MJ 0 3.9.13 LCO 3.7.16 The combinati of'initial enrichmen and bumup of ea fuel assembly stored in [Reg* n 2] shall be withinhe acceptable [bur up domain] of INSERT 1 Figure 3.7.16 1 or in accordance ith Specification 4. .1.1.

0 APPLICABILITY: Whenever any fuel assembly is stored in [Reg-n 2] of the spent fuel pool.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME Action A. Requirements of the A.1 - NOTE --...-----

LCO not met. LCO 3.0.3 is not applicable.

Initiate action to move the Immediately noncomplying fuel assembly. rom e on 0 to an allowable location SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.9.13.1 SR 3.7.16.1 Verify by administrative means the initial enrichment Prior to storing the and burnup of the fuel assembly is in accordance fuel assembly in with Figure 3.7.16-1 [or Speci ation 4.3.1.11. ~n~km0 00 BWOG STS 3.7.16-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 369 of 461

Attachment 1, Volume 12, Rev. 0, Page 370 of 461 3.7.16 CTS 0 INSERT 1 3.9.13 Fuel assemblies stored in the spent fuel pool shall be placed in the spent fuel pool storage racks in accordance with the criteria shown in Figure 3.7.16-1.

Insert Page 3.7.16-1 Attachment 1, Volume 12, Rev. 0, Page 370 of 461

Attachment 1, Volume 12, Rev. 0, Page 371 of 461 CTS MSpent Fuel Pool StorageE 3.7.16 0

INSRT2 FOR ILLU TRATION ONLY.

Figure 3.9-1 40,000 DO NOT U E FOR OPERATION.

(3.8. 35930.8)

. 30,000 (3.3: 30354.3) ,/

0

//

IB -2664 40 +(22584 X E)- (610 XE // /2 /

L E

0~

20.000 F

r- /

Not A / C B Permitted E

//

< 10,000 //

/

LL-(13,0.q) 0 I r T 0 .5 1 1.5 2.5 3 3. 4 4.5 Initial Fuel nrichment (E) wt% U,235 Category 'A" Fuel - May be located a ywhere within the storag racks.

Category 'B" Fuel - Shall only be Ioc ed adjacent to Category 'A" Fuel or water oles within the storage rac s.

Category 'C" Fuel - Shall not be locatI Iaeoy d adjacent to Category "Fuel.

Figure 3.7.16-1 (page 1 of 1)

Bumup versus Enrichment Curve for Spent Fuel §torage Racks Poo 0

BWOG STS 3.7.16-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 371 of 461

Attachment 1, Volume 12, Rev. 0, Page 372 of 461 3.7.16 CTS 0 INSERT 2 Figure 3.9-1 75 2 45 S40 35, 30; 2.00 2.50 3.00 3.50 4.00 4.50 5.00 5.50 lnitial Enrichment (wt% U-235) 0 INSERT 3 Figure 3.9-1 NOTE: Fuel assemblies with initial enrichments less than 2.0 wt%

U-235 will conservatively be required to meet the burnup requirements of 2.0 wt% U-235 assemblies. Loading pattern considerations applicable to Category "A," "B,"

and "C" assemblies are described in the Bases.

Insert Page 3.7.16-2 Attachment 1, Volume 12, Rev. 0, Page 372 of 461

Attachment 1, Volume 12, Rev. 0, Page 373 of 461 JUSTIFICATION FOR DEVIATIONS ITS 3.7.16, SPENT FUEL POOL STORAGE

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

2. Changes are made to the ISTS Specification which reflect the plant specific nomenclature, system description, analysis, or licensing basis description.

Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 373 of 461

Attachment 1, Volume 12, Rev. 0, Page 374 of 461 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 12, Rev. 0, Page 374 of 461

Attachment 1, Volume 12, Rev. 0, Page 375 of 461 MSpent Fuel Pool Storagem B 3.7.16 0

B 3.7 PLANT SYSTEMS B 3.7.16 MJSpent Fuel Pool StorageJ 0 BASES BACKGROUND The spent fuel storage facility is designed to store either new (nonirradiated) nuclear fuel assemblies, or burned (irradiated) fuel assemblies in a vertical configuration underwater. IThe storage pool i*

sized to store [735] fue assemblies, which in udes storage for [15] filed fuel containers . The pnt fuel storage cell,/are installed in paralle /rows.

with center to cent*ý sacing of [12 31/32] inches in one direction and

[13 3/16] inches i, the other orthogonal c ection. This spacing d/a"flux ro n 0

INSER 1ý r aop n t u *lti* h re b y t h e f u e l a s s ,mb lie s a re in s e rted in t

n e u t t"~~~

absorbing sta less steel cans, is suffi ent to maintain a kff o 5 0.95 for spent fuel oftoriginal enrichment of u to [3.3]%. However, higher initial enri -ment fuel assemblies arg stored in the spent fu I pool, they must beXtored in a checkerboard attern taking into acco nt fuel burnup to mairtain a k of 0.95 or less. i s APPLICABLE The spent fuel storage facility is designed for noncriticality by use of SAFETY adequate spacingý and -flux tr"p" construction wher y the fuel ANALYSES *assem Is are inserted into 9(eutron absorbinq stai less steel can 0 The spent fuel pool storage satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).

LCCO The restrictions on the placement of fuel assemblies within theifuel pool,e according to Figure M3.7.16-1 in the ac ing LCO ensure that the k& of the spent fuel pool will always remain < 0.95 assuming the pool to 000 be flooded with unborated water. The restrictions are consistent with the criticality safety analysis performed for the spent fuel pool, according to INER 3Figure R3.7.16-11 uel assemblies n meeting the cnteria figure [3.7.1 -1] shall be stored in ordance with Specifi tion 4.3.1.1.

00 APPLICABILITY This LCO applies whenever any fuel assembly is stored inR the spent fuel pool.

0D BVWOG STS B 3.7.16-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 375 of 461

Attachment 1, Volume 12, Rev. 0, Page 376 of 461 B 3.7.16 O* INSERT 1 The high density spent fuel pool storage racks are designed to maintain a keff equivalent to less than or equal to 0.95 when flooded with unborated water, which includes a conservative allowance for manufacturing tolerances and calculation uncertainty. The spent fuel pool facility is designed to assure the safe storage of irradiated fuel assemblies under normal and accident conditions. Each storage rack consists of a rectangular array of stainless steel cells with walls of 0.075 inches nominal thickness, spaced a nominal 9.22 inches on center in both directions. The neutron absorber material is utilized between each cell for criticality considerations.

The 21 spent fuel pool racks store a maximum of 1624 fuel assemblies. The rack cells are arranged in parallel rows with a center-to-center spacing of 9.22 inches.

O INSERT 2 A neutron absorber is attached to all four sides of each cell. In addition, there is a gap between individual racks and between the peripheral racks and the pool walls. These gaps form flux traps that reduces neutron movement between fuel assemblies in adjacent racks. Loading patterns maintain keff < 0.95 for fuel assemblies with initial nominal enrichments < 5.05 weight percent Uranium-235, assuming the spent fuel pool water is unborated.

O INSERT 3 The restrictions on the placement of fuel assemblies within the spent fuel pool as dictated by Figure 3.7.16-1 ensure that the kff of the spent fuel pool will always be

< 0.95 assuming the spent fuel pool is flooded with non-borated water. The restrictions delineated in Figure 3.7.16-1 and the Required Actions are consistent with the criticality safety analysis performed for the spent fuel pool (Ref. 1).

The criticality analyses qualify the high density rack modules for storage of the fuel assemblies in one of three different loading patterns subject to certain restrictions:

Mixed Zone Three Region (MZTR), Checkerboard (CB), and Homogeneous Loading (HL). Figure 3.7.16-1 provides the Category-specific burnup/enrichment limitations.

Different loading patterns may be used in different rack modules, provided each rack module contains only one loading pattern. The loading pattern restrictions are maintained in fuel handling administrative procedures.

MZTR is a loading pattern where fresh or low burnup assemblies (identified as Region 1 assemblies) are separated from each other and from intermediate burnup fuel assemblies (identified as Region 3 assemblies) by barrier fuel assemblies with high burnup (identified as Region 2 assemblies). CB is a loading pattern of empty cells, or cells with non-fuel bearing components, and cells with fresh or low burnup assemblies (Region 1). HL is a loading pattern of intermediate burnup fuel assemblies (Region 3). Region 2 assemblies correspond to Category A in Figure 3.7.16-1, Region 3 assemblies correspond to Category B in Figure 3.7.16-1, and Region 1 assemblies correspond to Category C in Figure 3.7.16-1.

Insert Page B 3.7.16-1 Attachment 1, Volume 12, Rev. 0, Page 376 of 461

Attachment 1, Volume 12, Rev. 0, Page 377 of 461 Dpent Fuel Pool StorageS]

B 3.7.16 0

BASES ACTIONS A.1 Required Action A.1 is modified by a Note indicating that LCO 3.0.3 does not apply. 0 When the configuration of fuel assemblies stored in the spent fuel pool is not in accordance with Figure [3.7.16-11 immediate action must be taken to make the necessary fuel assembly movement(s) to bring the configuration into compliance with Figure[R3.7.16-1[g.

"'ýIf moving fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not specify any action. If moving fuel assemblies while in MODE 1, 2, 3, or 4, the fuel movement is independent of reactor operation. Therefore, in either case, inability to move fuel assemblies is not sufficient reason to require a reactor shutdown.

SURVEILLANCE SR 3.7.16.1 REQUIREMENTS This SR verifies by administrative means that the initial enrichment and burnup of the fuel assembly is in accordance with Figure 3.7.16-1IF-n-e laccoR I[Figure 3..c1,prorac IFNor uel assemblEeSs in te unacceptableFrSinge ot yfteSR will ensure compliane with 010 SSpecificain,..1 ./ 0 REFERENCES N e 1. UFSAR, Scin9121 0

BWOG STS B 3.7.16-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 377 of 461

Attachment 1, Volume 12, Rev. 0, Page 378 of 461 JUSTIFICATION FOR DEVIATIONS ITS 3.7.16 BASES, SPENT FUEL POOL STORAGE

1. Changes are made to reflect changes made to the Specification.

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

3. Editorial changes for clarity. The first paragraph, which describes the addition of the Note, has been combined with the paragraph describing the reason for the Note.

