Text

Improved Technical Specification Conversion License Amendment Request, Volume 12, Revision 1, ITS Section 3.7, Plant Systems
	ML082270669
Person / Time
Site:	Davis Besse
Issue date:	08/07/2008
From:	; FirstEnergy Nuclear Operating Co
To:	; Office of Nuclear Reactor Regulation
References
	L-08-240, TAC MD6398
	Download: ML082270669 (463)
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{{#Wiki_filter:DAVIS-BESSE NUCLEAR POWER STATION UNIT 1 IMPROVED TECHNICAL SPECIFICATION CONVERSION LICENSE AMENDMENT REQUEST\.VOLUME 12 (Rev. 1)SECTION 3.7 -PLANT SYSTEMS Attachment 1, Volume 12, Rev. 1, Page i ofi Summary of Changes ITS Section 3.7 Change Description Affected Pages The changes described in the Davis-Besse Pages 98, 109, 123, 124, 126, 140, and 141 response to Question 200801101049 (in Section 3.3) have been made. The AFW SG Level Control System Surveillances have been added back into the ITS.The intent of the changes described in the Davis- Pages 307, 313, 314, 322, 323, and 324 Besse response to Question 200801161420 (in Section 3.3) have been made (in addition, the first ,paragraph, last sentence of DOC L02 was changed similar to the previous sentence). Changed the A plicability from During movement of irradiated fuel assemblies in the "spent fuel pool" to During movement of irradiated fuel assemblies in the spent fuel pool "building" (instead of "area negative pressure boundary," as shown in the draft markup).This clarifies that the Applicability applies during conditions that could result in a fuel handling accident outside containment, and also aligns with the Applicability of ISTS 3.7.13.The changes described in the Davis-Besse Page 308 response to Question 200801161532 (in Section 3.3) added back into the ITS the Decay Time Specification (ITS 3.9.3) and deleted the Containment Penetrations Specification (CTS 3/4.9.4). ITS 3.7.13 DOC L03 referenced these two Specifications. Therefore, the DOC has been changed to reflect the 200801161532 changes.The changes described in the Davis-Besse Page 372 response to Question 200710090904 (in Section 4.0) have been made. Editorial changes to the NOTE for Figure 3.7.16-1 have been made.Page 1 of 1 Attachment 1, Volume 12, Rev. 1, Page i of i Attachment 1, Volume 12, Rev. 1, Page 1 of 461 ATTACHMENT 1 VOLUME 12 DAVIS-BESSE IMPROVED TECHNICAL SPECIFICATIONS CONVERSION ITS SECTION 3.7 PLANT SYSTEMS Revision 1 Attachment 1, Volume 12, Rev. 1, Page 1 of 461 Attachment 1, Volume 12, Rev. 1, Page 2 of 461 0 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 0 Attachment 1, Volume 12, Rev. 1, Page 2 of 461 Attachment 1, Volume 12, Rev. 1, Page 3 of 461ATTACHMENT I ITS 3.7.1, MAIN STEAM SAFETY VALVES (MSSVs)0 0 Attachment 1, Volume 12, Rev. 1, Page 3 of 461 Attachment 1, Volume 12, Rev. 1, Page 4 of 461 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)Attachment 1, Volume 12, Rev. 1, Page 4 of 461 Attachment 1, Volume 12, Rev. 1, Page 5 of 461 ITS 3.7.1 ITS R4.7 PLANT SYSTEMS 314.7.1 TURBINE CYCLE SAFETY VALVES LIMITING CONDITION FOR OPERATION 3.7.1.) All main steam line code safety valves shall be OPERABLE.LCO 3.7.1 APPLICABILITY:

ACTION: MODES 1, 2 and 3.{Add proposed ACTIONS Note A0 With one c 1. '(ACTION A ACTION B Table 3.7.1-1 ACTION B r more main steam line code safety valves inoperable, pration ih MODESI1, 2 And 3. may proceedd provided that, within I. the inoperable valve is. ored to OPERABLE status, or-a) the High Flux"Trip Setpoint is reduced per Equation AddpropedRequiredonA.1 ___3.7-1 beloW, and b) [there are a minimum of two OPERABLE safety valves per Mot steam generator, at least one with a setpoint not ,greater than,1050 psig 1 , and c Fno OPERABLE safety valve has a setpoint greater than 1100 psig; t( 1%otherwise b. be in at least HOT STANDBY within the next 6 hours and in HOT SHIITflflWN .within fnllnwinn 12 hours.1c. The provisions of Spe cifý 3.0.4 are not applicae.Equation 3.7-1: SP = x.W where, Equation.3.7.1-1 SR 3.7.1.1 SP = Reduced High Flux TripSetpoint (Not to exceed W)W -High Flux Trip Setpoint for four pump operation as specified 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 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.4 Add proposed Table 3.7.1-1 IL 0j!The lift setting pressure shall corresp lto ambient conditions of the valve nominal operating temperature a ressure.DAVIS-BESSE, UNIT'1 3/4 7-1 Amendment No. Zl7,ljf,153 0 Page 1 of 1 Attachment 1, Volume 12, Rev. 1, Page 5 of 461 Attachment 1, Volume 12, Rev. 1, Page 6 of 461 DISCUSSION OF CHANGES ITS 3.7.1, MAIN STEAM SAFETY VALVES (MSSVs)0 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 hours 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 hours.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 0 Davis-Besse Page 1 of 4 " Attachment 1, Volume 12, Rev. 1, Page 6 of 461 Attachment 1, Volume 12, Rev. 1, 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 I 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 0 Davis-Besse Page 2 of 4 Attachment 1, Volume 12, Rev. 1, Page 7 of 461 Attachment 1, Volume 12, Rev. 1, 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.0 RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 3 -Removing Procedural Details 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. 1, Page 8 of 461 Attachment 1, Volume 12, Rev. 1, 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 details for meeting Technical Specification requirements are being moved from the Technical Specifications to the ITS Bases.LESS RESTRICTIVE CHANGES L01 (Category 3- 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 hours, 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 hours. 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 hours to 36 hours. 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 hours 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 hours.Thus operation of the unit at RATED THERMAL POWER with inoperable MSSVs is still only allowed for 4 hours, 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.0 Davis-Besse Page 4 of 4 Attachment 1, Volume 12, Rev. 1, Page 9 of 461 Attachment 1, Volume 12, Rev. 1, Page 10 of 461 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)Attachment 1, Volume 12, Rev. 1, Page 10 of 461 Attachment 1, Volume 12, Rev. 1, Page 11 of 461 CTS 0 MSSVs;3.7 PLANT SYSTEMS 3.7.1 Main Steam Safety ValVes (MSSVs)LCO 3.7.1 317.1.1 The MSsVs shall be OPERABLE as specified in"Table:3..1i-1i:ad Figue 3,7.-1-, 0 APPLICABILITY:. MODES 1, 2, and 3.ACTIONS'...------------------

* -NOTE-------

DOC A02 Separate Conditiion enty :is. allowed for.each MSSV.CONDITION REQUIRED ACTION -COMPLETION TIME_ _ _ _ _.. .....__ _ _ _ _ _ _Action a 0 A. One or morer MSSVs, inoperable.

A.1 Reduce power to less than the reduced power re uirement.-of Fl ure 37.1-1.Equtio A.2 U[High Flux Reduce the u epr love owertrip setpoint in accordance' with Be in MODE 3.Be in MODE 4.4, hours 36 hours 12 hours 0 0 0 0 0 Action a.2.b, B. RequiredAction and Action b associated Complet SfCdition m.A o Int"met.OR B.1 AND B&2 One or more steam generators vith less.than ":c MSSVs OPERABLE.0 OR One or more steam generators with no MSSVs with a lift setting of 1050 psig +/- 3% OPERABLE.BVWOG STS------------------------------... -~-3.7.1-1 Rev. 3,0j 03131104 0 Attachment 1, Volume 12, Rev. 1, Page 11 of 461 Attachment 1, Volume 12, Rev. 1, 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 tobe perforrned in' MODES 1 and 2.Verify eachh MSSV lift setpo.int per In accordance Tablei3.7.1

in accordance with the Inservice with the Inservice Testing-Program.

Following testing, lift settings Testing Programr shall be within +/- 1%.0 S BVVOG STS 3.7.1-2 Rev: 3.0, 03131104 0 Attachment 1, Volume 12, Rev. 1, Page 12 of 461 Attachment 1, Volume 12, Rev. 1, 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 FOF VALVES NUM8 ER LIFT SETTING (pi9~~k 00 r2mMSSVs/steam generator 7MSSVsIsteam generator: 0 10O 0 0 BWOG STS 3.7.1-3 Rev. 3.0, 03131104 0 Attachment 1, Volume 12, Rev. 1, Page 13 of 461 Attachment 1, Volume 12', Rev. 1, Page 14 of 461 CTS 0 MSSVs 3.7.1 Equation 3.7-1 WY = SP~ PP = V i 1OflW,~~.,Reactor Protection System (RPS)High Flux Z Instrumentation." W INucle vepowe trip setpoint for four pump operation as specified in LCO 3.3.1 Y = Total OPERABLE MSSV relieving capacity per steam generator based on summation of individual OPERABLE MSSV relief capacities per steam generatorIb/hourl 0 Z = Required relieving capacity per steam generator of T6,585,6004 lb/hour.SP = rverowertrp setpoint (not to exceed W).RP = Reduced power requirement (not to exceed RTP).These equations qre graphically represenfed below.Operation is restri ted to the area below ýnd to the right of line CDE.0 iDW -." ,-1 I , " 0,80W -UNACCEVI'AIBt I eI FOR ILLUSTRATION ONQ E e-t.00?$W I 0 u3.7.1-1 (page 1 of 1)Reduced Power andl Nuclee-OveowerpTrp Setpoint versus OPERABLE Main Steam Safety Valves o0 BWOG STS 3.7.1-4 Rev. 3.0, 03/31/04 0 Attachment 1, Volume 12, Rev. 1, Page 14 of 461 Attachment 1, Volume 12, Rev. 1, 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.0 Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 1, Page 15 of 461 Attachment 1, Volume 12, Rev. 1, Page 16 of 461 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)0 0 Attachment 1, Volume 12, Rev. 1, Page 16 of 461 Attachment 1, Volume 12, Rev. 1, Page 17 of 461 0 MSSVs B 3.7.1 Bi 3.0LANT :SYSTEMS B3:3.7.1 :Main Steam Safety Valves (MSS~vs)BASES BACKGROUND The primary purpose. of the MSSVs is to provide overpressure protection for thelsecondary system. The MSSVs also provide protection against overpressurizing the reactor coolant pressure boundary (RCPB) by providing a heat sinkfor 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 10. Cu)ii.4 SAR, Sectiorn (Ref, .1), The MSSV rated capacitypas es t( )C)u seam owa TP with the valves full oper). This meets the (D is 14.175E6 lb/hr, which requirements of the ASME Code, Section III (Ref. 2). The MSSV design is approximately 115% y/pof the total secondary I inclu elstagered setpoints, according to Table 3.7.1-1 [n 1(3 (system design flow. accom nying LCOs5 hat only the neded umber of valve Dwi actu 0e. Staggered s tpoints reduce e potential for valve \ ID begeuse ofinsufficint steam press Feto fully open all valv s following a t ine reactor tri : 0 APPLICABLE SAFETY ANALYSES The designbasis of the MSSVs comes from Reference 2 and its purpose is to limit.secondary syster'n'pressure to 5 110% of design pressure when passing 100% of design steam flow. This design basis is sufficientto 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 SRCS pressure, are those characterized as decreased heat removal Sevents, and are presented in the4FSAR, SectionM150 (Ref. 3). Of these, the full power turbine trip coincident with a loss of condenser heat sink is 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[] capacity is utilized in theIFSAR for mitigation of the following events: a. Loss of main feedwaterýM b $team line breal', c. Steam generator tube ruptur~gd d. Excessive heat removal due to feedwater system malfunction[]=`Z FThe MSSVs satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii). le. Small break loss of coolant accident.00 (0 0}BWOG STS B 3.7.1-1 Rev. 3.1, 12/01/05 0 Attachment 1, Volume 12, Rev. 1, Page.17 of 461 Attachment 1, Volume 12, Rev. 1, Page 18 of 461 0 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 ASM E Code following DBAs~initiated at full power. Operation with less than a full complemental MSSVs requires limitations on unit THERMALýPOVWER and adjustmentof 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 ea panyg n .The OPERABILITYof the MSSVs is defined as the ability to open within the setpoint tolerances, relievelsteam generator overpressure, and reseat when pressure has been:reduced. The OPERABILITY of the MSSVs is determined by periodic surveillance testing in accordancewith the Inservice Testing Program.The lift settings, according to Table 3.7,1-1 in the aggel-panying LCO, correspond'to ambient conditions of thevalve at nominal operating temperature andpressure:. 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.0 0 0 APPLICABILITY In MODE 1 ove [181% RTP, th number of MSSVs r steam generator required~t e OPERABLE mu be~within the accept ble region, accordi to Figure 3.7.1-1 in/e accompanying L .Below [18]% RTP in MO ES 1, 2, and,3, only MSSVs are requir d OPERABLE per ste generator.,In MODES 4 and 5, there is no credible transient requiring the MSSVs. ".[INSERT,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 3.7.1i-2 Rev. 3,1, 12101/05 0 Attachment 1, Volume 12, Rev. 1, Page 18 of 461 Attachment 1, Volume 12, Rev. 1, Page 19 of 461 B 3.7.1 0 (Q 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%.0 0 Insert Page B 3.7.1-2 Attachment 1, Volume 12, Rev. 1, Page 19 of 461 Attachment 1, Volume 12, Rev. 1, Page 20 of 461 0 MSSVs B 3.71 BASES ACTIONS (continued). A.1 and A.2 An alternative to restoring the inoperable MSSV(s) to OPERABLE status is toreduce power so that the available MSSV relieving capacity meets ASME quirements forthe power level. Operation ma continue, provided the IALL WABLE THERMAL POWER and RPS nu lear High Flux ieveowe trip, setpointare reduced by the application of the following K K formulas: RP=M1YI7Zx 100%and 0 0 SP =MY ap W where: HihFu Instrumentation W = lNucleoVeroweytrip setpoint for four pump operation as I specifiled-ir L O 3.3.1, "Reactor Protection System (RPS) j 0 0ýY = Total OPERABLE MSSV relieving capacity persteam generator based on a summation of individual OPERABLE MSSV relief capacitiesper steam generatorlb/houk 00 Z = Required relieving;capacity per steam-generator of 15,585,60Cjlb/hour, 17)00 RP = .Reduced power requirement (not to exceed RTP)and SP = Nude overpwertrip setpoint (not to exceed.".' provided in Equation These equations are lgraphicall esented in Fiqure 3-7.1-1it F LCQ. I Operation is ri'stricted to the area I~low and to the The operator should limit.the maximum steady state power level to some value slightly below this setpoint to avoid an inadvertent trip. _The 4 hour Completion Time for Required Action A.1 is a reasonable time period to reduce power level and is based on the low probability of an event occurring during this period that would require activation of the MSSVs. An additional 32 hours is allowed.in Required Action A.2 to 0 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 845,759 lb/hr. I BVNOG STS B 3.7.1-3 Rev. 31, 12/01105 0 Attachment 1, Volume 12, Rev. 1, Page 20 of 461 Attachment 1, Volume 12, Rev. 1, Page 21 of 461 0 MSSVs B 3.7.1 BASES ACTIONS (continued): High Flux trip reduce the setpoinhts. The Completion Time of 36-hours for Required Action A.2"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 p rotective function, and ýon the low probability of ohe.occurrence of a transientthat Could result~in steam generator overpressure during this period;B.1 and B.2 With one or re MSSVs inopera e,; a verification b administrative means that a east [two] required SSVs, per stea generator are0 OPERABLE, ith eachvalve,fro a differentlift se range, is performed. INSERT 2 If the MSSVd cannot be restored j,"OPERABLE status in th jassociated 0 ICompletioii Timr, the unit must be placed in a MODE in which the LCO.does not~apply, To achieve this status'.the unit must be placed in at least MODE 3 within 6 hours, and, in MODE 4 within 12 hours. The'allowed ..Completion Times are reasonable, based on operating experience,.to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.SURVEILLANCE SR 3.7.1.1 REQUIREMENTS This SR verifies the OPERABILITY of the MSSVs by the verification of each MSSV liftsetpoint in accordance withthe Inservice Testing Program. The

e vae4 test be performed in accordance with 09AASME OM,54M (Ref. -ae! to According to Reference , following tests are required for MSSVs: a. Visual examinatio

b. Seat tightness determinatio

c. Setpoint pressure determination (lift setting)0*d. Compliance with owners seattightness criteria and e. Verification of the balancing device integrityE on balanced valves.BWOG STS B 3.7.1-4 Rev. 3.1, 12/01/05 0 Attachment 1, Volume 12, Rev. 1, Page 21 of 461 Attachment 1, Volume 12, Rev. 1, Page 22 of 461 B 3.7.1 0 0 INSERT 2 If any Required Action and associated Completion Time of Condition A is not met, if one 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%0 Insert Page B 3.7.1-4 Attachment 1, Volume 12, Rev. 1, Page 22 of 461 Attachment 1, Volume 12, Rev. 1, Page 23 of 461 MSSVs B 31.1, BASES SURVEILLANCE REQUIREMENTS (continued)

I from each valve g-ou/rTheeSMEte testing of all valves every 5 years, Y with a minimum of 20% ofthevalvestestedaevery24 months.Reference fprovides the activitie§/and frequencies to satisfy\the reguir rments. Table 3.7.1-1 allows a :1: tolerance for OPERABILITY; howeverthe valves:'are reset to +/- 1% during:the Surveillance to allow for drift,]01 (Do 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 assistdevice 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 .pressureý REFERENCES Section E 2. ASME, Boiler and Pressure Vessel Code, Section 111, Article NC-7000,_ a-ss 2 Component 197 ditionI[- ,'--FSAR, Section .4. ASME Code for Operation and Maintenance of Nuclear Power Plants 1995 Edition with 1996 Addenda 15. ANSI/ASM OM-1-1987.1 00 0 00 0©0 BWOG STS B 3.7.1-5 Rev. 3.1, 12/01/05 Attachment 1, Volume 12, Rev. 1, Page 23 of 461 Attachment 1, Volume 12, Rev. 1, 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 tothe 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.

0 Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 1, Page 24 of 461 Attachment 1, Volume 12, Rev. 1, Page 25 of 461 Specific No Significant Hazards Considerations (NSHCs)0 0 Attachment 1, Volume 12, Rev. 1, Page 25 of 461 Attachment 1, Volume 12, Rev. 1, 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. 0 0 Davis-Besse Page 1 of 1.Attachment 1, Volume 12, Rev. 1, Page 26 of 461 Attachment 1, Volume 12, Rev. 1, Page 27 of 461 WATTACHMENT 2 ITS 3.7.2, MAIN STEAM ISOLATION VALVES (MSIVs)0 0 Attachment 1, Volume 12, Rev. 1, Page 27 of 461 Attachment 1, Volume 12, Rev. 1, Page 28 of 461 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)0 0 Attachment 1, Volume 12, Rev. 1, Page 28 of 461 Attachment 1, Volume 12, Rev. 1, Page 29 of 461 ITS 3.7.2 ITS PLANT SYSTEMS MAIN STEAM LINE ISOLATION VALVES LCO 3.7.2 ACTION A -I ACTION B4 ACTION C -ACTION D-0 SR 3.7.2.1 LIMITING CONDITION FOR: OPERATION 3.17.1-.. Each main steam line iso-iarion valve shall be OPERABi .L01 APPLICABILITY: MODES 1, 2 ,and .e cept when anl MSIVs are closed ACTION: MODE .-With one main steam line isolation valve inoperable, POWER L02[OPERATION may continde, ptovided the~inope'rable valve iseihe restored to OPERABLE status or c osed within hors. Otherwise, mOD S oE2 and 3 W With one main steam line isolation, valve inoperable, subsequent M01 operation in MODES KJ 2 or 3 may proceed provided in8 hours L02 a. The inoperable isolation valve -is ne closed.\ " .[-- -A d d p ro p o s e d R e q u ire d A ctio n D .1 } A d d p ro o e IL M 0 3 1Otherwise, be in HOT SHUTDOWN witin te next 12 urs. reýion ýjb:., The provis ons of Specification 3.0.4 #e not. applicable. SURVEILLANCE REQUIREMENTS 4.7,1.5 Each main steam line isolation valve shall be demonstrated OPERABLE ýper th requirements of Specification ... when tested pursuant to Specification 4.0.5. A03 Add proposed SR 3.7.2.2 M05 0 DAVIS-BESSE, UNIT I 3/4 7-9 Amendment, No. 119 Page 1 of 3 Attachment 1, Volume 12, Rev. 1, Page 29 of 461 Attachment 1, Volume 12, Rev. 1, 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 SR 3.7.2.1 ACTION A ACTION C ACTION D.All containment isolation valves shall be OPERABLEwith isolati:oh

-- ----.. ..-- -APPLlCABILITY: MODES 1except when all MSIVs are closed L01 ACT ION: e Wi~th one. or more of the isolation valve(:s) inoperable, either: 8 L02 a; Restore the inoper able valve(s) to OPERABLEý status within hours, or. =Add proposed ACTION B and Required Acton C.2_**b. Isolate each.affected penetration within 4 hours by use of at, least one.:deactivated .automatic valve secured in the isolation SeeITS posi ti on, or 3..3.1 0**c. Isolate each affected penetration within" hours by use of at 802 least. one.closed manual valve or bnd ange; or d. Be inat leas't:HOT STANDBY within the next 6 hours. and See ITS i 6,COLD S DON within'thefolo 30 hours. 3.6.3 UT NL03 SURVEILLA4NcE RIEQUIREMENTS,]4.6.3.1.1 The is yfation valves shall b/demonstrated OPERABLE ior to returninq the valve to ser ice after maintenance repair-or replacement ork that could affect the vale's performance is periormed on the valve or associated I actuator, co. trol or power circuit perfbrmance of a cyclng test and verificatioof

isolation time. 76 L05* Surveillance testing of valves MSIOD, MS1101, ICSI1A and [CS1lB is not required _ See ITS prior to entering MODE 4 but shall be performed prior to enterinc MODE.3. 3.6.3 The rpvisions of 3.0.4 arw not applicable I Selected valves may be opened on an intermittent basis under administrative controls.

AU DAVIS-BESSE, UNIT 1 3/4 6-14 Amendment No. 147 0 Page 2 of 3 Attachment 1, Volume 12, Rev. 1, Page 30 of 461 ITS Attachment 1, Volume 12, Rev. 1, Page 31 of 461 CONTAINMENT SMSTEMS SURVEILLANCE REOUIREMENTS (Continued) t ITS 3.7.2 SURVEILLANCIF REOUIRFMENTS (Continued) .4.6.3.1-2 Each isolation valve 'shall be demonstrated OPERABLE at least once each REFUELING INTERVAL, by.: a. Verifying that one a containment 1solation test signal, each J automatic isolation valve actuates to its isolation, position.b. DELETED 4.6.3.1.3 The isolation timeýof each power operated ý.or automatic valve shall be determined to be within -its limit when tested pursuant to Specification 4.0,5, I See ITS 3.6,3 SR 3.7.2.1 DAVIS-BESSE, UNIT I 3/4 6-15 Amendment No.. 147,413-,221 0 Page 3 of 3 Attachment 1, Volume 12, Rev. 1, Page 31 of 461 Attachment 1, Volume 12, Rev. 1, 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. 1, Page 32 of 461 Attachment 1, Volume 12, Rev. 1, 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 0 Davis-Besse Page 2 of 7 Attachment 1, Volume 12, Rev. 1, Page 33 of 461 Attachment 1, Volume 12, Rev. 1, 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 hours. Under similar conditions, ITS 3.7.2 ACTION B requires the unit to be shutdown to MODE 2 within 6 hours.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 if an 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 hour period. This change is acceptable because the proposed time of 6 hours 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 hours. 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 hours.Under similar conditions, ITS 3.7.2 ACTION D states to be in MODE 3 in 6 hours and MODE 4 in 12 hours. This changes the CTS by specifying that MODE 3 must be achieved within 6 hours.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 0 because a new intermediate MODE must be reached, consistent with the Davis-Besse Page 3 of 7 Attachment 1, Volume 12, Rev. 1, Page 34 of 461 Attachment 1, Volume 12, Rev. 1, 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 hour 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 O 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.0.Davis-Besse Page 4 of 7 Attachment 1, Volume 12, Rev. 1, Page 35 Of 461 Attachment 1, Volume 12, Rev. 1, 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 hours 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 hours 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 hours.ITS 3.7.2 ACTION A allows 8 hours to restore an inoperable MSIV prior to requiring a unit shutdown when in MODE 1. ITS 3.7.2 ACTION C allows 8 hours 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 hours to 8 hours 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 hours to 8 hours 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 hour 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 hour 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 (Category 2 -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 hours and in COLD SHUTDOWN (MODE 5) within the following 30 hours. 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 hours and MODE 4 within 12 hours. 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. 1, Page 36 of 461 Attachment 1, Volume 12, Rev. 1, 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 hours 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 hours 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. 0 Davis-Besse Page 6 of 7 Attachment 1, Volume 12, Rev. 1, Page 37 of 461 Attachment 1, Volume 12, Rev. 1, 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.0 Davis-Besse Page 7 of 7 Attachment 1, Volume 12, Rev. 1, Page 38 of 461 Attachment 1, Volume 12, Rev. 1, Page 39 of 461 VImproved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)0 0 Attachment 1, Volume 12, Rev. 1, Page 39 of 461 Attachment 1, Volume 12, Rev. 1, Page 40 of 461 CTS MSIVs 3.7.2 3.7 PLANT SYSTEMS 3.T2. Main Steam Isolation Valves (MSIVs)3.7.1.5, 3.6.3.1 LCO 3.7.2 Two MSIVs shall be OPERABLE.APPLICABILITY: MODE 1, MODES 2 and 3 except when all MSIVs are closed ýand doe 'ivated]0 ACTIONS CONDITION in AA REQUIRED ACTION Restore MSIV to OPERABLE status.COMPLETION TIME 0F8fhours 3.7.1.5 Action MODE 1, 3.6.3.1 Action a 3.7.1.5 Action MODE 1, DOC L02 3.7.1.5 Action MODES 2 and 3, 3.6.3.1 Action c A. One MSIV inoperable MODE'l.0:B. Required Action and associated Completion Time of Condition A not met.B.1 Be in MODE 2.Cý ---- .... ... NOTE --------. .I.Separate Condition entry is allowed for each AND MSIV.--........-----------.-.----. .C .2 Close MSIV.Verify MSIV is closed.6 hours Jhours Once per 7 days 6 hours 12 hours 0 One or more MSIVs inoperable in MODE 2 Or 3.Required Action and associated Completion Time of Condition C not met.3.7.1.5 Action D.MODES 2 and 3, 3.6.3.1 Action d D.1 Be in MODE 3.AND D.2 Be in MODE 4.BWOG STS 3.7.2-1 Rev. 3.0, 03131/04 0 Attachment 1, Volume 12, Rev. 1, Page 40 of 461 Attachment 1, Volume 12, Rev. 1, Page 41 of 461 CTS MSIVs 3.7.2 SU RVEILLANCE REQUiREMENTS§ SURVEILLANCE FREQUENCY 4.7.1.5, 4.6.3.1.3 DOC M05 SR 37.21 -N~'Only reqtu*ed to be ýperfo ~d in MOD 1- and 2.Verify isolation time of each MSIV is [61 siconds[ In accordance with the lnservice Ti ltsý j, Testing Program ,SR 3.7.21.2 ----- --NiTE ---- ----------- ---Only reqf red to be perfo .med in MOD. 1 and 2.Verify each MSIVactuates to the isolation position months on an actual or simulated actuation signal.--, -.I 0 TST-49 0 0 BWOG STS 317.2-2 Rev. 3,0, 03/31104 0 Attachment 1, Volume 12, Rev. 1, Page 41 of 461 Attachment I, Volume 12, Rev. 1, 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.0 Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 1, Page 42 of 461 Attachment 1, Volume 12, Rev. 1, Page 43 of 461 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)QN QN Attachment 1, Volume 12, Rev. 1, Page 43 of 461 Attachment 1, Volume 12, Rev. 1, 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 sec'o-ndary side of the-steam mainsteam generators followinh ndr line break e -. MSIV closure afeedwater't a r terminates flow from the unaffepted(intact) steam generator. One MSIV is located in each main steam line Ioutside of, but close to, ctai nt., The MSIVS are downstream from the main steamr safety-( an gencfeedwater pump turbine's steam supply* to. prevent their being isolated fromthe steamgeneratorstby MSIV*closure...Closing the MSs isolates each steam generator from the o0ther,and isolates the turbine, Turbine Bypass System; and other.auxiliary-steam supplies f.om the .stea.geerators. The MSIVs close.on a Steam and Feedwater Rupture Control System IGMain Steam Line -' signal gienerated by e~itherl w rter(genertrreurotam FPeewaterlSteam generatorto edwaterd erenti aressur ý The MSIVs fail closed on Generator Differential loss of control or actuation power. The MSIVs mayals6.be actuated Pressure -High oimanualSy.A.. ... ..... ..0 0 0 00 0D (D APPLICABLE: SAFETY, ANALYSES INSERT1 The design basis of :tho MSIVs is, established by.the containment analysis for the large steam ion break (SLB)' inside contain nnt ,as discussed in the FSAR; Section i62 I (Ref. 2). Itis alsoi6nfluenq d by the accident analysis of the SLB d~rents 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 MSIVýto close6n demand).:" The limiting case f r. the containment analysis is he SLB inside containment with ,loss ofý offsite power folloWin turbine trip. and'failure of.the MSIV.on the ected steam generator to cl se. Atl00%6 RTP, the steam generator' ventory and temperature ar at their maximum, makimizing the ss and energy release to th ýcontainment.: Due to 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 terisolation valve to close, nd failure of an emergerncy diesel genera r (EDG) to start..BWOG STS B 337.2-1 Rev. 3.1, 12/01105.0 Attachment 1, Volume 12, Rev. 1, Page 44 of 461 Attachment 1, Volume 12, Rev. 1, Page 45 of 461 B 3.7.2 O 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)." 0 0 Insert Page B 3.7.2-1 Attachment 1, Volume 12, Rev. 1, Page 45 of 461 Attachment 1, Volume 12, Rev. 1, Page 46 of 461 MSIVs B' 37.2 BASES APPLICABLE SAFETYANALYSES (continued) The accident.analysis mpares several different SLB ev nts against different acceptance c tteria. The largeSLB outside con" inment upstream of the MS8V is limiting for offsite dose, althouga break in this short section of main .team header has, a very low prob bilityý. 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 availableqand with a I ss of o6ffsite power following turbi oe trip. Wth offsite power.availab e, the reactor coolant pumps cont nue to circulate coolant through e teateam generators, maximizing the zeactor Coolant.System (RCS) cool own. With a loss of offsite power, the response of mitigatingsystems, uch as the High Pressure lnjecti 'n(HPI) System pumps, is delayed. Significant Single failures conside ed includefiiureof an MSIV to close, f ilureof an EDG, and'failure of an HPI pump.The MSIVs'serve nly a safety function and r'emain .pen during powe'r operation. These 'Ives operate Under the'followiing situations:

a. AnHELB, .a SLB,0or main feedwater line brea s (FWLBs), inside.containment In order to maximize the mass a d energyr release in-to the6contain nnt, the analysis assumes the M IV in the affected steam gene ator remains open., For this scen rio, steam is, discharged nto containment from both steam enerators until closure of the MSli in the intact steam generator occ rs. Ater MSIV closure,st -amis discharged into containmen only from the affected steam jen ratot and ioro the'residual steoa in the main steam header do stream of the c.losed 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 blowdownn 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 theMSIVs isolates th break and limits the blowdog to a single steam generator.

c. .Abrea downstream of the MSIVs will be isolated by the closure of the M Vs. Events such as increased st' am flow throuigh the turbine or the team bypass valves will alsoter, nate on closing the MSIVs.0 BWOG STS B 3.7.2-2 Rev. 3.1, 12/01/05 0 Attachment 1, Volume 12, Rev. 1, Page 46 of 461 Attachment 1, Volume 12, Rev. 1, Page 47 of 461 MS1Vs B 3.7.:2 BASES APPLICABLE SAFETYANALYSES (continued)

d. Foll0wingas am generator tube rupture, cosu oofthe MSIVs isolates.the ptureodsteam gener, ator fromthe ntact steam generator.