4. Changes are made to be consistent with similar phrases in other Bases.

Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 378 of 461

Attachment 1, Volume 12, Rev. 0, Page 379 of 461 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 12, Rev. 0, Page 379 of 461

Attachment 1, Volume 12, Rev. 0, Page 380 of 461 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.7.16, SPENT FUEL POOL STORAGE There are no specific NSHC discussions for this Specification.

Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 380 of 461

, Volume 12, Rev. 0, Page 381 of 461 ATTACHMENT 17 ITS 3.7.17, SECONDARY SPECIFIC ACTIVITY , Volume 12, Rev. 0, Page 381 of 461

, Volume 12, Rev. 0, Page 382 of 461 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 12, Rev. 0, Page 382 of 461

Attachment 1, Volume 12, Rev. 0, Page 383 of 461 ITS 3.7.17 ITS PLANT SYSTEMS ACTIVITY LIMITING CONDITION FOR OPERATION 3.7.1.4 The specific activity of the secondary coolant system shall be LCO 3.7.17

< 0.10 uCi/gram DOSE EQUIVALENT 1-131.

APPLICABILITY: MODES 1, 2, 3 and 4.

ACTION:

ACTION A With the specific activity of the secondary coolant system > 0.10 uCi/gram DOSE EQUIVALENT 1-131, be in at least HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

SURVEILLANCE REQUIREMENTS SR 3.7.17.1 4.7.1.4 The specific activity of the secondary coolant system shall be determined to be within the limit~by perpormance of thg sampling andI

/analVSiS/ rocram of Tab ve 4.7-2.

Ievery 31 days:)

S~ eO DAVIS-BESSE, UNIT I 3/4 7-7 Page 1 of 2 Attachment 1, Volume 12, Rev. 0, Page 383 of 461

Attachment 1, Volume 12, Rev. 0, Page 384 of 461 ITS 3.7.17 ITS TABLE 4.7-2 SECONDARY COOLANT SYSTEM SPECIFIC ACTIVITY SAMPLE AND ANALYSIS PROGRAM TYPE OF MEASUREMENT SAMPLE AND AND ANALYSIS ANALYSIS FREQUENCY

11. Gross Activfty Determination Z At leastA'nce Per 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months sF =L7l SR 2. lIsotopieAnal EQUIVALENT I- 33sis Concentration for DOSE a) 1 per 31 days, -whenev, the gross activity determ tion in icates iodine com tration greater than of the Ilowable limit.*lO0 b) 1 *er 6 months, when, the gr ss activity detefm indicates iodine conceniri, below *0% of the allowa li DAVIS-BESSE, UNIT 1 3/4 7-8 Page 2 of 2 Attachment 1, Volume 12, Rev. 0, Page 384 of 461

Attachment 1, Volume 12, Rev. 0, Page 385 of 461 DISCUSSION OF CHANGES ITS 3.7.17, SECONDARY SPECIFIC ACTIVITY ADMINISTRATIVE CHANGES A01 In the conversion of the Davis-Besse Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1430, Rev. 3.1, "Standard Technical Specifications-Babcock and Wilcox Plants" (ISTS).

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

MORE RESTRICTIVE CHANGES M01 CTS Table 4.7-2 Item 2.a requires the DOSE EQUIVALENT 1-131 sampling frequency to be once per 31 days whenever the gross activity determination indicates iodine concentrations greater than 10% of the allowable limit. CTS Table 4.7-2 Item 2.b allows the sampling frequency for the DOSE EQUIVALENT 1-131 to be extended to once per 6 months whenever the gross activity determination indicates iodine concentrations below 10% of the allowable limits.

ITS SR 3.7.17.1 does not provide this extended 6 month time frame for determining the DOSE EQUIVALENT 1-131 and requires verification of specific activity of the secondary coolant every 31 days. This changes the CTS by deleting CTS Table 4.7-2 Item 2.b and the CTS Table 4.7-2 Item 2.a qualifying statement of "whenever the gross activity determination indicates iodine concentrations greater than 10% of the allowable limit" in Item 2.a, and keeping the Frequency at 31 days all the time.

This change is acceptable because the 31 day Frequency is appropriate to detect trends in the secondary coolant level of DOSE EQUIVALENT 1-131 and allows for appropriate action to be taken to maintain levels below the LCO limit.

This change is designated as more restrictive because it requires the DOSE EQUIVALENT 1-131 concentration to be determined every 31 days whenever the unit is in MODES 1, 2, 3, and 4 while not allowing a Frequency extension to once every 6 months based on the gross activity determination.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 3 - Removing ProceduralDetails for Meeting TS Requirements or Reporting Requirements) CTS Table 4.7-2 Item 2 requires an isotopic analysis to determine whether DOSE EQUIVALENT 1-131 concentration is within limit.

ITS SR 3.7.17.1 requires the verification that specific activity of the secondary coolant is within limit (< 0.10 pCi/gm DOSE EQUIVALENT 1-131). This changes the CTS by moving the detail that an isotopic analysis must be performed to satisfy the requirements of the Surveillance to the Bases.

Davis-Besse Page 1 of 2 Attachment 1, Volume 12, Rev. 0, Page 385 of 461

Attachment 1, Volume 12, Rev. 0, Page 386 of 461 DISCUSSION OF CHANGES ITS 3.7.17, SECONDARY SPECIFIC ACTIVITY The removal of this detail for performing a Surveillance Requirement from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. ITS SR 3.7.17.1 still retains the requirement to verify secondary coolant DOSE EQUIVALENT 1-131 is within limit.

Also, this change is acceptable because this type of procedural detail will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L01 (Category5 - Deletion of Surveillance Requirement) CTS Table 4.7-2 Item 1 requires that the gross activity determination be completed once per 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

ITS 3.7.17 does not require any sampling to be performed to determine the gross activity of the secondary coolant. This changes the CTS by deleting the requirement for gross activity determination.

The purpose of CTS Table 4.7-2 Item 1 is to determine the gross activity in order to determine the sampling Frequency for secondary coolant DOSE EQUIVALENT 1-131. Based on the gross activity, the sample Frequency for determining DOSE EQUIVALENT 1-131 can be extended to once per 6 months from once per 31 days. This change is acceptable because the deleted Surveillance Requirement is not necessary to verify that the values used to meet the LCO are consistent with the safety analysis. Thus, appropriate values continue to be tested in a manner and at a Frequency necessary to give confidence that the assumptions in the safety analyses are protected. ITS SR 3.7.17.1 requires that the DOSE EQUIVALENT 1-131 be determined every 31 days without any allowance for an extension of this Frequency. The secondary coolant DOSE EQUIVALENT 1-131 is used in the accident analyses.

The gross activity of the secondary coolant is not used in any accident analysis.

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

Davis-Besse Page 2 of 2 Attachment 1, Volume 12, Rev. 0, Page 386 of 461

Attachment 1, Volume 12, Rev. 0, Page 387 of 461 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 12, Rev. 0, Page 387 of 461

Attachment 1, Volume 12, Rev. 0, Page 388 of 461 CTS Secondary SpecificActivity 3.7.17 3.7 PLANT SYSTEMS 3.7.17 Secondary Specific Activity 3.7.1.4 LCO 3.7.17 The specific activity of the secondary coolant shall be _<P.10 ]pCi/gm DOSE EQUIVALENT 1-131.

0 APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME Action A. Specific activity not A.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months within limit.

AND A.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 47 14 SR 3.7.17.1 Verify the specific activity of the secondary coolant is _0.10]RCi/gm DOSE EQUIVALENT 1-131.

[31MJdays 0 BXAOG STS 3.7.17-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 388 of 461

Attachment 1, Volume 12, Rev. 0, Page 389 of 461 JUSTIFICATION FOR DEVIATIONS ITS 3.7.17, SECONDARY SPECIFIC ACTIVITY

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

Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 389 of 461

Attachment 1, Volume 12, Rev. 0, Page 390 of 461 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 12, Rev. 0, Page 390 of 461

Attachment 1, Volume 12, Rev. 0, Page 391 of 461 Secondary Specific Activity B 3.7.17 B 3.7 PLANT SYSTEMS B 3.7.17 Secondary Specific Activity BASES BACKGROUND Activity in the secondary coolant results from steam generator tube out-LEAKAGE from the Reactor Coolant System (RCS). Under steady state conditions, the activity is primarily iodines with relatively short half lives and, thus, indicative of current conditions. During transients, 1-131 spikes have been observed, as well as increased releases of some noble gases.

Other fission product isotopes, as well as activated corrosion products, in lesser amounts, may also be found in the secondary coolant.

A limit on secondary coolant specific activity during power operation minimizes releases to the environment because of normal operation, anticipated operational occurrences, and accidents.

This limit is lower than the activity value that might be expected from a 1 gpm tube leak (LCO 3.4.13, "RCS Operational Leakage") of primary coolant at the limit of 1.0 pCi/gm (LCO 3.4.16, "RCS Specific Activity").

The steam line failure is assumed to result in the release of the noble gas and iodine activity contained in the steam generator inventory, the feedwater, and the reactor coolant leakage. Most of the iodine isotopes have short half lives (i.e., < 20 hours2.314815e-4 days 0.00556 hours 3.306878e-5 weeks 7.61e-6 months ).

With the sp ified activity limit, th /resultant 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months thyroi /dose person atft e exclusion area bo ndary (EAB) would be/out 0.,

the mai steam safety valves SSVs) are open for e 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 0

a trip am full power. " ;

[-d-*s-e-- Operating a unit at the allowable limits could result in aIourE2 exosur of a small fraction of the 10 CFR 100 (Ref. 1) limits, or consistent with -IestabI1fsheda the NRC staff approved licensing basis. 0 APPLICABLE The accident analysis of the main steam line break, as discussed in the SAFETY Section 15.4 ANALYSES U FS hapRaer [15] (Ref. 2) assumes tpe initial secondary co ant speci ic activ/fy to nave a radioactive isotope concentration 9(0.1 PCiu m 00 N DOSE EQLX4VALENT 1-131 . This assumption is used in the analysisfo

~determining the radiological consequences of the postulated accident.

The accident analysis, based on this and other assumptions, shows that 00 the radiological consequences of an MSLB do not exceed established limits, (Ref. 1) for whole body and thyroid dose rF-fe.

BWOG STS B 3.7.17-1 Rev. 3.0, 03131/04 Attachment 1, Volume 12, Rev. 0, Page 391 of 461

Attachment 1, Volume 12, Rev. 0, Page 392 of 461 B 3.7.17 0 INSERT 1 the reactor has been operating with 1% defective fuel and a 1 gpm steam generator tube leak. The steam line break occurs between containment and the main steam isolation valve. Reactor coolant leakage into the steam generator continues for 9 hours1.041667e-4 days 0.0025 hours 1.488095e-5 weeks 3.4245e-6 months until the RCS is cooled down and the pressure differential is equalized.

Insert Page B 3.7.17-1 Attachment 1, Volume 12, Rev. 0, Page 392 of 461

Attachment 1, Volume 12, Rev. 0, Page 393 of 461 Secondary Specific Activity B 3.7.17 BASES APPLICABLE SAFETY ANALYSES (continued)

With loss o offsite ower the remaining steam generator is available for core decay heat dissipation by venting steam to the atmosphere 0

through the MSSVs and stea The E enerator a s heric m valves gency Feedwater System supplies the necessary 0

makeup to the steam generator. Venting continues until the reactor (Decay Heat Removal coolant temperature and pressure has decreased sufficiently for the

-hutd Cooling System to complete the cooldown.

0 In the evaluation of the radiological consequences of this accident, the activity released from the steam generator connected to the failed steam line is assumed to be released directly to the environment. The unaffected steam generator is assumed to discharge steam and any entrained activity through the MSSVs n during the event. Since 0 no credit is taken in the analysis for activity plateout or retention, the resultant radiological consequences represent a conservative estimate of the potential integrated dose due to the postulated steam line failure.

Secondary specific activity limits satisfy Criterion 2 of 10 CFR 50.36(c)(2)(ii).

LCO As indicated in the Applicable Safety Analyses, the specific activity limit in the secondary coolant system of :50.10jp Ci/gm DOSE EQUIVALENT 1-131 maintains the radiological consequences of a Design Basis 0

Accident (DBA) to a small fraction of Reference 1 limits.

Monitoring the specific activity of the secondary coolant ensures that, when secondary specific activity limits are exceeded, appropriate actions are taken, in a timely manner, to place the unit in an operational MODE that would minimize the radiological consequences of a DBA.

APPLICABILITY In MODES 1, 2, 3, and 4, the limits on secondary specific activity apply due to the potential for secondary steam releases to the atmosphere.

In MODES 5 and 6, the steam generators are not being used for heat removal. Both the RCS and steam generators are at low pressure and primary to secondary LEAKAGE is minimal. Therefore, monitoring of secondary specific activity is not required.

BWOG STS B3.7.17-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 393 of 461

Attachment 1, Volume 12, Rev. 0, Page 394 of 461

.Secondary Specific Activity B 3.7.17 BASES ACTIONS A.1 and A.2 DOSE EQUIVALENT 1-131 exceeding the allowable value in the secondary coolant contributes to increased post accident doses. If is not within limits secondary specific activity Ica nnot>4 restored to within jinits within t~he]

associa e omnietion me, the unit must be placed in a MODE in which 0

the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

SURVEILLANCE SR 3.7.17.1 REQUIREMENTS

___ This SR verifies that the secondary specific activity is within the limits of the accident "analy5si.j mmaisotopic analysis of the secondary coolant, which determines DOSE EQUIVALENT 1-131, confirms the for 0

validity of the safety analysis assumptions[ffe'leases. It also serves to fa identify and trend any unusual isotopic concentrations that might indicate changes in reactor coolant activity or LEAKAGE. The 31 day Frequency is based on the detection of increasing trends of the level of DOSE EQUIVALENT 1-131, and allows for appropriate action to be taken to maintain levels below the LCO limit.

REFERENCES 1. 10CFR10OF5;9. 00 2.--- FSAR, Pt&tejr F[

BWOG STS B 3.7.17-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 394 of 461

Attachment 1, Volume 12, Rev. 0, Page 395 of 461 JUSTIFICATION FOR DEVIATIONS ITS 3.7.17 BASES, SECONDARY SPECIFIC ACTIVITY

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

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

3. Changes made to be consistent with the Specification.

4. This information is not necessary to be in the Bases, since the next paragraph states that the 10 CFR 100 limits are not exceeded.

5. Editorial change for clarity.

Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 395 of 461

Attachment 1, Volume 12, Rev. 0, Page 396 of 461 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 12, Rev. 0, Page 396 of 461

Attachment 1, Volume 12, Rev. 0, Page 397 of 461 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.7.17, SECONDARY SPECIFIC ACTIVITY There are no specific NSHC discussions for this Specification.

Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 397 of 461

, Volume 12, Rev. 0, Page 398 of 461 ATTACHMENT 18 ITS 3.7.18, STEAM GENERATOR LEVEL , Volume 12, Rev. 0, Page 398 of 461

, Volume 12, Rev. 0, Page 399 of 461 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 12, Rev. 0, Page 399 of 461

Attachment 1, Volume 12, Rev. 0, Page 400 of 461 ITS 3.7.18 ITS 3/4.7 PLANT SYSTEMS 3/4.7.9 STEAM GENERATOR LEVEL LIMITING CONDITION FOR OPERATION LCO 3.7.18 3.7.9 Each Steam Generator shall havela minimum waterjebl of 18 inches andithe maximum specified below as applicable:

MODES l and 2:

a. The acceptable operating region of Figure 3.7-1.

MODE 3*:

b. 50 inches Startup Range with the SFRCS Low Pressure Trip bypassed and one or both Main Feedwater Pump(s) capable of supplying Feedwater to any Steam Generator.

c. 96 percent Operate Range with:

1. The SFRCS Low Pressure Trip active, or

2. The SFRCS Low Pressure Trip bypassed and both Main Feedwater Pumps incapable of supplying Feedwater to the Steam Generators.

MODE 4: R

d. 625 inched/ull Range LevelI $ -I S

APPLICABILITY: MODES 1, 2, 3, and.s above.

ACTION:

I Add proposed ACTION A ACTION B With one or more steam generator's wg STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in=C[

SURVEILLANCE REQUIREMENTS SR 3.7.18.1 4.7.9 The steam generator shall be demonstrated OPERABLE by verifying steam generator level to be within limits at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

ACTIONS "Establish adequate SHUTDOWN MARGIN to ensure the reactor will stay subcritical Note during a MODE 3 Main Steam Line Break.

0 DAVIS-BESSE, UNIT I 3/4 7-38 Amendment No.-2-;-TF,-I 276 Page 1 of 2 Attachment 1, Volume 12, Rev. 0, Page 400 of 461

Attachment 1, Volume 12, Rev. 0, Page 401 of 461 ITS 3.7.18 ITS Figure 3.7-1 Figure 3.7.18-1 Maximum Allowable Steam Generator Level in MODES I and 2 100 (43.96)

S90 so tnacceptable Operating Region 60 50 AcceptabLe 40 Operating Region 20 20 10 40 30 60 Kain Steam Superheat (OF) 0 DAVIS-BESSE, UNIT 1 3/4 7-39 Amendment No. 492, 276 Page 2 of 2 Attachment 1, Volume 12, Rev. 0, Page 401 of 461

Attachment 1, Volume 12, Rev. 0, Page 402 of 461 DISCUSSION OF CHANGES ITS 3.7.18, STEAM GENERATOR LEVEL ADMINISTRATIVE CHANGES A01 In the conversion of the Davis-Besse Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1430, Rev. 3.1, "Standard Technical Specifications-Babcock and Wilcox Plants" (ISTS).

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

A02 The CTS 3.7.9 Action requires the unit to be ultimately placed in COLD SHUTDOWN (MODE 5) when the steam generator water level is not within limits.

ITS 3.7.18 ACTION B only requires placing the unit in MODE 4. This changes the CTS by only requiring the unit to be in MODE 4 in lieu of MODE 5 when outside the SG water level limits.

The purpose of the CTS 3.7.9 Action is to place the unit outside the Applicability of the LCO. CTS 3.7.9 includes MODE 4 SG water level requirements, thus placing the unit in MODE 5 was appropriate. ITS 3.7.18 only includes MODES 1, 2, and 3 SG water level requirements. The MODE 4 requirement has been removed as described in DOC LA01. Thus, the ITS 3.7.18 ACTION B requirement is consistent with placing the unit outside the Applicability of ITS 3.7.18. The proposed 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Completion Time to reach MODE 4 is consistent with the time normally provided in other Specifications. Therefore, this change is acceptable. This change is designated as administrative and is acceptable because it does not result in any technical changes other than those justified in DOC LA01.

MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 3 - Removing ProceduralDetails for Meeting TS Requirements or Reporting Requirements) CTS 3.7.9.d states that the maximum SG water level in MODE 4 shall be less than or equal to 625 inches full range level. ITS 3.7.18 does not include the MODE 4 SG water level requirements. This changes the CTS by moving the maximum SG water level detail to the Bases (of ITS 3.4.5 and ITS 3.4.6).

The removal of this detail, which is related to SG OPERABILITY, from the Technical Specifications is acceptable because this type of information is not Davis-Besse Page 1 of 3 Attachment 1, Volume 12, Rev. 0, Page 402 of 461

Attachment 1, Volume 12, Rev. 0, Page 403 of 461 DISCUSSION OF CHANGES ITS 3.7.18, STEAM GENERATOR LEVEL necessary to be in the Technical Specifications in order to provide adequate protection of the public health and safety. The ITS retains the requirement in ITS 3.4.5 that two RCS loops be OPERABLE and in ITS 3.4.6 that any combination of two DHR or RCS loops be OPERABLE. When the RCS loops are required OPERABLE, this will require the associated SGs to be OPERABLE and capable of removing decay heat (i.e., water level > 18 inches above the lower tube sheet and < 625 inches full range level), as stated in the ITS 3.4.5 and ITS 3.4.6 Bases. If the SG water level is not within the limit specified such that decay heat removal capability does not exist, the associated RCS loop would be inoperable and the appropriate ACTIONS of ITS 3.4.5 or ITS 3.4.6 would be entered. Also, this change is acceptable because these types of procedural details will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5.

This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L01 (Category 1 - Relaxation of LCO Requirements) CTS 3.7.9 requires a minimum of 18 inches in each steam generator (SG) in MODES 1, 2, 3, and 4. ITS 3.7.18 does not include any minimum SG level requirements. This changes the CTS by deleting the minimum SG level requirements from this Technical Specification.