n addition to minimizing radiologi, releases,.this, enables t e operator to mairntain the pressur of the steam generator with the uptured tube below theMSiVs'Ies points,; a .necessalrystep toward' solating flow through the rupture.e; The SlVs are also utilizedduring oth r eventsý such-as an.FVVLB.The MS!Vs~satisfy Criterion 3 of 1 0CFR 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 areý within limits and they close on an isol ation 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 MSI`Vs must be OPERABLE-in MODE 1 and in MODES:2 and 3 with, any.MSIVW open,when there is'significant mass and energy in the RCS and-steam generator;jtherefore, the MSIVs must be OPERABLE or closed. When the MSIVs are closed, theyare already performing the safety function.In MODE 4, theý steam generator energiy is low. Ther-efre, the MSIVs are not required to bef 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 hot required for isolation of potential high energy secondary system pipe breaks in these MODES.ACTIONS A.I Fm-tjv-M9h one MSIV inoperable in MODE 1, action rmust be taken to restore the OPERABLE Status within ehours. Some repairs can-be made to the MSIV with the unit hot. The Completion Time:is reasonable, considering the probability of an accident that would require actuation of the MSIVs occurring duringthis time intervall. The turbine stop vailves, arelavailable to provide the required isolation foe.ram Ilaed accidents. 0 0 0 BWOG STS B 3.7.2-3 Rev. 3.1, 12/01/05 0 Attachment 1, Volume 12, Rev. 1, Page 47 of 461 Attachment 1, Volume 12, Rev. 1, Page 48 of 461 MSIVs B 3.7.2 BASES ACTIONS (continued) The J]8hour Completion Time is greater, thanthat normally allowed'for containment isolation valves because the MSIVs are valves thatisolate a, closed.system/ enetrating contai pnent. These valvediffer from otherlcontainmensolation valves in at the closed provides an additional ansifor containment isolation. 0 N penetration that is neither part of the reactor coolant pressure I boundary nor is connected directly to the containment atmosphere.J J B.1'If the MSIV cannot be restored.to OPERABLE.status within the unit must be placed in MODE 2 land the inmo closed within the next 6 hours. The Completion Time5W reasonable, based on 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 M8fhour Completion Time is consistent with that allowed in Condition A.0 0 0 Inoperable.MSIVs that ýcannot be res)t6red to OPERABLE statswihn Ithe specified.Compretion Time, but are closed@ must 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 0 Attachment 1, Volume 12, Rev. 1, Page 48 of 461 Attachment 1, Volume 12, Rev. 1, Page 49 of 461 W MSIVs B 3.7.2 BASES ACTIONS (continued)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 hours. The allowed Completion Times are reasonable, basedon operating experience,:to reach the required unit conditions from MODE 2 conditions in an orderly mannereand without challenging unit systems.SURVEILLANCE SR 3.7.2,.1 the" REQUIREMENTS.This SR verifies that MIVclosure-tirn-e of each MSIV isj: ( 61 sqýconds.j 'within the limit giiven in " at.. 5and i wiet hin ýt h t Isi a I c ieia ;ssum orot~rr imden t/ SR analyses. This urea~nce normally performed upon returning the unit This SR also verifies the valve to operation following a refueling outage, because the MSIVs should not closure time is in accordance with be tested at power since even a partroke exercise increasesthe:, risk. of al the Inservice Testing Program.. a valve closure with the unit generating power. As the MSIVs are not1o be tested at poWer, they are exemrpt-from the ASM E Code (Ref9 requirements during operation in MODES I and 2..The Frequencyfor this SR is in accordance with the Inservice Testing Program'.This test is conicted in MODE 3;wit the unit at:operatihg temperature and pressure. this SR is rnodifid b, a Note that allows entry into and operation in*M DE 3 prior to perforrjing the, SR. This.a lowsdelayihg testing until M DE 3 in order to estoblish conditions co sistent withithose under which he acceptance 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 plant to operation following a refueling outage. The Frequency of MSIV testing iseyer months, The [ nth Frequency'for testingI is based on the refueling cycle. Operating experience has. shown that these components usually pass the Surveillance when performed at the~month Frequency. Therefore, this Frequency is acceptable from.a 0 reliability standpoint. BWVOG STS B 3.7.2-5 Rev. 3.1, 12/01105 Attachment 1, Volume 12, Rev. 1, Page 49 of 461 Attachment 1, Volume 12, Rev. 1, Page 50 of 461.MSIVs B 3.7.2 BASES REFERENCES -- 7 4 FSAR,Section110o.3 3,-ly SAR, Section 15,2%4. 10 CFR 100.11.ASME.Code for Operation and Maintenance of NuclearPower Plants..... ....'.......... 00 00 00 (DO (4O (DO~5.-w 0 Technical Requirements Manual.L BWOG STS B 3:7.2-6 Rev. 3.1, 12/01/05 0 Attachment 1, Volume 12, Rev. 1, Page 50 of 461 Attachment 1, Volume 12, Rev. 1, 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. 1, Page 51 of 461 Attachment 1, Volume 12, Rev. 1, Page 52 of 461 WSpecific No Significant Hazards Considerations (NSHCs)0 0 Attachment 1, Volume 12, Rev. 1, Page 52 of 461 Attachment 1, Volume 12, Rev. 1, 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. 0 0 Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 1, Page 53 of 461 Attachment 1, Volume 12, Rev. 1, 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)0 Attachment 1, Volume 12, Rev. 1, Page 54 of 461 Attachment 1, Volume 12, Rev. 1, Page 55 of 461 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)0 0 Attachment 1, Volume 12, Rev. 1, Page 55 of 461 Attachment 1, Volume 12, Rev. 1, Page 56 of 461 ITS 3.7.3 ITS PLANT SYSTEMS MAItN-EEDWATER CONTROL VALVES AND STARTUP FEEDWATER CONTROL VALVES LIMITING CONDITION FOR OPERATION LCO 3.7.3 33.1.8 The Main Feedwater Control Valves,(MFCVs) and associated Startup Feedwater Control;Valves (SFCVs) shall be OPERABLE.L.Cecept :he. M 1 MFSV2, MFCVs, and dssoclated F SFC-Vs are closed or isolated by aclsdmnavav APPLiCABILITY: MODES.I, 2,.and:3l I~iN; I Add proposed ACETIO:NS: Note "- ,----- --ACTIONS [_With oneor more MFCVs or SFCVs inoperable, isolate the affected flowpath within-72 hours and B, C, and 0 vLverify the flowpath is isolated once per 7 days, orbe in at least HOT STANDBY within the next 6_/--hours and in HOT SHUTDOWN within the following 6 hours.ACTION E SURVEILLANCE REQUIREMENTS LOl A02 MOl A03 M02 SR 3.7.3.2 4.7.1.8 Each MFCV and SFCV shall be demonstrated OPERABL by'performance of Surveillanceý- F R-exuirement 0 Add proposed SR 3.7.3.3 DAVIS-BESSE, UNIT 1 314 7-12d Amendment No. 246 0 Page 1 of 3 Attachment 1, Volume 12, Rev. 1, Page 56 of 461 Attachment 1, Volume 12, Rev. 1, Page 57 of 461 ITS 3.7.3 ITS CONTAiNMENT SYSTEMS 3/4.6.3 CONTAINMENT ISOLATION .VALVES LIMITING CONDITION FOR OPERATION LCO 3.7.3, SR 3.7.3.1 ACTIONS A and D OACTIONS A and DAll containment isolation valves shall be OPERABLE with isolation Itimes less than or equal to required isolation times.* *APPLICABILITY: except when all MFSVs, MFCVs, and associated SFCVs are closed or isolated by a closed rnan.ýal .ýJve MODES 1. 21,,3IfNN Wo vAdd proposed ACTIONS Note r W I t; one or more of the i'solation valve(.sj inop'erable, 'either:, 4. Res the inoperable valve(sXto OPERABLE sýl:4-6s hou7t_3s11'eor F-**b. Isolate each affected penetration wi,thin 4 hours by use of i See ITS at least one deactivated automatic. valve secured in the isolation 3.6.3 J position, or L03*4C. l Isolate each affected penetration within [A] hours by use of at least one closed manual valvelor blind flangel; or .1 SeeITS d. Be 'in at leastHOT STANDBY within the. next 6 hours and 3.6.3 ACTION E in ICOLD ,riUTOOWN -within the [foilin 30 hours.MODE 4 12U L02 SURVEILLANCE REQUIREMENTS 4.6.3.1.1 The is ation valves s hall be ýemonstrated OPERABLE prior to returni, the valve to serv ce after maintenance, Vepair or replacement ork that could affect the valve/s performance is perforilied on the valve or i s associated actuator,.contrql or power circuit by p~rformance of.a cycli g test and verification of/isolation time. I* Surveillance 'testing of valves MSIO,. MSlOl, ICSi1A and ICSIlB is not requir prior to entering MODE 4 but shall be performed prior to entering MODE 3.TS]3 iJ" The provisions of Specific~.aion 3.0.4 are F6t applicable.I Seeci Imavybe oopneo on an intermittent basis under a miniztrArivv rnnrh{See ITS 3.6.3 ]DAVIS-BESSE, UNIT I 3/4 6-14 Amendment No. 147 0 Page 2 of 3 Attachment 1, Volume 12, Rev. 1, Page 57 of 461 Attachment 1, Volume 12, Rev. 1, Page 58 of 461 ITS 3.7.3 ITS CONTAINMENT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) .4.6.3.1.2, Each isolation valve shall be demonstrated OPERABLE at least once SeelTS each' REFUELING INTERVAL, by: --4 3.6.3 a. Verifying that on a containment isolation test signal, each automatic isolation valve actuates to its isolation position.4.6.3.1.3 The isolation time of each power operated or automatic valve 4 3.6.3 shall be determined to be within its limit when tested pursuant to Specification 4.0.5..Add proposed SR 3.7.3.3 M02 SR 3.7.3.1 DAVIS-BESSE, UNIT 1 3/4 6-15 Amendment No. 147,21, 2 2 1 I 0 Page 3 of 3 Attachment 1, Volume 12, Rev. 1, Page 58 of 461 Attachment 1, Volume 12, Rev. 1, 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 MFCVand 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.0 Davis-Besse Page 1 of 6 Attachment 1, Volume 12, Rev. 1, Page 59 of 461 Attachment 1, Volume 12, Rev. 1, 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 SCONTROL 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 hours 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 hours or 8 hours, 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 hours and 8 hours) 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 TechnicalSpecifications. 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.0 Davis-Besse Page 2 of 6 Attachment 1, Volume 12, Rev. 1, Page 60 of 461 Attachment 1, Volume 12, Rev. 1, 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 hours. ITS 3.7.3 ACTION D will require isolation of the affected flowpath within 8 hours 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 hours in lieu of the current 72 hours. 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. 1, Page 61 of 461 Attachment 1, Volume 12, Rev. 1, 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 hours and in COLD SHUTDOWN (MODE 5) within the following 30 hours. 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 hours and MODE 4 within 12 hours. 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 0 been modified to only require entering MODE 4, which will exit the new Davis-Besse Page 4 of 6 Attachment 1, Volume 12, Rev. 1, Page 62 of 461 Attachment 1, Volume 12, Rev. 1, 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 hours to isolate the affected penetration when one or more of the MFSVs are inoperable. ITS 3.7.3 ACTION A will allow 72 hours 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 hours to isolate the affected flowpath. This changes the CTS by extending the Completion Time from 4 hours to 72 hours when a MFSV is inoperable and from 4 hours to 8 hours 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 hours 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 hours 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. 0 Davis-Besse Page 5 of 6 Attachment 1, Volume 12, Rev. 1, Page 63 of 461 Attachment 1, Volume 12, Rev. 1, Page 64 of 461 0 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.0 0 Davis-Besse Page 6 of 6 Attachment 1, Volume 12, Rev. 1, Page 64 of 461 Attachment 1, Volume 12, Rev. 1, Page 65 of 461 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)9 Attachment 1, Volume 12, Rev. 1, Page 65 of 461 Attachment 1, Volume 12, Rev. 1, Page 66 of 461 CTS[MFSVs, MFCVs, and Associated SFCVsp 3.7.3, 3,7 PLANT SYSTEMS, 3.713 Feedwater Stop Valves (MFSVs), Main Feedwater Control Valves (MFCVs), and 0s(sociated Startup. Feedvwater Cohtrol Valves ,(SFCVs) " 3.7.1.8, LCO 3.7.3. CVs ed SFCVs~shall be OPERABLE.3.6.3.1 APPLICABILITY' MODES -1, 2, and 3,except when aocated SFCVsfjare.closedl[andadeaivated or isolated by.a closed mhanual.vaive4.ACTIONS MFSV, MFCV, and SFCV---a---.--- .-- NOTCon .i.o n i...ll.wed.....a.h..-ye. DOC A02 Se~parate.'C~ndition entry is :a!!f*d for,each v e'.0 0 00 00 0 CONDIITION, REQUIRED ACTION 3.6.3.1 , A i Action c I rorflow patot inoperable. 3.7.1.8 B.~ Oeo Action [ me ra-Fow pat. ssI inoperable. 3.7.1.8 One FC in. eor Action owpat inoperable. AJ AND Al.BA1 AND B.2 Close or iso.ateowMFSV{ VerifyHMFSVMis closed or isolated.Close or isolate IAFCj Verifyj VFC\q is closed or isolated.QOMPLETiON TIME[P72&hours Once per 7 days M[8or 72hours Once per.7 days 8]or 72E hours Once per 7 days 00 0 00 0 00 0.AND 0.2 Close or isolate &FC\.Verify DFCVais closed or isolated.BWOG STS 3.7.3-1-Rev. 3.0, 03131104 0l Attachment 1, Volume 12, Rev. 1, Page 66 of 461 Attachment 1, Volume 12, Rev. 1, Page 67 of 461 CTS PMFSVs,, MFCVs, and Associated SFCVs}3.7.3" ACTIOqS Jcontin uecl CONDITION 3.7.1.8 Action, 3.6.3.1 Action c 3.7.1.8 Action, 3.6.3.1 Action d D. Two valves in the same flow path inoperableFo f ne or morO flow E. Required Action and associated Completion Time not met.D.1-E.1 REQUIRED ACTION Isolate !affected flow path.,.Be in MODE 3.COMPLETION TIME 8 hours 6 hours 12 hours'm 0 0 00 E.2 Be in MODE 4.SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 0 4.6.3.1.3 SR 3.7.3,1.......... = .... NOTE- -....-/'L....- --...Only required t be performned;ýý iT 9~Sand 2.Verify the isolation time of each MMIFSVI~islj- (71 scond 0 DOC M02 SR 3:7.3tI In accordance with the Inservice Testing Program[1 *11months 0 TST-49 Only required ' be performed in MO.S 1 and 2.Verify each RMFSVjjMFCV) andpSFCVjactuates to the isolation. posi ion on anactual or simulated actuation signal., BVOG STS 3.7.3-2 Rev. 3.0, 03131/04 0 Attachment 1, Volume 12, Rev. 1, Page 67 of 461 Attachment 1, Volume 12, Rev. 1, Page 68 of 461 CTS 3.7.3 0 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.InserPage 3.7.3-2 Attachment 1, Volume 12, Rev. 1, Page 68 of 461 Attachment 1, Volume 12, Rev. 1, 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 if the 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. 0 Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 1, Page 69 of 461 Attachment 1, Volume 12, Rev. 1, Page 70 of 461 W Improved Standard Technical Specifications (ISTS) Bases Markup and Justificationfor Deviations (JFDs)0 Attachment 1, Volume 12, Rev. 1, Page 70 of 461 Attachment 1, Volume 12, Rev. 1, Page 71 of 461 All changes are (1unless otherwise noted!0 DM FSVs, MFCVs, and/ssociated .SFCVs B 37.3.0 B 3.7 PLANT SYSTEMS B3.7,3 MMain Feedwater Stop Vaives:(MFSVs), Main Feedwater Control Valves (MFCVs), and$ssociated Startup Feedwater Control Valves (SFCVS) M BASES 0 BACKGROUND Main Steam Line Pressure-Low or Feedwater/Steam Generator Differential Pressure -High The. main feddwater isolation valves .(MFIVs) for each steam generator consist.of the MFSVs,,MFCVs, and the SFCVs. The MFIVs isolate main.feedwater .(MFW)A 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 forsteam line breaks ( LBs) or FWLBs inside containment and reducing the cooldown effects forLBs. M The MFIVs close on receipt-of a Steam and Feedwater Rupture Control System (SFRCS)e signalrgenerated byaeither low ream generator steartfn endratortfeedwater differenitial IreSsrureL Thm Ftvs 0 can also be closed manually,[The MFIVs and assoc ted bypass valves close on receot 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 rnually. In addition tothe MFIVs and a sociated bypass valves,.a check alve inside'containment is avtlable to isolate the feedwater line penetrating containment and t ensure that the consequences o events do not exceed the capa ity of the containment heat remov I systems. ]0 IA description of thelVs is found in the FSAR, Seqtidn [1 04.7] (Ref.1l).I APPLICABLE The design basis of the MFIVs is established by the analysis for the mfa SAFETY SLB. It is also influenced by the accident analysis for the large FWLB.ANALYSES Closure of the MFIVs may also be relied on to terminate a steam break* for core response analysis and excess feedwaterevent upon the receipt of a steam generator water level -high signal.Failure of an MFIV to close following anýLB, 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 antLB or FWLB event.The MFIVs satisfy Criterion 3 of 10 CFR 50.36(c).(2)(ii). BWOG STS B 3.7.3-1 Rev. 3.1, 12/01105.0 Attachment 1, Volume 12, Rev. 1, Page 71 of 461 Attachment 1, Volume 12, Rev. 1, Page 72 of 461 0 [FSVs, MFCVs, and (A'ssociated SFCVsM B 3.7.3 0 BASES LCO This L-COensureslthat the MFIVs Will isolate MFW flow to the steam generators'following:a FWLB or a mainsteam line break. Thevl e will also isolate the nonsafety related portions from the safety related nortions of t~he sysitem ZTwcJMFSV!JMFCVs ssociate~d SFCV , are required to be OPERABLE. The MFIVs are.considered.OPERABLEwhen the isolation times are within limits and they closelon an isolation actuation signal.Failure to meet.the LCO requirements can result in additionalimass and M energy being released to, containment"following, arSLB or FWLB inside containment. If the SFFCS on high steam.generator/evel is relied on to terminate~an excess fe dwater flowevent, failure-to Oheet the LCO may Iresult inthe introductio/ ofwater info themain stearh lines-I 00 0 0 APPLICABILITY The 01FSVQ4jMFCV4, Ea'ssociated SFCV\must be OPERABLE n wheneverthere is significant mass and energy in .the RCS and steam MSLB or generators. This ensures that.in the event of an H"L a single failure cannot result'in the blowdown of more than one steam generator. In MODES 1,2, and 3, the SMCVsjare 0 requiredto be.OPERABLEin order to limit the amount of available fluid that could be added to containment in the case of a secondary system pipe:break inside containment. When the yalves are,close, theylare already performing.their safety function. o by a clOsed manual valve 0 In MODES 4, 5, an 6, steam generator energy is low. Theref0re, the MFSV~~[jMFCV r]associated SFCVjar6 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 valve.A.A andAX2 For -mor-e-With .ondjMFS n m e opath inoperable, action must be a resto rt e ted e B sta totclose or ia inoperable affected vaivej within M 721 hours. V'hent or. isolated, t performingh-required safety function. ........10 BWMG STS B 3.7.3-2 Rev. 3.1, 12/01/05 0 Attachment 1, Volume 12, Rev. 1, Page 72 of 461 Attachment 1, Volume 12, Rev. 1, Page 73 of 461[1AFSVs, MFCVS, and ýsociated.SFCVQ (B 3.7;3 BASES ACTIONS (continued) I For units with only on MFIV per feedwater.line: The f ] hour Completion Time is reasonable toclose the MFIV.or its associated bypass valve, which includes perfo/ming a controlled unit shutdown o MODE 2. The 0(D Completion Time is/easonable,,based on operating xperience, to reach, MODE2 from~full bwer conditions with the MFIVs osed, in an orderly manner and withoot challenging unitsystems.] 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 M FW flowpaths. The!37.hour Completion Time is-reasonable, ii)basedon operating experience. Eý -nprbeMSWtaaf~ sdo isolated, must be verified on~a i)[ periodic basis tha .te ar, closed or isolated. This isrnecessary to 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@ii valvz5 Y closed or isolated.B.1 and B,.2*WithoneNFC4\ in one or oe fl ow paths linoperable, action must be..hetaken to Irestore the affected valvy.-o-QPERABLE status or 6 Ol OSe or isolate noperable affected valvegmwithin F[8 or17hours VWhen Qs.closed or isolated,. a performing ti required safety function. its For units with only o MFIV per feedwater line: The ] hour Completion Time is reasonable, ased on operating experience, close the MFiV or its a ssociated byp ss va lve .] ' c / ' " " 1 TheM'72Mhour Completion Time takes into. account the redundancy C?afforded by the remaining OPERABLEýand the low probability of (an event: occurring during -this time period that would require isolation of the MFFW flow paths.EZJ','noperable[MFCVA that Ifqioed or isolated must be verified on a 02 periodic bas tha closed or isolated. This is necessary to JCi 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.BWVOG STS B 3.7.3-3 Rev. 3.1, 12/01/05 Attachment 1, Volume 12, Rev. 1, Page 73 of 461 Attachment 1, Volume 12, Rev. 1, Page 74 of 461[OMFSVs, MFCVs, and /ssociated SFCVs 0 B 37.3 BASES ACTIONS (continued) CA and C.2 or moe Wt ~ ~inoperable,.action must be taken tolrestore the affected valve us-oOPERABLE-status, orto close or 4 i noperable affected valvevwithin[8o72fhoursý. Whents [jI valveRjl Iclosed or isolated, t performing K ]required safety J .J function.7K"-F_3 J i[For units with only 0 M FIV per feedwater line. The hour Completion Tirnejs reasonabli, based on operating experience o close the MFIVor its associatedby ass'valve. ] /The 2M hour Completion Time takes into account the redundahcYy 0 MF afforded by:the remaining OPERABLesand the low probability of 0 an event occurring during thistime period that would. require.isolation of the M FW flow paths. SFC-/gVthat Ma e d or isolated must be verified on a periodic basis tha rclosed or isolated. This is necessary to E ensure that the assumptions'in the safety analysis remain valid. The 7 day Completion Time isý 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 path there m no no redundant, system to operate automaticall and erform the required.safety function. /Although the co ainment can be isolated/wth the failure to two:v es in parallel in the sme flow path, the doubl yfailure can be an inti ation of a common rnqe failure'in the valvesoffthis flow path and as. ch is treated the same's a loss of the isolation c~pability of this fwo I :Under these condlitions, laffeoted valves in each flQ.Wpath must.bl (I restored to OPERABLE status, o the affected flow pat 4 isolated within mus e 8 hours. The 8 hour Completion Timeis reasonable, based on operating experience, to close the MFIV or otherwise isolate the affected flow path.BVVOG STS B 3.7.3-4 Rev. 3.1, 12/01/05 0 Attachment 1, Volume 12, Rev. 1, Page 74 of 461 Attachment 1, Volume 12, Rev. 1, Page 75 of 461ýMFSVs, MFCVs, andfssociated SFCVs 0 B 3.7.3 BASES ACTIONS '(continued) E.1 and E2.If the [MFSVs], [MFCV6], and: lassociated.SFCVs] 9nnot be restored to any Required Action an OPERABLE statusAr closed, or isolated within tpr associated isnot m 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 hours and in MODE 4 within 12 hours. Theýallowed Completion Times. are. reasonable, based on operating experience, to reach .the required unit conditions from full power conditions in an orderly manner and withouttchalienging unit systems.SURVEILLAN CE SR 3.7:3. 1 and SR 373.2 REQUIREMENTS These SRs verfy .that the closure time of each ýMFSV1. MFC~d, and (2)3-491 withfeirn thealinmit n--Th [ MiS/], [F ],adasoited timeasuein.-4 " Re e e an s wt hi te the accid e nt la d c n t ~ b e a na lyse s '* ~ l urve la nce no rm a lly C T TJ performed upon returning'the unit to-operation following a.efue ingr outdge, The MMF,§[ IVIFC\, and iIsso0iated SFCM should not be 491 3.7.3.1 _M S , also verifies the valve te te ...at. "". .c3osure tree sis n accordance wi tested atpower since even.a pa stroke exercise.increases the risk-of a Liii the Inservice Testing Program. valve closure with the unit.generating power, This.is consistent.with the, ASME Code (Ref. requirements during operationinMODES 1 and 2 TSTF al -491 This SR is modifiedV y a Note that allos entry it and operation in MODE 3 prior to p/rformingthe SR. 0 .)The Frequency for M SR s in accordance with the Inservice Testing PrograrLrF 37.3.1 SIand for SR 3.7.3.2 is 24 months }This SR verifies that-eachTMFSV, MFCV, and associatedSFCV4can close on an actual or simulated actuation signal. Th is Surveillance is normally performed:upon returning therplant to operation following a refueling outage. 24 The Frequency for this SR is every u-months. The [l month Frequency for testing is based on the refueling cycle. Operating experience has shown that these :components.usually pass the Surveillance whenperformed at the U['month Frequency. Therefore, 0 ()this Frequency is acceptable~from a reliability standpoint. BWZOG STS B 3.7.3-5 Rev. 3.1, 12/01/05.0 Attachment 1, Volume 12, Rev. 1, Page. 75 of 461 Attachment 1, Volume 12, Rev. 1, Page 76 of 461 MM FSVs,.M FCVs, and (ssociated SFCVs B 3.7.3 0 BASES REFERENCES I1. FSAR, pction [10.4.7.1----1 Technical Requirements ManuaI]F ASME Code for Operationmand Maintenance. of Nuclear Power Plants.to BWVOG STS B 3.7.3-6 Rev. 3.1, 12/01/05.Attachment 1, Volume 12, Rev. 1, Page 76 of 461 Attachment 1, Volume 12, Rev. 1, 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.

0 Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 1, Page 77 of 461 Attachment 1, Volume 12, Rev. 1, Page 78 of 461 WSpecific No Significant HazardsConsiderations (NSHCs)0 Attachment 1, Volume 12, Rev. 1, Page 78 of 461 Attachment 1, Volume 12, Rev. 1, 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. 0 Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 1, Page 79 of 461 Attachment 1, Volume 12, Rev. 1, Page 80 of 461 O ATTACHMENT 4 ITS 3.7.4, TURBINE STOP VALVES (TSVs)0 QC Attachment 1, Volume 12, Rev. 1, Page 80 of 461 Attachment 1, Volume 12, Rev. 1, Page 81 of 461*Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)0 Attachment 1, Volume 12, Rev. 1, Page 81 of 461 Attachment 1, Volume 12, Rev. 1, Page 82 of 461 ITS 3.7.4 ITS 0 PLANT SYSTEMS TURBINE STOP VALVES LIMITING CONDITION FOR OPERATION 3.7.1.9 Four Turbine Stop Valves shall be OPERABLE.3.7.4 APPLICABILITY: MODES 2, and 3 except when all TSVs are closed ACTION:Add proposed ACTIONS Note ACTION A __With one or more Turbine Stop, Valves inoperable, close.the inoperable valve(s) within 8 hours and N verify the valve(s) is closed once per 7 days,orbe inat least, HOT STANDBY within the next 6 hours ACTION B- an in --within the oowng 6 hours.SURVEILLANCE REQUIREMENTS LO 1 A02 A03 MOl SR 3.7.4.1 4.7.1.9 Each Turbine Stop Valve shali.be demonstrated OPERABLEIby performance of Surveillanceý jReguirement. 4.3.2.2.31 0 Add proposed SR 3.7.4.2 DAVIS-BESSE, UNIT I 3/4 7-12e Amendment No. 246 Page 1 of 1 Attachment 1, Volume 12, Rev. 1, Page 82 of 461 Attachment 1, Volume 12, Rev. 1, Page 83 of 461 DISCUSSION OF CHANGES ITS 3.7.4, TURBINE STOP VALVES (TSVs)0 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 hours 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 change is 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. 1, Page 83 of 461 Attachment 1, Volume 12, Rev. 1, 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.0 Davis-Besse Page 2 of 2 Attachment 1, Volume 12, Rev. 1, Page 84 of 461 Attachment 1, Volume 12, Rev. 1, Page 85 of 461 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)S 0 Attachment 1, Volume 12, Rev. 1, Page 85 of 461 Attachment 1, Volume 12, Rev. 1, Page 86 of 461 0*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.TSVs 3.7.4 APPLICABILITY: MODE 1, MODES 2 and 3 except when all TSVs are closed.DOC A02 ACTIONS--------------------------------------- NO Separate Condition entry is allowed for each TS\Ir I------------------------------------------------------------ Action CONDITION REQUIRED ACTION COMPLETION TIME A. One or more TSVs A.1 Close inoperable TSV. 8 hours inoperable. AND A.2 Verify inoperable TSV is Once per 7 days closed.B. Required Action and B.1 Be in MODE 3. 6 hours associated Completion Time not met. AND B.2 Be in MODE 4. 12 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.4.1 Verify isolation time of each TSV is within limits. 24 months SR 3.7.4.2 Verify each TSV actuates to the isolation position on 24 months an actual or simulated actuation signal.4.7.1.9 DOC M0l 0 3.7.4-1 Attachment 1, Volume 12, Rev. 1, Page 86 of 461 Attachment 1, Volume 12, Rev. 1, Page 87 of 461 0 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). 0 Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 1, Page 87 of 461 Attachment 1, Volume 12, Rev. 1, Page 88 of 461 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)0 0 Attachment 1, Volume 12,-Rev. 1, Page 88 of 461 Attachment 1, Volume 12, Rev. 1, 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. 1, Page 89 of 461 Attachment 1, Volume 12, Rev. 1, 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 hours. The 8 hour 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 hours and in MODE 4 within 12 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from 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 0 B 3.74-2 Attachment 1, Volume 12, Rev. 1, Page 90 of 461 Attachment 1, Volume 12, Rev. 1, 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.0 B 3.7.4-3 Attachment 1, Volume 12, Rev. 1, Page 91 of 461 Attachment 1, Volume 12, Rev. 1, 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.

0 Davis-Besse Page 1 of.1 Attachment 1, Volume 12, Rev. 1, Page 92 of 461 Attachment 1, Volume 12, Rev. 1, Page 93 of 461 Specific No Significant Hazards Considerations (NSHCs)0 0 Attachment 1, Volume 12, Rev. 1, Page 93 of 461 Attachment 1, Volume 12, Rev. 1, 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. 0 0 Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 1, Page 94 of 461 Attachment 1, Volume 12, Rev. 1, Page 95 of 461 qw ATTACHMENT 5 ITS 3.7.5, EMERGENCY FEEDWATER (EFW)0 0 Attachment 1, Volume 12, Rev. 1, Page 95 of 461 Attachment 1, Volume 12, Rev. 1, Page 96 of 461 WCurrent Technical Specification (CTS) Markup and Discussion of Changes (DOCs)0 0 Attachment 1, Volume 12, Rev. 1, Page 96 of 461 ITS Attachment 1, Volume 12, Rev. 1, Page 97 of 461 PLANT SYSTEMS"AUXILIARY FEEDWATER SYSTEM LIMITING CONDITION FOR OPERATION ITS 3.7.5 LCO 3.7.5 3.7.1.2 Two trains of auxiliary feedwate j each consistin of an auxi arLA Ofeedwater A uLmp an. a~sociat h steam ge/rator_, s a e OPERABLE.APPLICABILITY: MODES 1, 2, and 3.: Add proposed ACTION Note A0 ACTION E d rooe CTO-a. With one train of auxiliary feedwater inoperable to either or both ACTION B steam generator(s), restore the inoperable train to OPERABLE status within 72 hoursor be in HOT SHUTDOWN within the next 12 hours. Add proposed ACTION D Required Action I L01 b. With any AuxilV ryFeed Pump Turbine Inlet. Steam' ressure Interloc inoperable, estore the inoperable interlocks OPERABLE status within 7'Ys or be in HOT SHUTDOWN within )t next 12 hours.0 c.. With steam,uanerator inlet valve AFbeg or A tF608 closed, O ePERA LE: Addpropo the close once pe AF 5a998 on A ST8AwEtEST hour or be in HOy STANDS within the next 6 hours and rOTe UTDOWN within the foll ing 6 hours. /, SURVEILLANCE REQUIREMNS AdpooeACINCndscnCodtoofCTOD t02 41.7.1.2.1 Each Auxiliary Feedwater train shall* be °demonstrated OPERABLE: /a. At least once per-92 days Io STBSSby:*1. Verifying the differential pressure of each steam turbine L0 driven pump is greater than or equal to the required differential pressure 3.ecie recircu on ow ra pri nsa I c i c QjtM~1n 4.0. are noi cap e M0 enryino OD .F SR 3.7.5.2* When conducting tests of an auxiliary feedwater train in DES 1, 2, and 3 which require local anuai 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 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.M02 DAVIS-BESSE, UNIT I 3/4' 7-4 Amendment No. #67442--144,'1U,200 0 Page 1 of 6 Attachment 1, Volume 12, Rev. 1, Page 97 of 461 Attachment 1, Volume 12, Rev. 1, Page 98 of 461 ITS 3.7.5 ITS PLANT SYSTEMS SURVE.ILLANCE REQUIREMENTS (Continued), b. At-least once per 31 days on a STAGGERED TEST BASISI by: SR 3.7.5.1 1. Verifying that each valve (power- operated or automatic) in that is not locked, the fl.OW pathtis in its correct position. sealed,ý or otherwisel Ssecured in position S2. Verifying tha all manual valves in the aux*liary feedwater pump suctfi and discharge lines that affot the osytem's fepdcity o deliver water tobthe steam generator are locked in theiC nproper position. w 3. Verifyingla t valves CW 196,. CW HN7, , FW 91 and FW least on p oserd.. C atles oc c. At least once each REFUELING INTERVAL by: L05 DAVIS-BESSE, ~ ~ ~ ~ ~ ~ Ad UNITse SR 3/7.5 N-o Amnmn.N.a36,9,2,3,9,l SR 3.7.5.4 -.V rfi gthat each ve in the flo LatA04.actuates to its correct position on a Ptea~mand L06h Control/Systeml actuation tetsga 00 SR3.7.5.5

2. Verifin tht each a omatcal upon receipt 2 f ,of a1 Steam and-feMedwater Rupture Ck itrolSstemlactuation M03)aculr-test.

Signal. IThe provisions of Specification 4.0.4 are: notFI l~~ap-plicable, for entry in MODE 3.1 (SR 3.7.5.6 3., Verifying that there is a flow. path. frot each auxili Iary feedwater pump to both steam gener~ators by pumping wat~er , from the: Condensate'Storage Tank. with'each pump to both steam generators. The flow paths' s all be ve'rified by either: eam g1 enerator level change or/Auxiliary Feedwater Safety/Grade Plow -Indication. the Feedwater ISystem's fl, capacity is not required.- SR 3.7.5.8, d. The Auxi~iiary Feed Pump Turbine Steam *Generator Level Control SR 3.7.5.9, .System shall be demonstrated. OPERABLE by performance of a CHANNEL SR 3.7.5.10 CHECK at least once per 1.2 hours, a CHANNEL FUNCTIONAL TEST at least~once per,31, days, and a CHANNEL CALIBRATION at least once each REFUELING INTERVAL.e. The Auxilllr MFe Pump Sution Pressure Itr~gls shall be " delmonstrated PERABLE by performance of aCHA INL FUNCTIONAL TEST ----(LA071 at least o~e per 31. days, and a CHANNEL CAL I4RATION at lea{st once-- s each REFyELING INTERVAL.DAVIS-B.ESSE, UNIT 1 3/4 7-5 Amendment. No. Q3 39,2,311325-1 Page 2 of 6 Attachment 1, Volume 12, Rev. 1, Page 98 of 461 Attachment 1, Volume 12, Rev. 1, Page 99 of 461 ITS ITS 3.7.5 ITS SURVEILLANCE REOUIRENENTS (Continued) f After. any modificat on or repair to the Auxiliary Feedwate System that could affect the system' capability to deliver water to the st am generator, the affected flow path shall, be demonstrated available as fol ows: 1. If the mddif ation or repair is downstream of the est flow line, each auxiliaqy f pump(s) associated with the affected flow path shall pump ,water from e Condensate Storage Tank to the stea generator(s) associated th the affected flow path; and the fl path availability will be ver fled by steam generator level change Auxiliary Feedwater Safety Gra e Flow Indication.