The purpose of the minimum SG level requirement is to ensure adequate level in the SG so it can perform its heat removal function. This change is acceptable because the minimum level requirement is not necessary in this Specification to ensure the heat removal function. The Steam and Feedwater Rupture Control System (SFRCS) Instrumentation includes an actuation on low steam generator level. The Allowable Value for the Steam Generator Level - Low Function is

> 17.3 inches (ITS Table 3.3.11-1 Function 3), and it is required in MODES 1, 2, and 3. However, the actual trip setpoint for this Function is approximately 23 inches. When actuated, the SFRCS instrumentation initiates the Auxiliary Feedwater System (AFW) to restore SG water level, and send a signal to the Anticipatory Reactor Trip System (ARTS), which will then generate a reactor trip signal. This results in the unit being automatically placed in MODE 3. While the ARTS is not maintained in the ITS, it is being maintained in the Technical Requirements Manual. ITS 3.4.5, "RCS Loops - MODE 3," and ITS 3.4.6, "RCS Loops - MODE 4," provide the loop requirements to ensure decay heat can be removed when in these MODES. ITS 3.4.5 requires two RCS loops to be OPERABLE and ITS 3.4.6 requires two loops of any combination of RCS loops and decay heat removal (DHR) loops. The LCO section of the Bases for both of these Specifications states that an OPERABLE RCS loop includes an OPERBLE SG. The Bases further states that an OPERABLE SG requires at least

> 18 inches of secondary side water level above the lower tube sheet.

Therefore, maintaining a specific minimum SG water level requirement in the Technical Specifications is not required, since other plant systems (ARTS) and other ITS requirements (ITS 3.3.11, ITS 3.4.5, and ITS 3.4.6) in combination with other plant design features (ARTS) will ensure adequate decay heat removal Davis-Besse Page 2 of 3 Attachment 1, Volume 12, Rev. 0, Page 403 of 461

Attachment 1, Volume 12, Rev. 0, Page 404 of 461 DISCUSSION OF CHANGES ITS 3.7.18, STEAM GENERATOR LEVEL capability using an RCS loop is maintained. This change is designated as less restrictive because less stringent LCO requirements are being applied in the ITS than were applied in the CTS.

L02 (Category 3 - Relaxation of Completion Time) CTS 3.7.9 Action states that when SG water level for one or more SGs is outside the limits, be in HOT STANDBY (MODE 3) within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and COLD SHUTDOWN (MODE 5) within the next 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . No time is provided to restore a SG water level prior to requiring a unit shutdown. Under similar conditions, ITS 3.7.18 ACTION A provides a 15 minute restoration time prior to requiring a unit shutdown. This changes the CTS by providing 15 minutes to restore the SG water level to within limits prior to requiring a unit shutdown. The change in the requirement to be in MODE 5 is discussed in DOC A02.

The purpose of CTS 3.7.9 Action is to restore the SDM to within its limit promptly.

This change is acceptable because the Completion Time is consistent with safe operation under the specified Condition, considering the low probability of a DBA occurring during the allowed Completion Time, and provides a reasonable time for restoring the SG water level. The ITS 3.7.18 Required Action A.1 Completion Time of 15 minutes is considered a reasonable time for an operator to restore SG water level to within limits, and avoids an unnecessary unit shutdown if the problem can be promptly restored. This change is designated as less restrictive because additional time is allowed to restore parameters to within the LCO limits than was allowed in the CTS.

Davis-Besse Page 3 of 3 Attachment 1, Volume 12, Rev. 0, Page 404 of 461

Attachment 1, Volume 12, Rev. 0, Page 405 of 461 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 12, Rev. 0, Page 405 of 461

Attachment 1, Volume 12, Rev. 0, Page 406 of 461 CTS Steam Generator'Level 3.7.18 3.7 PLANT SYSTEMS 3.7.18 Steam Generator Level 3.7.9

)ýE=

LCO 3.7.18 Water level ofach steam generat* shall be less tha or equal to the maximum wua4fer level shown in Fiqlure 3.7.1:8-1. 0 APPLICABILITY: MODES 1 2( F Ond 3 0

INSERT 2 0

CONDITION REQUIRED ACTION COMPLETION TIME DOC L02 A. Water level in one or A.1 Restore steam generator 15 minutes more steam generators level to within limit.

nt within greater thannaximum water leve n 0

limits Figure 3/ .18-1[

Action B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion - INSERT3 Time i- K not 00 met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.7.9 SR 3.7.18.1 Verify steam generator water level to be within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months limits.

BWOG STS 3.7.18-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 406 of 461

Attachment 1, Volume 12, Rev. 0, Page 407 of 461 3.7.18 CTS 0 INSERT 1 3.7.9 Water Level of each steam generator shall be:

a. Less than or equal to the maximum water level shown in Figure 3.7.18-1 when in MODE 1 or 2;

b. < 96% Operate Range with LCO 3.3.11, "Steam and Feedwater Rupture Control System (SFRCS) Instrumentation," Function 1 (Main Steam Line Pressure - Low) not bypassed when in MODE 3;

c. < 96% Operate Range with LCO 3.3.11, Function 1 bypassed and both main feedwater (MFW) pumps not capable of supplying feedwater to the steam generators when in MODE 3; and

d. < 50 inches Startup Range with LCO 3.3.11, Function 1 bypassed and one or both MFW pumps capable of supplying feedwater to the steam generators when in MODE 3.

OINSERT 2

NOTE --------------------------

Footnote' Enter applicable Conditions and Required Actions of LCO 3.1.1, "SHUTDOWN MARGIN (SDM)," when high steam generator water level results in exceeding the SDM limits.

0 INSERT 3 AND Action B.2 Be in MODE 4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Insert Page 3.7.18-1 Attachment 1, Volume 12, Rev. 0, Page 407 of 461

Attachment 1, Volume 12, Rev. 0, Page 408 of 461 3.7.18 Steam Generator Level 3.7.18

-j LU Uj

-J z

LU 0

LU

-j 0

STEAM SUPERHEAT (F)

Figure 3.7.18-1 (page 1 of 1)

Maximum Allowable Steam Generator Level BWOG STS 3.7.18-2 Rev. 3.0, 03/31/04 Insert Page 3.7.18-1 Attachment 1, Volume 12, Rev. 0, Page 408 of 461

Attachment 1, Volume 12, Rev. 0, Page 409 of 461 3.7.18 CTS 0 INSERT 4 Figure 3.7-1 100 (43,96) 90 80 Unacceptable Operating Region 70 60 Acceptable Operating Region 50 40 -1 0 10 ZO 40 50 60 Insert Page 3.7.18-2 Attachment 1, Volume 12, Rev. 0, Page 409 of 461

Attachment 1, Volume 12, Rev. 0, Page 410 of 461 JUSTIFICATION FOR DEVIATIONS ITS 3.7.18, STEAM GENERATOR LEVEL

1. ISTS 3.7.18 has been modified to include MODE 3 steam generator water level requirements. The Davis-Besse main steam line break accident analysis assumes a maximum water level to ensure both the containment pressure and the SHUTDOWN MARGIN is maintained within limits. Maintaining the steam generator water level within limits in MODE 3 prevents a containment over-pressurization event and a return to criticality concern following a main steam line break. Thus LCO 3.7.18 includes the Davis-Besse current licensing basis MODE 3 water level limits. Due to this addition, ISTS 3.7.18 ACTION B has been modified to include a shutdown to MODE 4. Furthermore, due to the addition of LCO 3.0.6, a Note has been added to ensure the applicable Conditions and Required Actions of LCO 3.1.1, "SHUTDOWN MARGIN (SDM)," are entered when steam generator water level is not met in MODE

3. This is also consistent with the Davis-Besse current licensing basis, since CTS 3.7.9 includes a Note (footnote *) that references the SHUTDOWN MARGIN requirements.

2. Since Condition B applies to all Conditions in the ACTIONS Table, the term "of Condition A" is not necessary. This is consistent with the Writer's Guide for the Improved Standard Technical Specifications, TSTF-GG-05-01, Section 4.1.6.i.5.ii.

3. The Davis-Besse Steam Superheat verses maximum Allowable Operating Level curve is substituted for the curve provided for illustration in the ISTS.

Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 410 of 461

Attachment 1, Volume 12, Rev. 0, Page 411 of 461 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 12, Rev. 0, Page 411 of 461

Attachment 1, Volume 12, Rev. 0, Page 412 of 461 Steam Generator Level B 3.7.18 B 3.7 PLANT SYSTEMS B 3.7.18 Steam Generator Level BASES BACKGROUND A principal function of the steam generators is to provide superheated LJ steam at a constant pressureýQ psia) over the power range. Steam generator water inventory is maintained large enough to provide 0

adequate primary to secondary heat transfer. Mass inventory and indicated water level in the steam generator increases with load as the length of the four heat transfer regions within the steam generator vary.

Inventory is controlled indirectly as a function of power and maintenance of a constant average primary system temperature by the feedwater controls in the Integrated Control System.

The maximum opera tig steam generator level is based primarily on preserving the initial ndition assumptions for stea generator inventory used in the FSAR s am line break (SLB) analysis ( ef. 1). An inventory of 62,600 lb was u ed in this analysis. The 62,600 - must not be exceeded due to t e concerns of a possible return o criticality because of 0 primary side cool' g following an SLB and the ma imum pressure in the reactor building.

For a clean once through steam generator, the mass inventory in a steam Senerator for operating at 100% power is approximately 39,0 0 lb to 0 lb.

As a steam generator becomes fouled and the operating level approaches the limit of 96%, the mass inventory in the downcomer region increases approximately 10,000 lb, and adds to the total mass inventory of the steam generator. In matching unit data of startup level versus power, the steam generator performance codes have shown that fouling of the lower tube support plates does not significantly change the heat transfer characteristics of the steam generator. Thus, the steam temperature, or superheat, is not degraded due to the fouling of the tube support plates, and mass inventory changes are mainly due to the added level in the downcomer.

Analytically, increasing the fouling of the steam generator tube surfaces degrades the heat transfer capability of the steam generator, increases the mass inventory, and decreases the steam superheat at 100% p 1(2540 MWV. The results were presented as the amount of mass inventory in each steam generator versus operating range level and steam 0 superheat.

BWOG STS B 3.7.18-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 412 of 461

Attachment 1, Volume 12, Rev. 0, Page 413 of 461 B 3.7.18

( INSERT 1 The maximum operating steam generator level is based primarily on preserving the initial condition assumptions for the steam generator inventory used in the main steam line break (MSLB) accident analysis (Ref. 1). The mass and energy release data that are input into the peak pressure analysis of the containment vessel were generated with the TRAP computer code. The analysis was performed with the bounding plant conditions to maximize heat generated in the Reactor Coolant System (RCS), heat transfer from the primary to secondary systems, and maximum inventory in the steam generators. Each of these conditions maximizes the mass and energy release from the MSLB. The analysis includes evaluation of the reactivity transient due to the MSLB.

Insert Page B 3.7.18-1 Attachment 1, Volume 12, Rev. 0, Page 413 of 461

Attachment 1, Volume 12, Rev. 0, Page 414 of 461 Steam Generator Level B 3.7.18 BASES BACKGROUND (continued)

The limiting curve, which was determined from several steam generator performance code runs at a power level of 100%, conservatively bounds steam generator mass inventory value, when operating at power levels

< 100%.

2 The points displayed in Figure 3.7.18-1[ in the acoManvin are the intercept points of the 57,000 lb mass value, and the operating range level x and steam superheat values.

The steam generator performance analysis also indicated that startup and full range level instruments are inadequate indicators of steam generator mass inventory at high power levels due to the combination of static and dynamic pressure losses. If the water level should rise above the 96%

upper limit, the steam superheat would tend to decrease due to reduced feedwater heating through the aspirator ports. Normally, a reduction in water level is manually initiated to maintain steam flow through the aspirator port by reducing the power level. Thus, the superheat versus level limitation also tends to ensure that, in normal operation, water level will remain clear of the aspirator ports.

Feedwater nozzle flooding would impair feedwater heating, and could result in excessive tube to shell temperature differentials, excessive tubesheet temperature differentials, and large variations in pressurizer level.

APPLICABLE SAFETY ANALYSES main-The most limiting Design Basis Accident that would be affected by steam

ýgenerator operating level is a team line failure. This accident is evaluated in Reference 1. The parameter of interest is the mass of water, 0

or inventory, contained in the steam generator due to its role in lowering Reactor Coolant System (RCS) temperature (return to criticality concern),

and in raising containment pressure during angSLB accident. A higher {. 0 inventory causes the effects of the accident to be more severe.

Figure 3.7.18-11, in the accoe anying LL;U, is based upon maintaining 0 inventory < 57,000 lbX *hich is M-bo Is than the inventor used in the 1-FSAR accident analysis, and theref re is conservative. - 0 The steam generator level satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).

BWOG STS B 3.7.18-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 414 of 461

Attachment 1, Volume 12, Rev. 0, Page 415 of 461 B 3.7.18 O INSERT 2 Figure 3.7.18-1 was reviewed following reanalysis of the MSLB, which assumed approximately 56,000 Ibm, and was considered to remain bounding. It has been determined that the plant response when operating at the limit of the Figure is consistent with the MSLB analysis.

Insert Page B 3.7.18-2 Attachment 1, Volume 12, Rev. 0, Page 415 of 461

Attachment 1, Volume 12, Rev. 0, Page 416 of 461 Steam Generator Level B 3.7.18 BASES LCO This LCO is required to preserve the initial condition assumptions of the accident analyses. Failure.to meet the maximum steam generator level LCO requirements can result in additional mass and energy released to M

containment, and excessive cooling (and related core reactivity effects) following an LB. In addition, feedwater nozzle flooding would impair feedwater heating, and could result in excessive tube to shell temperature 0

differentials and excessive tubesheet temperature gradients.

- -- -':ý[ and 3 APPLICABILITY U -lnMODES114-g2'a maximurn steam generator water level is required main to preserve the initial condition assumption for steam generator inventory steam generator wused

/level (in conjunction with/

in the steam line failure accident analysis (Ref. 1).

meeting the requirements In MODE 3, limits on JRCS boron n ýcentrationswillorevent a return to of LCO 3.1.1, - criticality in the even of anaSLB. Iln MODES 4, 5, and 6, the water in the SHUTDOWNM steam generator has a low specific enthalpy; therefore, there is no need to limit the steam generator inventory when the unit is in this condition.

ACTIONS A.lINT3 0 With the steam generator level in excess of the maximum limit, action must be taken to restore the level to within the bounds assumed in the analysis. To achieve this status, the water level is restored to within the limit. The 15 minute Completion Time is considered to be a reasonable time to perform this evolution.

B-1 If the water level in one or more steam generators cannot be restored to within the limits - less than of/equal to the maydmum level in Fiure 3.7.18-11, the unit must be placed in a MODE that minimizes the accident risk. To achieve this status, the unit must be placed in at least MODE 3 within 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months The allowed Completion Tim '] reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. and in MODE 4 SURVEILLANCE SR 3.7.18.1 within REQUIREMENTS 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months I *s1 verities the steam generator level to De witnin acceptable limits.

SlRs The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency is adequate because the operator will be aware of unit evolutions that can affect the steam generator level between checks. Furthermore, the 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency is considered adequate in view of other indications available in the control room, including alarms, to alert the operator to steam generator level status.

REFERENCES W1-*.-FSAR, Section M15.4.41 00 BWOG STS B 3.7.18-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 416 of 461

Attachment 1, Volume 12, Rev. 0, Page 417 of 461 B 3.7.18 O* INSERT 3 In the event a high steam generator water level results in exceeding the SDM limits of LCO 3.1.1, "SHUTDOWN MARGIN (SDM)," the ACTIONS Note directs entry into the applicable Conditions and Required Actions of LCO 3.1.1. This is an exception to LCO 3.0.6 and ensures the proper actions are taken for SDM not within the required limits.

Insert Page B 3.7.18-3 Attachment 1, Volume 12, Rev. 0, Page 417 of 461

Attachment 1, Volume 12, Rev. 0, Page 418 of 461 JUSTIFICATION FOR DEVIATIONS ITS 3.7.18 BASES, STEAM GENERATOR LEVEL

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

2. Changes are made to be consistent with similar phrases in other Bases.

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

4. Editorial change for clarity.

5. Changes made to reflect changes made to the Specification.

Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 418 of 461

Attachment 1, Volume 12, Rev. 0, Page 419 of 461 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 12, Rev. 0, Page 419 of 461

Attachment 1, Volume 12, Rev. 0, Page 420 of 461 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.7.18, STEAM GENERATOR LEVEL There are no specific NSHC discussions for this Specification.

Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 420 of 461

, Volume 12, Rev. 0, Page 421 of 461 ATTACHMENT 19 RELOCATED/DELETED CURRENT TECHNICAL SPECIFICATIONS , Volume 12, Rev. 0, Page 421 of 461

Attachment 1, Volume 12, Rev. 0, Page 422 of 461 CTS 3/4.7.2, STEAM GENERATOR PRESSURE/TEMPERATURE LIMITATION Attachment 1, Volume 12, Rev. 0, Page 422 of 461

, Volume 12, Rev. 0, Page 423 of 461 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 12, Rev. 0, Page 423 of 461

Attachment 1, Volume 12, Rev. 0, Page 424 of 461 CTS 3/4.7.2 PLANT SYSTEMS 3/4.7.2 STEAM GENERATOR P SSURE/TEMPERATURE LIMITATION LIMITING CONDITION FOR OP_ ATION 3.7.2.1 The temperature f the secondary coolant in the steam generators shall be > 110*F when the pres re of the secondary coolant in the steam generator is

> 237 psig.

APPLICABILITY: At all t mes.

ACTION:

With the requirements o the .above specification not satisfi d:

a. Reduce the st am generator pressure to < 237 psig ithin 30 minutes, and

b. Perform an e gineering evaluation to determine th effect of overpressuri ation on the structural integrity of the steam generator.

Determine t t the steam generator remains accept ble for continued operation pr or to increasing its pressure above 37 psig.

4.7.2.1 be The tem determined to }erature of at

> 1100F the least secondary once coolant per hour in e ehsecondary whe steam generator pressure shall in the steam generat or is > 237 psig and Tavg is < 2000F.

DAVIS-BESSE, T 1 3/4 7-13 Amendment No. 135 Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 424 of 461

Attachment 1, Volume 12, Rev. 0, Page 425 of 461 DISCUSSION OF CHANGES CTS 3/4.7.2, STEAM GENERATOR PRESSURE/TEMPERATURE LIMITATION ADMINISTRATIVE CHANGES None MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS R01 CTS 3.7.2.1 states that the temperature of the secondary coolant in the steam generators shall be > 110OF when the pressure of the secondary coolant in the steam generator is > 237 psig. The limitation on steam generator pressures and temperatures ensures that pressure-induced stresses on the steam generators do not exceed the maximum allowable fracture toughness limits. These pressure and temperature limits are based on maintaining a steam generator RTNDT sufficient to prevent brittle fracture. As such, the Technical Specification places limits on variables consistent with structural analysis results. However, these limits are not initial condition assumptions of a DBA or transient. These limits represent operating restrictions and Criterion 2 includes operating restrictions.

However, it should be noted that in the Final Policy Statement the Criterion 2 discussion specified only those operating restrictions required to preclude unanalyzed accidents and transients be included in Technical Specifications.

This Specification does not meet the criteria for retention in the ITS; therefore, it is not included in the ITS. This changes the CTS by relocating this Specification to the Technical Requirements Manual (TRM).

This change is acceptable because CTS 3.7.2.1 does not meet the 10 CFR 50.36(c)(2)(ii) criteria for inclusion into the ITS.

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

1. The steam generator pressure and temperature limits are not used for, nor capable of, detecting a significant abnormal degradation of the reactor coolant pressure boundary prior to a design basis accident (DBA).

2. The steam generator pressure and temperature limits are not a process variable, design feature, or operating restrictions that are an initial condition of a DBA or transient.

3. The steam generator pressure and temperature limits are not part of the primary success path in the mitigation of a DBA or transient.

4. As discussed in B&W Owners Group Technical Report 47-1170689-00 (Appendix A pages A-73 and A-74), the steam generator pressure and temperature limits were found to be a non-significant risk contributor to core damage frequency and offsite releases. Davis-Besse has reviewed this evaluation, considers it applicable to Davis-Besse Nuclear Power Station, and concurs with the assessment.