2. If the fication or repair Is upstream of the est flow line, the auxiliary feed punp.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 11i8i This Surveil ance Testing shall be performed prior o entering MODE 3 if the modification is made in 1ODES 4, 5 or 6. Verificat on of the Auxiliary FeedwaterS' tern's flow capacity is not required.SR 3.7.5.6 g. Following each extended cold shutdown.(>

30 days in 1OOE 5), by: 1. Verifying that there Is a flow path from each auxiliary feedwater pump to both steam enerators by iumpn Condensate Storage Tank water with each ptmp~~~~~~~~~~~~ tobt tmgneaos Tet6eptssal verified byt _ ..161ther as,4i.generatr Ileve!.chane ar ter Safet Ir~~low Ind41Ctlon. I he provisions of Specification 4.u.4 am, not, applicable for entry into MODE 3.Verification of iAuxiliary Feedwater System's. capacity is not LA05 4.7.1.2.2 The Auxiliary.. ed Pump Turbine Inlet Steam Pressure In erlocks shall be demonstrated OPERABLE ,en the steam line pressureis greater tln 275 psig, by performance of a FUNCTIONAL TEST at least once per 31 dtys, and a & EL LA02 CALIBRATION at leastonce each REFUELING IMTERVAL. TheW FUNCTIONAL TEST shall be performed withi 24 hours after exceeding 275 psig durn each plant startup, If the test has not bee/peford within the last 31 days.When conducting tes of an auxiliary feedwater train in MOD 1, 2, and 3 which require local manu realignment of valves that make the trMin inoperable the Motor Driven Fe ter Pump .and its associated flow paths hall be OPERABLE per.Specification

3. .1.7 during the performance of this surv illance. If the Motor Driven Feedwate pmp or an associated flow path is ino rable, a dedicated Individual sha be stationed at the realigned auxilia feedwater train's valves (in comaunica ion with the control room) able to resto the valves to normal system OP LE status.DAVIS-BESSE, UNIT 1 3/4 7-5a Amendment No. 96ri4rd 9 218 Page 3 of 6 Attachment 1, Volume 12, Rev. 1, Page 99 of 461 Attachment 1, Volume 12, Rev. 1, Page 100 of 461 ITS 3.7.5 ITS 0 PLANT SYSTEMS MOTOR DRIVEN FEEDWATER PUMP SYSTEM LIMITING CONDITION FOR OPERATION LCO3.7.5 3.7.I.7 The Motor Driven Feedwater Pump land associatedC ow paths to the train LA01 u Auxiliary Fewater SystemI shall be OPERABLE.APPLICABILITY:

MODES 1, 2 -and 3., Add proposedsecondApplicability ACTIO: [Add proposed ACTION Note A0* With th'e.Motor Drive Feedwater Pum or its associate flow paths to the LAO1 ACTION B uxi iar aer ystem noperable, restore to OPERABLE status wii in 72.h orforbin HOTSHUTDOWN within the. next 12 .hdursi ... .ACTION D ERQIEET d rpsdRqie cinD 0 S RVILLNCERE VREMNTSAdd proposed ACTION C and second Condition of ACTION D Add proposed M04 437.1.7 The required Motor Driven Feedwater Pump and flow paths to the ACTIONF Auxil1ary Feedwater System shall be.,demonstrated OPERABLE: a. Deleted b. At least once per 31 days by: I 0.1.When in MODE- with RATED THERMAL POWER great than40%, verifying th t each manual valve in the Moto Driven Feedwatev Pump sucti96 and discharge lines that affec/ the system's capabilitYto deliver water to-the steam enerators is locked in its poqper' position.SR 3.7.5.1 2. When. in MODE 1 verifying that in its correct with RATED THERMAL POWER greater than 40%, each power operated valve in the flow path is position., that is not locked, sealed, or otherwise secured in position DAVIS-BESSE, UNIT I 3/4 7-12a Amendment No. 4,-3_ 200 0 Page 4 of 6 Attachment 1, Volume 12, Rev. 1, Page 100 of 461 Attachment 1, Volume 12, Rev. 1, Page 101 of 461 ITS ITS 3.7.5 PLANT SYSTEMS that is not locked, sealed, or L04 SURVEILLANCE REQUIREMENTS, (Continued) othenwise secured inn position0 SR 3.7.5.1 3. When in MODE I *at RATED THERMAL POWER equal to or less 'than (including Note) 40% or when i n MODES 2 or 3,, verifying that each valve t (manual or power the Motor Driven Feedwater Pump flow path is able to. be .positioned locally for del~ivering, flow to the Auxiliary Feedwater System.(Abi.lity i s dlemon .rate.d by verifying; theý p~rese-e 0of handwheel s for alll manual. >Ives and .the bf-eit r(r:handwheels or1 lavai~lable pow/' :supply for motor operated v ves.)SR 3.7.5.3 c. At least once per 92 days an prior to. entry ifto MODE 3 from MODE:A03 SR .75. C. iq(.if, notA perfored~in .the:past 92 days)I by:-1. Verify~ing prer; operation of each power. o erated and:auto atic in' the Motor Driven .F eedw)ter Pup .to thie Lxil iary Feedwater System.. ' 2. otojlomVeri fyi ng ýle. Motor.* Driven Feedwater tarts -,fromth 3.. Verifying proper operation of the Motor Dri~ven:-Feedwater Pump.**ISR 3.7.5.7 d. At least once each. REFUELING INTERVAL by: I. 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 StoragelTanks .to the steam A03 generators. JThe fl~ow path to the steam generathrs shall be)Verifiel 1prior to/en eringTMlDE 3 flom ME. 4 y either steam g nerator level change ,or Auxiliary Feed ater. Safety LA05 Grade low Indication. Verification of Motor /riven Feedwa er:Pump System'flow capacity 'is not re uired.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'Systemp the Surveillance Requirement shall be met within 72 hours 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 I greater than 40% RATE THERMALI 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 htis surveillance. Ifone auxiliary feedwater pump or flow 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. 1, Page 101 of 461 Attachment 1, Volume 12, Rev. 1, Page 102 of 461 ITS 3.7.5 ITS 0 PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

2. VerifYingPN operaino the Motor raio o ven F ter Pump lube oil 3., Verifying prope6 operation of manual valves by shiti the Motor Driven I FeedwatrPump between the Main Feedwater Ste and the Auxiliary Lo Feedwat~r System.I e. After any modificatio or repair to the Motor Drien Feedwater Pum System that could affect the system's pabIlity to deliver water from the Condensate torage Tanks tothe Auxiliary Feedwate System, the affected flow path shall be demo strated available as follows:*1. If the mod' cation or repair is in the Auxillary Feedwaterfowpath downstream of th--;$ I.tnr nfIr/rnn PImn tI t flow line tiein.to MotOr Driven 0 Feedt Pump shall pump water Storage Tanksto the: Auxilia Feedwater System andthe flow path avallaill will be veffled by either steam. enerator level change orAuxlilary Feedwater afety Grade Flow Indica n.2. If the odification or repair is upstream of the Motor riven Feedwater Pump test ow line tie-in, the Motor Driven Feedwater Pu p.shall pump water from the Con ensate Storage Tanks to the test flow linea thie flow path availability will be erfied by Motor Driven Feedwater Pump flow ndlcatlon.

n Following each extended COLD SHUTDOWN (greater that 30days In MODE 5). by.1 Verifying that there is a flow path between the Motor Driven FeedwaterSystem and the Auxiliary Feedwater System by pumping water from the:Condensate The flow path to the 4eam generators A shall bve feed or to tern MOE3 OD 4bye e!rsteam generator I vel change or-Auxillary Feedwater Safety Grade 0ow Indication. L ,)Verificatil of Motor Driven Feedwater Pump flow capacity iý not required.SR 3.7.5.7 f........... i ........... This surveillanc Oting shall be performed prior to entering DE 3 from MODE 4 if the modificati is made In MODES 4, 5, or6. Verification of the Motor Driven Feedwater>Pump flow capacity is not required.DAVIS-BESSE, UNIT I 3/4 7-12c Amendment No. 103,.193, 261 0 Page 6 of 6 Attachment 1, Volume 12, Rev. 1, Page 102 of 461 Attachment 1, Volurme 12, Rev. 1, Page 103 of 461 DISCUSSION OF CHANGES ITS 3.7.5, EMERGENCY FEEDWATER (EFW)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 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 monthsj 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 O applicability shall not be made unless the Surveillance Requirement(s) Davis-Besse Page 1 of 14 Attachment 1, Volume 12, Rev. 1, Page 103 of 461 Attachment 1, Volume 12, Rev. 1, 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 hours. 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 hours. Under similar conditions, ITS 3.7.2 ACTION D states to be in MODE 3 in 6 hours and MODE 4 in 12 hours. This changes the CTS by specifying that MODE 3 must be achieved within 6 hours.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 hour 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 hour, and the unit to be placed in MODE 3 in the next 6 hours and in MODE 4 in the following 6 hours. 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 hours to restore the inoperable AFW train to OPERABLE status and the CTS 3.7.1.7 Action would allow 72 hours 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 9 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. 1, Page 104 of 461 Attachment 1, Volume 12, Rev. 1, Page 105 of 461 DISCUSSION OF CHANGES ITS 3.7.5, EMERGENCY FEEDWATER (EFW)as these footnote allowances are followed, the 72 hour 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 hours 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 hours and to , MODE 4 within 12 hours 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 hours to 48 hours; 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 hours to no time (i.e., no restoration time is provided); and c) reducing the time to be in MODE 3 from 7 hours to 6 hours and MODE 4 from 13 hours to 12 hours 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 if the 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 hours 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 hours after reaching 800 psig in the steam generators is acceptable Davis-Besse Page 3 of'! 4 Attachment 1, Volume 12, Rev. 1, Page 105 of 461 Attachment 1, Volume 12, Rev. 1, 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.O RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 1 -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. 1, Page 106 of 461 Attachment 1, Volume 12, Rev. 1, 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 requirement to 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. 1 Page 107 of 461 .Attachment 1, Volume 12, Rev. 1, 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 I -Removing Details of System Design and System Descriptioný 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 Procedural Details 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. 1, Page 108 of 461 Attachment 1, Volume 12, Rev. 1, 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 Not used.LA07 (Type 4 -Removal of LCO, SR, or other TS requirement to the TRM, UFSAR, ODCM, QAPMIST Program, or /iP) 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 hours at MODE 3 steaming to atmosphere, followed by a cooldown to decay heat removal Davis-Besse Page 7 of 14 Attachment 1, Volume 12, Rev. 1, Page 109 of 461 Attachment 1, Volume 12, Rev. 1, Page 110 of 461 DISCUSSION OF CHANGES ITS 3.7.5, EMERGENCY FEEDWATER (EFW)entry conditions at the designý 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 Procedural Details 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 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 Procedural Details 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 Davis-Besse Page 8 of 14 Attachment 1, Volume 12, Rev. 1, Page 110 of 461 Attachment 1, Volume 12, Rev. 1, Page 111 of 461 DISCUSSION OF CHANGES ITS 3.7.5, EMERGENCY FEEDWATER (EFW)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, IST 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 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 (Category 4 -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 hours 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 hours 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 Davis-Besse Page 9 of 14 Attachment 1, Volume 12, Rev. 1, Page 111 of 461 Attachment 1, Volume 12, Rev. 1, Page 112 of 461 DISCUSSION OF CHANGES ITS 3.7.5, EMERGENCY FEEDWATER (EFW)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 (Category 4 -Relaxation of Required Action) 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 hour or be in HOT STANDBY (MODE 3) within 6 hours and HOT SHUTDOWN (MODE 4) within the following 6 hours. 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 hour, 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 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 hour.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, if the 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.0 Davis-Besse Page 10 of 14 Attachment 1, Volume 12, Rev. 1, Page 112 of 461 Attachment 1, Volume 12, Rev. 1, Page 113 of 461 DISCUSSION OF CHANGES ITS 3.7.5, EMERGENCY FEEDWATER (EFW)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 Frequen6ies 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 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.0 Davis-Besse Page 11 of 14 Attachment 1, Volume 12, Rev. 1, Page 113 of 461 Attachment 1, Volume 12, Rev. 1, Page 114 of 461 DISCUSSION OF CHANGES ITS 3.7.5, EMERGENCY FEEDWATER (EFW)The purpose of CTS 4.7.1.2.1.b.l, 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 hours 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 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 (Category 6 -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 Davis-Besse Page 12 of 14 Attachment 1, Volume 12, Rev. 1, Page 114 of 461 Attachment 1, Volume 12, Rev. 1, Page 115 of 461 DISCUSSION OF CHANGES ITS 3.7.5, EMERGENCY FEEDWATER (EFW)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 (Category 5 -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 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 0 of the turbine driven Main Feedwater pumps. At that time, the MDFP is realigned Davis-Besse Page 13 of 14 Attachment 1, Volume 12, Rev. 1, Page 115 of 461 0 Attachment 1, Volume 12, Rev. 1, Page 116 of 461 DISCUSSION OF CHANGES ITS 3.7.5, EMERGENCY FEEDWATER (EFW)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.0 0 Davis-Besse Page 14 of 14 Attachment 1, Volume 12, Rev. 1, Page 116 of 461 Attachment 1, Volume 12, Rev. 1, Page 117 of 461 5 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)0 0 Attachment1, Volume 12, Rev. 1, Page 117 of 461 Attachment 1, Volume 12, Rev. 1, Page 118 of 461 CTS EFW te 3.7.5 0 3.7 PLANT SYSTEMS 3.7.5 Emergency Feedwater (EFW te wo Auxiliary Feedwater (AFW) trains; and he Motor Driven Feedwater Pump (MDFP) train.00 j, consisting of: sEFWtrains shall be OPERABLE 3.7.1.2, 3.7.1.7 DOC M04 LCO 3.7.5--------- ------- ý!-t--NOTE- [the MDFP train Only ne EFWVtr which includes a mgt efdriven' Urp is required to be OPERABLE. in MODE 4.0 APPLICABILITY: MODES 1, 2, and 3, MODE 4 when steam generator is relied upon for heat removal.ACTIONS------ ---------------------------- .--------------- NOTE DOC A02 LCO 3.0.4.b is not applicable when entering MODE 1.CONDITION REQUIRED ACTION COMPLETION TIME DOC L01 A, One stea supply to 1 A.1 Restore laffected 9uipment:] urbine driv n EFW one to OPERABLE status.pump ino rable. AFW train T inoperable due to one OR I inoperable steam supply------------ NOTE -.......... Only applicable if MODE 2 has not been entered following.refueling. OneFturbine doen EFWI F inoperable in MODE 3 following refueling. 0 BWOG STS 3.7.5-1 Rev. 3.1, 12/01/05 0 Attachment 1, Volume 12, Rev. 1, Page 118 of 461 Attachment 1, Volume 12, Rev. 1, Page 119 of 461 CTS 0 EFWS 3.7.5 0 ACTIONS £oninue)... CONDITION REQUIRED ACTION COMPLETION TIME 3.7.1.2 Action a, 3.7.1.7 Action 3.7.1.2 Action a, 3.7.1.7 Action, DOC M02 B. One EFW train B Restore EEWtrain to 72 hours inoperablegfor reasons OPERABLE status.other than Condition in MODE 1,2, or 3..1[WLequired Action and associated Completion Time of Condition A MOR.1 Be in MODE 3.A N.D BnDD E2 Be in MODE 4.6 hours (0 TSTF-412 Two EFFW trains for reasons other than Condition C inoperablel in MODE 1, 2, or 3.0 DOC L02 fThreel EFW trains inoperable in MODE 1, 2, or 3.FO. 1-NOTE --.-.---..---- LCO 3.0.3 and all other LCO Required Actions requiring MODE changes are suspended until one EFWtrain is restored to OPERABLE status.Initiate action to restore one EFW train to OPERABLE status.Immediately MDFP DOC M04 Required E train M1 Initiate action to restore inoperable in MODE 4. E train to OPERABLE ET1 --status.Immediately TS2F 0 BWOG STS 3.7.5-2 Rev. 3,1, 12/01/05 0 Attachment 1, Volume 12, Rev. 1, Page 119 of 461 Attachment 1, Volume 12, Rev. 1, Page 120 of 461 3.7.5 CTS 4 INSERT 1 AFWI DOC M02 C. Onelturbine den EFW train inoperable due to one inoperable steam supply.C.1 Restore the steam supply to the r e train to OPERABLE status7.4[2o 48hours 4[2o 4 hours 00 0 00 AND 4mFp FMotor dr en EFW train inoperable. OR C.2 Restore the o ldrive EFW train to.OPERABLE status.0 ,Insert Page 3.7.5-2 Attachment 1, Volume 12, Rev. 1, Page 120 of 461 ( Attachment 1, Volume 12, Rev. 1, Page 121 of 461 cTs EFW t 3.7.5 0 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.7.1.2.1.b.1, 4.7.1.7.b.2, 4.7.1.7.b.3 Verifyeach E FWmanual, power operated, and INET2 automatic valve in each~water flowpath and in both steam supplyfiow paths to the steam tur fne nrven-pumps, that is not locked, sealed, or otherwise secured in position, is in the correct position.4.7.1.2.1.a.1 SR 3.7.5.2.......................-.....- NOTE --.------------------------- Not required to be pe rformed for the-eurbiri-driven F p n juntil 24M] hours after reachingpsig in the steam generators. Verify the developed head of each u'the flow test point is greaterthan orequal to, the required developed head.4.7.1.2.1.c.1 SR .7.5 1 ,-.----.--

ý-NOTE§ý ---------------------- W Not required tobe performed until 124Mhours after reaching [800lpsig in the steam generators. 31 days In accordAnce with the fnserviceT Testing/Program fi months 0D 0 00 00 0 0 12. Not required jo-be met in MODE 4.1 Verify each tEV automatic valve that is not locked, 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 37.5.%---..........................- NOTF .-.---------------......... [ Not required to be performed until B24Ehours after reaching P000psig in the steam generators. 0 0 00 12. Not required ta-6e met in MODE 4.1 Verify each EwI__pump starts automatically on an actual or simulated actuation signal.BWOG STS 3.7.5-3 Rev. 3.1, 12/01/05 0 Attachment 1, Volume 12, Rev. 1, Page 121 of 461 Attachment 1, Volume 12, Rev. 1, Page 122 of 461 3.7.5 CTS 4.7.1.7.b,3 INSERT 2 0---------

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 hours after MDFP train is aligned to the AFW System.Operate the MDFP train.92 days 0 Insert Page 3.7.5-3 Attachment 1, Volume 12, Rev. 1, Page 122 of 461 Attachment 1, Volume 12, Rev. 1, Page 123 of 461 CTS EFW t 37.5 0 SURVEILLANCE REQUIREMENTS centiriued~ ___SURVEILLANCE FREQUENCY 4.7.1.2.1.c.3, SR 3.7.51 Verify proper alignment of thezyequired JEFIVfloW paths by verifying valve nrmenl0vfrom the: condensate stora I jto each steam generator. MODE 5" MODE 6, or defueled for a cumulative period of> 30 days SR 3.7.5.67 [P rma CHANNEL FUNCTIONALTEST'for the 31 days']E pump suictio mpressure interlocks. E 0" I, '. e in SR 3.7.5.7 Perform CHANNEL CALIBRATION for the FW [18] months.]pumpesuctionpressure interlocks. / _0 0 INSERT 4 NSERT 5 BWOGSTS 3.7.5-4 .Rev. 3.1, 12101/05 0 Attachment 1, Volume 12, Rev. 1, Page 123 of 461 Attachment 1, Volume 12, Rev. 1, 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 4.7.1.7.f.1 MDFP flow paths by verifying flow from the condensate storage tanks to each steam generator. Prior to entering MODE 3 following refueling or whenever plant has been in MODE 5, MODE 6, or defueled for a cumulative period of > 30 days INSERT 5 4.7.1.2.1.d 0 SR 3.7.5.8 Perform CHANNEL CHECK on each AFW 12 hours train Steam Generator Level Control System.SR 3.7.5.9 Perform CHANNEL FUNCTIONAL TEST on 31 days each AFW train Steam Generator Level Control System.4.7.1.2.1.d 4.7.1.2.1.d SR 3.7.5.10 Perform CHANNEL CALIBRATION on each AFW train Steam Generator Level Control System.24 months 0 Insert Page 3.7.5-4 Attachment 1, Volume 12, Rev. 1, Page 124 of 461 Attachment 1, Volume 12, Rev. 1, 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 0 Davis-Besse Page 1 of 2 Attachment 1, Volume 12, Rev. 1, Page 125 of 461 Attachment 1, Volume 12, Rev. 1, 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).12. ITS SRs 3.7.5.8, 3.7.5.9, and 3.7.5.10 have been added to be consistent with CTS 4.7.1.2.1 .d.0 0 Davis-Besse Page 2 of 2 Attachment 1, Volume 12, Rev. 1, Page 126 of 461 Attachment 1, Volume 12, Rev. 1, Page 127 of 461 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)0 0 Attachment 1, Volume 12, Rev. 1, Page 127 of 461 Attachment 1, Volume 12, Rev. 1, Page 128 of 461 All changes are 0 er B 3.7.5 B 3.7 PLANT SYSTEMS B,3;7.5 Emergency Feedwater(EFVW ter 0'BASES iINSERT Ij BACKGROUND The EFW Sstem auto D ically supplies fee ter to the: earn INSRT .generatouto iremove, ecay heat from the eactorCoo'n Sytem (RCS) Pon the lo.t of normal feedwater u I The umps take.suction through 4edparae an enent ctlon linesfrom the AEW"condensate storage tank4(CS) (LCO 3.7.6' "Condensate Storage Tank (S _ "), and pump to the steamrgenerator secondary side through the J [' nozzles. The stearmi 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 stearnmsafety valves (MSSVs) (LCO 317,1, 'Main Steam Safety Valves (MSSVS)"), or atmospheric vent valvesl(AWs) (LCO 3,7,.4 "Atmospherc Vent Valves]s)"1. Itle main condenser/is available, steam may releasedvi eurbi Bypass System an recirculated to the CST/.SI(yThe fell~wn ytedescription is providodd.s an example A ug.AFW stemdescrtion should be. provided by the specific unit. The steam Ysemconsts o urbie rive E Wpumps, each of whichIEM II-O p~rovides a nominal 100% and o enonsafet-JademotR-f~n * .E_ E pur. The steam tur ine rive pumps receive'stearn from AFW either of the two main steam h-aders, upstream of the main steam isolation valves (MSIVs). heF ystem supplies.p com nhea er headers, capable offeeding either o steam generators. The 100% capacity each is sufficient to remove decay heat and cool the unit to 4ecay $eat meoval Sysem (DR entry conditions. The normally. receives a supply of water from the CS .A safety grade source of water is alsofsupplied by[ the Service WaterSystem (SWS). Automatic valves on the supply piping open on low pressure in the supply piping to transfer the water supply from the CS to the SWS. A third source of.water can be supplied by A-W@-Lmroanua ly aligning the fire protection header to the E._ ump suctioni-- Thus, the requir ments for diversity i motive Power sour esfor the EFWI System are t.R EFW is capable of supplying feedwater to the' steam generators during normal unit startup, shutdown, and hot standby conditions. We] FW t is designed to supply sufficient water to cool the unit to s D HRFentry conditions with steam being released through theAy-s or M oratmospheric vent valves BWOG STS B 3,7.5-1 Rev. 3.1, 12/01/05 0!Attachment 1, Volume 12, Rev. 1, Page 128 of 461 Attachment 1, Volume 12, Rev. 1, Page 129 of 461 B 3.7.5 0 INSERT I 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 0 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. 0 Insert Page B 3.7.5-1 Attachment 1, Volume 12, Rev. 1, Page 129 of 461 Attachment 1, Volume 12, Rev. 1, Page 130 of 461 All changes are QI"7 unless otherwise noted J EFW B 3.7,5 0 BASES BACKGROUND (continued) [ AFW System INSERT 4 The E actuates automatically on/low.steam gerator level, low stea generator press e, or loss of fourjreactor coo nt pumps. _EF" tF e is discussed in thehFSAR, Sectionsp9.2 7,jandh9 2 81 (Refs. 1 and.2, respectively). 0 APPLICABLE SAFETY ANALYSES The System mitigates the consequences of any event with alass of n _/normal feedwa"ter ... .. ..The ddesignrbasisof the Systemr is. to supply water to the steam generator to remove~decay heat and other residual.heat, by delivering at AFW least the minimum required flowratetothe steamgeneratarsat pressures corresponding to the. lowest stearenerator safet N.valve set pressure plus 3%0..In addition, the System must supply:enough makeup water to replace steam~generatar seconda inventory being lost;as steam as the unit cools to MODE 4 conditions. )fficient EFW flow mustals' be_availa e to account for flow oss e.such as pump recirculatiorand a inir Ibrea s.0 The limiting Design Basis Accidents (DBAs) and transients fodr the System are as follows-ate lne break and b. Loss of main feedwater. In addition, theminimum availableP flow and system characteristics are serious considerations in the analysisof a small break loss.of coolant accident.AFW _SThe Systemdesign is~such that it can perform its function following a loss of the turbine driven main feedwater pumps or an F" combinedI loss ofinormal o~4ser power." The F System satisfiesiCrterion 3 of 10 CFR 50.36(c)(2)(i0ip and the MDFP train satisfies Criterion 4 of 10 CFR 50.36(c)(2)(ii). 0 BVAOG STS B 3.7.5-2 Rev. 3A, 12101/05 0 Attachment 1, Volume 12, Rev. 1, Page 130 of 461 Attachment 1, Volume 12, Rev. 1, 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. 0 0 Insert Page B 3.7.5-2 Attachment 1, Volume 12, Rev. 1, Page 131 of 461 Attachment 1, Volume 12, Rev. 1, Page 132 of 461 I All changes are l, unless otherwise noted EFWSte B 3.7.5'0 BASES LCO This LCO provides assurance that f] EFW t 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 AFW trains and,* .*. .' ,the MDFP trai)boundary. MThreeeen ent EFWpumpsrn two iverstrain s-re. tjh)required.to be OPERABLE to ensure the availability of Fr ea... cayt removal capability for all events accompanied by a loss of offsite power and a single failure. VThis is accomplished by powering, twopumps by'steam driven turbines supplied with steam from a source not isolated by AF k the closure ,f the MSIVs, and onehump from a power source that, in the event of loss of offsite power,NSupplied by {}emergency diesel motor driven generator.m c EFW en is considered to be OPERABLE when the components each of and flow paths required to provide EFW flow to the steam generators are OPERABLE. This requires tha EFWhmp{ be r OPERABLE with redundant steam supplies from each of the main steam, w e g t lines-upstream of the MSIVs and'capable of supplying EFW flow to: (except when a steam generator of theL~ steam genereato^rs, Th..nonsafety grade_ M,..is inoperable and isolated) "tth Syemaelo J..p.u-_... s and #t Iassociated flow path to the ,ystemWare aIso required to be OPERABLF. The piping, valves, instru mentation, and controls in the required flow paths shall also be OPERABLE. The primary and capable of supplying flowto and secondary sources of water to W- EFW are requiredto be both steam generators (except OPERABLE. The associated flow paths from K EFW primary when a steam generator is and secondary sources of water to all EFW pumps also are required to, be inoperable and isolated) f OPERABLE.The LCO is modified by a Note indicating that EH ýrain ich I includols'a motordriven EF ump is required in MODE 4. This is 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 lturbin"riven EFpumpE!-W A 0 00 0 APPLICABILITY. In MODES 1, 2, and 3, t e EFW t is 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, em eratu. above , e EFW t may be used for heat removal via the steam generators. In MODE 4, the 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 forD-R andcIR EFW t is not required. heat removal 0 BWOG STS B 3.7.5-3 Rev. 3.1, 12/01/05 0 Attachment 1, Volume 12, Revi 1, Page 132 of 461 Attachment 1, Volume 12, Rev. 1, Page 133 of 461* K All changes are TSTF unless otherwise noted ý 4 EFVtV t BASES ACTIONS A.Note prohibits the application of LCO 3.0.4.bto an inoperable EFW train when entering MODE 1. There is an increased risk associated with entering MODE 1 with EFW inoperable and the provisions of LCO3.0.4.b, which allow entry into a MODE or other specified condition in the Aoplicability with. the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this :circumsta nce.A.1 one AFW train 4 due to one inoperable 'With oneoeth earn tepl-s t he turbin FW *um steam supply no-perab la turbi r purnlis inoperableowhile in MODE 3 foran reason immediately following refueling, action must betaken to restore the f a rao an AFW train inoperable ecluipment to an OPERABLE status within 7 days. The 7 day AFW Completion Time is reasonable, based on the following: reasons:. an AFW train.-- 1a ' eo th noperabitity, of]steaý to thturbin e EFV "and thetubrdvn" due to one inoperable I .'" , train is still capable of steam supply the 7 day Completion Time is reasonablesince there is a performing its specified reIuadintisteaonsupplyh fneofor theeiutrhenrf o/- ... -ostulated events .,[ý b Frteioeaiiy t1ubh rvrEMp while ih.MOD E 3- 4---(bie'yu to te mnjreuei dcy hea'tleesin this situation.

c. the inopera bility of h steam ne tot etur. river an AFW train due to one inoperable an-inoperable turbine urn ven-EFWpum hile in MODE.3 AFWtrain 4 steam supply immediately following refueling, the:7 day Completion Time is' due to the availability of redundant OPERABLEEFW due to the low probability of an event re r use off the pump.for animo erable Condition Ais modified by a Note Which limits the applicability of the pump in ODE 3 iConditionto when the unit has not entered MODE 2 following a refueling.

pump.in........ C. ondition A allows one EP rain to be inoperable for 7 days vice the 72 hour Completion Time in Condition B. This longer Completion Time is based on the. reduced decayheat following refueling and prior to the.reactor being critical.B\AOG STS B 3.7.5-4 Rev. 3.1, 12/01105 0 Attachment 1, Volume 12, Rev. 1, Page 133 of 461 Attachment 1, Volume 12, Rev. 1, Page 134 of 461 0 I All changes are 'STF unless otherwise noted J EFW t B 3.7.5 0 BASES...ACTIONS (continued). in MODE 1, 2, or 3 Efor B.1 reasons other than B.1 Condition When one EFW trains, (pump-or flow path) is inoperable, action must be taken to restore the-train to OPERABLE status within turs This Condition includes the loss of two steam supply lines to on theturbiW pumpsr The 72 hour Completion Time is reasonable, based on the redundant capabilities afforded byf( EFW , tirne.needed..for repairs, and the low probability of a DBA E ocurring during this time period.LI2 D. r, C.1, or C.2]M When r RequiredAction:A. or Re Action BA cannot be completed within the required Completion Time, or when two EFWtrains for reasons other than are inoperablein MODE 1,2, or 3,Mthe unit must be placed in a MODE in Condition C -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 I]i--F!dhours. 0 0 0 0)0 0 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.In MODE 4, witho`*= trains inoperable, operation is allowed to the MDFP continue because only lne moi EFWVrain is required in accordance with the Note that modifies the LCO. Although not required.the unit may continue to cool down and initiate DHR.Required Ai .1 is modified by a Note indicating that all required MODE changes.or po uctioný are suspended until at least one EFW train is restored to OPERABLE status-WithlaljEFW trains inoperable in MODE 1, 2, or 3, 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 nonsafety grade equipment. In such a condition, the unit should not be perturbed by any action, including ac power change, that might result in a trip. The seriousness of this condition requires that action be started immediately to restore at least one EFWtrain to OPERABLE status.LCO.3.0.3 is not applicable, as it could force the units into a less safe condition. 0 0 BWOG STS.B 3.7.5-5 Rev. 3.1, 12/01/05 0 Attachment 1, Volume 12, Rev. 1, Page 134 of 461 Attachment 1, Volume 12, Rev. 1, Page 135 of 461 0 K All changes are TSTF unless otherwise noted J INSERT 6 B 3.7.5 C.1 and C.2 train_____ With the fImotoimdEF train (pump or flow path) inoperable and one C AWtouf rbin FFW trains inoperable due to one inoperable steam supply, action must be taken to restore the affected equipment to OPERABLE status within [M48M hours. Assuming no single active failures when in this condition, the accident (a I MSLB) could result in the loss of the remaining steam steam generator supply to the inoperable EFWM pump due to the faulted .In this condition, the EFW may no longer be able to meet the required flow to generators the assumed in the safety analysis, [either due to the analysis yquiring flow from two EFW pumps or d o the remaining EFW pump having feed a faulted SG].I 4 0 0 0------------------------------------ REVIEWER'S NOTE ----------

I ER E E i R c N Licensees should adopt the appropriate Completion me based on their plant 0 e p a r a u et f M e S io i -n e design. The 24 hour Completion Time is applica to plants that can no longer meet the safety analysis requirement of 100% FW flow to the SG(s)* assuming Itu qe Vp0e L eT is no single active failure and a FLB or MSLB sulting in the loss of the remaining................................ steam supply to the inoperable turbine ven EFW pump. The 48 hour Completion Time is applicable to pla s that can still meet the safety analysis.................. 0[The 24 hour Completion Time is reasonable based e remaining OPERABLE steam supply to the affected tur driven EFW pump, the availability of the remaining OPERAB urbine driven EFW pump, and the low probability of an event occurrin at would require the inoperable steam supply to be available for the aleted turbine driven EFW pump]0 A _ MThe 48 hour Completion Time is reasonable based on the fact that the remaining-train is capable of providing 100 % of the EFW flow requirements, and the low probability of an event occurring that would challenge the T (0 0 0 Insert Page B 3.7.5-5 Attachment 1, Volume 12, Rev. 1, Page 135 of 461 Attachment 1, Volume 12, Rev. 1, Page 136 of 461 EFW B 3t7.5 BASES ACTIONS (continued) In MODE 4, eithertheý steamgenerator loops or the DHIR, loops can be used to' provide: heat removal, which is ad dressed in LCO 3,4.6, "RCS r iLoo's -MODE 4'" Vflth nEiWtrain inoperable, action must.be[R1i nfl imrnediately estore the; inoperable train to OPERABLE status. 0K0 SURVEILLANCE $SR 3.5.:1 .REQUIREMENTS Verifying the. correct alignment for mrianual, 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 applyi.tovalves 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 applyto valves that cannot be inadvertently misaligned, such as check valves. This Surveillance does, not require any testing or valve, manipulation; rather, it involves verification thatthosedvalves 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 37.5.2 Verifying that each Tpumps developed head at the flow test point is 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 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. BWOG STS B 3.7.5-6 Rev. 3.1, 12/01/05 0 Attachment 1, Volume 12, Rev. 1, Page 136 of 461 Attachment 1, Volume 12, Rev. 1, Page 137 of 461 OINSERT 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.B 3.7.5 0 Insert Page B 3.7.5-6 Attachment 1, Volume 12, Rev. 1, Page 137 of 461 Attachment 1, Volume 12, Rev. 1, Page 138 of 461 B 3.7.5 BASES SURVEILLANCE REQUIREMENTS (continued) This SR is modified by.a Note indictting that theSR should be deferred until suitable test conditions are estab ished. This deferral is .reqUiredl because there is insufficientstearm pressure to perform the~test, SR 3.7.5.1 This SR verifies that Ee delivered to the appropriatesteam generator in the event of any accident or transient that generates a earn lan Fee dwat ture o tro stem SFRC signal by ..LAFW demonstrating that each*automatic valve:'in the flow path actuates tO ýi corrept positionon an actual or simulated actuation signal. This SR is nolt required for valves that are locked, sealed ,Ior otherwise secured in position under administrative controls., The (Bmonth .requency is, based on the need to perforrmthis Surveillance under the conditionsthat apply~during a unit outageand the potential for an Unplanned transient:if r-]- the, Surveillance were performed with the reactor at, power. The m Fnth. Frequency islalso acceptabl e based on operating experience 0 and design reliability of the equipment.]This SR is rdified by a Note I/'TSTF-ý I that states the SR i not required to be met in MO, 4.ý InMODE 4, thei Sre u12.A tr n is already alined and oi er n.-This SR Is modified sya Not s. o ,in ica es that the SR be deferred' until; ~ I Lndcting suitable test-onditions are established. This deferral is.required:becauuse thereis insufficient steam pressureto perform the test] [The] Note[2]1 states that the SR is. not required to be met in MODE 4. [In MODE 4, the required pump is alreadyloperating and the autostart function is not, required.] [in MODE 4,.the heatfremoval requirements: would be less providing more time foroperator action to manually start the required, F- pump] p SR 3 ,7.5.t9--]This SR.verifies that the l Wfpumps start in the event of any accident or transient that generates an SFRCS signal by FW d6monstrating that each E-EW urmp starts automafi-i-lly on 24 an actual or simulated actuation signal. rrhese pur3ps-a -equired in 0The monthFrequency is based.on the need to perform this.Surveillance under the~conditionslthat.apply during a unit outage and the potential foran unplanned transient if the Surveillance were performed inwiththe reactor at power. This SR is modified by1DaE J. Note[ J]dicate that the SR be deferred until suitable test conditions are established. This deferral i.s required because there is insufficient steam BWOG STS B 3.7.5-7 Rev. 3.1,,12/01/05. 0 Attachment 1, Volume 12, Rev. 1, Page 138 of 461 Attachment 1, Volume 12, Rev. 1, Page 139 of 461 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 hours 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).B 3.7.5 0 Insert Page B 3.7.5-7 Attachment 1, Volume 12, Rev. 1, Page 139 of 461 Attachment 1, Volume 12, Rev. 1, Page 140 of 461 All changes are (: 1 unless otherwise noted:EFW t B 3.7.5 BASES SURVEILLANCE REQUIREMENTS (continued) pressure to perform the tejst.) [Tle]'Note [2] states thafthe SR is not,' required to be met in MOOBE 4. [in MODE 4. .the req~ie pump is already , operating and the aut>ýart fynctionis not required..j [tnMODE.4, thelh'eat- T.o va[ requi mentwo , dd be less providir mo;re time for "" ST-4, hngs start the required.A~c pum p.]not shown ........ ... ........ R VE E SN T ..,. ... ..TL--, .... --';Some plants. y not USe e AFN for heat rem val in MO The second j tificatio6 is provided r plants that use a tartupfeedwater pump rathe~r an AAN for startup ad shutdown_ _ _(for SR 3.7.5.6) and MODE 3 SR 37 .. -6 and SR 3.7.5.7} (for SR 3.7.5.7), following refueling or ThisSR ensures that teEFW is properly aligned by verifying the: flow paths-to eachsteam generator prior to entering MODE.:after~nore than 30.days in any combination of MODE 5 or 6, or defueled.OPERABILITY of EFW floW paths must bedemonstrated before sufficient core heat is generated that would require the0operation of[R EFWduring a subsequent shutdown. The.: Frequency isý reasonable, INSERT 9 based on engineering judgment, in view of other administrative controls to ensure that the flaw paths are OPERABLE. To further ensure EFWalignment, flow path OPERABILIT is Verified, f0ollwing extended 0 outages to determine no misalighmert of valveshas occurred. This SR ensures that the ow pathmfrom the CSItothe steam generator is cpropertyaligned. (T s SR is not required by the. units thatuse EFW for normal startuo a shutdown /0 SR 3.75,6 and SR 3 5.7 t w d 5 N 7 s* 7 hi P4 Forthisfacilitythe HANNEL FUNCTIONAL TEST alndCH NIEL dn CH NEl a Ica I CALIBRATION f the &W pump suction:pTe .s ure interloc are. as A heEF 5, 1 f t ot 0 r te i e Ica I S ecifica follows: T 0 a relay .This is ac(B N te 1)10 CH N EL FUNCTIC ca xt 0 S._ a I he herrequirc sure in f 'ta a s ngle -cont, A sticocessfu est of the required contact(s) of a chann relay may be TE T y may I of a cha nn rela rlo performed y the verification of the ch f tate a sinýle-contact of n_ 0 h i ý p 'cWication 0 per refueling interv c thmelay. This clarifies what is an acceptable, CH, NEL FUNCTIONAL t ti ange 0 ' S, re TEST: b 'a relay. This.isacceptablebecauseall the other;required nta s of the relay a r e Ver p IiTc'6 eLrP /chn corita of the.rela.yý.are Verified byoth6r Tech ical Specifications and a i c I nc IS ' I u0Lr non- echnica.1,Specffic;ationstestsýa.tleas.t,6

perrefueling interval with.icablo.6tehnsions.

0 0.INSERT 10 BWOG STS B 3.7.5;8 ,Rev. 3.1,12/01/05 Attachment 1, Volume 12, Rev. 1, Page 140 of 461 Attachment 1, Volume 12, Rev. 1, Page 141 of 461 B 3.7.5 OD 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.(D INSERT 10 SR 3.7.5.8, SR 3.7.5.9, and SR 3.7.5.10 These SRs are performed on each AFW train's Steam Generator Level Control System channels. This helps ensure the each AFW train properly controls steam generator level after an automatic start of the AFW train.Performance of the CHANNEL CHECK every 12 hours ensures a gross failure of instrumentation has not occurred. A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the two instrument channels could be an indication of excessive instrument drift in one of the channels or of something even more serious. CHANNEL CHECK will detect gross channel failure; therefore, it is key in verifying that the instrumentation continues to operate properly between each CHANNEL CALIBRATION. Agreement criteria are determined by the unit staff, based on a combination of the channel instrument

uncertainties, including isolation, indication, and readability.

If a channel is outside the criteria, it may be an indication that the detector or the signal processing equipment has drifted outside its limit. If the channels are normally off scale during times when surveillance is required, the CHANNEL CHECK will only verify that they are off scale in the same direction. A CHANNEL FUNCTIONAL TEST is performed on each channel to ensure the entire channel will perform the intended function.CHANNEL CALIBRATION is a complete check of the instrument channel, including the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy.CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drift between successive calibrations to ensure that the channel remains operational between successive tests. CHANNEL CALIBRATIONS must be performed consistent with the unit specific setpoint and tolerance. The CHANNEL CHECK Frequency of every 12 hours is based on operating experience that demonstrates channel failure is rare. Since the probability of two random failures in redundant channels in any 12 hour period is extremely low, the CHANNEL CHECK minimizes the chance of loss of protective function due to failure of redundant channels. The CHANNEL CHECK supplements less formal, but more frequent, checks of channel operability during normal operational use of the -displays associated with the LCO's required channels.The CHANNEL FUNCTIONAL TEST Frequency of 31 days is reasonable, based on operating experience and on other Surveillances (such as a CHANNEL CHECK), that ensure proper functioning between CHANNEL FUNCTIONAL TESTS.The CHANNEL CALIBRATION Frequency of 24 months is based on the need to perform this Surveillance under the conditions that apply during a plant outage.Insert Page B 3.7.5-8 Attachment 1, Volume 12, Rev. 1, Page 141 of 461 Attachment 1, Volume 12, Rev. 1, Page 142 of 461 EFWStr B 3.7.5 0 BASES REFERENCES

1. FSAR, Section]9.227$

2. FSAR, SectionfJ9.2.81

3. ASME Code forOperation and Maintenance of Nuclear Power Plants.00 00 BWNOG STS B 3.7.5-9 Rev. 31, 1210105 0 Attachment 1, Volume 12, Rev. 1, Page 142 of 461 Attachment 1, Volume 12, Rev. 1, 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. 0 Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 1, Page 143 of 461 Attachment 1, Volume 12, Rev. 1, Page 144 of 461 Specific No Significant Hazards Considerations (NSHCs)0 Attachment 1, Volume 12, Rev. 1, Page 144 of 461 Attachment 1, Volume 12, Rev. 1, 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. 0 Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 1, Page 145 of 461 Attachment 1, Volume 12, Rev. 1, Page 146 of 461 O ATTACHMENT 6 ITS 3.7.6, CONDENSATE STORAGE TANKS (CSTs)0 0 Attachment 1, Volume 12, Rev. 1, Page 146 of 461 Attachment 1, Volume 12, Rev. 1, Page 147 of 461*Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)0 0 Attachment 1, Volume 12, Rev. 1, Page 147 of 461 Attachment 1, Volume 12, Rev. 1, Page 148 of 461_ C ITS 3.7.6 ITS PLANT SYSTEMS CONDE NSATE STORAGE TANKS5 LIMITING CONDITION FOR OPERATION LCO 3.7.6. --7.1.3 The condensate storage tanks shall be OPERABLEFwith a.minimum A04 SR3.7.6.1 --vU gallons of water..usable APPLICABILITY: MODES 1, 2 and:3. Add proosedseondA Alicabilit M0 With the condensate storage-tanks inoperable,,within 4, hours'either ACTION A -a- a [Rjestore the, conden t6rae tanks to OPERAB r in MT ACTION 13 --=-jSHTDOWNfwlthin 0he 12 hors o, 4 .....-ACTIN B HUTDWN wthin e ex 12 ours or 4 wthout reliance on steam generator for heat removal b., Verif b administrative means the OPERA ILITY of the servfice water ACTION A s ste as a ac up supply to th auxiliar eedwater verify LA01 M01 once per 12 hours thereafter, and restore the'condensate storage anks to OPERABLE statu's within 7days or be:in HOTSHUTDOWN within ACTIONB n hours.ACTION~2 ..[wthout reliance on steam generator for heat removal.J 0L0 SURVEILLANCE REQUIREMENTS--,,, SR3.7.6.1 4.7.1.3.1 The condensate storage tanks shall be demonstrated OPERABLE at.least once per 12hours b verifying the con ile water volume to be within its limitslwhOf the tanks- are the suppR source for th uxl yfeedwater A03 DAVIS-BESSE, UNIT 1 3/4 7-6 Amendment No. 4447 200 0 Page 1lof I Attachment 1, Volume 12, Rev. 1, Page 148 of 461 Attachment 1, Volume 12, Rev. 1, 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 hours.CTS 3.7.1.3 Action b alternatively allows 4 hours 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 hours. 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 hours and once per 12 hours 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 hours.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 hours 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 0 Davis-Besse Page 1 of 3 Attachment 1, Volume 12, Rev. 1, Page 149 of 461 Attachment 1, Volume 12, Rev. 1, 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 if a 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 O 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 hours 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. 1, Page 150 of 461 Attachment 1, Volume 12, Rev. 1, 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 (Category 3 -Relaxation of Completion Time) With the CSTs inoperable, CTS 3.7.1.3 Action a requires restoration of the CSTs within 4 hours or be in MODE 4 within the next 12 hours, while CTS 3.7.1.3 Action b requires demonstration of OPERABILITY of the backup supply within 4 hours and restoration of the CSTs to OPERABLE status within 7 days or be in MODE 4 within the next 12 hours. ITS 3.7.6 Required Action A.1 requires the verification of OPERABILITY of the backup water supply within 4 hours 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 hours and in MODE 4 without reliance on steam generator for heat removal within 24 hours.This changes the time to be in MODE 4 without reliance on the steam generators for heat removal from 12 hours to 24 hours and adds an additional requirement to be in MODE 3 within 6 hours.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 hours 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 hours 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..0 Davis-Besse Page 3 of 3 Attachment 1, Volume,12, Rev. 1, Page 151 of 461 Attachment 1, Volume 12, Rev. 1, Page 152 of 461* Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)0 0 Attachment 1, Volume 12, Rev. 1, Page 152 of 461 Attachment 1, Volume 12, Rev. 1, Page 153 of 461 CTS CST3.7.3.7.6 0 3.7 PLANT SYSTEMS S ,0 3.7.6 Condensate Storage Tank4(Cý3.7.1.3 LCO 3.7.6 APPLICABILITY: The CSTItsshall be OPERABLE.MODES 1, 2, and 3, MODE 4 when steam generator is relied upon for heat removal.0 ACTIONS CONDITION Action a, Action b A. The ]CSfl inoperable. A.1 AND A.2 REQUIRED ACTION Verify by administrative means OPERABILITY~of backup water supply.Restore CST] to OPERABLE status.COMPLETION TIME 4 hours 0 AND Once per 12 hours.thereafter 0 7 days Action a, Action b 4.7.1.3.1 B. Required Action and B.1 Be in MODE 3. 6 hours associated Completion Time not met. AND B.2 Be in MODE 4 without 124M]hours reliance on steam generator for heat removal.SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.6.1 Verify tSý[Mee is gale 12 hours 0 0 000 usablvoume in the BVVOG STS 3.7.6-1 Rev. 3.0, 03/31/04 0 Attachment 1, Volume 12, Rev. 1, Page 153 of 461 Attachment 1, Volume 12, Rev. 1, 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.0 Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 1, Page 154 of 461 Attachment 1, Volume 12, Rev. 1, Page 155 of 461 WImproved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)0 0 Attachment 1, Volume 12, Rev. 1, Page 155 of 461 Attachment 1, Volume 12, Rev. 1, Page 156 of 461 K unless otherwise noted T AhnaCSTP B 3.7.6 B 3.7 PLANT SYSTEMS s BJ3.7.6 Condensate Storage Tanki,(CSo -f" and the Motor Driven r-:---q .lFeedwater Pump when (BASES waligned to the AFW mode BASES p _ the primary j--BACKGROUND ide asafety grad source of water to .thesteam generators .. "for reemovin decay and sensible heat fromi.the Reactor Coolant System/(RCS). The CSTprovideW a passive flow of water, by gravity, to the t Auxiliryenc_ Feedwater System (LCO 3,7.5, "Emergency A Feedwater (EFV) t ). The steam produced is released to the atmosphere by the main steam safety valves (MSSVs) or the atmospheric Vent valves.WVten the main stea! isolation valves ar open, the preferred eans-of heat removal is to ischarge to the con enser by the nonsafe grade path of the turbin bypass valves. T condensed steam i returned to the CST by the ondensate pump. his has the advanta of conserving condensate wle minimizing rele es to the environme Becauseothe C T is a principal compone in removing residual/eat from the RCS, it is esigned to withstand ea quakes and other rl INSERT 1 phenomena, as well as missiles that ight be generated by atural phenomen The CST is designed Seismic Category I t7 ensure availabili of the feedwater suppl .Feedwater is also av ilable from an alternat source s.A description of the CSZis found in thFSAR, SectionJ9.2.6g (Ref. 1). 2 I. f~or teAF ,source of APPLICABLE DThe -CSTprovide n water to [remove dqam.y heat and cool down system SAFETY h nitfollwing all .evetsin teaccident analysis, adiscussed in ANALYSES ei RChapters [6] and 5] (Refs. 2 dsp cively F 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 lanalysisasumpion i -water inventory for Soffstepower 30 minutes at MODE 3, steamingtroug1e ollowed-. by a cooldown to decay heat removal (DHR) entry conditions at the to atmosphere 13 ho design cooldown rate, The limiting event for the volume is the larl feedwater line break coincidht with a loss of offsie power. Single fa'ures that also affect this ev nt include the followi/g: BW2OG STS B 3.7.6-1 Rev. 3.0, 03/31/04 0 Attachment 1, Volume 12, Rev. 1, Page 156 of 461 Attachment 1, Volume 12, Rev. 1, 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 II.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.0 Insert Page B 3.7.6-1 Attachment 1, Volume 12, Rev. 1, Page 157 of 461 Attachment 1, Volume 12, Rev. 1, Page 158 of 461.I All changes are unless otherwise noted J CSTP B3.7.6 0 BASES.APPLICABLE SAFETYANALYSES (continued)

a. Failure oft dieselgenerator, p eringthe -motor dri en EFWpump to. the unaff cted steam generate (requiring addition.

I steam to drive.the tremaino~ig EFW pump turbin and.bU: Failure of he steam driven E pur. p (requiring .a I niger timhe for cooldown using only one motor riven EFW pump), These are no usually theý limitingf lures in terms of co sequences for these events I y~DTjeCS7satis

Criteria 2 and 3 of 10 CFR 50.36(c)(2)(ii).

LCO To satisfy laccident apat.ss assumption t4he[fWoAtt CQ5s must contain design considerations Jsufficient cooling water to, remove decay heat for 13 hours following-a with steam discharge to the atmosphere reactor trirom A02% RTI and then to cool down the RCS to DHR System entry condition assumin a cocet oss o0 o0stte power anp AF ms a e singe failur. VVbileý.so. doing, the CSTs must retain sufficient'water to ensure adequate net positive suction~head for the[Eduring the cooldown, to account-for any losses from the steamý drive [EFVV pump turbin , as well as toss curred before isolatingl ______________270,300 0 Lntain 'h love] reauire-is eauNv~aent~ta a usable volume of 25.0 gallons, which is based on holding the unit in MODE 3 for 13 hours, followed by a cooldo wn to bHR RSystem entry conditiorns. usable The OPERABILITY ofthe maintaining thetank aat or above~the minimum required e 00 0 0 APPLICABILITY In MODES 1, 2, 3, and in MODE 40]when'steam generator is being relied !upon for heat removal, the CST required to be OPERABLE.sare In MODES, 5 and 6, the CSTLNnot required because the System is not required.BW2OG STS B Rev. 3.0, 03/31/04 0 Attachment 1, Volume 12, Rev. 1, Page 158 of 461 Attachment 1, Volume 12, Rev. 1, Page 159 of 461 0 CSTP 0 B 3.7.6, BASES ACTIONS Al1 and.A.2 As an alternative to unit shutdown, the OPERABILITY of the backup (the Service Water System) water suppls shouId be'verified within 4 hours and once every 112 hours thereafter. The OPERABILITY of the backup feedwater supply must include'verification, by administrative means, of the OPERABILITY of flow EEýýýpaths rom the ackup suyto.te pumpsland aVa jlilityof thej Srequired volume, oI-atr in~the backup~suppl. The CST must be s restored to OPERABLErstatus within 7 days because.the backup supply may be erforming this fuy. rtienn addition to its n rmal function,. The is not the preferred source of 4 hour Completion Time!is reasonable, based on operating experience, to water (i.e.. it is not preferred to verify the OPERABILITY of the backup water supply. Additionally, add this backup source of water to the steam generators) verifying the backup:water supply every 12 hours is adequate to ensure the backup water supply continues totbe 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 .wter from the CSTN.B.1 and B12 any Required Action and If the CST'cannot be re telto OPERABLE status in the associated is not met Completion Time, the unit must be placed in a MODE in which' the LCO does no apply with the DHR System in operation. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours, and in MODE 4, without reliance on steam generators for heat removal, :within M24]hours.1 This allp<ANs an additional 6 hs fort e DHSystem to e Iplaced in service/,ifter-entering MODE V..0 40o 00 00 0 00 0 SURVEILLANCE REQUIREMENTS The allowed Completion Times arereasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without'challenging unit systems.SR 3.7.6.1 ble This SR verifies that the CSTS] containg the required olume of cooling water. The 12 hour Frequency is based onmOperating experience and the need for operator awareness of unit evolutions that may affect the CST4--a inventory between checks, The 12 hour 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.00 d 0 BWOG STS B 3.7T6-3 Rev. 3;0, 03/31/04 0 Attachment 1, Volume 12, Rev. 1, Page 159 of 461 Attachment 1, Volume 12, Rev. 1, Page 160 of 461 CSTs B 3.7.6 0 BASES REFERENCES 1J..FSAR, SectionM 1 .2461 2 SAR7hapte.

13. LFSAR, r1[5].I 00 0 i BWOG STS B 3.7.6-4 Rev. 3.0, 03531104 9 Attachment 1, Volume 12, Rev. 1, Page 160 of 461 Attachment 1, Volume 12, Rev. 1, Page 161 of 461 0 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.

0 0 Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 1, Page 161 of 461 Attachment 1, Volume 12, Rev. 1, Page 162 of 461 Specific No Significant Hazards Considerations (NSHCs)0 0 Attachment 1, Volume 12, Rev. 1, Page 162 of 461 Attachment 1, Volume 12, Rev. 1, 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. 0 Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 1, Page 163 of 461 Attachment 1, Volume 12, Rev. 1, Page 164 of 461* ATTACHMENT 7 ITS 3.7.7, COMPONENT COOLING WATER (CCW) SYSTEM 0 0 Attachment 1, Volume 12, Rev. 1, Page 164 of 461 Attachment 1, Volume 12, Rev. 1, Page 165 of 461*Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)0 0 Attachment 1, Volume 12, Rev. 1, Page 165 of 461 Attachment 1, Volume 12, Rev. 1, Page 166 of 461 ITS 3.7.7 ITS PLANT SYSTEMS 3/4.7.3. COMPONENT COOLING WATFR SYSTEM LIMITING CONDITION FOR OPERATION LCO3.7.7 3.7.3.1 Two Jindelkndentl component cooling water loops shall be OPERABLE.LAQi APPLICABILITY: MODES 1, 2,, 3 and 4.ACTION: Add proposed Required Action A.1 Notes V10 ACTIONA W[t one component cooling water loop inoperable, restore the inoperable loop to OPERABLE status within 72 hours o-r be in at least HOT STANDBY within the ACTION B nex hours. and in COLDSHUTDOWN within the following 30 hours.SURVEILLANCE REQUIREMENTS SR 3.7.7.1 4 .7.3.1 Each component cooling water loop shall be demonstrated OPERABLE:------- { A d d p ro p o s e d S R 3 .7 .7 .1 N o te } ....a. At least once per 31 days by veriying that each valve (manual, in the flow path power operated or automatic)*servicing safety related equi ment that is not locked, sealed or otherwise secured in position, is in its correct position. A03 b. At least once each REFUELING INTERVAL, by: 0 SR 3.7.7.2 SR 3.7.7.3 1. Verify~ing that each automatic valve, in the flow path,-C actuates to its. correct position on an[ Sfest.signal. that is not locked, sealed,r othe ised secured in position, t 2 VeriTy.ing.pnareacn component COOling water-emegnc u starts automatically on an [,test signal.DAVIS-BESSE, UNIT 1 3/4 7-14 Amendment No. 216 Page 1 of 1 Attachment 1, Volume 12, Rev. 1, Page 166 of 461 Attachment 1, Volume 12, Rev. 1, 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 hours 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. 1, Page 167 of 461 Attachment 1, Volume 12, Rev. 1, Page 168 of 461 DISCUSSION OF CHANGES ITS 3.7.7, COMPONENT COOLING WATER (CCW) SYSTEM S"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 I -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 0 necessary to be included in the Technical Specifications to provide adequate Davis-Besse Page 2 of 4 Attachment 1, Volume 12, Rev. 1, Page 168 of 461 Attachment 1, Volume 12, Rev. 1, 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 (Category 6 -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 (Category 5 -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. 1, Page 169 of 461 Attachment 1, Volume 12, Rev. 1, 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. 1, Page 170 of 461 Attachment 1, Volume 12, Rev. 1, Page 171 of 461 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)S 0 Attachment 1, Volume 12, Rev. 1, Page 171 of 461 Attachment 1, Volume 12, Rev. 1, Page 172 of 461 CTS CcwSystem 3.7.7 3.7 PLANT SYSTEMS 3.7.7 Component Cooling Water (CC". System OloopsB LCO 3.7.7 Two CCW& ýshall 'be .OPERABLE.. 3.73.1 0 APPLICABILITY: MODES 1, 2, 3, and 4.ACTIONS CONDITION Action A. One inoperable. REQUIRED ACTION A.1 --.-...---- NOTES.I. Enter applicable Conditionsa6nd Required Actions of LCO 3;8.1,"AC Sources -Operating,'ý for emergency diesel generator made inoperable by CCW., 0'COMPLETION TIME 2.Enter applicable Conditions and Required Actions of LCO 3.4.6, "RCS Loops-MODE 4," for decay heat removalre loop inoperable by CCW.0 0 Restore COW r into OPERABLE status.72 hours Action B. Required Action and B.1 Be in MODE 3. 6 hours associated Completion Time i not AND met.B.2 Be in MODE'5. 36 hours 0 BWOG STS 3.7.7-1 Rev. 3.0, 03131104 Attachment 1, Volume 12, Rev. 1, Page 172 of 461 Attachment 1, Volume 12, Rev. 1, Page 173 of 461 CTS CCW System SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.7.3.1.a SR 3,7.7T1 Isolation of CCWflowto individual components does not render. CCW System inoperable. Verify 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.Verify each CCW automatic valve in the flow path that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal.31 days 4.7.3.1.b.1 4.7.3.1.b.2 SR 3.7.7,2 m~~onthsý0 00~rquired SR 3.7:3 Verify each CCW pump starts automatically on an. [I I months actual or simulated actuation signal. 24 BVVOG STS 3,7.7-2.Rev. 3.0, 03131/04 0 Attachment 1, Volume 12, Rev. 1, Page 173 of 461 Attachment 1, Volume 12, Rev. 1, Page 174 of 461 0 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 4.1.3.0 0 Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 1, Page 174 of 461 Attachment 1, Volume 12, Rev. 1, Page 175 of 461 0 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)0 Attachment 1, Volume 12, Rev. 1, Page 175 of 461 Attachment 1, Volume 12, Rev. 1, Page 176 of 461 0 K All changes are 0 1 unless otherwise noted: CCW System 13.7,.71-B 3.7 PLANT SYSTEMS B 3.7.7 Component Cooling Water (CC") 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 CCWSystem serves as a-barrier to-the release Of radioactive byproducts between potentially radioactive systems and the Service Water System, and thus to the environment. 6 The 1AKtypical CCW System is arranged as two independent full capaci *-cooling loops, and has isolatable nonsafety related components. ach J~~safety relate,4 train includes a :flycal acty pump, surge~tank, .__--exchanger/piing, valves, and E~ach :safety re, ted train\* ' ' is powerea from a separate bu .-A~surge,:tanlk inthe system provides , __ __iced sufficient net positive suction head Vor each pump and isolation of arate enter l nonessential components on a low"tank levelsignal.0The pump in each half the P ri is automatically-started on receipt of a safety feature actuation ch :signai, and all nonessential components are. isolated. 'The surge tank is divii internally into two sep compartments by a c baffle approximately height of the tank. Ea compartment serves separate loop. This a that if a leak on one In occurs, water remains available to the other 0 nsures loop..Additional information on the design and operation of the CCW System along with a list of the components served, is presented in thelFSAR, Section[9.2.2] (Ref. 1). The principal safety related function of the CCW ler S stem is the~removal of decay heat from the reactor via the [Pecay heat removal (DHR heat chan e This may utilize the DHR System during a normal or post accident cooldown and shutdown, or duringthe-recirculation phase following a loss of-coolant accident. -0 APPLICABLE The design basis of the CCW System is to provide cooling water to the SAFETY Emer ency Core Cooling Systerfandlemereonjese generators -ANALYSES DBA conditions. The CCW System also supplies cooling components 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.MODE 4 -The CCW System also functions to cool the unit fromIIHPHentry conditions (T, <cjF) to MODE 5 Tr"id <M200 FTduring normal and 2* -post accident operations. The time required to coo from 3-,, o[j20drF is a function of the number of CCW and tDH i OeC; is sufficient to remove decay heat during subsequient l operations with. T 5 ,0 < 200PF. .The CCW System satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii). 0 BWOG STS B 37.7-1 Rev. 3,0, 03/31J04 0 Attachment 1, Volume 12, Rev. 1, Page 176 of 461 Attachment 1, Volume 12, Rev. 1, Page 177 of 461 B 3.7.7 (O INSERT I 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.0 Insert Page B 3.7.7-1 Attachment 1, Volume 12, Rev. 1, Page 177 of 461 Attachment 1, Volume 12, Rev. 1, Page 178 of 461 I All changes are 0 unless otherwise noted CCW System B 3.7.7 BASES LCO lpiare independent of each other to the degreethat each fip has separate controls and power supplies and the operation0of one does not depend on the other. In the event of a DBA, one i CCW is required-to provide the minimum heat removal~capability assumed in the lyanal sis for $ stems to which it supplies cooling water. To ensure loop this is met, two CC *rimust be OPERABLE. At least one CCW _will operate assuming the worst case single active failure occurs coincident with loss of.offsite. power.ACC r i is consideredOPERABLEwhen: portion of the a. It hasan OPERABLE pump and associated surge tanIkand F 0 0 b. The~associated piping, valves, heat exchanger,.and instrumentation and controls required to perform the safety related function are SOPERABLE.. individual The isolation of CCW frorn other components or;systemrs not required for safety may render thv'components or, systems inoperable, but:.does not affect the OPERABILITY of the CCW System.APPLICABILITY In MODES 1, 2, 3, and 4, the. CCW System is a normally operating system that must be prepa red to perform its post, accident safety functions, primarily Reactor Coolant System heat removal, by coolingthe DHRheat In: MODES 5 and 6, the OPERABILITY requirements of the CCWSystem are determined by thesystems it supports.ACTIONS A.1 Required Action A.1 is modified by a Note indicating that the applicable Conditions and Required Actions of LCO3.8.1, "AC Sources -Operating," and LCO 3.46, "RCS Loops- MODE 4," should be entered if an@ inoperalbleC results in an inoperable EDG or DHR loop. Thisis an-exception to LCO 3.0.6 and ensures the proper actions are taken-for these components. @ If one CC i is.inoperable, action must be taken'to restore*OPERABLE statuswithin 72hours. In this Pondition, the remaining@ OPERABLE CCWl is adequate to perform the heat removal function.The 72 hour Completion Time is reasonable, based on the redundant capabilities afforded bythe OPERABLE and the low probability of a DBA:occurring during this period.-0 0 BWOG STS B 3.7.7-2 Rev. 3.0, 03131104 Attachment 1, Volume 1,2, Rev. 1, Page 178 of 461 Attachment 1, Volume 12, Rev. 1, 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. 0 Insert Page B 3.7.7-2 Attachment 1, Volume 12, Rev. 1, Page 179 of 461 Attachment 1, Volume 12, Rev. 1, Page 180 of 461 I All changes are 1 unless otherwise noted J CCW System B 3.7.7 BASES ACTIONS '(continued),B.1 and.B2Z@ !f6the CCVi cannot be, restored to OPERABLE status in the Completion Time, the unit must be 'placed in a MODE in which the LCO To achieve this status, the unit must be placed in at least MODE 3within.6 hours and in MODE 5 within 36 hours.The allowed Completion Times are reasonable, based onoperating experience, to reach the required unit conditions from, full power conditions in' an orderly manner and without challenging unit systems.SURVEILLANCE REQUIREMENTS SR 3.7.7.1 This SR is modified by a Note'indicating.that the isolation of the CCW flow to individual cdmponents may iender those components inoperable, but does not affect the OPERABILITY of the CCW System.0 Verifying the correct alignment for manual, poWee 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 aremverified to be in the correct posit ion prior to .loking, sealing, or securing. This SR also does not apply to valves.which'cannot be iniadvertently misaligned,;such as check vaives. 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 isbased 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 CCWvalves on an actual or simulated actuatiorlfsignal. 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, 03131104.0!Attachment 1, Volume 12, Rev. 1, Page 180 of 461 Attachment 1, Volume 12, Rev. 1, Page 181 of 461 0 CCW System B 3.7.7 BASES, SURVEILLANCE REQUIREMENTS (continued) 24 month Frequency is based on the need to perform this Surveillance underuthe cýonditions that apply during a plant outage and the potentija ran-unplanned.transient if the Surveillance were performed with the rietor at power. Operating experience has shown that these mponents usually passthe Surveillance when performed at the 8 month Frequency.,Therefore,,the Frequencylis.acceptable from a reliability standpoint. 0 0 SR 3.7.7.3 (i.e., SFAS) This SR verifies proper, automatic operation of'the CCW pumps on an actual orsimulated actuatio signal. The CCW System is a normally operating system that cannotbe4 fully actuated as part of routine testing during normal operation. The month Frequency is based on.the need to perform thisý Surveillance under the conditions that apply during a plant oputage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power Operating experience has shown that thesecomponents usuallyepass theSUrveillance when p performed at thel8] month Frequency. Therefore, the Frequency is.acceptable from a reliability standpoint. REFERENCES ID 1.FSAR,SectionN .:4 0 o0 0 BWOG STS B 3.7.7-4 Rev. 3.0, 03/31/04 0 Attachment 1, Volume 12, Rev. 1, Page 181 of 461 Attachment 1, Volume 12, Rev. 1, Page 182 of 461 0 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.