Davis-Besse Page 1 of 2 Attachment 1, Volume 12, Rev. 0, Page 425 of 461

Attachment 1, Volume 12, Rev. 0, Page 426 of 461 DISCUSSION OF CHANGES CTS 3/4.7.2, STEAM GENERATOR PRESSURE/TEMPERATURE LIMITATION Since the 10 CFR 50.36(c)(2)(ii) criteria have not been met, the Steam Generator Pressure/Temperature Limitation LCO and associated Surveillances may be relocated out of the Technical Specifications. The Steam Generator Pressure/Temperature Limitation Specification will be relocated to the TRM. The TRM is currently incorporated by reference into the UFSAR, thus any changes to the TRM are made under 10 CFR 50.59, which ensures changes are properly evaluated. This change is designated as a relocation because the LCO did not meet the criteria in 10 CFR 50.36(c)(2)(ii) and has been relocated to the TRM.

REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES None Davis-Besse Page 2 of 2 Attachment 1, Volume 12, Rev. 0, Page 426 of 461

Attachment 1, Volume 12, Rev. 0, Page 427 of 461 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 12, Rev. 0, Page 427 of 461

Attachment 1, Volume 12, Rev. 0, Page 428 of 461 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS CTS 3/4.7.2, STEAM GENERATOR PRESSURE/TEMPERATURE LIMITATION There are no specific NSHC discussions for this Specification.

Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 428 of 461

, Volume 12, Rev. 0, Page 429 of 461 CTS 3/4.7.7, SNUBBERS , Volume 12, Rev. 0, Page 429 of 461

, Volume 12, Rev. 0, Page 430 of 461 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 12, Rev. 0, Page 430 of 461

Attachment 1, Volume 12, Rev. 0, Page 431 of 461 CTS 3/4.7.7 PLANT SYSTEMS 3/4.7.7 SNUBBERS LIMITING CONDITION FOR OPERATION 3.7.7 All safety- elated snubbers shall be OPERABL.

APPLICABILITY: MODE* 1, 2, 3 and 4. (MODES 5 and 6 jor snubbers located on systems required pPERABLE in those MODES).

ACTION:

a. With one or more snubbers inoperable: 1. within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months replace or restore the inoperable snubber(s) to OPERABLE status, or 2. verify system operability with the snubber(s) inoperable by engineering evaluation within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ; or 3. declare the supported subsystem inoperable See ITS Section 3.0 and follow the appropriate ACTION statement for that

.system.

and, fo snubbers which have failed eit er the visual or function al test:

b. Perfo an engineering evaluation withi 90 days to determi e if any safety-related system r component has been a versely affected by the inoperability of the snubbe and if the snubber mode of fai ure has imparted a significant effect or degradation on t e supported compon nt or system.' The provisions f Technical Specif cation 3.0.4 are not applicable for the component or sys em.

SURVEILLANCE REQUIRE _S 4.7.7 Each snubbe 2 shall be demonstrated OPERAB by the requiremen of the following surveillance pursuant t requirements of Specification 4.0.5.

rograms and LA&

4.7.7.1 Visua Inspection Program 1

Engineering evaluat on is not required when a snubb r is removed for surveillance testin provided it is returned to OPE LE status within the requirements of ACTION statement a.

2 Safety-related snub ers are listed in the latest re ision of applicable surveillance test rocedure(s). Snubbers may be ad ed to, or removed from, safety-relat d systems and their assigned grops without a License Amendment.

DAVIS-BESSE, UNIT I 3/4 7-20 Amendment No. V4,11'Y1', 161 Page 1 of 8 Attachment 1, Volume 12, Rev. 0, Page 431 of 461

Attachment 1, Volume 12, Rev. 0, Page 432 of 461 CTS 3/4.7.7 PLANT SYSTEMS SURVEILLANCE REQUIREMENTS Continued)

a. General Rejuirements At least a ce per inspection interval, each roup of snubbers i use in the Plant shall be visually inspected in accorda ce with Specification 4.7.7.1.b nd 4.7.7.1.c.

Visual ins ections may be performed with bi oculars, or other vis al support devices, for those snu bers that are difficult to access and where required to k ep exposure as low as re sonably achievable. Response to ailures shall be in acc rdance with Specification 4.7.7.1.d.

b. Inspecti Interval The insp ction interval may be applied on he basis of snubber roups. The snubber groups may be established based on physical characteristics and acc ssibility.

"Inaccess ble snubbers are defined as thos located: (a) inside contain nt, (b) in high radiation exposu e zones, or (c) in areas w ere accessibility is limited by p ysical constraints such as the need for scaffolding.

Each of the groups may be inspected inde endently according LA01 to the chedule determined by Table 4.7- . The visual inspection interval for each snubber gro p shall be determined based upon the criteria provi ed in Table 4.7-5, and th first inspection interval determ ned using the criter a shall be based upon the previou inspection interval as est blished by the requirements in ef ect before amend-ment 1 1 DAVIS-BESSE, UNIT 3/4 7-21 Ame dment No. 9, 161 (next page is 3/4 7-21a)

Page 2 of 8 Attachment 1, Volume 12, Rev. 0, Page 432 of 461

Attachment 1, Volume 12, Rev. 0, Page 433 of 461 CTS 3/4.7.7 TABLE 4.7-S SiNBBER VISUAL INSPECTION INTERVAL NUMBER OP UNACCEPTABLE SNUBBERS Population Column A Column B Col C or Group Extended terval Repeat Interval Reduced terval (Notes 1 and 2) (Notes 3 d 6) (Notes 4 and 6) (Notes 5 d 6) 0 0 80 0 0 100 0 1 150 0 3 200 2 5 3 300 5 12 400 8 18 36 500 1 24 48 750 2 40 78 1000 or greater 2 56 109 Note 1: The next visu,. inspection interval for a snubber pop lation or group size s I be determined based upon the previo inspection interval and t e number of unacceptable snubbers to d during that interval. Snu bers may be grouped, based upon their accessibility during pover o eration, as accessible or inaccessibl . These categories ma be examined separately or jointly. H vever, the licensee must make and document that decision befor any inspection and shall use that decision as the basis upon vhichh to determine the next inspecti n interval for that group.

Note 2: Interpolatio betveen population or group sizes and the number of unacceptable snubbers is permissible. Use next I er integer for the value of the limit for Columns A, B, or C if that nteger includes a fractional v ue of unacceptable snubbers as dete ned by intarpolatlo Note 3: If the nun r of unacceptable snubbers is equal t or less than the number in lun A, the next inspection interval y be tvice the previous in erval but not greater than 48 months.

Note 4: If the numi r of unacceptable snubbers is equal t et less than the number in lumn B but greater than the number in Column A, the next inspection interval shall be the sane as the pre ious interval.

16 1 DAVIS-BESSE, UNIT 1 3/4 7-21a Am ndment No.

Page 3 of 8 Attachment 1, Volume 12, Rev. 0, Page 433 of 461

Attachment 1, Volume 12, Rev. 0, Page 434 of 461 CTS 3/4.7.7 Note 5: If the number of unacce table snubbers is equal to or gr ter than the number in Column C, th next inspection interval shall e tvo-thirds of the previous interv 1. Hovever, if the number of u ceeptable snubbers is less than he number in Column C but greate than the number in Column B, t next interval shall be reduced roportionally by interpolation, tha is, the previous interval shall be reduced by a factor that is one-th rd of the ratio of the differenc betveen the number of unacceptabl snubbers found during the previ us interval and the number in Column B to the difference in the numbe in Columns B and C.

Note 6: The provisions of S cificatlon 4.0.2 are applicable or all inspection interval up to and including 48 months, ith the exception that inspection of naccessible snubbers may be defe red to the next shutdovn when plan conditions alloy five days for I spection.

LAO01 3/4 7-21b 61 DAVIS-BESSE, UNI 1 (next page is 7-22) Amendment No.1 Page 4 of 8 Attachment 1, Volume 12, Rev. 0, Page 434 of 461

Attachment 1, Volume 12, Rev. 0, Page 435 of 461 CTS 3/4.7.7 PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (C ntinued)

c. Acceptance C iteria A snubber sh 11 be considered OPERABLE as a result of a visual inspe tion if: (1) there are no visi le indica-tions of da age or inoperability, and (2) at achments to the foundat on or supporting structure are s cure.

d. Response to Failures For each s ubber unit which does not meet t e visual inspection acceptance criteria of Specific tion 4.7.7.1.c:

1. Dete ine the snubber OPERABLE by fun tionally testing the snub er in the as-found condition per Specification 4.7. .2, unless the (hydraulic) snub er was determined inop rable because the fluid port wa found uncovered; and

2. Cle 'ly establish and remedy the cau e of the rejection for that particular snubber and for other snubbers that may be generically susceptible; and

3. Cl ssify the snubber as acceptable or the purpose of es ablishing the next visual inspe tion interval.

LAe OR

1. P rform the ACTION specified in 3.7.7a; and

2. erform an engineering evaluation as specified in

.7.7.b; and

3. lassify the snubber as unaccept ble and establish the frequency of group inspection as described in Specification 4.7.7.1.b.

e. Tra sient Event Inspection An nspection shall be performed of 11 hydraulic and mec anical snubbers attached to sec ions of systems that have ex erienced unexpected,, potentially damaging transients as de ermined from a review of operati nal data. A visual in pection of the snubbers on these systems shall be performed wi hin six months following such a event. In addition to s tisfying the visual inspection a ceptance criteria, f eedom-of-motion of mechanical sn bbers shall be verified u ing at least one of the followin : (1) manually induced s ubber movement; or (2) evaluati of in-place snubber iston setting; or (3) stroking t e mechanical snubber through ts full range of travel.

DAVIS-BES SE, U IT 1 3/4 7-22 Amendment No. W,0,I1,161 Page 5 of 8 Attachment 1, Volume 12, Rev. 0, Page 435 of 461

Attachment 1, Volume 12, Rev. 0, Page 436 of 461 CTS 3/4.7.7 PLANT SYSTEMS /

SURVEILLANCE REQUIREMENTS (Cintinued) ~/

- i 4.7.7.2 Functional Test P ouram At least on e per inspection interval a represent tive sample of eich group of snubber in use in the Pla t shall be functio ally tested in accordance with Specifications 4.7.7.2.b nd 4.7.7.2.c. Response to the failur s shall be in acco dance with Specification 4.7.7.2.d.

For all s: ubbers, functional testing shall consist of either beich testing or in-place testing.

b. Inspecti n Interval and Sample Criteria The snub ers may be categorized into groups bas d on physica characteristics and accessibility. E ch group may be ested independently from the standpoin of performing additional tests if failures are di covered.