0 0 Davis-Besse Page 1 of I Attachment 1, Volume 12, Rev. 1, Page 182 of 461 Attachment 1, Volume 12, Rev. 1, Page 183 of 461 Specific No Significant Hazards Considerations (NSHCs)0 Attachment 1T, Volume 12, Rev. 1, Page 183 of 461 Attachment 1, Volume 12, Rev. 1, 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. 1, Page 184 of 461 Attachment 1, Volume 12, Rev. 1, Page 185 of 461* ATTACHMENT 8 ITS 3.7.8, SERVICE WATER SYSTEM (SWS)0 0 Attachment 1, Volume 12, Rev. 1, Page 185 of 461 Attachment 1, Volume 12, Rev. 1, Page 186 of 461 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)Attachment 1, Volume 12, Rev. 1, Page 186 of 461 Attachment 1, Volume 12, Rev. 1, Page 187 of 461 ITS 3.7.8 ITS PLANT SYSTEMS 3/4.7.4 SERVICE WATER SYSTEM LIMITING CONDITION FOR OPERATION!LACi LCO3.7.8 3.7.4.1 Two ind-enffservice water loops shall-be OPERABLE.\APPLICABILITY: MODES 1, 2, 3 and 4.A T O :_.--- Add proposed Required Action A.1INotesM0 ACTION A ith one service water loop inoperable, restore the inoperable loop to A N ERABLE status within 72 hoursj-or be in at least HOT STANDBY within the next.ACTIONB- -_hours and in COLD SHUTDOWN within the following 30 hours.SURVEILLANCE REQUIREMENTS 4.7.4.1 Each service water loop shall be demonstrated 'OPERABLE: [ Add proposed SR 3.7.8.1 SR3.7.8.1

a. At least once per 31 days y veri ying a each valve(manual, inthe flow path power operated or automatic),servicing safety related eguiyjp ....t that is not locked, sealed or otherwise secured in position, is in A03 its correct position.i b. At least once each REFUELING INTERVAL, by: I SR 3.7.8.2 SR 3.7.8.3 I.. Verifying that each automatic valve in'the flow path I actualor L0 actuates to its correct position on ant est signal. .A02 tht__ isnot locked, sealed, or oth sod secured in positio, actuatio 2. Veri ying a eac service wa er emergency pump s arts L01 actuation LA02 DAVIS-BESSE, UNIT I 3/4 7-15 Amendment No. 216 Page 1 of 1 Attachment 1, Volume 12, Rev. 1, Page 187 of 461 Attachment 1, Volume 12, Rev. 1, 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 hours 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. 1, Page 188 of 461 Attachment 1, Volume 12, Rev. 1, 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 0 necessary to be included in the Technical Specifications to provide adequate Davis-Besse Page 2 of 4 Attachment 1, Volume 12, Rev. 1, Page 189 of 461 Attachment 1, Volume 12, Rev. 1, 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 (Category 5 -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. 1, Page 190 of 461 -Attachment 1, Volume 12, Rev. 1, 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.0 Davis-Besse Page 4 of 4 Attachment 1, Volume 12, Rev. 1, Page 191 of 461 Attachment 1, Volume 12, Rev. 1, Page 192 of 461 p Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)S 0 Attachment 1, Volume 12, Rev. 1, Page 192 of 461 Attachment 1, Volume 12, Rev. 1, Page 193 of 461 CTS SwS 3.7.8.3*.7 :PLANT SYSTEMS, 3.1.8 Service Water System (sws)Two SWS g shall be:OPERABLE. 3.74.1 LCO 3.7T8 0 APPLICABILITY: MODES 1, 2,3; and 4.ACTIONS CONDITION A. One SVW N-inoperable. REQUIRED ACTION Action A.1-...........- NOTES -............

1. M Enter applicable Conditionsand Required Actions of LCO 3.8.1, "AC Sources- Operating," for emergency diesel generator made inoperable by SWS.2. M Enter 4pplicable Conditions and Required Actions of LCO 314.6, "RCS Loops-MODE 4," for decay heat removal inoperable by SWS& [Restore SWS rn OPERABLE status.COMPLETION TIME 72 hours 0 0 00 0 0 Action B. Required Action and BA1 Be in MODE 3. 6 hours associated Completion Time lon not AND met.B.2 Be in MODE 5. 36 hours 0 BWOG STS 317.8-1 Rev. 3.0, 03/31/04 0 Attachment 1, Volume 12, Rev. 1, Page 193 of 461 Attachment 1, Volume 12, Rev. 1, Page 194 of 461 CTS SWS 3.7.8 4.7.4.1.a 4.7.4.1.b.1 4.7.4.1.b.2' SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.81 --.- -Isolation of'SVVS flow t'oindividual.compohents does'not render the SWS 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.SR 3.7.8.2 Verify each SWS automatic valve in the flow path [8] months that is not locked, sealed, or.otherwise secured in 24 position, actuates tO the correct position;oh an actual or simulated actuation signal.Frequired S R 3.7.8.3 Verify eachSWS pump.starts automatically on an 81 months actual or simulated actuation signal. 24 0 00 BVAOG STS 37.8-2 Rev. 30, 03/31104 Attachment 1, Volume 12, Rev. 1, Page 194 of 461 Attachment 1, Volume 12, Rev. 1, 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.

I)Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 1, Page 195 of 461 Attachment 1, Volume 12, Rev. 1, Page 196 of 461'p Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)0 Attachment 1, Volume 12, Rev. 1, Page 196 of 461 Attachment 1, Volume 12, Rev. 1, Page 197 of 461 I All changes are I u unless otherwise noted sws B 3.7:8 B 3.7 PLANT SYSTEMS B 3.7.8 Service Water System (SWAS)BASES BACKGROUND The SWS provides a heat sink for the removal of process and operating heat from safety related components during a Itrar iiin Design Basis Accident (DBA) or transient. During normal operation and normal shutdown, the SMVS also provides this function for various safety related and nonsafety related components. The safety related is covered by this LCO. 7 0 0 An MSV3 c 'nsists of two separate,'1/00% capacity safety re~tdcoig I ISE~t = wterra~s Eahtaiconsist, f a 10604 capacity pumnjd, one competent cooling water (CCV~he~at exchanger, pipingKvalving, and/Sinstru entation, The. pumps and valves are remote manually aligned, except in the unlikely event of a loss of coolant accident (LOCA). The n pumps are automatically started upon receipt of a safety feature actuation non-essential lsignal, and all essential valves are aligned to their post accident positions#" loads are isolated The SWSEaLi provides cooling r to the Control Room Emergency Ventilation System water cooled condensing unit, the .Emergency Core s_Cooling System (ECCS) pump room coolers, containment aircooler, and Component Cooling Water ..System heat exchangers urbmeriven coo nq waterystems The system provides cooling and is also a sourc of water to the WCS pump and the e rgencylfeedwater 0_ _ _ _ pumps, ap can provide a xurce 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 alon u Feedwater System and the MotorU Driven Feedwater Pump. With a list.of the components served, is presented in the FSAR, 2 SectionN9.2.1] (Ref. 1). The principal safety related function of the SWS is the removarof decay heat from the reactorvia the NCCW Systenr.APPLICABLE The design basis of the SVWS is for one-SWS HA-in conjunction with the SAFETY CCW System and a 100% capacity containment cooling system, ANALYSES -(containment spray, containment air coolers, ora combination) to. remove rj. core decay heat following a design basis LOCA, as discussed in the 0-FSAR, Section[6.

(Ref. 2). This provides for a gradual reduction in the temperature of this fluid, as it is supplied to the Reactor Coolant System (RCS) by'the Ion pumps.The SWS is designed to perform its function with a single failure of any active component, assuming loss of offsite power.0 BWOG STS B 3.7.8-1 Rev. 3.0, 03/31/04 0 Attachment 1, Volume 12, Rev. 1, Page 197 of 461 Attachment 1, Volume 12, Rev. 1, Page 198 of 461 B 3.7.8 0 INSERT I 0 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. Ope 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.0 Insert Page B 3.7.8-1 Attachment 1, Volume 12, Rev. 1, Page 198 of 461 Attachment 1, Volume 12, Rev. 1, Page 199 of 461 I All changes are nl)unless otherwise noted SWS B 3.7.8 0 BASES APPLICABLE SAFETY'ANALYSES (continued)

The SWS, in conjunction with the CCW System, also cools the'unit from Decay Heat Removal (DHR) Syster, as discussed -in the'F Section 8.3j (Ref. 3 entry conditions to MODE5 during normal and ost thie numbper tn oCeiquiredfor.this evolution is a function of the number of CCW and DHR Systemhat are operating. One SwS train is sufficient to remove decay heat during subse t an initial operation in MO S 5 and .This assumesa m ImurWS Swith Te, 6 < 200°F temperature of [ F occurring simultaneously with maximum heat loads on the system. , 9 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 P SWSr iýn are required to be OPERABLE to provide the required redundancy to ensure that the system functions to remove post accident heat loads, assumingthe worst case single active failure occurs coincident with the loss of offsite power.rloop_'Ansis considered OPERABLE when: a. It'has'an OPERABLE b. The associated piping, valves, [heat 9ý(changer and instrumentation and controls required to perform the safety related function are INSERT 2 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 if one ýS is inoperable, action must be taken to restore loop OPERABLE status within 72 hours. In this Pondition, the remaining rOPERABLE S is adequate to-perform the heat removal function, However, the overall reliability is reduced because a single failure in the 0 0 BWOG STS B 3.7.8-2 Rev, 3.0, 03/31/04 0 Attachment 1, Volume 12, Rev. 1, Page 199 of 461 Attachment 1, Volume 12, Rev. 1, Page 200 of 461 B 3.7.8INSERT 2 Furthermore, the spare SWS pump can be substituted for a normal SWS pump, provided the power supply for the pumpis aligned to the same essential bus as the pump it is replacing. 0 Insert Page B 3.7.8-2 Attachment 1, Volime 12, Rev. 1, Page 200 of 461 Attachment 1, Volume 12, Rev. 1, Page 201 of 461 B 3.7.8 SWS B 3.7.8 BASES ACTIONS (continued) Floop OPERABLE SVII. 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 inoperableSWS f resu0tsin an inoperable EDG. The~second Note indicates that the applicable 4 Conditions and Required Actions of LCO 3.4.6, "RCS Loops -MODE 4" should be entered if an inoperable SWS faIrkesults in an inoperable---i-L The 72 hour Completion Time is based on the redundant capabilities afforded by the OPERABLE r in, and the low probability of a DBA occurring during this period. loo B,_1 an d B.?2 lo If the SWS 4cannot be restored to OPERABLE status within the associated Completion Time, the unit must be placed in a MODE in which the LCO does not apply, To achieve this status, the unit must be placed in at least MODE 3 within 6 hours, and in MODE 5 within 36 hours.The allowed Completion Times are reasonable; based on operating experience, to: reach the required unit conditions from full power conditions in an orderly manner and without challenging 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_BVAOG STS B 3.7.8-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 1, Page 201 of 461 Attachment 1, Volume 12, Rev. 1, Page 202 of 461 SVS B 3.7.8 BASES SURVEILLANCE REQUIREMENTS (continued) SR 37.82on an actual or simulated actuation (i.e., SFAS) signal The SR verifies proper automatic operation of the SWS valves/TheSWS SW is a:norrnally operating system that cannot be fully actuated as part of the 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 ,/under 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 componentsusually pass the Surveillance when performed at the 8] month Frequency. Therefore, the Frequency is acceptable from a reliability standpoint, SR 3.7T8.3 The SR verifies proper automatic operation of the SWS pumps on an S actual or simulated'ctuation signal. The SWS is a normally operating 0 system that cannotbe fully actuated as part of normal testing during 24 normal operation, Th 8] month Frequency is based on the need to p erform 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 re liability standpoint. REFERENCES LI , FSAR, Section D9.21 2. FSAR, section 00 3, I'7iFSAR, S22ti~on.64 BVWOG STS B 3.7.8-4 Rev. 3.0, 03131/04 0 Attachment 1, Volume 12, Rev. 1, Page 202 of 461 Attachment 1, Volume 12, Rev. 1, 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.0 Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 1, Page 203 of 461 Attachment 1, Volume 12, Rev. 1, Page 204 of 461 Specific No Significant Hazards Considerations (NSHCs)0 0 Attachment 1, Volume 12, Rev. 1, Page 204 of 461 Attachment 1, Volume 12, Rev. 1, 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.

0 0 Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev.,1, Page 205 of 461 Attachment 1, Volume 12, Rev. 1, Page 206 of 461 pATTACHMENT 9 ITS 3.7.9, ULTIMATE HEAT SINK (UHS)e 0 Attachment 1, Volume 12, Rev. 1, Page 206 of 461 Attachment 1, Volume 12, Rev. 1, Page 207 of 461 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)0 0 Attachment 1, Volume 12, Rev. 1, Page 207 of 461 Attachment 1, Volume 12, Rev. 1, Page 208 of 461 ITS 3.7.9 ITS PLANT SYSTEMS 3/4.7.5 ULTIMATE HEAT 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 SR 3.7.9.2 a. A minimum water level at or above elevation 562.0 feet International' Great Lakes Datum, and b. An average water, temperature of 5 900 F.j 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 .hours and in COLD SHUTDOWN within jthe fo)16wing.30 hours.aO 0 SURVEILLANCE REQUIREMENTS SR 3.7.9.1, 4.7.5,1 The ultimate heat sink shall be determined OPERABLE at least once per 24 hours 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 0 Page 1 of I Attachment 1, Volume 12, Rev. 1, Page 208 of 461 0 Attachment 1, Volume 12, Rev. 1, 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 0 None LESS RESTRICTIVE CHANGES L01 (Category I -Relaxation of LCO Requirements) The CTS 3.7.5.1 Action states to be in HOT STANDBY in 2.5 hours and in COLD SHUTDOWN in the following 30 hours when the UHS is inoperable. ITS 3.7.9 ACTION A states to be in MODE 3 in 6 hours and in MODE 5 in 36 hours when the UHS is inoperable. This changes the CTS by providing an additional

3.5 hours

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. 1, Page 209 of 461 Attachment 1, Volume 12, Rev. 1, Page 210 of 461 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)0 0 Attachment 1, Volume 12, Rev. 1, Page 210 of 461 Attachment 1, Volume 12, Rev. 1, 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 APPLICABILITY: The UHS sha'll be OPERABLE.J'MODES 1, 2, 3, and 4.ACTIONS 0 CONDITION REQUIRED ACTION COMPLETION TIME A. [One or mor cooling A.1 lestore coolingltowe/ 7 days]towers with fne cooling fan(s) to OPERABL tower fan i operable. status......REVIEWER'S OTE----- B.1 Veri water temperature of Once per hour]The [ ]'F is the ma imum the OfHS is. [90]F allowed UHS temp rature 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 tern erature of the UHS > 0]°F and[ I°F.0 0 ACTION[ Required Actioaand associated Co pletion Time of Con ion A or B not met.OR ]UHS inoperablef-[- Ireasoys other t6n IContihon A or/]I P-1Be in MODE 3.AND g2 Be in MODE 5.-6 hours 36 hours D0 BWOG STS 3.7.9-1 Rev. 3.0, 03/31/04 0 Attachment 1, Volume 12, Rev. 1, Page 211 of 461 Attachment 1, Volume 12, Rev. 1, Page 212 of 461 CTS UHS 3.7.9 3.7.5.1.a, 4.7.5.1 3.7.5.1.b, 4.7.5.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 37. 9,1 Verify water level of UHS is >-a562Jft Ime rsea] 24 hoursm MIN In-ternational Gr7eat Lakes Da-tu-m{SR 3.7.9.2 @Verify average water temperature of..UHS is 24 hours,:5WOIfF.JSR 3.7.9.3 Operate-each coolinq fowerfan for> 15 ] utes. 31days 0 0 0 BWMOGSTS 3,719-2 Rev. 3.0, 03131/04 0 Attachment 1, Volume 12, Rev. 1, Page 212 of 461 Attachment 1, Volume 12, Rev. 1, Page 213 of 461 0 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 hour period., The analysis assumes the initial intake temperature is -90'F. Therefore the ACTION to verify UHS temperature averaged over 24 hours 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. 1, Page 213 of 461 Attachment 1, Volume 12, Rev. 1, Page 214 of 461 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)Attachment 1, Volume 12, Rev. 1, Page 214 of 461 Attachment 1, Volume 12, Rev. 1, Page 215 of 461 UHS B 3.7.9 B 3.7 PLANT SYSTEMS: B3,.7;9, Ultimate Heat'Sink (UHS), BASES5 BACKGROUND The UHS provides a heat sink.for process and operating heat from safety.related components during a transient oraccidentas Well as.during normal operation. This is done utilizing the Service Water System (SWS).The UHS 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 Idam), and the canals or conduits connecting the sources with, but not including, the cooling water-system intake structures, as discussed in the'*SAIR, 1)*./If cooolfg towers or portions thefeof are/required to accoyhplish the U HS'satfiny functions, they shouldAleet the/lsamerequirerr6nts as the si n(.FThe~two principal functions ofthUH are the dissipation of residual heat after a. reactor shutdown, and dissipation of residual heat after an accident.A variety of corplexes is used to meeI the requirements fjr a UHS. A lake or an ocea may qualify as a sin le source. If the c mplex includes INSERT 1 a water source 4ontained by a. structu e, it is likely that e cond source wll~d ra=n' I 00 (D0 0 (D The basic perf rmance requirements are that a 30 day s pply of water be available, and hat the design basis t rmperatures of safe related equipment not be exceeded. Basin of cooling towers g nerally include less than a 30 day supply of water, pically 7 days or le s. A30 day supply would e dependent on anolt er source(s) and a akeup system(s) for eplenishing the sourc in the cooling to r basin. For smaller basin ources, which may b 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 ma be required to meet the- sa e design criteria as ai Engineered Safety Feature (e.g.,!single failure considerations and m Itiple makeup wate sources may be reauired).-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 0 Attachment 1, Volume 12, Rev. 1, Page 215 of 461 Attachment 1, Volume 12, Rev. 1, Page 216 of 461 B 3.7.9 0 INSERT I 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 I (Ref. 2).0 Insert Page B 3.7.9-1 Attachment 1, Volume 12, Rev. 1, Page 216 of 461 Attachment 1, Volume 12, Rev. 1, 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 ANALYSES cooled down and piaced onMdecay~heat'remorval its- maximum post at swapover to the containment accident heatload occurs pproxin 2mInu es] after a designbasis. emergency sump loss bf.coolant accident (LOCA). eartis timeahe unit switches-from injection'to recirculation and the containment cooling systems are This is when required 'tb 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 uncertaintieszwhen.calculating decay heat, and the worst case failure (e.g;, singl failure of a Manmade structure). The UHS is designed in ac rdance 'with -consistent I Regulatory Guide 1.27 (Ref. 2), which, requires a 30 day supply of cooling\water in the UHS.The UHS satisfies Criterion 3 of ,10,CFR 50.36(c)(2)(ii). 0 0 0 LCO 0 The .UHS.is required to be OPERABLEand is~considered OPERABLE if Nit~contains a sufficient volume of water at or below the maximum temperaturejathat.would allow the SVVS to operate for at least 30 days 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 temperature should not and the level should not fall belowft mearea level during normal unit operation. Inentonal Great Lakes Datum 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 5and 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 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. ]Q 0 0 BWOG STS B 3.7.9-2 Rev. 3,0, 03/31/04.0 Attachment 1, Volume 12, Rev. 1, Page 217 of 461 Attachment 1, Volume 12, Rev. 1, Page 218 of 461* UHS B 3.7.9 BASES ACTIONS (continued) [B.1-------- REVIEWE 'S NOTE ---------- --. .The [ ] F.is th maximuma alowed U S 'teinperaturevalu and is based on temperatur limitatios.of the equ pmentthat is relied pon for 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 ded the temperature o the UHS averaged o er the previous 24 our period is>:[90])F. Wit the water temperatur of the UHS > [90]° , long term cooling capa ility of the ECCS load an 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 onitor the water te perature of the UHS and ver fy the temperature is [90]°F when avera ed over the previous 24. our period. The once per hour Completie Time tks into.consideratio UHS temperature va iations and the incr ased monitoring frequency n eded to ensure desigi basis assumptions ]nd equipment limitations a e not exceeded in this condition. If the wa er'temperature of the UHS ex eeds [90]°Fwhen ave aged over the% preyi us 24 hour period or the water temperature of the U S exceeds [ ]*F, C ndition C must be.entered im nediately.] 0 00 0 Ifthe equired Actions and Comp tion Time of Condition [A B] are not Imet/__. the UHS is inoperablelffoyreasons other than Condit n A or B]the unit must be placed in a MODE in which the LCO does not apply. o achieve this status, the unit must be placed in at least MODE 3 within 6. hours and in MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.SURVEILLANCE MSR 3.7.9.1 REQUIREMENTS 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\M pumps. The 24 hour 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 [a ft 1mea r4ea leve 562International Great Lakes Datum 0 0 0 0 BWOG STS B 3.7.9-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 1, Page 218 of 461 Attachment 1, Volume 12, Rev. 1, Page 219 of 461 0 .UHS B 3.7.9 BASES SURVEILLANCE REQUIREMENTS (continued) ]SR 3.7.912 This SR verifies that the SWS can cool the CCWIS stem to at least it, maximum design'temperature within the maximu.m accident or normal heat Ioadsfor 30 days following a Design Basis, Accident. The 24 hour 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 0 0 0[SR 3.7.9.33 Operatingea cooling tower fan fo ý: [15] minutes ens resthat all fans are OPERAB E and that all associ ted controls are fun ioning properly.It also ensur that fan or motor fai ure, or~excessive vi ration, can be detected for orrective action. 'The 31 day Frequency i basedon operating ex erience, known relia ilityvof the fan;uiits, the redundancy available, a d the-Iow probability f significant degrad tion of the UHS coolina tow r fans occurrina be ensurveillances. 1 0 00 0 0 REFERENCES Reg1ulFSAR, Sectiond.2.5 -e 2. Regulatory Guide 12ýýBWOG. STS B 3.7.9-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 1, Page 219 of 461 Attachment 1, Volume 12, Rev. 1, Page 220 of 461 0 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. 1, Page 220 of 461 Attachment 1, Volume 12, Rev. 1, Page 221 of 461 Specific No Significant Hazards Considerations (NSHCs)0 0 Attachment 1, Volume 12, Rev. 1, Page 221 of 461 Attachment 1, Volume 12, Rev. 1, 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. 1, Page 222 of 461 Attachment 1, Volume 12, Rev. 1, Page 223 of 461 Vp ATTACHMENT 10 ITS 3.7.10, CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS)0 0 Attachment 1, Volume 12, Rev. 1, Page 223 of 461 Attachment 1, Volume 12, Rev. 1, Page 224 of 461* Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)0 Attachment 1, Volume 12, Rev. 1, Page 224 of 461 Attachment 1, Volume 12, Rev. 1, Page 225 of 461 ITS 3.7.10 ITS 0 " PLANT SYSTEMS 3/4.7.6 CONTROL ROOM EMERGENCY VENTILATION.'SYSTEM LIMITING CONDITION-FOR OPERATION LCO 3.7.10 3.7.6.1 Two lindepondenticontrol room-emergency ventilation systems shall be OPERABLE," ,Add proposed LCO Note 1 L01 APPLICABILITY: MODES 1, 2, 3 and 4. MotAdd.ACTION: [Add proposed second Applicability] / for reasons other than Condition B ACTION A a. 5With one control room emergency ventilation system inoperable, restore the inoperable ssstem to OPERABLE status within,7. days or be in at least HOT STANDBY Within the, ACTION C [next 6hours and inCOLD SHUTDOWN within the following 30 hours.q Add proposed ACTION:B:ý L0 b. With one~channel of Station Vent Normal Range Radiation Monitoring instrumentation inoperable, restore the inoperable Channel to OPERABLE status, orisolate the control roomnormal: 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 both channels of Station Vent Normal Range Radiation Monitoring instrumentation O ~ ~inoperable, within, I hour, isolate the control room normal ventilation system and place a (,lea~st one control room emergency ventilation.system train in operation. ," proposed ATO ~dpooe SURVEILLANCE REQUIREMENTS Add proposed ACTION EA 4.7.6.1 Each control room emergency ventilation system shall be demonstrated OPERABLE:.... ' .ee ITS a. At least once per 12 hours by verifying that the control room air temperature is less than- 37 11 or equal to II 0OF when the control room emergency ventilation system is operating. SR 3.7.10.1 b. At least once per 31 days [on a STAGGEF&1 TEST BASIS yyioitiatingfromthýe L Icontrol room, flow tlOough the HEPA filters and charcoal dsrers and Pverif~y~ing~that 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, 0 Page 1 of 3 Attachment 1, Volume 12, Rev. 1, Page 225 of 461 ITS SR 3.7.10.3 Attachment 1, Volume 12, Rev. 1, Page 226 of 461 0 PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

1. [Dekted]2I [Deleted]3. [Deleted]d. [Deleted]e, At least once each REFUELING INTERVAL by:[. [Deleted]2. Verifying that the control room normal ventilation system is isolated by a[* signal and a Station Vent Normal Radiation Monitoring test signal;ITS 3.7.10 DAVIS-BESSE, UNIT 1 3/4 7-18 Amendment Nq. 134, 135, 155, 209, 217, 227, 244, Page 2 of 3 Attachment 1, Volume 12, Rev. 1, Page 226 of 461 Attachment 1, Volume 12, Rev. 1, Page 227 of 461 ITS 3.7.10 ITS 0 PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

SR 3.7.10.5 3.. Verifyfing that the makeup flow of the system is 300 cfm +/- 10% when supplying the control room with outside, air.f. :[Deleted] Agd [dDeleted1[Add proposed SR 3,7.10.4 e~0-DA VlS-B1Essr-,,UNT 1 3/4 7-19 Amendment No. 155,244;0 Page 3 of 3 Attachment 1, Volume 12, Rev. 1, Page 227 of 461 Attachment 1, Volume 12, Rev. 1, 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. 1, Page 228 of 461 Attachment 1, Volume 12, Rev. 1, 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 I -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 statesthat 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 o Technical Specifications. LA02 (Type 3 -Removing Procedural Details 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 I -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. 1, Page 229 of 461 Attachment 1, Volume 12, Rev. 1, 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. 1, Page 230 of 461 Attachment 1, Volume 12, Rev. 1, 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 hours 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. 1, Page 231 of 461 Attachment 1, Volume 12, Rev. 1, 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. Thischange 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 0 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. 1, Page 232 of 461 Attachment 1, Volume 12, Rev. 1, 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.0 Davis-Besse Page 6 of 6 Attachment 1, Volume 12, Rev. 1, Page 233 of 461 Attachment 1, Volume 12, Rev. 1, Page 234 of 461 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)0 Attachment 1, Volume 12, Rev. 1, Page 234 of 461 Attachment 1, Volume 12, Rev. 1, Page 235 of 461 K All changes are TSTF unless otherwise noted --CTS CREVS 3.7.10 3.7 PLANT SYSTEMS 3.7.10 Control Room Emergency Ventilatiofi System (CREVS)3.7.6.1 LCO 3.7.10 Two .CREVS trains shall beOPERABLE. DOC L01 DOC M01 El The control rom oundary may be opened intermitteritly under administrative control.T '-442. Only the d RE boundary is required to be OPERABLE TSTF during movement of irradiated fuel assemblies. APPLICABILITY: MODES 1, 2,3; d[During movement of rechy irradiated fuel assemblies]. 002 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME Action a A. One C.REVS train for reasons other inoperable than Condition B 1 DOC L01 B. ]CREVS trains GrE Oneormo inoperable due to A,1 Restore CREVS train to OPERABLE status.Restore contr room RE boundary to OPERABLE 7 days daysr I I LU 1I, I b I I". U i I ;> usI L. OL4 .boundary in MODE 1, 2, 3, or4.C. Required Action and C.1 Be in MODE 3.associated Completion Time of Condition A or B AND not met in MODE 1, 2, 3, or 4. C.2 Be in MODE 5.Action a.6 hours 36 hours BVWOG STS 3.7.10-1 Rev. 3,0, 03131/04 0 Attachment 1, Volume 12, Rev. 1, Page 235 of 461 Attachment 1, Volume 12, Rev. 1, Page 236 of 461 CTS 3.7.10 INSERT 1 DOC L01 B.1 Initiate action to implement mitigating actions.AND B.2 Verify mitigating actions ensure CRE occupant exposures to radiological, chemical, and smoke hazards will not exceed limits.AND Immediately 24 hours 0 Insert Page 3.7.10-1 Attachment 1, Volume 12, Rev. 1, Page 236 of 461 Attachment 1, Volume 12, Rev. 1, Page 237 of 461 CTS CREVS'3.7.10 ACTIONS continued) CONDITION REQUIRED ACTION COMPLETION TIME D. [Requited Actionand associated Completion Time of Corndition A no met during movement f[recently] irradiated fu I assemblies. DA OR D.2 Place in emergency mode if automatic transfer to emergency mode inoperable. Place OPERABLE CRE S train in emergency mod Suspend movement f[recently]irradiated f el assemblies.. L TSTF-448 changes not shown Immediately Immediately] ---G)G RE boundary DOC M01 O Ininoperable during movement of irradiated fuel assemblies. Suspend movement of~ irradiated fuel assemblies, Immediately LTSTF-44]8 changes not(1 shown DOC A02 Two CREVSitrains inoperable KF-FJ i1 MODE 1,2, 3, or 4 for reasons other than Condition B.Enter LCO 3.0.3.Immediately 448ST D SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.7.6.1.b SR 3,7.10.1 Operate each CREVS train for [(>10 cntinuous hours with e heaters operating or (fo system 1without he tersl > 15 minutes; S TSTF-448 31 days 0 0 BWOG STS 3.7.10-2 Rev. 3.0, 03131104 Attachment 1, Volume 12, Rev. 1, Page 237 of 461 Attachment 1, Volume 12, Rev. 1, Page 238 of 461 CTS CREVS 3.7.10 4.7.6.1.c 4.7.6.1.e.2 DOC L01 4.7.6.1.e.3 SURVEILLANCE REQUIREMENTS (continued)__ SURVEILLANCE FREQUENCY ,SR 3.7.10.2 Perform required CREVS filter testing in accordance In accordance with the &entilation Filter Testing Program (VFTPA. with the biFTF, SR 3.7.10.3 Verm [eac CREVS train actuate or the control ] months room isola es] on an actual or simulated actuation SR 3.7.104 Verify one CREVS tr *n can maintain a positive [18] months on a pressure of [0.125 inches water gauge relative t STAGGERED Ithe adjacent [area during the [pressurization] m e TEST BASISoperation at a ow rate of,<- 1330.0] cfm. /SR 3,7.10,5 lVerify the system makeup flow rate is,>_027ýn [1months M1_9M330Mcfm when supplying the M control room cfm with outside air.0 0 TST}448 BWOG STS 3,7.10-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 1, Page 238 of 461 Attachment 1, Volume 12, Rev. 1, Page 239 of 461 3.7.10-44 INSERT 2 Perform required CRE unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program.In accordance with the Control Room Envelope Habitability Program 0 Insert Page 3.7.10-3 Attachment 1, Volume 12, Rev. 1, Page 239 of 461 Attachment 1, Volume 12, Rev. 1, Page 240 of 461 0 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. 0 Davis-Besse Page 1 of I Attachment 1, Volume 12, Rev. 1, Page 240 of 461 Attachment 1, Volume 12, Rev. 1, Page 241 of 461 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)Attachment 1, Volume 12, Rev. 1, Page 241 of 461 Attachment 1, Volume 12, Rev. 1, Page 242 of 461 All changes are TST unless otherwise noted -CREVS 8 3.7.10 B 3.7 PLANT SYSTEMS 83.7.10 Control Room Emergency Ventilation System (CREVS)BASES BACKGROUND The CREVS provides a protected environment fromri which iocant ocpat control the unit following an uncontrolled release' of radioactivityL-or toxic ga~s]k-4-hazardous chemcais, -or smoke }INSERT 1 The CR EVS consists of two independent, ft a water con nsing unit, ass mblies. Eah train consists of.a roughingfilter, a high efficiency particulate air (HEPA)Jfilterla-a charcoal ie adsorber ConrThe CREVSis an emergencysystem. Upon. receipt of the activating C z- om- C E signal(s), the fr---ma Ic npl roo l itilation Oystem is automatica~l~l (approximately 300 cfm of' isolated which W and the CREVS can be manually started;: The roughing filters [outside air and 3000 cfm solatestheCRE Iwater ensin unitsremove any.large particles inthe aira of recirculation air) boundary, entrained drople present .to prevent excessive loading of the[operating at a flow rate of s< 300jcfmr HEPA and charcoal filters.ES A singlehrain, pressurize the ontrol room a 1.5 ft LEAKAGE CRE a eato about 1/8 inch water gauge,. he CREVS operation is discussed in th' FSAR, Section 9 4] (Ref. 1). relative to external areas adjacent to the CRE boundary (,.K 7 , r_9.-4.-1 a habitable environment in The CREVS is designed to maintain theý n o or30 days of ___continuous occupancy after a Design Basis-Accident (D0A), without exceeding a15 rem whole body dose or its equivalent to. any part of the body APPLICABLE The CREVS components are arranged in redundant safety related J SAFETY ventilation trains. The location of componentsandcducting within the ANALYSES ORE contro r yelo e ensures an adequate supply of filtered air to all ORE occupant RE occu areas requiring access. The CREVS provides airborne radiological CRocupntsprotection for thcontrol. eratorslas demonstrated by the coo Iroo entdose analyses for the most limiting design basis loss of coolant accident fission product release presented in th FSAR, .Section 15.4.6 Cha t15 (Ref. 2).INSERT3 0 The worst 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 unt t0eaen sources ofticgssochmcshtcul be released t/affect control room h itability,] The CREVS satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii). BW2OG STS B 3.7.10-1 Rev. 3.0, 03/31/04 Attachment 1ý, Volume 12, Rev. 1, Page 242 of 461 Attachment 1, Volume 12, Rev. 1, Page 243 of 461 B 3.7.10 TT- INSERT I trains that recirculate and filter the air in the control room envelope (CRE) and a CRE boundary that limits the inleakage of unfiltered air 448 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 accident conditions. This area encompasses the control room, and-r(encompas other non-critical areas to which frequent personnel access or also 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).. 0 Furthermore, the fuel handling accident, both. inside and outside containment, Yl'assumes the control room is isolated (Ref. 5).Insert Page B 3.7.10-1 Attachment 1, Volume 12, Rev. 1, Page 243 of 461 Attachment 1, Volume 12, Rev. 1, Page 244 of 461 I All changes are TSTF unless otherwise noted 9 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 requiredto be active OPERABLE to ensure that at least one is available if a. single ailure whole body or its equivalent to any disables the other train. Total system failurekcould. resu!t in exceeding a part of the body EDE dose of15 rere o the control wm opera ors inthe event of a large radioactive release. O CRE occupants/iýCREVS'ris~coidered OPERABLE when the individual-compodnents lim.it.CRE.occ.. nt n-eessary to controroperator exposure are OPERABLE in b trains A CREVS train is considered OPERABLE when the associated:

a. Fan is OPERABLqr-Fl

b. HEPA filter and charcoal absorber are not excessively restricting flow, and are capable of performing theirfiltration functionsm and c.

5 uctwork, valves, and dampers are OPERABLE, and air circulation can-be maintained. 0 0 0 0 0s In addition, the/control room boundary/ including the.inte. Iity of the walls,/floors, ceiling/X, ductwork, and acces~do~ors, must be nrintained within the assumpti~ons of the design analy~sisl T he LCO is modified by a Note allowing thelcn oetal boundary to be opened intermittently under administrative controls.1 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 should be proceduralzed and controls'consist of stationing a dedicated individual at the opening who, is and to restore the CRE boundary toa in continuous communication with the con roon. This individual Will o in t condition equivalent to tihe design condition jave a metod to rapidly caose e openingwen a need for o isolation is indicated. I A ORE0 4 and APPLICABILITY In MODES 1. 2, 3, ad 4,ý the CREVS must be OPERABLE to ensure that [5, and 6] and" roomlwill remain habitable during and following a DBA. during mo ment of CRE boundary irradia ed fuel the CREVS i required to During movement ofr irradiated fuel assembliest t l cope with e release must be OPERABLE to cope.with a release due to a fuel handling from a ru ture of an accidentl[invo ing handling recently irradiated fui. Due to radioactive outside w te gas tank. d R i oue 7ste is only required to mitigate fue~l h'NdlIng accidents LLeJinvolving har ling recently irradiated fuel (i.e. flk that has occupied p-a.... T.* ~ ~of a critical r actor core within the previous [X]-jays)]I BWOG STS B 3.7.10-2 Rev. 3.0, 03/31/04 0 Attachment 1, Volume 12, Rev. 1, Page 244 of 461 Attachment 1, Volume 12, Rev. 1, Page 245 of 461 0 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-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.INSERT 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.O INSERT 5A The LCO is modified by a second Note (Note 2) indicating that only the ORE 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. 1, Page 245 of 461 Attachment 1, Volume 12, Rev. 1, Page 246 of 461 0 I All changes are "--F unless otherwise notedg9 CREVS B 3.7.10 BASES ACTIONS A:1 for reasons other than an I inoperable CRE boundary, With one CREVS train inoperabl action must betaken to restore the inoperable CREVS train to OPERABLE status within 7 days. In this kondition, the remaining OPERABLE CREVS train is adequate to perform the.con room GCRE occupant ra ion 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, 0D0.---. B. P3....-------------

.-- -------- --- REVIE, E 'S NOTE-------------......

---..------- 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 intent nal or unintentiona entry into Condition B.[ INSERT 6 If the control ro m boundary is inoper ble in MODE 1, 2,13, or4, the CREVS trains c nnot perform their i ended functions, tions must be taken to restor an OPERABLE cont ol room boundary 'thin 24 hours.During the pern d that the control ro m boundary is inop rable, appropriate co npensatory measure (consistent with th intent of GDC 19) should be tilized to protect con ol room operators rom potential hazards such is radioactive. conta ination, toxic chemi ks, smoke, temperature a d relative humidity, nd physical securi .Preplanned measures shl uld be available to a ress these concer s for intentional and unintenti nal entry into the con ition. The 24 hour 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 hour Completion ime is a typically rea onable time to diag ose, plan and possibly rep i r, and test most pro ems with the contr I room boundary.C.1 and C.2 if any Required Action and associated Completion Time of I.nMODE1,2,3,or4,i-ftheinor Condition A or B cannot be met boundary caonot be restored to I that minimizes/accident risk Completion rimd, the unit must be placed in a MODE lin whifthe Le oes ot apply To achieve this status, the unit must.be placed in at:least MODE 3 within 6 hours, and in MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.in which the LCO does not apply 4I BWOG STS B 3.7.10-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 1, Page 246 of 461.) Attachment 1, Volume 12, Rev. 1, Page 247 of 461 B 3.7.10 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 to15 rem whole body or its equivalent to any part of the bod ] [50em T , 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 id el ,initiated to 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 hours 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 S of Required Page B 3.7.10-5 intentional or unintentional. The 24 hour Completion Time is reasonable based Action1B.2 of Required on the low robabilit of a DBA occurrin durnn this time period, and the use of mitigating actions. The 90 day Completion Tim is reasonable based on the 0 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. 1, Page 247 of 461 Attachment 1, Volume 12, Rev. 1, Page 248 of 461 CREVS B 3.710 BASES ACTIONS (continued) 0.1 and D.2 TSTF-448 Schanges not In MODE 5 oror] d ing movement of [recently] irradiat d fuel shown assemblies, if the ino rable CREVS train cannot be rest red to.'OPERABLE status wi hin the required Completion Time, he OPERABLE CREVS train must imi ediately be placed in the emerge cy mode. This action ensures that t " remaining train is OPERABLE, tt t no failures*preventing automatic actuation will occur, and that any a :failure will be readily detected, Required Action 0.1 is modified by aNote indicating to place the system' the emergency mode if automati transfer to emergency mode is inoperable. An alternative to R quired Action D0I is to immediately suspend activities that could release r dioactivity that might require, isola on of the control room. This places he unit in a condition that minimiz s the accident risk;This does not prec ude the movement of fuel to a safe position. ]101 Uor uring movement of[ifthe CRE assemblies, -o *boundary is immediately to suspend activities.that cou inoperable might require isolation of thej TSTF-448 condition that minimizes the accident risk.changes not movement of fuel to a safe position.shown 0 If both CREVS trains are inoperable inMODE 1,2, 3,or 4 for reasons other than an inoperableontr roomlboundary (iLe., Condition B), the CREVS may not be capable of performing the intended function and the unit is~in a condition outside the accident analysis, Therefore, LCO 3.03 must be entered immediately.,ST BWOG STS B 3.7.1.0-4 Rev, 3,0# 03/31/04 Attachment 1, Volume 12, Rev. 1, Page 248 of 461 Attachment 1, Volume 12, Rev. 1, Page 249 of 461 I All changes are TSTF unless otherwise noted CREVS B 3.7.10 BASES SURVEILLANCE REQUIREMENTS SR :3.7.10.1 Standby, systems should be checked periodically to ensure that they function properly. As the environment and normal operating.conditions on this system are not severet testin each train once every month th EAd filters, and o her cating oper led for ;> 15 minutes the ~___function of The 31 day Frequency is based on the knownpreliability of the equipment and the two train redundancy available. b SR 3.7.10.2 This SR verifies that the required CREVS testing is performed in accordance with the P!entilation Filter Testing Program (VFTP)O The MVFTPEiincludes testing HEPA filter performance, charcoal absorber efficiency, mini um system flow rate, and the physical properties of the activated charcoal. Specific test Pequencies and additional information are discussed in detail in theFVFTF _00 INSERT 7 This SR verifies the integrity of the co trol room enclosure and the assumed inleakpge rates of the poten ially contaminated ir. The control room positive pNessure, with respect potentially contaminated adjacent areas, is perio cally tested to verify at the CREVS is frnctioning properly. Dunig the emergency mo e of operation, the eREVS is ,designed to prossurize the control ro m [0.1251 inches water gauge positive pressore, with respect to adjacent areas, to pre ent unfiltered inleakage. Tý1 CREVS is designed to maintain this po tive pressure with one train at a flow rate of s [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 BWAOG STS B 3.7.10-5 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 1, Page 249 of 461 Attachment 1, Volume 12, Rev. 1, Page 250 of 461 B 3.7.10 0 TSF 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 rem whole body or its equivalent to any part of the body] [5. rerrTEDE] and the CRE occupants are protected from hazardous chemicals and smoke. This SR 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 rate. Condition B must be entered. /Required A ion B.3 allows time to restore the CRE boundary to OP7ERABLE status provi ded mitigating actions can en ure that the CRE remains w~ithin the licensing habitability limits for the occ pants following an accident. Compensatory measures are discussed in Regulatory Guide 1.196, Section C.2.7.36 (Ref. M) which endorses, with exceptions, NEI 99-03, Section 8.4 and Appendix F (Ref. ). These compensatory measures may[a-a[[ be -used as mitigating actions as required by Required Action B.2. Temporary analytical methods may also be used as compensatory measures to restore OPERABILITY (Re---IlM. 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. I 0-o Move to Insert __Page B 3.7.10-3 7 8 T 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 [ months is consistent with industry practice and other filtration SRs. T 4 0 0 Insert Page B 3.7.10-5 Attachment 1, Volume 12, Rev. 1, Page 250 of 461 Attachment 1, Volume 12, Rev. 1, Page 251 of 461 I All changes are TSTF unless otherwise noted " CREVS B 3.7.10 BASES REFERENCES

1. ,FSARS66tion

3. FSAR, Section 6.4 S 4. FSAR, Section AR, t 7 NEI 99-03, "Control Room Habitability Assessment." June 2001. .UFSAR, Section 15.4.7. (a8 bLetter from Eric J. Leeds (NRC) to James W. Davis (NEI) dated January 30 200anuary 30, 2004, "NEI Draft White Paper, Use of Generic Letter 91-18I~Process and Alternative Source Terms in the Context of Control Room~Habitability" (ADAMS Accession No. ML-040300694).

00 00 BWOG STS B 3.7.10-6 Rev. 3.0, 03/31/04 0 Attachment 1, Volume 12, Rev. 1, Page 251 of 461 Attachment 1, Volume 12, Rev. 1, 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. 0 Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 1, Page 252 of 461 Attachment 1, Volume 12, Rev. 1, Page 253 of 461 WSpecific No Significant Hazards Considerations (NSHCs)0 Attachment 1, Volume 12, Rev. 1, Page 253 of 461 Attachment 1, Volume 12, Rev. 1, 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. 0 Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 1, Page 254 of 461 Attachment 1, Volume 12, Rev. 1, Page 255 of 461 ATTACHMENT 11 ITS 3.7.11, CONTROL ROOM EMERGENCY AIR TEMPERATURE CONTROL SYSTEM (CREATCS)Attachment 1, Volume 12, Rev. 1, Page 255 of 461 Attachment 1, Volume 12, Rev. 1, Page 256 of 461 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)Attachment 1, Volume 12, Rev. 1, Page 256 of 461 ITS 0 Attachment 1, Volume 12, Rev. 1, Page 257 of 461 0 PLANT SYSTEMS 3/4.7.6 CONTROL ROOM EMERGENCY VENTILATION SYSTEM ITS 3.7.11 LIMITING CONDITION FOR OPERATION LCO 3.7.11 3.7.6.1 Two indepndent control room emergency vent ation systems slibeOPERABLE. APPLICABILITY: MODES 1, 2,3 and 4. Air Temperature A02 ACTION: A O A a. [With one control room emergency venti ation system inoperable, restore the inoperable Lsystem to OPERABLEstatus within [ays or be in at least HOT STANDBY within the ACTION B -next 6 hours and in COLD SHUTDOWN within the following 30 hours.b. With one channel of Station Vent Normal Range Radiation Monitoring instrumentation inoperable, restore the inoperablechannel to OPERABLE status, or isolate the control room normal ventilation system and place at least 6ne control room emergency ventilation system train in operation within.7 days.c, With both channels ofStation Vent Normal Range Radiation Monitoring instrumentation inoperable, within i hour, isolate the control room normal ventilation system and place at least one control room emergency ventilation system train in operation, See ITS 3,3.16 ]SURVEILLANCE REQUIREMENTS Air Temperature Control A 4.7.6.1 Each control room emergency entitionsystem shall be demonstrated OPERABLE: v a. At least once per l ours by verifying that the control room a1,tr mperature is less than L02 or equal to 110I when the control room emergency ventilgti6n system is operating.. ali~ ~ ~ ~~e ITStm soertn.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.c. At least once each REFUELING INTERVAL and in accordancewith the Ventilation Filter Testing Program (VFTP)..1 1_ See ITS 3.7.10 L08[Add proposed SR 3.7,11,1 DAVIS-BESSE, UNIT I 3/4 7-17 Amendment No. 1.35, 155,217,227, 0 Page 1 of I Attachment 1, Volume 12, Rev. 1, Page 257 of 461 Attachment 1, Volume 12, Rev. 1, 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 < 1 10 0 F every 12 hours 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. 1, Page 258 of 461 Attachment 1, Volume 12, Rev. 1, 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 hours that the control room air temperature is < 1 101F 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 hours 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. 1, Page 259 of 461 Attachment 1, Volume 12, Rev. 1, Page 260 of 461 0 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.0 0 Davis-Besse Page 3 of 3 Attachment 1, Volume 12, Rev. 1, Page 260 of 461 Attachment 1, Volume 12, Rev. 1, Page 261 of 461 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)0 0 Attachment 1, Volume 12, Rev.'1, Page 261 of 461 Attachment 1, Volume 12, Rev. 1, Page 262 of 461 CTS CR EATCS 3.7.11 3.7 PLANT SYSTEMS 37. 1 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 4 5 d 6 I[Durinq movement of frecentifrrradiated fuel assemblies].I Action a Action b ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One CREATCStrain I A.1 Restore:CREATCS train to 30 days inoperable. OPERABLE status..'B. Required Action and B.1 Be in MODE 3. 6 hours associated Completion Time of Co ition A not AND metfin MODV1, 2,3 o 4 B.2 Be in MODE 5. 36 hours C. [Required Action and I C.1 Place OPERABLE I mediately associated Completio CREATCS train'in Time of Condition A n t I operation. met during movemen of 1[recently].irradiated f9el OR assemblies. C.2 Suspend movement of Immediately] [recently] irradiated fuel assemblies. D. [ Two CREATC trains D.1 Suspend movement of Immediately] inoperable durig [recently] irradiated fuel movement of [r cently] assemblies. irradiated fue l / "" i assemblies. 0 0 BW0G STS 3.7.11 -1 Rev. 3.0, 03131/04 0 Attachment 1, Volume 12, Rev. 1, Page 262 of 461 Attachment 1, Volume 12, Rev. 1, Page 263 of 461 CTS 0 CREATCS.3.7.11 ACTIONS (continuedý CONDITION REQUIREDACTION ýCOMPLETION TIME E. Two CREATCS train E. Enter LCo 3.03. m/rheciately inoperable during /MODE 1, 2, 3, or.SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.11.1 Verify each CREATCS train has the capability to months remove'the assumed heat. load: 0 0 DOC L02 0 BWOG STS 3.7.11-2 Rev. 3.0, 03131/04 Attachment 1, Volume 12, Rev. 1, Page 263 of 461 Attachment 1, Volume 12, Rev. 1, Page 264 of 461 0 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.0 Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 1, Page 264 of 461 Attachment 1, Volume 12, Rev. 1, Page 265 of 461 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)0 0 Attachment 1, Volume 12, Rev. 1, Page 265 of 461 Attachment 1, Volume 12, Rev. 1, Page 266 of 461 i Alchanges are 1 u nless otherwise noted 9 0 CREATCS B 3.I11.B 3.7 PLANT SYSTEMS B13.7.11.

Control Room Emergency Air Temperature Control System (CREATCS)BASES BACKGROUND The CREATCS provides temperature control'for the control room following isolation of thecontrol 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 andair cooled condensing units must be OPERABLE for the CREATCS.to be-.OPERABLE. During emergency operation, the CREATCS maintains the and 85°. The CREATCS is a subsvstem< 1 10°F in the control room providing air temperature control for the control room .Operation of the CREVS is required for a Safety Features Actuation The CREATCSis an emergency system. On detection of high CREATCSto be hiygheam(SFAto signal a_ Icontainment bu ping pressure-or radiati low Reactor Cool t System in operation. of the Station Vent Normal 1pressure, or igh noble gas radioactvix in the station vent the nor a Range Radiation Monitors bontrol orrentilation Oystem~is automaticallyshut down, and the NCaontrol Room Emergency Ventilation Systemtcan be manually started.,A single train will provide the required temperature control. The CREAT CS operaton to maintain control room temperature is discussed in thetlA, 4 (Ref. 1). (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 S110°F in the control room temPera ur etween an .A single active failure of a CREATCS component does not impair the ability of the system to perform 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. 0 The CREATCS satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii). BWOG STS B 3.7.11-1 Rev. 3.0, 03/31104 Attachment 1, Volume 12, Rev. 1, Page 266 of 461 Attachment 1, Volume 12, Rev. 1, 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 resuft in the equipment operating temperature exceeding limits in the event of an accident.T,; e-- CAC ýtrain.4[ýý F!eJCRETC, iconsidered OPERABLE~when the individual components that are necessary to maintain control room temperature are OPERABLEib rn These component include thejcooling coils, 07 r YI-rw et ooled condensing units, and associated.temperature control traiý instrumentation. In additiontCREATCS~must be OPERABLEt0o the extent that air circulation can be maintained. APPLICABILITY and In MODES 1, 2, 3, 4, 15, and.6,] anp during movemen of [recently] 0 0.... irradiateid'fuk! assemblies [i,e,, fue/that has 0ccupied/part of a critical reactor coro within the previous[ days)], the CREATCS'must be OPERABLE to ensure that.the control room temperature wilt not exceed equipment OPERABILITY requirements following isolation of the control room, 3 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 ;ondition, 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 resultrin 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 tracan provide the required capabilities, and the alternate r nonsafety related cooling means (i that are available. Concurrent failure Wtwo CREATCS trains would re tin the loss of function capab lty; therefore, LCO 3.03 must0 b ntered immediately.J B.1 and B.2 In MODE , 2, 3, or 4, f the inoperable CREATCStrain cannot be: (I restored to OPERABLE status within the required 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 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner without challenging unit systems.BWOG STS B 3.7.1 1-2 Rev. 3.0, 03/31/04 0 Attachment 1, Volume 12, Rev. 1, Page 267 of 461 Attachment 1, Volume 12, Rev. 1, Page 268 of 461 O CREATCS B 37A11 BASES ACTIONS (continued) Cj and C.2[In MODE.5 or 6, or] during movement of [recently] irrad ated fuelAf the%inoperable CREAT Strain cannotbe restored to OPE ABLEstatus 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 adilyidetected. An alternative to R quired Action:C.11'is to immediatel suspend activities that could release adioactivity that might require: the i olation of the control room. Thi places unit in a condition that inimizes.accident risk. This does n t preclude the movement of fuel to ..safe position. ][In MODE 5.or 61or] during movement of [recently]i radiated'fuel assemblies, wit two. CREATCS trains inoperable,, ctionh must be taken to immediately uspend activities that couldrelease radioactivity that might require is lation of the control room. This pl es the unit in a condition that inimizes:accident risk. This does n t preclude the movement ofF el toa safe position..] E 1 If both CREA CS trains areinoperable in MODE ,2,3, or 4, the CREATCS m y not be capable of performingthe intended function and the unitis in condition outside the accident ana yses. Therefore, LCO 3.0.3 r st be'entered immediately. SURVEILLANCE SR 3.7.11.1 REQUIREMENTS This-SR .verifies that the heat removalcapabilityof the system is sufficient to remove the heat load assumed in the Msafety analyses SRs 24I consists of a combination of testing and calculations. A m onth.Frequency istappropriate, as significant degradation of the CREATCS is slow and is not expected over this time period.REFERENCES.

1. .1FSAR,.Section (D0,0331 0 0 BWOG STS B 3.7.11-3 Re~v. 3.0, 03131/04 Attachment 1, Volume 12, Rev. 1, Page 268 of 461 Attachment 1, Volume 12, Rev. 1, 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.0 Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 1, Page 269 of 461 Attachment 1, Volume 12, Rev. 1, Page 270 of 461 Specific No Significant Hazards Considerations (NSHCs)0 Attachment 1, Volume 12, Rev. 1, Page 270 of 461 Attachment 1, Volume 12, Rev. 1, 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.

0 Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 1, Page 271 of 461 Attachment 1, Volume 12, Rev. 1, Page 272 of 461 ATTACHMENT 12 ITS 3.7.12, STATION EMERGENCY VENTILATION SYSTEM (EVS)0 Attachment 1, Volume 12, Rev. 1, Page 272 of 461 Attachment 1, Volume 12, Rev. 1, Page 273 of 461 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)Attachment 1, Volume 12, Rev. 1, Page 273 of 461 Attachment 1, Volume 12, Rev. 1, Page 274 of 461 ITS 3.7.12 ITS CONTAINMENT SYSTEMS 3/4.6,5 SHIELD BUILDIQN EMERGENCY VENTILATION SYSTEM LIMITING CONDITION FOR OPERATION[AOl LCO 3.7.12 3.645,1 Two -e mergency ventilation'systems shall be OPERABLE, APPLICABILITY: IMODES 1, 2, 3 and 4.ACTION: ACTION A--- With one emergency .entilation system inoperableý,restore the inoperable systern to OPERABLE status within 7 days or be in at least HOT STANDBY within the nlext 6 hours and in COLD ACTION C --"within the following 30 hours;, SR 3.7.12.1 SR 3.7.12.2 SURVEILLANCE REQUIREMENTS 4.6.5.1 Each eimergency ventilation system shall be demonstrated OPERABLE: ,a. At least onceper 31:days0ona STA GERE TEST ASI bylinritiati ifrom t Scontrol room, flow/through the HEP:A fillers 42d charcoal adsorbers that the systemnoperates for at least 15 minutes.b. At least once each REFUELINGr INTERVAL and in accordance.with the Ventilation Filter Testing Program (VFTP).DAVIS-BESSE,J JNIT I 3/4'6-28 A~mendment No. 155,217,244, Page 1 of 4 Attachment 1, Volume 12, Rev. 1, Page 274 of 461 Attachment 1, Volume 12, Rev. 1, Page 275 of 461 G ITS 3.7.12 ITS CONTAINMENT SYSTEMS SURVEILLANCE REQUIREMENTS (Coritinue-d)' I. [Deletedl 2. [Deleted], 3. [Deleted]'

c. [Deleted]d. At least once each REFUELING INTERVAL by: 1. [Deleted]SR 3.7.12.3 2. Verifying that thle system starts automatically on any ontai n" isolation test signal; and SR 3.7.12.5 3. VePrify'ing that the filter cooling bypass valves canibe manually opened.DAVIS-BESSE, UNIT 1 3/4.6-729 Amendment No. 43;135,155,209,217,233, 244, Page 2 of 4 Attachment 1, Volume 12, Rev. 1, Page 275 of 461 Attachment 1, Volume 12, Rev. 1, Page 276 of 461 ITS 3.7.12 ITS CONTAINMENT SYSTEMS SHIELD BUILDING INTEGRITY LIMITING CONDITION FOR OPERATION.

LA01 3.6.5.2 Shield b fding integriX shall be rrintained. -LCO 3.7.12 APPLICABILITY: MODES 1, 2, 3 and 4 ACTION: ACTION B without shield building integrity, restore shield, building integrity within 24 or be in at least HOT STANDBY within: the next 6 hours and in COLD ACTION C HUTDOWN withinrthe following 30 hours.SURVEILLANCE REQUIREMENTS 4.6.5.2.1 jShi ed building integr~~alb dembnstrat/e'd at least once per ....131 "days- byverifying t h'at~airtjn d -osind the. bloou panels listed inf.ITa le-4,-1 a~re closed_ lxcept when the~airtight~doors ar eing used for](LCO NOTE --normal ransi ten and exit*SR 3.7.12.4 4.6.5.2,2 Shield building. integrity shall be, demonstrated at least once per I L05 REFUELING INTERVAL by verifying tha-tehEmnergency Ventilation System I train produces a negative pressure of greater than or equal to 0.25 inches I Water Gauge in the annulus within 4 seconds after the fan attains a flow I rate of 8000 cfm +/-. 10%. T[his test is t (ibe performed wit the flow path , AO2 restablished pri to starting the EV'fahn,, and the otherd ampers associated w/h the'. negative prissure boundary co,/ed.DAVIS-BESSE, UNIT 1 3/46-31 Amendment No.233 0 Page 3 of 4 Attachment 1, Volume 12, Rev. 1, Page 276 of 461 Attachment 1, Volume 12, Rev. 1, Page 277 of 461 ITS 3.7.12 TABLE ,6-.ACCESS OPENINGS REý 6UIRED TO BE CLOSED TO ENSURE SHIELD UILDING INTEGRITY AIR TIGHT DOORS DOOR.NO. ESCRIPTION 100 Access Door from he No. 1 ECCS Pump Room ,(Room 195) to Pip Tunnel 101 104A Access Door fro Stair AB-31to the No. 1 ECCS Pump: Roo (Room 105)105 Access Door.fro Passage 11 A to the area above the Decay Heat Coolers 107 Access Door fra nthe No.2 ECCS Pump Room (Room 115) tot e Miscellaneous Waste Monitor Tank-and Pure Room(Room 1 "4)108 Access Door fr m the No. 2 ECCS Pump Room (Room 115) to he Detergent Waste Drain Tank and Pump Ro m (Room 125)201-A Access Door ram Corridor,209 to the No. 1 Mechanical enetration Room (Room. 208)204 Access Doo. frqm Passage 227 to the Makeup-Pump Room (Room 225)205 Access.Docr from Passage 227 to the No.2 Mechanic I Penetration Room (Room 236)307 Access Do r from Corridor 304 to the No. 3 Mechanic I Penetration Room (Room 303)308 Access D or from Corridor 304to the No. 4 Mechani al Penetration Room (Room 314)11. BLOWOUT PANELS TOTAL NO. LOCATION No. 2.M Chanical Penetration Room (Room 36)6 No. 3 echanical Penetration Room (Room 303)6 No. 4 echanical Penetration Room (Roo 314)LAO4 ELEVATION 545'555'555'.555, 5685 585'ELEVATION 565'585'585'.I DAVIS-BESSE, UNIT 1 3/4 6-33 Amendment No. 233-Page 4 of 4 Attachment 1, Volume 12, Rev. 1, Page 277 of 461 Attachment 1, Volume 12, Rev. 1, 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. 0 Davis-Besse Page 1 of 6 Attachment 1, Volume 12, Rev. 1, Page 278 of 461 Attachment 1, Volume 12, Rev. 1, Page 279 of 461 DISCUSSION OF CHANGES ITS 3.7.12, STATION EMERGENCY VENTILATION SYSTEM (EVS)LA02 (Type 3- Removing Procedural Details 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 I -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. 1, Page 279 of 461 Attachment 1, Volume 12, Rev. 1, 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. 1, Page 280 of 461 Attachment 1, Volume 12, Rev. 1, 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 (Category 5 -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. 1, Page 281 of 461 Attachment 1, Volume 12, Rev. 1, Page 282 of 461 DISCUSSION OF CHANGES ITS 3.7.12, STATION EMERGENCY VENTILATION SYSTEM (EVS)L04 (Category 1 -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 0 Davis-Besse Page 5 of 6 Attachment 1, Volume 12, Rev. 1, Page 282 of 461 Attachment 1, Volume 12, Rev. 1, 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.0 Davis-Besse Page 6 of 6 Attachment 1, Volume 12, Rev. 1, Page 283 of 461 Attachment 1, Volume 12, Rev. 1, Page 284 of 461 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)0 Attachment 1, Volume 12, Rev. 1, Page 284 of 461 Attachment 1, Volume 12, Rev. 1, Page 285 of 461 CTS I All changes are unless otherwise noted Station EVS 3.7.12 3.7 PLANT SYSTEMS Station 3.ý7.2 merge ncyVentilation System (EVS)Two FVS trains'shall be OPERABLE.3.6.5.1, 3.6.5.2 4.6.5.2.1 LC0 3.7.12-----------------------------------------------------

The buildingl'negative pressure.r boundary mayl be opened intermittently under administrative control.APPLICABILITY. MODES 1, 2, 3, and 4.3.6.5.1 Action 3.6.5.2 Action 3.6.5.1 Action, 3.6.5.2 Action ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One EVS train S A.1 Restore EVS train to 7days inoperable, OPERABLE status.B. TwEvS tram B Restore building 24 hours inoperable due to., negative pressure*inoperable I boundary to OPERABLE building negative status.pressureT boundary. I C. Required Action and CA1 Be in MODE 3. 6 hours associated Completion Time not met. AND C.2 Be in MODE 5. 36 hours BWOG STS 3,7.12-1 Rev. 3.0, .03/31/04 0 Attachment 1, Volume 12, Rev. 1, Page 285 of 461 Attachment 1, Volume 12, Rev. 1, Page 286 of 461 CTS St EVS 3.7:12 0 4.6.5.1.a 4.6.5.1.b 4.6.5.1.d.2 4.6.5.2.2 4.6.5.1.d.3 SURVEILLANCE REQUIREMENTs_ SURVEILLANCE FREQUENCY SR 3-7:1211 Operate eachvEVStrain for [>A 1Ocon nuoush 31 days with th eheaters operatin or(for s tems without J he r SR 3.7.12.2 Perform re'quired*VSfiltertesting in accordance In accordance with the lVentilation Filter Testing Program (VFTP)j with the M/FTFE SR 3.7.12:3 Verify each*EVStrain actuates on an actual or d months simulated actuation signal.'SR 3.712.4 Verify onevVS can aapressure jonths on a in the annulus inches water gaugelrelativetb atmospheric ppssureI STAGGERED 1 4 seconds after th du the ost.accident] ode of operatiorat a TEST BASIS flow rate m-isl7200cfm and SFtSatio oln gr SR 3.7:12.5 Verify each'EVS -filter coolin~g bypass damper can F[W]monthslI beopened.00O 0 0 00 000 00@BWOG STS 3.7.12-2 Rev. 3.0,031 3 1/04 Attachment 1, Volume 12, Rev. 1, Page 286 of 461 Attachment 1, Volume 12, Rev. 1, 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 I Attachment 1, Volume 12, Rev. 1, Page 287 of 461 Attachment 1, Volume 12, Rev. 1, Page 288 of 461 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)0 0 Attachment 1, Volume 12, Rev. 1, Page 288 of 461 '

Attachment 1, Volume 12, Rev. 1, Page 289 of 461 All changes are Q1-71 L unless otherwise noted J B3.7.12 B3.:7 PLANT SYSTEMS 9 Emergency ventilation System (EVS)BASES BACKGROUND The:EVSfi air from the a;of the active Emerency Core Coolingj Syste EC Comp~nients the reociicuiationý pqser 6fa: liosSdf:'c00!Qoant accidetc%The EVS consists of two independent, redundant trains. Each train consists of a prefilter, a high efficiency particulate air (HEPA) filter', an activated charcoal adsorberv setion for removai ofgaseousactivity (principally iodines), and:a fan. Ductwork, valves or:dampers. andr instrumentation also form: part of the system. The syste nitiates filtered ven tilat n o t e.uxiltary ing negatjive .essure area: owing, receipt of safety features.act tion signal (SFlS).The E is a standy system. Durin .emergency operat ns, the EVS NE2 dampers re, realigne ,.and fans are s rted to begin.filtrati. 'Upon receipt of e SFAkSigal(s), noral ai ischarges from the egative pressure ar6a are isolat!, and the strera of ventilation airdis ar-es Al~ul'h stefier trins.Thepreflters remove anýýarge~particles O i~te air, an' ýany entrain! water.droplet4'relsent,l;o prevlant excessive~~loadn ofte Ekflers ad charcoal adsgrbers, T~eEVS is discussed i'nothe FSAR, SectionsR0.2.4.4 6~i.4.'6 I(Refs .1,. 2, and 3, respectively). APPLICABLE E The design basis.ofthe EVS is established by the large break LOCA.SAFETY The system evaluation assumes a passive failure of the ECCS outside ANALYSES contaninent, 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 theeffects and consequences of a large break LOCAis presented in Reference 3I 47h_EVS so actuates following a mall break LOCA, in tho"cases where the unit es into the recirculatio, mode of long term cool,, and to cleanup re ses of smaller leaks, ch as from valve stem packing.BWOG STS B 3.7.12-1 Rev. 3.0, 03/31/04: 0 Attachment 1, Volume 12, Rev. 1, Page 289 of 461 Attachment 1, Volume 12, Rev. 1, 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 % 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.0 Insert B 3.7.12-1 Attachment 1, Volume 12, Rev. 1, Page 290 of 461 Attachment 1, Volume 12, Rev. 1, Page 291 of 461 I All changes are unless otherwise noted j EB .7EVS 13 3.7.12 BASES APPLICABLE SAFETY ANALYSES (continued) edassumptins Two types of system failures are conýdered in the accident analysis.complete loss of function, and excessiveIlEAKAG-Either type of failure may result in a lower efficiency of removal of any gaseous and particulate. activity released to the ECCS pump roomsfollowing a LOCA.Following a LOCA, an ESFAS signal starts theEVS fns and opens the Idam er -ed in th* etration room-ft etductwor , The MSFAS signal closes all containment isolation valves an urge"stem lye The purge system fans, if running, are shut down.automatically.. EStation NS1RT 4A The VS satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii). 0 LCO S Two independent and redundanttrains of theAEVS are required to be.OPERABLE to ensure that at least one is available, assuming thatza single failure disables the other train coincident with loss ofoffsite power, Total system failure could result in atmospheric release from the negative pressure area boundary exceeding Reference 4 limits in the event 0fa Design.Basis Accident (DBA).ý The EVS is considered OPERABLE when the individual components Station necessary to maintain the negative pressure area boundary filtration are OPERABLE in both trains.VS train is considered OPERABLE when its associated:

a. Fan is. OPERABLEFl

b. HEPA filter and charcoal adsorber are not excessively restricting flow, and are capable of performing their filtration functionsmandr

c. r [He'er, bt~er,] u-twork, valves, and dampers are OPERABLE, and air circulation can be maintained.