LAS DAVIS-BESSE Unit 1 3/4 7-22a Ame dment No. ;;.;,/M 1161 (Next page is 3/4 7-23)

Page 6 of 8 Attachment 1, Volume 12, Rev. 0, Page 436 of 461

Attachment 1, Volume 12, Rev. 0, Page 437 of 461 CTS 3/4.7.7 PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Cnt nued)

The inspection nterval for functional testing shal be each REFUELING INTER AL. I Snubbers which are scheduled for removal for seal maintenance m be included in the test sample pri r to any maintenan e on the snubber.

The represen ative sample shall consist of at lea t 10 percent (rou ded off to next highest integer) of ach group of snn bers in use in the Plant. The sele tion process sha 1 ensure that all snubbers, regardle s of their acces ibility classification, are functio ally tested at least once every ten inspection inter als.

c. Acceptanc Criteria For hydra lic snubbers (either inplace testing or bench testing) the test shall verify that:

1. Sn bber piston will allow the hydraulic fluid to "b pass" from one side of the piston to the other to a sure unrestrained action is achieved ithin the secified range of velocity or accelTer ion in both LA01 nsion and compression.

2. hen the snubber is subjected to a mo ement which creates a load condition that exceeds the specified range of velocity or acceleration, th hydraulic fluid is trapped in one end of the s ubber causing suppression of that movement.

3. Snubber release rate or bleed rate, here required, occurs in compression and tension.

F r mechanical snubber in place and benc. testing, the

t. st shall verify that:

The force that initiates free mov ment of the snubber rod in either tension or compress on is less than the specified maximum drag force.

2. Activation (restraining action) s achieved in both tension and compression within t e specified range.

DAVIS-BESS , UNIT 1 3/4 7-23 endment No. 53,94,111, 217 Page 7 of 8 Attachment 1, Volume 12, Rev. 0, Page 437 of 461

Attachment 1, Volume 12, Rev. 0, Page 438 of 461 CTS 3/4.7.7 PLANT SYSTEMS SURVE]LLANCE REQUIREMENTS (Con/inued)

d. Res onse to Fa lures For each inop rable snubber per Specification 4.7.7.2.c:

1. Perform the ACTIONS specified in 3.7.7a and 3 7.7b; and

2. Within the specified inspection interval, f ctionally test a additional sample of at least 10 per cent of the s ubber units from the group that the in perable snubb r unit is in.

The u-actional testing of an additional sam le of at leas 10 percent from the inoperable snubb r's group is equired for each snubber unit determin d to be ino erable in subsequent functional tests, or until al snubbers in that group have been test d; and

3. T e cause of snubber failure will be eval ated and, i caused by a manufacturing or design d ficiency, a 1 snubbers of the same or similar desi n subject to he same defect shall be functionally te ted within 0 days from determining snubber inoper ility. This testing requirement shall be independen of the requirements in 4.7.7.2.d(2) above.

DAVIS-BE SE, UNIT 1 3/4 7-24 endment No. 1b,94 Tables 3.7-3 and 4.7-4 eleted. Next Page is 3/4 7-36).

Page 8 of 8 Attachment 1, Volume 12, Rev. 0, Page 438 of 461

Attachment 1, Volume 12, Rev. 0, Page 439 of 461 DISCUSSION OF CHANGES CTS 3/4.7.7, SNUBBERS ADMINISTRATIVE CHANGES None MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 4 - Removal of LCO, SR, or other TS requirement to the TRM, UFSAR, ODCM, QAPM, IST Program,or liP) CTS 3.7.7 provides the requirements for all safety-related snubbers. This specification with the exception of CTS 3.7.7 Action a is not included in the ITS. This changes the CTS by moving the explicit snubber requirements from the Technical Specifications to the Technical Requirements Manual (TRM).

The removal of these details from the Technical Specification is acceptable because this type of information is not necessary to provide adequate protection of public health and safety. The purpose of CTS 3.7.7 Action a is to ensure that the structural integrity of the reactor coolant system and all other safety related systems is maintained during and following a seismic or other event initiating dynamic loads. This change is acceptable because the LCO requirements continue to ensure that the structures, systems, and components are maintained consistent with the safety analyses and licensing basis. The requirement to perform snubber inspections is specified in 10 CFR 50.55a and the requirement to perform snubber inspections and testing is specified in ASME Section XI, as modified by approved relief requests. Therefore, both Davis-Besse commitments and NRC Regulations or generic guidance will contain the necessary programmatic requirements for the inspection and testing of safety related snubbers without repeating them in the ITS. Also, this change is acceptable because the removed information will be adequately controlled in the TRM. The TRM is currently incorporated by reference into the UFSAR, thus any changes to the TRM are made under 10 CFR 50.59, which ensures changes are properly evaluated. This change is designated as a less restrictive removal of detail change because a requirement is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES None Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 439 of 461

Attachment 1, Volume 12, Rev. 0, Page 440 of 461 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 12, Rev. 0, Page 440 of 461

Attachment 1, Volume 12, Rev. 0, Page 441 of 461 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS CTS 314.7.7, SNUBBERS There are no specific NSHC discussions for this Specification.

Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 441 of 461

Attachment 1, Volume 12, Rev. 0, Page 442 of 461 CTS 3/4.7.8, SEALED SOURCE CONTAMINATION Attachment 1, Volume 12, Rev. 0, Page 442 of 461

, Volume 12, Rev. 0, Page 443 of 461 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 12, Rev. 0, Page 443 of 461

Attachment 1, Volume 12, Rev. 0, Page 444 of 461 CTS 3/4.7.8 3/4.7.8B SEALED SOURCE CONTAMIN ION LIMITING CONDITION FOR OPERATIJN/

3.7.8.1 Each sealed source c ntaining radioactive material either in excess of 100 microcuries of eta and/or gamma emitting mater~al or 5 microcuries of alpha emittin material shall be free of > 0.0 5 microcuries of removable contamination.

APPLICABILITY: At all time ACT~ION:

a. Each sealed sour e with removable contamination i excess of the above limit sha I be immediately withdrawn from e and:

1. Either dec ntaminated and repaired, or

2. Disposed f in accordance with Commission egulations.

b. The provision of Specifications 3.0.3 and 3.0. are not applicable.

S URVEIL.LANCE REQIRE " t 4.7.8.1.1 Test Requirements -Each sealed source shal be* tested for leakage and/or conta ination by:

a. The licen ee, or

b. Other pe sons specifically authorized by th Commission or an Agreemen State.

The test method s all have a detection sensitivity o at least 0.005 microcuries per t st sample.

4.7.8.1.2 Test requencies - Each category of seal d sources shall be tested at the fr quency described below.

a. Sourc s in use (excludina startup source and fission oeprsi detectors previbusly subjected to core flux)-Ates mont s for all sealed source's containin radioactive material:

DAVIS-BESSE, IT 1 3/4 7-36 Amendment No. 94 (Tables 3.7-3 and 4.7-4 deleted.

Previous page is 3/4 7 24.)

Page 1 of 2 Attachment 1, Volume 12, Rev. 0, Page 444 of 461

, Volume 12, Rev. 0, Page 445 of 461 CTS 3/4.7.8 PUN.T SYSTEMS "/

SUbVLLANCE REQUIREMENTS (C ntinued)

1. With a half- ife greater than 30 days (excluding ydrogen

3) andd

2. In any foru other than gas.

b. Stored sources ot in use - Each sealed source and fi sion detector shall e tested prior to use or transfer to nother licensee unles tested within the previous six month . Sealed sources and fi sion detectors transferred without a ertificate placed into the indicating u e./last test date shall be tested prior o being

c. Startup sourc s and fission detectors - Each sealed startup source and fssion detector shall be tested within 1 days prior to bei g subjected to core flux or installed *n the core and followin repair or maintenance to the source.

4.7.8.1.3 Reports - report shall be prepared and submitte to the Commission on an annu I basis if sealed source or fission de ector leakage tests reveal he presence of > 0.005 microcuries of removable contamination._

DAVIS-BESSE UNIT 1 3/4. 7-37 Page 2 of 2 , Volume 12, Rev. 0, Page 445 of 461

Attachment 1, Volume 12, Rev. 0, Page 446 of 461 DISCUSSION OF CHANGES CTS 3/4.7.8, SEALED SOURCE CONTAMINATION ADMINISTRATIVE CHANGES None MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS R01 CTS 3.7.8.1 states that each sealed source containing radioactive material either in excess of 100 microcuries of beta and/or gamma emitting material or 5 microcuries of alpha emitting material shall be free of > 0.005 microcuries of removable contamination. The limitations on sealed source contamination are intended to ensure that the total body and individual organ irradiation doses do not exceed allowable limits in the event of ingestion or inhalation. This is done by imposing a maximum limitation of < 0.005 microcuries of removable contamination on each sealed source. This requirement and the associated surveillance requirements bear no relation to the conditions or limitations that are necessary to ensure safe reactor operation. This specification does not meet the criteria for retention in the ITS; therefore, it is not included in the ITS. This changes the CTS by relocating the Specification to the Technical Requirements Manual (TRM).

This change is acceptable because CTS 3.7.8.1 does not meet the 10 CFR 50.36(c)(2)(ii) criteria for inclusion into the ITS.

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

1. Sealed source contamination is not used for, nor capable of, detecting a significant abnormal degradation of the reactor coolant pressure boundary prior to a design basis accident (DBA).

2. Sealed source contamination is not a process variable, design feature, or operating restriction that is an initial condition of a DBA or transient.

3. Sealed source contamination is not part of a primary success path in the mitigation of a DBA or transient.

4. As discussed in B&W Owners Group Technical Report 47-1170689-00 (Appendix A pages A-77 and A-78), sealed source contamination was found to be non-significant risk contributor to core damage frequency and offsite releases. Davis-Besse has reviewed this evaluation, considers it applicable to Davis-Besse Nuclear Power Station, and concurs with the assessment.

Since the 10 CFR 50.36(c)(2)(ii) criteria have not been met, the Sealed Source Contamination LCO and associated Surveillance may be relocated out of the Technical Specifications. The Sealed Source Contamination Specification will be Davis-Besse Page 1 of 2 Attachment 1, Volume 12, Rev. 0, Page 446 of 461

Attachment 1, Volume 12, Rev. 0, Page 447 of 461 DISCUSSION OF CHANGES CTS 3/4.7.8, SEALED SOURCE CONTAMINATION relocated to the TRM. The TRM is currently incorporated by reference into the UFSAR, thus any changes to the TRM are made under 10 CFR 50.59, which ensures changes are properly evaluated. This change is designated as relocation because the LCO did not meet the criteria in 10 CFR 50.36(c)(2)(ii) and has been relocated to the TRM.

REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES None Davis-Besse Page 2 of 2 Attachment 1, Volume 12, Rev. 0, Page 447 of 461

Attachment 1, Volume 12, Rev. 0, Page 448 of 461 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 12, Rev. 0, Page 448 of 461

Attachment 1, Volume 12, Rev. 0, Page 449 of 461 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS CTS 3/4.7.8, SEALED SOURCE CONTAINMENT There'are no specific NSHC discussions for this Specification.

Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 449 of 461

Attachment 1, Volume 12, Rev. 0, Page 450 of 461 ATTACHMENT 20 Improved Standard Technical Specifications (ISTS) not adopted in the Davis-Besse ITS Attachment 1, Volume 12, Rev. 0, Page 450 of 461

, Volume 12, Rev. 0, Page 451 of 461 ISTS 3.7.4, ATMOSPHERIC VENT VALVES , Volume 12, Rev. 0, Page 451 of 461

Attachment 1, Volume 12, Rev. 0, Page 452 of 461 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 12, Rev. 0, Page 452 of 461

Attachment 1, Volume 12, Rev. 0, Page 453 of 461 AWs 3.7.4 3.7 PLANT SYSTEMS 3.7.4 Atmospheric Vent Valves (AWs)

LCO 3.7.4 [Two] AWs [lines per stea nerator] shall be OPERABLE.

APPLICABILITY: M 1, 2, and 3, ODE 4 when steam generator is relied upon for heat removal.

CONS CONDITION REQUIRED ACTION ICOMPLET TIME A. One required AVV [line] A.1 Restore required AW [line] [7 d-a inoperable, to OPERABLE status.

B. [ Two or more required B.1 Restore all one AW 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months s]

AVV [lines] inoperable. [lineJ PERABLE status.

__0 C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Co ion Time not . AND C.2 Be in MODE 4 without [24] hours reliance upon steam generator for heat removal.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SBR 3.7.4.1 Verify oneRvcom.pl of each A . [18] months BMVG STS 3.7.4-1 Rev. 3.0, 03131/04 Attachment 1, Volume 12, Rev. 0, Page 453 of 461

Attachment 1, Volume 12, Rev. 0, Page 454 of 461 AWs 3.7.4 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.7.4.2 [ Verify one complete cycleof AVV block18]

valve.

BWOG STS 3.7.4-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 454 of 461

Attachment 1, Volume 12, Rev. 0, Page 455 of 461 JUSTIFICATION FOR DEVIATIONS ISTS 3.7.4, ATMOSPHERIC VENT VALVES (AWs)

1. ISTS 3.7.4, "Atmospheric Vent Valves (AVVs)" is not being adopted because Davis-Besse does not credit the AVVs in the accident analysis. ISTS 3.7.4 Bases Background Section states that the Atmospheric Vent Valves (AVVs) provide a method for cooling the unit to decay heat removal (DHR) entry conditions, should the preferred heat sink via the Turbine Bypass System to the condenser not be available. ISTS 3.7.4 Bases Applicable Safety Analyses Section further states that the AVVs are assumed to be used by the operator to cool down the unit to MODE 3 for accidents accompanied by a loss of offsite power. At Davis-Besse, the AVVs are not credited in the accident analysis. Steaming the non-faulted steam generator to the main condenser and the Main Steam Safety Valves are credited with this function. Therefore, it is not necessary to include the AVVs.

Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 455 of 461

Attachment 1, Volume 12, Rev. 0, Page 456 of 461 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 12, Rev. 0, Page 456 of 461

Attachment 1, Volume 12, Rev. 0, Page 457 of 461 AWs B 3.7.4 B 3.7 PLANT SYSTEMS B 3.7.4 Atmospheric Vent Valves (AWs)

BASES BACKGROUND The AWs provi amthod for cooling the unit to decay heat removal (DNR) et.r;ý onditiaon~sshould the preferred heat sink via the Turbine B *system

-- to the condenser not be available, as discussed in the SAR, Section [10.3] (Ref. 1). This is done in conjunction with the Emergency Feedwater System, providing cooling water from the condensate storage tank (CST). The AWs may also be required to meet the design cooldown rate during a normal cooldown when steam pressure drops too low for maintenance of a vacuum in the condenser to permit use of the Turbine Bypass System.

[The AVVs are provided with upstream block valves to permit t eing tested at power, and to provide an alternate means of is *on.]

The AWs are equipped with pneumatic con ers to permit control of the cooldown rate.

[The AVVs are providedi a pressurized gas supply of bottled nitrogen that, on loss of pre e in the normal instrument air supply, automatically supplies nitr to operate the AVVs. The nitrogen supply is sized to provid cient pressurized gas to operate the AVVs for the time ired for Reactor Coolant System (RCS) cooldown to DHR entry conditions. )

A description of the AWs is found in Reference 1.

APPLICABLE The design basis of the AVVs is established by the capability to cool the SAFETY unit to MODE 3. The design rate of [75]°F per hour is applicable for both ANALYSES steam generators, each with one AW. This rate is adequate to cool unit to DHR entry conditions with only one AVV and one stea erator utilizing the cooling water supply available in the CST.

In the accident analysis presented in Refere 1, the AVVs are assumed to be used by the operator to cool do unit to MODE 3 for accidents accompanied by a loss of offsit wer. Prior to operator actions to cool down the unit, the AWs e main steam safety valves (MSSVs) are assumed to operat omatically to relieve steam and maintain the BWOG STS B 3.7.4-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 457 of 461

Attachment 1, Volume 12, Rev. 0, Page 458 of 461 A\Ns B 3.7.4 BASES APPLICABLE SAFETY ANALYSES (continued) steam generator's pressure and ter ature below the design value.

This is about 30 minutes fol1o .initiation of an event; however, this may be less for a stea herator tube rupture (SGTR) event. Some initiating events .g into this category are a main steam line break upstream o main steam isolation valves, a feedwater line break, and anSn S event (although the AWs on the affected steam generator may

. be available following an SGTR event).

For the recovery from an SGTR event, the operator is also required to perform a limited cooldown to establish adequate subcooling as a necessary step to terminate the primary to secondary break flow into the ruptured steam generator. The time required to terminate the primary to secondary break flow for an SGTR is more critical than the time require to cool down to DHR conditions for this event, and also for other accidents. Thus, the SGTR is the limiting event for the AV lhe number of AWs required to be OPERABLE to satise SGTR accident analysis requirements depends upon the cons ation of any single failure assumptions regarding the failur one AW to open on demand.

[The design must accommo the single failure of one AW to open on demand, thus eachs AWs are equi generator must have at least one AVV. The with manual block valves in the event an AW

-_0 spuriou ils open, or fails to close during use.]

he AVVs satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO [Two] AVVs [lines per steam generator] are required to be OPERABLE.

Failure to meet the LCO can result in the inability to cool the unit to DHR entry conditions following an event in which the condenser is unavailable for use with the Steam Bypass System.

An AW is considered OPERABLE when it is capable of providin controlled relief of the main steam flow, and is capable off opening and closing on demand.

APPLICABILITY In MODES 1, 2, and 3, and in MODE 4 en steam generator is being relied upon for heat removal, t1h s are required to be OPERABLE.

In MODES 5 and 6, GTR is not a credible event.

BWOG STS B 3.7.4-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 458 of 461

Attachment 1, Volume 12, Rev. 0, Page 459 of 461 AV~s B 3.7.4 BASES ACTIONS A.1 With one AW [line] inoperable, acti ust be taken to restore the inoperable AW to OPERAB atus. The 7 day Completion Time allows for redundant ca i ity afforded by the remaining OPERABLE AW and a nons grade backup in the Steam Bypass System and MSSVs.

[1B.1 With more than one AW [line] inoperable, action must be taken to res tore U..

Lail LIJULoU!tj MVV LlUnesJ Lu kr"r'MADLI- bLGdLUS. PS LIt UIUWe VbdlVc Lve-can Ue closed to isolate an AW, some repairs may be possible with the unit at power. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is reasonable to repair inoperab AW [lines], based on the availability of the Steam Bypass Syste.9.nd MSSVs, and the low probability of an event occurring du is period that would require the AW [lines]. ]

C.1 and C.2 If the AVV [lines] ca fe restored to OPERABLE status within the associated Co etion Time, the unit must be placed in a MODE in which -- 0 the LCO es not apply. To achieve this status, the unit must be placed east MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in MODE 4 within [24] hours, without reliance upon the steam generator for heat removal- The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

IIiIHPV/II IA r" ('P q7A1 REQUIREMENTS To perform a controlled cooldown of the RCS, the AVVs must b e to be opened either remotely or locally and throttled through r full range.

This SR ensures that the AWs are tested through control cycle at least once per fuel cycle. Performance of ins ice testing or use of an AW during a unit cooldown may satis s requirement. Operating experience has shown that these ponents usually pass the Surveillance when perfor t the [18] month Frequency. Therefore, the Frequency is a able from a reliability standpoint.

BWOG STS B 3.7.4-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 459 of 461

Attachment 1, Volume 12, Rev. 0, Page 460 of 461 AWs B 3.7.4 BASES SUR\ fEILLANCE REQUIREMENTS (continued)

[SR 3.7.4.2 The function of the blo a ye is to isolate a failed open AVV. Cycling the block valve c d and open demonstrates its ability to perform this function. Pormance of inservice testing or use of the block valve dun nit cooldown may satisfy this requirement. Operating experience s shown that these components usually pass the Surveillance when performed at the [18] month Frequency. Therefore, the Frequency is acceptable from a reliability standpoint. ]

REFERENCES 1. FSAR, Section [10.3].

--0 BVVDG STS B 3.7.4-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 460 of 461

Attachment 1, Volume 12, Rev. 0, Page 461 of 461 JUSTIFICATION FOR DEVIATIONS ISTS 3.7.4 BASES, ATMOSPHERIC VENT VALVES (AWs)

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

Davis-Besse Page 1 of 1

Attachment 1, Volume 12, Rev. 0, Page 461 of 461

ML072200477

Text

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