The LCO is modified by a Note allowing the d uildingegative pressuref.- boundary to be opened intermittently under 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 puildinginegatiVe pressur-ea isolation is indicated. 0 0 0 0 0 BWOG STS B 3.7.12-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 1, Page 291 of 461 Attachment 1, Volume 12, Rev. 1, 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 0 Attachment 1, Volume 12, Rev. 1, Page 292 of 461 Attachment 1, Volume 12, Rev. 1, Page 293 of 461 Alchanges are i unless otherwise noted jB 3.712 BASES APPLICABILITY In MODES 1, 2, 3, and 4, th4EVS is required to be OPERABLE consistent with the OPERABILITY requirements.of the ECCS.In MODES 5 and 6 ,the EVSis not requireýdto be OPERABLE since the ECCS is not required to be OPERABLE.ACTIONS A.1 the inoperable Station n-- so n EVS train to )With one 4 EVS train inoperable, action must be taken to restore(OPERABLE status within 7 days. During this time, the remaining station OPERABLE train is adequate to perform the 1-VS safety function.However, the overall reliability is reduced because.a single failure in the OPERABLEw.VS train could result in loss o EVS function.The 7 day Completion Time is appropriate because the risk contribution is less than that of the ECCS (72 hour 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 EVIEWEI'S NOTE --------------.--

Adoption of Co dition B is dependenton 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 Condition B.Station shedIf th"e u i ary Ouildingtinegative pressur ra boundary is inoperable, D teth 'EVS trains cannot perform their intended functions.

Actions must be taend th peruildingdth egative pressurelden0 status 4' .negative pressure laleal boundaryils Inoperable, appropriate shel K.JK compensatory measures E~consistent

~th the intent, as/ptica e, of" IGOC 19, 63, and 10 CFR Part 1 t0] should be utilized to protect plant personnel from potential hazards such as radioactive contamination, 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 hour 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 hour Completion Time is a typically reasonablertime, to diagnose, plan and possibly repair, and test most problems with the 5 Vuildingvnegative pressurer boundary.BWOG STS B 3.7.12-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 1, Page 293 of 461 Attachment 1, Volume 12, Rev. 1, Page 294 of 461 O I u~~niess other'wise ES All changes are B 3.7.12 BASES ACTIONS '(continued) CI1 and C.2 If the VS train or theA i uilding~iegative:pressurere boundary cannot be restored toOPERAB E status within the associated Completion Time,'the unit must be placed'in a MODE in which the LCO does not apply, To achieve this status the unit must be placed in at least MODE 3 within 6, hours, and in MODE 5 within 36 hours. The allowed Completion Times are reasonable; based on operating~experience to reach the required unitconditions from iful power conditions in an orderly manner and without challenging unit systems.SURVEILLANCE SR 3.7.12.1 REQUIREMENTS Sta ndby 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. Mont heateroper 'ons dry .out anyoisture, that may h e accumulated in e charcoal fro" umidity in control room, with flow through _ the rrient air. [Systemsx~th heaters' must b operated 1.0 .. t~in uousI the HEPA filters and charcoal i1 hurwt'the hea ters :energiA4., systems' with0o'ut adsorbers, and operating o erate for 15 minutes demonstrate the function of each train The 31 day Frequency is based on known -eliability of equipmen and the twotrain redundancy available. s SIR 3.7.12.2: This SR.,verifies that the require VS testing is performed in~accordance with.the l!entilation Filter Testing. Program (VFTP). The 'FITFT includes testing H EPAfilter performance, charcoal adsorber (0 systemflow..rate, and the physicaI properties of the activated charcoal.(general use and following specific operations). Specific test frequencies and additional information are discussed in detail in the NVFTFj SR 3.7.12.3 (ie., containment isolation !s SR verif2es that e VS train starts and operates on an actual or.... simulated actuation signal. ýThi 18] month Frequen.'ijs consistent with operating experience has shown that theseT Scomponents usually pass the Surveillance Iwhen performed at the 24 month Frequency._y STherefore, the Frequency is acceptable from Sa reliability standpoint. BWO1G STS B 3.7.12-4 Rev. 3.0, 03/31/04i Attachment 1, Volume 12, Rev. 1, Page 294 of 461 Attachment 1, Volume 12, Rev. 1, Page 295 of 461 I All changes are unless otherwise noted[iZZEVS B 3.7.12 BASES SURVEILLANCE REQUIREMENTS (continued) SR 3.7.12.4 ( shield building area]This SR Verifies the integrity of thetnegative pressure boundary!4. [ inhennulus The ability of the EVS to[ma aa negative pressur, s t Stati potentily-ucontaminae-d cen areas is periodically tested to verify\ proper functioning of th EVS. During the Npost accidený mode of shield building area the EVS is designed to maintain a slight negative pressure in the negative pressure boundary [1with respect to adjacent areas to~prevent-unfilte~re is designed to h S negative pressure at a flow rate of m from the*negative pressure T'he Surveillance is performed with the flow Frequency of[F months on a STAGGERED TEST path established prior to starting the Station BASIS is consistent with industry/Aractice landoter filtra s EVS fan, and the other dampers associated I 7 a , 8 with the shield building area negative 2 -2 ,pressure boundary closed. } -I I0 0 0 REFERENCES

1. FSAR, Section M.2.4J 2. FSAR, SectionM9.4..4

3. FSAR, Section M15.4.E 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.

4. 10CFR 100.11.5. jRe ltoryquide 1A.2. Rev. 2, 0RequirementsManual BWOG STS B 3.7.12-5 Rev. 3,0, 03/31/04 1 Attachment 1, Volume 12, Rev. 1, Page 295 of 461 Attachment 1, Volume 12, Rev. 1, 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.

0 Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 1, Page 296 of 461 Attachment 1, Volume 12, Rev. 1, Page 297 of 461*Specific No Significant Hazards Considerations (NSHCs)0 Attachment 1, Volume 12, Rev. 1, Page 297 of 461 Attachment 1, Volume 12, Rev. 1, 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. 1, Page 298 of 461 Attachment 1, Volume 12, Rev. 1, Page 299 of 461 ATTACHMENT 13 ITS 3.7.13, SPENT FUEL POOL AREA EMERGENCY VENTILATION SYSTEM (EVS)Attachment 1, Volume 12, Rev. 1, Page 299 of 461 Attachment 1, Volume 12, Rev. 1, Page 300 of 461 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)Attachment 1, Volume 12, Rev. 1, Page 300 of 461 Attachment 1, Volume 12, Rev. 1, Page 301 of 461 ITSA01 ITS 3.7.13 SITSU0 REFUELING OPERATIONS STORAGE POOL VENTILATION LIMITING CONDITION FOR OPERATION LCO 3.7.13 3_39.12 Two indendent[-emergency ventilation systems servicing the storage Pool area shall be A02" ° PE!ABE.\ýWheni an emergency ventilation system servicing the storage pool is incapable of meeting ]-~thc acceptance criteria of Surveillance Rcq'uirement 4.9.12.1 solely because Ithe containmnt equipmen L-____tA03" LCO 3.7.13 hatch"openan both doors of the containment personnel air lock are oper, it maybe considered Note OPERABLE provied that at least one personnel r lock door is capable of bein/closed and adesignate Not /individual is avai)Able imimediatel utie th irsorirel, air lock to close the d 6ri==/ L0 APPLICABILITY: lWhenever irradiated fuel is in the spent fuel do or durinn CO , L02 A LT E RA T ! ON ý or m ovem ent of irradiated fuel w ithin o t i m n ~ i h t e ------- 0 ._.Icontainment equiipment h atch open.] ecnanmnwihteL03 ACTION B a. With one emergency ventilation system servicing the storage po area inoperable, fuel movement05 within the spent.fuel pool ]or crane oa ration with o ds over the spnt fuel pool0 nayprocee

[provided the OPERABLE emergency ventilation system servicing the storage pool area is in operationland discharginz-1irough at least one tr, iof HEPA filters a .charcoal adsorbersL b.ý With one emergency ve ilation system servicing the storage pool area operable; CORE ALTERATIONS and el movement within containment may procee provided eitherthe OPERABLE emerg cy ventilation system servicing the' storage p 1 area is in operation and. L03 )discharging throu at least one train of HEPA filters and charcogd adsarbers or the coritainment equipment.hatc cover is closed and held in placeby a minimu of four bolts.ACTION C c. With no emergency ventilation system ser,,eing the storage pool area OPERABLE.

suspend IALTE ATIONS and all operations involving movement of-- With the etaiment fuel.._L05 pool, jor crane optration with lo s over the spet Iuel pool until at least one system is restoredRto j OPERABLE status. FCOR-E ALTERATONS and fuel movement witl~in containiment may. proceed-l[provided the contaitnment eq~ipment hatch cover is closed and held jý p'lace by a minlimum: of [bolts. 1 ACTIONS d. The provisions of Specifications 3.0.3 3 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 demonstrated OPERABLE per the applicable Surveillance Requirements of 4.6.5.1, and at least-once each L06 REFUELING INTERVALby veii fying that the emergency ventilation system servicing the storage pool area maintains the storagepool area at a negative pressure of> >/8 inches Water Gauge relative tothe outside atmosphere. during system operation. 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 system tans sto, automaticolly and th am er actual or[automatica udivert flow into Ve emergency

veilation system[ on a uel s ra e ar high'r diatiaon test signal.DAVIS-BESSE, UNIT I 3/49-12 Amendment No. 135,217;237, 247,251 266 Page 1 of 3 Attachment 1, Volume 12, Rev. 1, Page 301 of 461 Attachment 1, Volume 12, Rev. 1, Page 302 of 461 ITS IT~33.7.13 See ITS 3.7.12 CONTAINMENT SYSTEMS 3/4.6.5 SHIELD BUILDING EMERGENCY VENTILATION SYSTEM LIMITING CONDITION FOR OPERATION 3.6.5.1 Two independent emergency ventilation'syStems shall be OPERABLE.APPLICABILITY:

MODES 1, 2, 3 and 4.ACTION: With one emergency ventilation system inoperable, restore'the inoperable system to0OPERABLE status within 7 days or be in at least HOT STANDBY within the next 6 hours aid in COLD SHUTDOWN within the following 30 hours.SR 3.7.13.1 SR 3.7.13.2.SURVEILLANCE REQUIREMENTS 4.6.5.1 Each emergency ventilation system shall be demonstrated OPERABLE: a. At least once per 31 days on a ISTAGGE.KED TEST BAS by initiatingrom the...I control room, Rlow tirough the HEPA filters and/charcoal adsorbers "--that the system operates for at least 15. minutes. LA05.b. At least once each REFUELING INTERVAL and in accordance with the Ventilation FilterTesting Program (VFTP).DAVIS-BESSE, UNIT I 3/4 6-28 Amendment No. 155,217, 244, 0 Page 2 of 3 Attachment 1, Volume 12, Rev. 1, Page 302 of 461 ITS Attachment 1, Volume 12, Rev. 1, Page 303 of 461 0 CONTAINMENT SYSTEMS 5gT JRVPTLLANCE. REOUITREMENTS ITS 3.7.13 SURVEILLANCE REQUIREMENTS (Continued)

1. [Deleted]2. [Deleted]3. [Deleted]c. [Deleted]d'. At least once each REFUELING INTERVAL by: 1. [Deleted]2. Verifying that the systemn starts automatically on any con~ainrnent isolation test, signal; and See ITS 37.12 SR 3.7,13.5 3. Verifying that the filter cooling bypass valves can be manually opened.DAVIS-BESSE, UNIT I 314.6-29 Amendment No. 43,135,155,209,217,233, 244:, Page 3 of 3 Attachment 1, Volume 12, Rev. 1, Page 303 of 461 Attachment 1, Volume 12, Rev. 1, 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 Attachment1, Volume 12, Rev. 1, Page 304 of 461 Attachment 1, Volume 12, Rev. 1, 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 Procedural Details 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 Procedural Details 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. 1, Page 305 of 461 Attachment 1, Volume 12, Rev. 1, 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 Procedural Details 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. 1, Page 306.of 461 Attachment 1, Volume 12, Rev. 1, 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 building." 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 building, i.e., during the movement of irradiated fuel assemblies in the spent fuel pool building.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 building. This change is designated as less restrictive because the LCO requirements are applicable in fewer operating conditions than in the CTS.L03 (Category 2 -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 Davis-Besse Page 4 of 8 Attachment 1, Volume 12, Rev. 1, Page 307 of 461 Attachment 1, Volume 12, Rev. 1, Page 308 of 461 DISCUSSION OF CHANGES ITS 3.7.13, SPENT FUEL POOL AREA EMERGENCY VENTILATION SYSTEM (EVS)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 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, 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 hours, since CTS 3.9.3 (ITS 3.9.3) does not allow any irradiated fuel movement in containment until the reactor has been shutdown for 72 hours.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 were also covered by CTS 3.9.4. However, as part of this ITS conversion, CTS 3.9.4 has been deleted as described in CTS 3/4.9.4 DOC L01. The DOC justified why the Specification was not needed after the reactor has been shutdown for > 72 hoiurs. Any time the containment equipment hatch is opened, 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 whenever the boundary is opened (for example, the containment equipment hatch and air lock doors are 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. 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 Davis-Besse Page 5 of 8 Attachment 1, Volume 12, Rev. 1, Page 308 of 461 Attachment 1, Volume 12, Rev. 1, Page 309 of 461 DISCUSSION OF CHANGES ITS 3.7.13, SPENT FUEL POOL AREA EMERGENCY VENTILATION SYSTEM (EVS)* 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 Required Action) 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 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 Davis-Besse Page 6 of 8 Attachment 1, Volume 12, Rev. 1, Page 309 of 461 Attachment 1, Volume 12, Rev. 1, Page 310 of 461 DISCUSSION OF CHANGES ITS 3.7.13, SPENT FUEL POOL AREA EMERGENCY VENTILATION SYSTEM (EVS)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 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 Davis-Besse Page 7 of 8 Attachment 1, Volume 12, Rev. 1, Page 310 of 461 Attachment 1, Volume 12, Rev. 1, Page 311 of 461 DISCUSSION OF CHANGES ITS 3.7.13, SPENT FUEL POOL AREA EMERGENCY VENTILATION SYSTEM (EVS)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.0 Davis-Besse Page 8 of 8 Attachment 1, Volume 12, Rev. 1, Page 311 of 461 Attachment 1, Volume 12, Rev. 1, Page 312 of 461 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)Attachment 1, Volume 12, Rev. 1, Page 312 of 461 Attachment 1, Volume 12, Rev. 1, Page 313 of 461 CTS Spent Fuel Pool Area EVS Fb' V 3.7.13 3.7 PLANT SYSTEMS -Area Emergency m 3 Fuel S Pool eventilation Systerm (. V[Spent Fuel Pool Area EVS 3.9.12 LCO 3.1713 :TWO{j trains shall be OPERABLE.spent fuel pool area --------- -......................................... N------------- negative pressure 'The fue uildin _bbundaiyrray.be. openei d inter itteiitl Und6'administrative control.APPLICABuILITY:e MOlES 1 3i e4 Duringý, moeenfren irait~eld fuel ,assemnblies, in. th fu1el 0 0 00 0 (ACTIONS-NOTE-Action d LCO 3:0,.3Ais; not applicable. 'CONDITION Spent Fuel Pool Area EVS DOC L04 ,A. Opne :iabne inoperalple', REQUIRED ACTION AX.1 Resore train to OPERABLE status.-COMPLETION TIME 7 days 0 B. Two FSPVS trns, B.1 :Res re fuel building 24 hours inoperable dUI o bou cdaryjtoPERABLE inoperable full building ,sta us.boundary.in VAQD E 1 ,;,2,/3, or'4. o 0 BVWOGSTS 3:17.13-1 Rev. 310, 03131/04 Attachment 1, Volume 12, Rev. 1, Page 313 of 461 Attachment 1, Volume 12, Rev. 1, Page 314 of 461 CTS Spent Fuel Pool Area EVS F VS'3 0 ACTIONS (Sntinued):.ONDI40TION REQUR ED1ACTON ,COMPLETION 'TIME C. [Required Act on and C.1 in MODE 3. 6 hours-Cmpletion, Time of Cond ion Aor B AND notmetIn M ,DEA,ý2, 3, or 4. C.2 Bin-MODE 5. 36 hours]OR TWo, FSPVs trains i6operable' MODE 1 2, 3,or 4 f. reasoIns .otherithan. ondition B.Action a, Action b RequirWed.Action and associated Completio.n Time, of Condition A not, mtdurj~ ryer t of, AS, rd a fuel a bites in t fueld di 1 OR:.162 Plabe OPERABLEF VS I Immediately ,train hinoperation. Spent Fuel Pool Area EVS 0 00 0 0 Suspedn rnoyement~ofr re assembliesin~th~ueu o~ui.i.d iing. 4-e ,Im r'ediately' Spent Fuel PArea EVS Tw Srains Action c inmoperable, uring/move.e nt of,[re/ntly] irradi ass mb-lies in e fuel bu din 1 Suspend 6ovem-ennt6fr niirad~iated:.fuel C '&ssemblies~in thefuel building L e Immediaftely SORVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.6.5.1. a SoR 3713.1 / Operate4,each F Strainf~or [It10 ontinuou Spent Fuel Pool hours wi e eaters .operatin' or or'systemrs Area EVS without aters> 15rainutes6J 3idaVs~00 BW2G STS,Rev. 310,:O,03/31/04 Attachment 1, Volume 12, Rev. 1, Page 314 of 461 Attachment 1, Volume 12, Rev. 1, Page 315 of 461 CTS Spent Fuel Pool Area EVS F V 3.7.13 0 4.6.5.1.b 4.9.12.2 4.9.12.1 4.6.5.1.d,3 SURVEILLANCE REQUIREMENTS contin,2,ued) SURVEILLANCE SR 3.7.13.2 / OPerform requiredFý VS filter testing in Spent Fuel Pool accordance with thefVentilation Filter Testing SR 3.7.13.3 OVerifyeachF VS train actuates on an actual or simulated actuation signal.In accordance with the [VFTFU I monthsj 24 FREQUENCY{Spent Fuel Pool Area EVS -j_, ["e atv [ -SIR 3.7.13.4 verify one FLý train can mnaintain atpressureinche~s water gauge_ with respect to[amoperic pressure during the [p!6st~acidn] Frelative to outside- md of oprtioin a t a flow rate _%/[30001 efm.t atmosi~here I[pmonths an a STAGGERED TEST BASIS 00 00 00 0 00 SR 3.7.13.5 MVerify each F VSfiltefpass damper can be opened. Spent Fuel Pool Area EVS~months 24f BVVOG STS 3.7.13-3 Rev. 3.0, 03/31/04 0 Attachment 1, Volume 12, Rev. 1, Page 315 of 461 Attachment 1, Volume 12, Rev. 1, 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-Bessecurrent 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.0 Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 1, Page 316 of 461 Attachment 1, Volume 12, Rev. 1, Page 317 of 461 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)0 Attachment 1, Volume 12, Rev. 1, Page 317 of 461 Attachment 1, Volume 12, Rev. 1, Page 318 of 461 I All changes are unless otherwise noted J Spent Fuel Pool Area EVS B 3.7.13 0 0 B3.7 PLANT SYSTEMS Spent Fuel Pool Area Emergency Ventilation System (EVS)B3:7.13 JFuel Stobrag Pool Veiqtjlation Syst-4n.(FSPVVS_)I BASESI BAC KGROUND The provides negative pressure in the a e rea; and filters~airborne radioactive particulates from-the area of the fuel pool S following a fuel handling accidentJl ý Wspent fuel pool .n Area EVs The F S consists of portions of the normnal Fuel Handling Area equipment hatch Ventilation System (FHAVS), the Aation EmergencyVentilation System open, the spent fuel (EVS), ductwork bypasses, and dampers. The portion of the normal pool area negative" " * .pressure boundary FHAVS used by consists of ducting between the spent-fuel extendstoinclude 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 exhaust fan ducting, The portion of the*EVS used by the S consists of two independent, redundant trains. Each train consists of a prefilter, [M 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 t....the system. Tw iso Ives are installed in series in the ductwork[ttobetween the FHAVS and the+EVS to provide, isolation of the'lEVS from the w, FHAVS on an IEnfer Safety Feature~ctuation ignal, Thesev[nral c re do'ened priolkto'fuel hahdling operatio'lqs [involvin."andlinci re'bently nolyoe raiad fuel The EVS is the subject of LCO 3.7.12, 'Emergency Si eniajton System e EVS)," and is fully described in the FSAR (R Sectionf. e 0 .. A ductwork bypass with redundant Si dampers connects the FHAVS to the EVS.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 P train), 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'ductwork, and start the 4 EVS fans. fans pull the air from the fuel handling area, creating a negative pressure, and discharge the filtered air[___NSERT_ 1 to the station vent.INSERT 1.The F AVS is discussed in t4 FSAR, Sections [6.2. , [9.4.2], and [15.\.71 (Refs. 1,2, and 3,,espectively), because i may be used for normal a 1wel as post accident, tmospheric cleanup fu ions.BWOG STS B 3.7.13-1 Rev. 3.0, 03/31/04 0 Attachment 1, Volume 12, Rev. 1, Page 318 of 461 Attachment 1, Volume 12, Rev. 1, Page 319 of 461 B 3.7.13 O INSERT 1 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.0 0 Insert Page B 3.7.13-1 Attachment 1, Volume 12, Rev. 1, Page 319 of 461 Attachment 1, Volume 12, Rev. 1, Page 320 of 461 I All changes are 0 unless otherwise noted Spent Fuel PoolArea EVS EB 3.7,13 0 BASES APPLICABLE. The Sdesign'basis is established'bythe consequences of the SAFETY limiting Design Basis Accident (DBA), which is a fuel handling accident ANALYSES invo rriate fuel. The analysisof the fuel Spent Fuel Pool Area EVS handling.accident, given in Reference assumes at a certain number/-of fuelireds in an assembly are damaged. The DBA analysis of the fuel (outside containment) handling accident ioying a-irradiated fuel assumes th S lPool -A-r that aý yone train of,tIV FSPVS is funct nal due to a si le failure that he \pene acciden analys rrea EVS actuation aligns the 3sa5 4le the other trainhe accidentana sis accounts fo the reduction ventilation flow path fr_ airboMe radioactive maerial provided by he remaining on train of this throcgha letHEPArs nod t filtration ysteM. These assumptions and the analysis follow the discharging to the station guidance provided in Regulatory Guide 1.25 (Ref. z).0 0 0 K.. ent... Spet Fuel PoolAreaES FSpent Fuel Pool The _S _satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii), 1 Area EVS LCO MTwcN independent and redundant trains of the required to be OPERABLE to ensure that at least one is available, assuming a single failure that disablesthe other train Icoincid-en offsite powed.Total system failure could result. in the atmospheric release from the fuel handling area exceeding 10 CFR 100 (Ref.9_, limits in the event of a fuel W handling accident invelvin-rgradiatedfuei], Spent Fuel Pool--, Area The is considered OPERABLE when the individual components ensure offsite and control necessary"tocontrol opejatoYexposure in the fueltiaffling building are room dose limits ýare notý yt exceeded OPERABLE in both trains. A train is considered OPERABLE.when its associated: "--]Spent Fuel Pool (.Area EVSJ@. Fan is OPERABLEM_, KI ([J-+: HEPA filter and charcoal adsorber are not excessively restricting flow, and are capable of performing their filtration functionsd.\,Heater-, emister, .;uctwork, valves, and dampers are, OPERABLE, 7 and air circulation can be maintained. spent fuel pooi area negative pressure The LCO is modified by a Note allowing the ue din boundary to be. (opened intertently under 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 forfu- -d t (isolation is indicated. INSERT IA Ispent fuel pool area negative pressure boundary D2 D BVOG STS B 3.7.13-2 Rev. 3.0, 03/31/04 0 Attachment 1, Volume 12, Rev. 1, Page 320 of 461 Attachment 1, Volume 12, Rev.,1, Page 321 of 461 B 3.7.13 0 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.0 Insert Page B 3.7.13-2 Attachment 1, Volume 12, Rev. 1, Page 321 of 461 Attachment 1, Volume 12, Rev. 1, Page 322 of 461 All changes are 0 L unless otherwise noted j Spent Fuel Pool Area EVS 1B'37.13 0 BASES APPLICABILITY [In I DES 1:,2;;3-.:a~nd 4jt, FSPVSis required:todbe

FOPF uABLE'to a" 0 proVide fi 'onproducterrioval a iaftdWidh ECCS.Ieaks due ' a loss of-,,'cooIanta*

ent;(referto LOG3.71 r urinits that use this syst 'as part ofttheir EV Du'r'ing mov6emen66tofrr-eziiyI irradiated fuelasebisnthiEJ0 spent fuel pool hann re , the aiwass ,e 'uireat, be OPERABLEto building ! mitigateWthe, onsequences

ofa' fuel handling accident.

Spent Fuel Pool Area EVS In iM and FPS ot required to beOPE Esic'the' ECCS is,, equired to be OPERAt-ACTIONS LCO-3.0.3 is not applicable whilein MODE:5 or.6. However, since irradiated fuel assembly movement can occur in MODE , 2, 3,. or4,.the.ACTIONS, have been.modified by ai Note stating that LCO 3.0.3 is not applicable.; If, moving irradiated'f'ueI assemblies while in MODE 5 or 6,[CO 3.0.3 would specify any~action. if moving irradiated'fuel assemblies whilein. MODE 1, 2, 3,or4, the fuel movement is independent of reactor operations. EnteringLCO 3.013 while in-MODE 1, 2, 3, or,4wquld requirethe unit to be shutdown unnecessarily. ýA. the inoperable Spent Fuel 6 Pool Area EVS train to Apti -one toain inoperabie,p action musto.mbetaken to restore nee S.OPERABiE:dstatus, within 7 days. Duesngcthrtime pensad toeremaining [Spent Fuel Pool Area EVS OPEýRABLE~taini is adequate~t0, performrW6 thSEV-S function. iHowever, I dhe viabll it , red u~ced becaluse~a r ,i the , (o bPEtRABLe i train tncoud tna lor unintt ionarenctr Mt~The 7"dayCompletion Time ýis- bas~edonjhetherisk, from~a n evernt occurring" o requiihingtheijno6'erable trbinn a acnabiiitY 0..f aihe t I 9,LEi MSJ.tfain,.to =provide,:thd fe,,uired protection. Cponditionn .B dSe. .it 0 ,ommitt tB,haTeTB.n7nprocedures-av3ailable escrRbingcompepsator easure0 tobe taken,iin heý,even of'.an .intent ion Sor, unintentional entry. BX S AIGTS .B 3.7.713213 Revw-3i.0 03/31104 Attachment 1, Volume 12, Rev. 1, Page 322 of 461 Attachment 1, Volume 12, Rev. 1, Page 323 of 461 I All changes are unless otherwise notedl Spent Fuel Pool Area EVS B 307.13 0 BASES ACTIONS (contin.ued) If the fuel building bounda is ino~perable irn0MDE -2, 3, or 4- the, FSP triscno efrtheir:intended~functions Actions,.must~be taken, restore anOPERABL fuel building boundar ithin' 24 houfrs.Duig e periodtat the fuel uilding boundary is mnope able, appropri te compensatory mea' res-[consistent with'the i tent, as appicblo GC 9,0,616 4 nd10CF 10]sh I b uilze to prtectlant ersonel rmpon iahzrdsuhra ate contaminat n, toxicchem~~~~Icas mktmeaueadrlt humidity, an physical s~~~euIt.relndmaueshod reasoniabletm ofGDiC go1'9,0:1, 6lan-a d1 po ibly rei Id bn~et motize prob~ n~ ith~ thefu~ l'b~ ldin bother Q 0[C'l, d.C,".22 n InWO 1,.'2, 3, or 4,.wheh R Wred Action A.1 or B.1.: nnot be t q 3 i Ad a ons e cornplet d'within thb.associate 'ornpletion Time, or whe both FSPVS r u .T trains are therthan an.i n.opera ble f I building 0 M 0 M(C _ I i t tio B nnot be 0 do s notap ac V tZn r he both FSPVýýn I s er tha n ra boundayi, e., Condition B), the uni must'beplaced in,ý,a MO inwhich IcC 0 MO in whicl C t t bý i nýn pla red I t- 'd 0 P' 0 ral wit he I _ QO ply., To achiev this status, the unit must placed ra ns a r. 0. n m et AXnýin ýat least k1l 'DE 3within 6'hourt,'an in MODE 5ýwithih'36 hýhou The,.le f I building 0' r st c 0 0rnCorn-hpletionTi s are reasonable, bas d.on..op6r;ýtinoýý.eýperience.', a Mreachthe Irequi d unit-condition5jromf I power condition'5Jhn ýan or erly: io 0 V manner,,andwiO Lit:.Challenging.,un\it'.,.syste sý I If the inoperable train cannotbe: restored to OPERABLE status Pool I Areal 0 within the. required:G'ompletion Time, urinn E, 3 lirradiate -... .. fue l'b uildin the O P E R A BLE 2( r ierfyiadiated~fu T rmove rment (suspended. remaining

trainis OPERABLE,'thatno undetected failures :prveriting'systemoperatibn will occur, and thatany-actiye failures -will, b~e readily. dietecte.in the spent fuel pool If.the.s stem is n6t 'lacedin o 'eration, this action.requires-suspensionof building r Jrradiatedjfuel movement, which precludes'a fybl handling accidlent

[nvlc andlin niiare.tl, irrat I. This-action does-not preclude the,.movemrent of fuel assemrbliesto a safe position.( I0 B\OG; STS B 3.7.13-4 Rev. 3:01 03/31104 Attachment 1, Volume 12, Rev. 1, Page 323 of 461 Attachment 1, Volume 12, Rev. 1, Page 324 of 461 r All changes are unless otherwise noted J Spent Fuel Pool Area EVS 13:7.13 0 BASES ACTIONS ,(continued) Spent Fuel Pool Area EVS q,,,twotrqains of he re inoperable urin tolrecently] irra -the.fuel buildin nit muSt b'e pla'edi inalcondition in which the This LCG spent involves immediatel/ suspending'mbvementpf irradiated fuel E assemblies in the uel'uilding. This does, not. preclude~the. movement of fuel to a safeý position. ......0 00 00 SURVEILLANCE REQUIREMENTS MSR 317.13.1 Standby,systems'should be checked periodically to eqnsureý thatihey function properly. As the-environment and normal operating conditions on'this system areýnot severe, testing each train once every'month proIvi~de's:a'n a-de U~te check_,66 this'yste.I n~yhetroe~ton ._... dries oUta: n-,oisture'a(;curUldte MnAthecharcoal frrmi' huh;idity in' the\hoursvwtlh'the heaters.'energized. Sy ems:"wthoutl,+heaters d fora 1 5'hinutes f unction Kihsvstehta The 31 day Frequency is based'on theknown reliability. of'the equipment' and.the two train redundancy available. JJ" - Fuel Pool Area EVS This:SRverifies thajt the req-uired F Ste'sting is performeiddin"accordance:wth:{he['entilationrFilter testing The,includes testing HEPA filter pedormance, charcoal,, adisrber effi ci enc A ['Y' ]systerM flow rate., an .the.6 physic Ial pr .pervties;of-the. activated chaircoalI (general use and following specific operations). Sipecifib'test

stfreque6ciesand
additiora I i6formati6n' ar~e idiscussed in detaqjlin.the j I (0 0 0 0 0 0 0D E]SR 1 J3ý7 33: I ) I 371. 3 IIISpent Fuel ýPool Area EVS actuates (i. e., Fuel Handling Exhaust ThisISR verifies'thatveach Fp ýstrzain onan actual-High Radiation) t or. simulated actuation si'nal. FThe 18 mowthFrequencyis.n e that specified i Reference 6.(INSERT 3ýBVVOG!STS B 3.7.13M5 ,Rev. 03131104 Attachment 1, Volume 12, Rev. 1, Page 324 of 461 Attachment 1, Volume 12, Rev. 1, 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. 0 Insert Page B 3.7.13-5 Attachment 1, Volume 12, Rev. 1, Page 325 of 461 Attachment 1, Volume 12, Rev. 1, Page 326 of 461 0 I All changes are unless otherwise noted[ F S Spent Fuel Pool Area EVS B f3.71 0 BASES s'"spent fuelp pressure boun the containme equipmen[, SURVEILLANCE' REQUIREMENTS (continued) s fuel p are* * *

spent fuel pool areaI-.negative pressure pool area negative SR 7 ..13" boundary.

..dary (which includes S I 3 A bondr nt if the containment nt hatch is open) This SR. verifies the integrity of the fueM area] The ability of the uia h fue ý ýabarea to maintain a negative pressure, with respect to oent -- acentzarea is periodicailyltested-to verify (Spent Fuel Pool proper function of the- E Z01 During the Mpostraccident 1[ mode of 0 ( )1, Area EVS operation, lI FaW9 is designed to main in a slight negative pressure spent fuel pool area in the uel area to. prevent unfiltere4dLEAKA. h FSPVS~is negative pressure esigne to intain this nega ivk pressure ata fow rate of S0001 cfr boundary fo the fuel ha ing area. The Frequency.f 'months on am STAGGERED TEST BASIS isconsistentwith industry practice,1 2 4 SR 3.7,13.5 ling (i.e., EVS fans cross tie dampers, each Spent Fuel nd 5057n IPool Area EVS Operatinglthe-VSfilterypass dampe s necessary to ensure that rSpent Fuel Pool the system functions properly, The OPERABILITY.of the LF'SR-LS ilter-[ Area EVS 2 colng bypass-damper is verified if it can be openedA Fre ency o I ERT4 [18] months s ecfied in Refere) ce

6.0 REFERENCES

1 FSAR Sectionm.24 J U F FnfTS L9:4.2]I[jfj--.-FSAR,Section`15.4.71 (T"--, Regulatory. Guide 1.25.6 0. Re FR 1200.2.1.16. Reg 2Rev, 121.1 0 0 0 BWOG STS B 3.7.13-6 Rev. 3.0, 03/31/04 0 Attachment 1, Volume 12, Rev. 1, Page 326 of 461 Attachment 1, Volume 12, Rev. 1, Page 327 of 461 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. B 3.7.13 0 Insert Page B 3.7.13-6 Attachment 1, Volume 12, Rev. 1, Page 327 of 461 Attachment 1, Volume 12, Rev. 1, 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.

0 0 Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 1, Page 328 of 461 Attachment 1, Volume 12, Rev. 1, Page 329 of 461 WSpecific No Significant Hazards Considerations (NSHCs)0 Attachment 1, Volume 12, Rev. 1, Page 329 of 461 Attachment 1, Volume 12, Rev. 1, 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. 0 Davis-Besse Page 1 of I Attachment 1, Volume 12, Rev. 1, Page 330 of 461 Attachment 1, Volume 12, Rev. 1, Page 331 of 461* ATTACHMENT 14 ITS 3.7.14, SPENT FUEL POOL WATER LEVEL 0 Attachment 1, Volume 12, Rev. 1, Page 331 of 461 Attachment 1, Volume 12, Rev. 1, Page 332 of 461 pCurrent Technical Specification (CTS) Markup and Discussion of Changes (DOCs)S 0 Attachment 1, Volume 12, Rev. 1, Page 332 of 461 Attachment 1, Volume 12, Rev. 1, Page 333 of 461 ITS 3.7.14 ITS REFUELING OPERATIONS STORAGE POOL WATER LEVEL LCO 3.7.14 ACTION A LIMITING CONDITION FOR OPERATION 3.9.11 As a minimum, 23.feet of water shall be maintained over the top of irradiated fuel assemblies seated in the storage racks in the spent fuel pool. During movement of irradiated fuel -L01 SEassemblies in the fuel storage poolR With.the requireme~nto fthe specificatiion, not satisfied, suspendS allmovement c loperatiio swith lod th~uls agcnel~dIetr Vwtrlve]6witi it " .... "i" /"-"N 14.o The provisions of Speel ficati~oa 3.0.3,are not applicable.

S URVEILLANCE REQUIREMENTS.

....SR 3.7.14.1 4'.9' I The water level in the spent fuel pool shall bel determined to be at least .ils minimum required depth at leastonce per 7 days J:yhen irradiated fuel aas~emts are in the ýent fuel.Eool LOl DAVIS-BESSE, UNIT I 3/4 9-11 Amcndiient No. 237,247 2t66 Page 1 of 1 Attachment 1, Volume 12, Rev. 1, Page 333 of 461 Attachment 1, Volume 12, Rev. 1, 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. 1, Page 334 of 461 Attachment 1, Volume 12, Rev. 1, 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 hours 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 directlyrelated 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 0 Davis-Besse Page 2 of 3 Attachment 1, Volume 12, Rev. 1, Page 335 of 461 Attachment 1, Volume 12, Rev. 1, 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.0 0 Davis-Besse Page 3 of 3 Attachment 1, Volume 12, Rev. 1, Page 336 of 461 Attachment 1, Volume 12, Rev. 1, Page 337 of 461 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)0 Attachment 1, Volume 12, Rev. 1, Page 337 of 461 Attachment 1, Volume 12, Rev. 1, Page 338 of 461 CTS I All changes are unless otherwise noted J Fuel t Pool Water Level 3.7.14 3.7 PLANT SYSTEMS 3.7.14 'Fuel t-a Pool Water Level 3.9.11 LCO 3.7,14 e poolwater level shall be _23 ft over the top of irradiated fuel assemblies seated in the storage racks.During movement of irradiated fuel assemblie infuel pool.APPLICABILITY: ACTIONS CONDITION REQUIRED ACTION Action A juel pool waterý level not within limit.AA.1..C ....... iNOTE----

LCO 3.0.3 is not applicable.

COMPLETION TIME Immediately Suspend movement of irradiated fuel assemblies.in s fuel s pool.I SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.14.1 Verthefuel age pool water level is.> 23 ft 7 days above the top of irraiated fuel assemblies seated in the storage racks.4.9.11 BVocG STS 3.7.14-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 1, Page 338 of 461 Attachment 1, Volume 12, Rev. 1, 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. 0 Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 1, Page 339 of 461 Attachment 1, Volume 12, Rev. 1, Page 340 of 461 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)Attachment 1, Volume 12, Rev. 1, Page 340 of 461 Attachment 1, Volume 12, Rev. 1, Page 341 of 461 I All changes are unless otherwise noted Fuel t Pool Water Level pentB I3.7.14 0 B 3.7 PLANT SYSTEMS B 3714 Fuel Pool Water Level BASES 0 sentýBACKGROUNE The minimum water level in th~fuel s 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.general description-of the*fuel pool design is given in the SAR, Seci1on .2 Reference

1. The Spent Fuel Pool Cooling and Cleanup em is given in t eFSAR, Section M9.1.3M (Ref. 2). The assumptions of the fuel handling accident are given in the 1 FSAR, Section115.4.71](Ref. 3).0 APPLICABLE The minimum water level in th 'fuels pool meets the assumptions SAFETY of the fuel handling accident described, in Regulatory Guide 1,25 (Ref. 4).ANALYSES The resultant 2 hour 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 to of the fuel bundle and the surface, by the width of the bundlelTo Nofset this small no}/conservatism, the O/alysis~assumeiis I INERhIat a I fu I rods fail, although the/analysis shows that the first I~~rows fail/from a hypothetial rnm'um dropr_/s~pent_ -The-fuel s 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 forýfirdae stor e a:nmovement within theJuel age pool. APPLICABILITY This LCO applies during movement of irradiated fuel assemblies in the fuel pool since the potential for a release of fission products exists...BVVOG STS B 3.7.14-1 Rev. 3.0, 03/31/04 0 Attachment 1, Volume 12, Rev. 1, Page 341 of 461 Attachment 1, Volume 12, Rev. 1, Page 342 of 461 B 3.7.14INSERT I 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.0 Insert Page B 3.7.14-1 Attachment 1, Volume 12, Rev. 1, Page 342 of 461 1 Attachment 1, Volume 12, Rev. 1, Page 343 of 461 Fuel t Pool Water Level SpEnt B 3.7.14 BASESj 0 0 ACTIONS ,A1 Required Action A.1 is modified by a Note indicating that LCO 3.0.3 does not apply.When the initial conditions for-an accident cannot be met, immediate action must be. taken to preclude the occurrence of an accident. With the spent -fuel J pool at less than the required level, the movement off4uel frWadited 1( 3.assemblies, in th fue e a pool, is immediately suspended. This effectively precludes the occurrence of a fuel handling accident. In such 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 REQUIREMENTS SR 3.7.14.1 This SR verifies that sufs ueln pool water is available in the t event of afuel handling accident. The water level in the fuel sqage pool ,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 the~uels pool is at equilibrium with that inthe refueling canal, and the level in the refueling canal is checked daily in accordance with SR 3.9.6.

1.0 REFERENCES

1. FSARe Sectionr9.1

.25.2. FSAR, SectionR9.1.3J

3. FSAR, Section~1 5.4.7 I 4. Regulatory Guide 1.25-5. 10CFR100.11.

B.BWOG STS B 3.7,14-2 Rev. 3,0, 03/31/04 Attachment 1, Volume 12, Rev. 1, Page 343 of 461 0 Attachment 1, Volume 12, Rev. 1, 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. 1, Page 344 of 461 Attachment 1, Volume 12, Rev. 1, Page 345 of 461 Wt Specific No Significant Hazards Considerations (NSHCs)0 0 Attachment 1, Volume 12, Rev. 1, Page 345 of 461 Attachment 1, Volume 12, Rev. 1, 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. 0-J 0 Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 1, Page 346 of 461 Attachment 1, Volume 12, Rev. 1, Page 347 of 461 ATTACHMENT 15 ITS 3.7.15, SPENT FUEL POOL BORON CONCENTRATION Attachment 1, Volume 12, Rev. 1, Page 347 of 461 Attachment 1, Volume 12, Rev. 1, Page 348 of 461 WCurrent Technical Specification (CTS) Markup and Discussion of Changes (DOCs)0 Attachment 1, Volume 12, Rev. 1, Page 348 of 461 Attachment 1, Volume 12, Rev. 1, Page 349 of 461 ITS 3.7.15 ITS ITS 3.7.15 0 Pagel1of I Attachment 1, Volume 12, Rev. 1, Page 349 of 461 Attachment 1, Volume 12, Rev. 1, 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. 1, Page 350 of 461 Attachment 1, Volume 12, Rev. 1, Page 351 of 461 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)0 Attachment 1, Volume 12, Rev. 1, Page 351 of 461 Attachment 1, Volume 12, Rev. 1, Page 352 of 461 CTS MSpent Fuel Pool Boron ConcentrationM 3.7.15 0 3.7 PLANT SYSTEMS 3.7.15 MSpent Fuel Pool Boron Concentration M DOC M01 LCO 3.7A15 APPLICABILITY: 630 The spent fuel pool boron concentration shall be 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.0 0 DOC M01 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Spent fuel pool boron NOTE ----------- -concentration not within LCO 3.0.3 is not applicable. lim it. -.............................................. A.! Suspend movement of fuel Immediately assemblies in the spent fuel pool.AND A.2.1 Initiate action to restore ImmediateIy spent fuel pool boron concentration to within limit.OR A.2.2 Initiate action to perform a Immediately fuel storage pool verification. BWOG STS 3.7.15-1 Rev. 3,0, 03131/04 0 Attachment 1, Volume 12, Rev. 1, Page 352 of 461 Attachment 1, Volume 12, Rev. 1, Page 353 of 461 CTS Mpent Fuel Pool Boron Concentrationl 3.7.15 0 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.15,1 Verify the spent fuel pool boron concentration is 7 days within limit.DOC M01 BWOG STS 3.7.15-2 Rev. 3.0, 03/31/04 0 Attachment 1, Volume 12, Rev. 1, Page 353 of 461 Attachment 1, Volume 12, Rev. 1, Page 354 of 461 JUSTIFICATION FOR DEVIATIONS ITS 3.7.15, SPENT FUELPOOL BORON CONCENTRATION) 1.. The brackets are removed and the proper plant specific information/value is provided.0 0 Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 1, Page 354 of 461 Attachment 1, Volume 12, Rev. 1, Page 355 of 461 p) Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)QS 0 Attachment 1, Volume 12, Rev. 1, Page 355 of 461 Attachment 1, Volume 12, Rev. 1, Page 356 of 461 0 Spent Fuel Pool Boron Concentratiorl B 3.7.15 0 B 3.7 PLANT SYSTEMS B:3.7.15 ý Spent Fuel Pool Boron Concentration BASES ... .. .BACKGROUND; As described g LOO 3.7.16ý, "Spent Fuel oo (" Mixed Z n hree " St orage,, fuel assem bli es :are stored i ni t .h ,e spent fuel pool ra dks~i n a C~gi n C h e boar 'd. or -- "c h e _6 a rd 'jp a tte nr in ,a c c o rd a n c e w.it hi c rite 'ria :b a se d o n gin it lia ![, Hom og n u Lo 'in~ e n ric h m e nt a nq l d isey.J r .qe b rn~ut j A Ith ug h th e "te r in th 0sp e r J;ue lof~a/fuel'ass~emnb/tdýtý pec-ific 10ations ar 6rie6 lop'ed~ reditfor'baron ...... .. '/APPLICABLE SAFETY ANALYSES A fuel assembly could. lbe minaqertently lQaded into spent fuel rack .location not allowed by LO3.7.16 (e-g., anunir ,u diated fuel assembW , or an, insuyfficiently dep fuel assembly. jis accident is anal 'd assuminrg the extre case of complete.ly ading thespent fue ool racks1with unirradi ed assemblies imum erichment./nother type of postula d accidentisassoci dwithha fuelasse lythat ist dropped on the fully loadedsp fuel peel storage Either incident could ha a positive reactivit" ect, de'creasing th margin to criticality., Hw~e _r, the-negative reac; ity efetothslebrncmpsas yHe--f th s l ' ot nc o m p e n s a te t for e increased reactivi caused'by either o of the two postulated 0 0 0 0 0 0 00 The 'concentratio'n of dissolved boron in .thefuel It pool satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii). spent LCO The specified concentrat of dissolved boron in'theuel t .oep preserveslthe assumption usedoin the analyses of the potential accidentscenarios described above, Thisconcentration of dissolvIed boron is the minimum required concentration for fuel assembly Storage and movement withinmthe uel to epool.spent APPLICABILITY This. LCO applieswhenever fuel assemblies are stored inthe spent fuel pool, until a corppete spent fuel pool Verification has been, performed following the last rnoverment:oflfuel assemblies in the spent fuel pool, This LCO does not apply following the, verification sincevthe 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.BWOG STS B 3.7.15-1 Rev. 3.0, 03/31104 0 Attachment 1, Volume 12, Rev. 1, Page 356 of 461 Attachment 1, Volume 12, Rev. 1, Page 357 of 461 B 3.7.15 O INSERT I 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, keff. 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 10x8; 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. 1, Page 357 of 461 Attachment 1, Volume 12, Rev. 1, Page 358 of 461 W Ppent Fuel Pool Boron ConcentrationM II B 3;7.115 BASES ACTIONS A.1 A.2.1,and A.2.2 hThe Required Actionsare modified by a Note indicating:that LCO 3.0.3 ddoes not. apply.When the concentration of boron in theifuel poe1lis le'ss than required, immnediate action mlust be taken.to occurrence of an accident or to mitigate the consequences of an accident in progress.This is most efficiently achieved by immediately suspending the movement of the fuel assemblies. This does not preclude movement of~a fuel assembly to a safe~position. Thec*oncentration of boron is restored*simultaneously with suspending movement of the fuel assemblies. Alternatively,, beginning a verification of the spent fuel pool locations, to ensure proper locationsof the fuel, can be performed.-=However, prior to resuming movement of fuel assemblies, the concentration .of.boron mUst be restored,'If moving irradiated fuel assemblies while in MODE 5 orG,. 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.operation. Therefore, inability to SUspend movement of fuel assemblies .is not a sufficient reason to require a. reactor shutdown.SURVEILLANCE SR verifies that the concentration of boron in the fe oo pn REQUIREMENTS /is within the required limit. As long as this SR is met, the analyzed ,-- -, Iincidents are fully addressed. The 7 day Frequency is appropriate sR 3.7.15.1 because no major replenishment of pool water is expected to take place over a Short period of time.REFERENCES @~USR~c~o9121 BWOG STS B 3.7.15-2 Rev. 3.0, 03/3!1/04 0 Attachment 1, Volume 12, Rev. 1, Page 358 of 461 Attachment 1, Volume 12, Rev. 1, 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. 1, Page 359 of 461 Attachment 1, Volume 12, Rev. 1, Page 360 of 461 Specific No Significant Hazards Considerations (NSHCs)Attachment 1, Volume 12, Rev. 1, Page 360 of 461 Attachment 1, Volume 12, Rev. 1, 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.

S Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 1, Page 361 of 461 Attachment 1, Volume 12, Rev. 1, Page 362 of 461* ATTACHMENT 16 ITS 3.7.16, SPENT FUEL POOL STORAGE 0 Attachment 1, Volume 12, Rev. 1, Page 362 of 461 Attachment 1, Volume 12, Rev. 1, Page 363 of 461 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)0 Attachment 1, Volume 12, Rev. 1, Page 363 of 461 Attachment 1, Volume 12, Rev. 1, Page 364 of 461 ITS 3.7.16 ITS REFUELING OPERATIONS SPENT FUEL ASSEMBLY STORAGE LCO 3.7.16 ACTION A LIMITING CONDITION FOR OPERATION 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.A C T I O N :. With the requirements of the above specification not satis riedj suspend allotFe fuel movement FNYvithin th e..sgcn r fuel. pool andl , the no~n-complying fuel ass embli es to allowable locations'in intaem edte that the initial enrichment and burnup of the fuel assembly are:in accordance withaFigure 39-.SR 3.7.16.1 DAVIS-BESSE, UNIT I 3/4 9-13 Amendment No. 130, 181,237, 247, 266 9 Page 1 of 2 Attachment 1, Volume 12, Rev. 1, Page 364 of 461 Attachment 1, Volume 12, Rev. 1, 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 5C 0 2,00 2.50 3.00 3.50 4.00 4.50 5.00 Initial Enrichrent (wt% U-235)5.50 Notes: Fuel assemblies with initial enrichments less than 2 wt% U-235 willconservatively be required to meet the burnup requirements of2.0 wt% U-235 assemblies.. Loading pattern considerations applicable to Category "A"' "B", and "C" assemblies are described in the Bases 0 DAVIS-I3ESSE,VNIT I 3/4 9-14 Amendment No. 247, 2,6 Page 2 of 2 Attachment 1, Volume 12, Rev. 1, Page 365 of 461 Attachment 1, Volume 12, Rev. 1, 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.0 Davis-Besse Page 1 of 2 Attachment 1, Volume 12, Rev. 1, Page 366 of 461 Attachment 1, Volume 12, Rev. 1, 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 0 0 Davis-Besse Page 2 of 2 Attachment 1, Volume 12, Rev. 1, Page 367 of 461 Attachment 1, Volume 12, Rev. 1, Page 368 of 461 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)0 0 Attachment 1, Volume 12, Rev. 1, Page 368 of 461 Attachment 1, Volume 12, Rev. 1, Page 369 of 461 CTS 0 PSpent Fuel'Pool StorageM 3.7:16 0 3.7 PLANT SYSTEMS 3.7.16 jlSpent Fuel Pool Storage 3.9.13 LCO 37.16 The combinatio of initial enrichmenand burnup of eagh fuel assembly stored in (Reg' n 2] shall be within e acceptable [bur upqdomain] of I NSERT 1 .37.1 1 or in accordance Oth Specificatiion 4*.1:1.0 0 0 APPLICABILITY: Whenever.any fuel assembly is stored in [Regn 2] of the spent fuel pool.ACCTIONS.CONDITION REQUIRED ACTION": ýCOMPLETION TIME Action 0 A. Requirements ofthe. A.11 ----------NOTE- --- ---LCO~notmet. LCO 3.0.3 is not applicable. initiate action to move the Immediately' noncomplying fuel assemblyfromi Ion to an allowable location}SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 0 4.9.13.1 SR 3.7.16.1 Verify by administrative means the .initial enrichment and burnup of the fuel assembly is in accordance with Figure 3.7.16-1 ýor Speqjfk ation 4.31.1.Prior to storing the fuel assembly in[R1°2lý h 00 BWOG STS 3.7.16-1 Rev. 3. 0, 03/31/04 Attachment 1, Volume 12, Rev. 1, Page 369 of 461 Attachment 1, Volume 12, Rev. 1, Page 370 of 461 3.7.16 CTS Q 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 3.7.16-1.0 0 Insert Page 3.7.16-1 Attachment 1, Volume 12, Rev. 1, Page 370 of 461 Attachment 1, Volume 12, Rev. 1, Page 371 of 461 CTS[Spent Fuel Pool Storagefl 3.7.16 0 INSERT 2-1 Figure 3.9-1 I.c C-J I FOR ILL TRATION ONLY. I 40,000 DO NOT U E FOR OPERATION._ ./ (3"- (3.3, 30354.3)30,000 ...B -26640+(22584 X E) -(16.10 X E " o.,."~ L. i/:/I 20,000 /A C B< 10,000- ./= /_- /(1/0" .-!/(103, 0.0))0 L 0 .5 1 1.5 2.5 3 3. 4: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 located adjacent to Category 'A" Fuel or water oles within the storage racl s.Category 'C" Fuel -Shall not be locat d adjacent to Category" "Fuel.N8 o 35930.8)-Not Pe rrnitted 4.5 0 0 Figure 3.7.16-1 (page 1 of 1)Burnup versus Enrichment Curve for Spent Fuel Storage Racks {'-d INSERT3 0 BWOG STS 3.7.16-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 1, Page 371 of 461 Attachment 1, Volume 12, Rev. 1, Page 372 of 461 3.7.16 CTS Figure 3.9-1 0 INSERT 2 75 3.00 3,50 4.00 .4,50 ý5.00, i nitial Enrichment',(WM' U-Z35).50 Figure 3.9-1 O INSERT 3 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. The approved loading patterns applicable to Category "A," "B," and "C" assemblies are specified in the Bases.0 Insert Page 3.7.16-2 Attachment 1, Volume 12, Rev. 1, Page 372 of 461 0 Attachment 1, Volume 12, Rev. 1, 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. 0 Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 1, Page 373 of 461 Attachment 1, Volume 12, Rev. 1, Page 374 of 461 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)Attachment 1, Volume 12, Rev. 1, Page 374 of 461 Attachment 1, Volume 12, Rev. 1, Page 375 of 461 fPSpent Fuel Pool Storage]B 3.7.16 0 B13.7 PLANT SYSTEMS B 3.7.1!6 j] Spent Fuel Pool Storage J 0 BASES BACKGROUND The spentfuel storage facility is designed to store.either new (nonirradiated) nuclear fuel assemblies, or burned (irradiated)fuel assemblies in a vertical configuration underwater. t The storage pool i sized to store [735e fuel assemblies, which in udes storage for [15] p ile fuel containers. The nspnt fuel storage cella are installed in paralley row with center to spacing of [12 31/32]/nches in one direction /and[13 3/161 inhsi" the other orthogonall direction. This spacing. "flux trap" construcuito whereby the fuel ass.mblies are inserted int neutron absorbing staes Stel cans, is suffi ent to maintain a o s< 0.95 for spent fuel of/originai enrichm-ent of u to [3.3]%, However, initial enrighlment fuel assemblies ar stored in the spent fu I pooi,.they must in a checkerboa rd) attern taking into, acco nt fuel burnup Ito mairycain a of 0.95 or less, APPLICABLE The spent fuel, storage facility -is designed for noncriticality by use of SAFETY adequate and "flux trr" construction _th ANALYSES [assembhJs are nserted into eutron absorbing sta hless steel can The spent fuel pool storage satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii). I 0 0 oo0 00 0 LC 0 The restrictions on the placement of fuel assemblies within the~fuel pool,s according to Figure 13.7.16-1 fin the ac ing LC, ensure that the keff of the spent fuel pool will always remain < 0.95 assuming the pool to be flooded with unborated water. The restrictions are consistent with the criticality safety analysis performed for the spent fuel pool, according to INSET Fuel assemblies npt meeting the cnteria__qT_ Figure [3.7,1 -1] shall be stored in q4ýcordance with Specifiation 4.3:1, APPLICABILITY This LCO applies whenever any fuel assembly is stored ine the spent fuel pool.BWOG STS B 3.7.16-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 1, Page 375 of 461 Attachment 1, Volume 12, Rev. 1, Page 376 of 461 B 3.7.16 O( INSERT I 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. 0 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 keff 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. 1, Page 376 of 461 Attachment 1, Volume 12, Rev. 1, Page 377 of 461 MSpent Fuel Pool StoragejE B 3.7.16 0 BASES ACTIONS Al, Required Action A.I is modified by a Note indicating that LCO 3.0.3,does not apply.When the configuration of fuel assemblies stored in the spent fuel pool is hot in accordancewith FigureJ3.7.16-111 immediate action must be~taken to make the necessary fuel assembly movement(s) to bring the.configuration into compliance with Figure[j3.7.16-1], If 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 I acco~ pnyFig Lc. For fuel assemblit 1 in the unacceptable .nge o[Figure efrance of the ;7will ensure compliange with REFERENCES N e 1. UFSAa, Section 9.1.2. 1.0 0 0 0©0 BWOG STS B 3.7.16-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 1, Page 377 of 461 Attachment 1, Volume 12, Rev. 1, 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 paragraphdescribing 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. 1, Page 378 of 461 Attachment 1, Volume 12, Rev. 1, Page 379 of 461 Specific No Significant Hazards Considerations (NSHCs)Attachment 1, Volume 12, Rev. 1, Page 379 of 461 Attachment 1, Volume 12, Rev. 1, 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. 1, Page 380 of 461 Attachment 1, Volume 12, Rev. 1, Page 381 of 461 0 ATTACHMENT 17 ITS 3.7.17, SECONDARY SPECIFIC ACTIVITY Attachment 1, Volume 12, Rev. 1, Page 381 of 461 Attachment 1, Volume 12, Rev. 1, Page 382 of 461 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)Attachment 1, Volume 12, Rev. 1, Page 382 of 461 Attachment 1, Volume 12, Rev. 1, Page 383 of 461 ITS 3.7.17 ITS PLANTSYSTEMS ACTIVITY LIMITING CONDITION FOR OPERATION 3.7.1.4 The specific activity of the secondary-coolant system shall be S40.10 uCi/gramiDOSE EQUIVALENT 1-131.LCO 3.7.17 ACTION A APPLICABILITY: MODES 1, 2, 3 and 4.ACTION: 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 hours and in COLD SHUTDOWN within the following 30hours.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 performance of the" sampling and]Fanalysis/ program of Tab)e 4.7-e .Mýl e~DAVIS-BESSE, UNIT 1 3/4 7-7 0 Page 1 of 2 Attachment 1, Volume 12, Rev. 1, Page 383 of 461 Attachment 1, Volume 12, Rev. 1, 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 AND ANALYSIS SAMPLE AND ANALYSIS FREQUENCY 11. Gross Actj'fty Determination X At leastince per_72 hoursF L01 SR3.7.17.1

2. lsotopi- Anal sis for DOSE EQUIVALENT I-131 Concentration ,a) 1 per 31 daysF, -whenev, the gross activi~ty determ!tion indicates iodine con, tratio,"n greater than 10%j of the .1lowable ilimi~t./b) 1 &; months-, whenv e0 the gr ss, activity dete j'indica es iodine concen rýbelow 0% of the allowa 11 DAVIS-BESSE, UNIT I 3/4 7-8 Page 2 of 2 Attachment 1, Volume 12, Rev. 1, Page 384 of 461 Attachment 1, Volume 12, Rev. 1, 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 Procedural Details 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 (5 0.10 pCi/gm DOSE EQUIVALENT 1-131). This changes the CTS by moving the detail that an isotopic analysis must be performed to 5 satisfy the requirements of the Surveillance to the Bases.Davis-Besse Page 1 of 2 Attachment 1, Volume 12, Rev. 1, Page 385 of 461 Attachment 1, Volume 12, Rev. 1, 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 (Category 5 -Deletion of Surveillance Requirement) CTS Table 4.7-2 Item I requires that the gross activity determination be completed once per 72 hours.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 acceptab le 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.0 Davis-Besse Page 2 of 2 Attachment 1, Volume 12, Rev. 1, Page 386 of 461 Attachment 1, Volume 12, Rev. 1, Page 387 of 461 WImproved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)0/0 Attachment 1, Volume 12, Rev. 1, Page 387 of 461 Attachment 1, Volume 12, Rev. 1, Page 388 of 461 CTS ,Secondary Specific Activity 3.7.17 3.7 PLANT SYSTEMS 3.7.17 Secondary Specific Activity 3.7.1.4 LCO 3:7.17 APPLICABILITY: The specific activity of the secondary coolant shall be s--0.1lOM]ACi/gmn DOSE EQUIVALENT 1-131.MODES 1, 2, 3, and 4.0 ACTIONS CONDITION Action A. Specific activity not within limit.A.1 AND A,2 REQUIRED ACTION Be in MODE 3.COMPLETION TIME 6 hours 36 hours Be in MODE 5.SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.17.1 Verify the specific activity of the secondary coolant M31Mdays is <40.10lpCi/gm DOSE EQUIVALENT 1-131.4.7.1.4 0 BWOOG STS 3.7.17-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 1, Page 388 of 461 Attachment 1, Volume 12, Rev. 1, 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. 1, Page 389 of 461 Attachment 1, Volume 12, Rev. 1, Page 390 of 461 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)0 0 Attachment 1, Volume 12, Rev. 1, Page 390 of 461 Attachment 1, Volume 12, Rev. 1, Page 391 of 461 Secondary Specific Activity B 3.7.17 B 3.7 PLANT SYSTEMS B3.7.17 Secondary Specific Activity BASES BACKGROUND Activity in the secondary coolant results from steamgenerator tubesout-LEAKAGE from the Reactor Coolant System (RCS). Under steady state conditions, the activity is primarily iodines with relativelyshort half livesýand, 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 inthe 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 activityvalue that might be expected from a 1 gpm tube leak (LCO 3.4.13, "RC$ 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 ontained in the stea mgenerator inventory, the feedwater; and the reactor coolant leakage. Most of the iodine isotopes have short ihalf lives (iLe., < 20 hours).With the sp ified activity limit, th resultant 2 hour thyroi dose to a person athe 'exclusion areabo ndary (EAB) would be out 0.79 rem if the mai steam safety valves 'SSVs) are open forthe 2 hours following e are a trip omfull power. boUndary Fd,,e Operating a unit at the allowable limits could result in ex sur of a small fraction of the 10!CFR 100 (Ref. 1) limits, ort limits consistent with estshe a the NRC staff approved licensing basis.APPLICABLE The accident analysis of the main steam line break, as discussed in the SAFETY section 15.4 FSAR, ha er [151 (Ref. 2) assumes t e initial secondary co Tant ANALYSES { specitic activlty to have a radioactive i otope concentration Qr0.1 pCi/tm,-DOSE EQ IALENT 1-131.1 This assumption is used in the analysis for (NET1 determining the radiological consequences of the postulated accident.The accident analysis, based on this and other assumptions, shows that the radiological consequences of an MSLB do not exceed established limits, (Ref. 1) for whole body and thyroid dose r ( 0 BWOG STS B 3.7.17-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 1, Page 391 of 461 Attachment 1, Volume 12, Rev. 1, Page 392 of 461 B 3.7.17 0 INSERT I 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 hours until the RCS is cooled down and the pressure differential is equalized. Insert Page B 3.7.17-1 Attachment 1, Volume 12, Rev. 1, Page 392 of 461 Attachment 1, Volume 12, Rev. 1, Page 393 of 461 0 ,Secondary Specific Activity B 3.717 0 BASES APPLICABLE SAFETY ANALYSES (continued) Wth Aloss ooffsite w the: remaining steam generator is available for core~decay heat.dissipation by venting steam to the atmosphere A through the MSSVs and stea eneratora s heric m valves The E gency[ Feedwater System supplies the necessary makeup to the steam generator. Venting continues until. the reactor coolant temperature and pressure has decreased sufficiently forthe SDecay Heat Removal SSystem to complete thecooldown. 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 tothe environment. The unaffected steam generator is assumed to discharge steam and any entrained activity through the MSSVs nP during the event. Since no credit is taken in the analysis for activity plateout or retention, the resultant radiological consequences represent a conservative estimate of the potentialintegrated 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 -R0.1 0qp Ci/gm DOSE, EQUIVALENT 1-131 maintains the radiological consequences of a Design Basis Accident (DBA) to a small fraction of Reference 1 limits.Monitoring the specific activityof 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 con sequencesof 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.0 0 0 0 0 BWOG STS B 3.7.17-2 Rev. 30, 03/31/04 Attachment 1, Volume 12, Rev. 1, Page 393 of 461 Attachment 1, Volume 12, Rev. 1, Page 394 of 461 0 Secondary Specific B 3:7.17 BASES ACTIONS A.1 and A.2 DOSE EQUIVALENT I-331 exceeding the allowable value. in the secondary coolant contributes:to increased post accident doses. If.secondary specific activ~itylcannotOg restored to within *Jits wthin thie is not within limits associa ed ametion Tim ,the unit mustbe placed ina *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 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to, reach the required unit conditions from full power conditions in an orderly manner and without'challenging unit systems.0 SURVEILLANCE REQUIREMENTS SR 3.7.17.1 An This SR verifies that the secondary specific activity is within the limits of[' the accident analysis.' A g~mmI isotopic analysis of the secondary coolant, which determines DOSE EQUIVALENT 1-13.1 confirms the: validity of the safety analysis assumptionsjreleases. It also serves to o 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.D DO 0 REFERENCES

1. 10CFR100FYf.T rU-((BWOG STS B 3.7.17-3 Rev. 3,0, 03/31/04 0 Attachment 1, Volume 12, Rev. 1, Page 394 of 461 Attachment 1, Volume 12, Rev. 1, 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. 1, Page 395 of 461 Attachment 1, Volume 12, Rev. 1, Page 396 of 461 Specific No Significant Hazards Considerations (NSHCs)0 Attachment 1, Volume 12, Rev. 1, Page 396 of 461 Attachment 1, Volume 12, Rev. 1, 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. 1, Page 397 of 461 Attachment 1, Volume 12, Rev. 1, Page,398 of 461 0 ATTACHMENT 18 ITS 3.7.18, STEAM GENERATOR LEVEL Attachment 1, Volume 12, Rev. 1, Page 398 of 461 Attachment 1, Volume 12, Rev. 1, Page 399 of 461 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)Attachment 1, Volume 12, Rev. 1, Page 399 of 461 Attachment 1, Volume 12, Rev. 1, 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 L-e LCO 3.7.18 3.7.9 Each Steam Generator shallhaveja minimum water leVel of 18 inches and the maximum specified below as applicable: MODES I and'2:, ,a. The acceptable operating region of Figure 3,7-1.MoDE 3*: b. 50 inches Startup Range with theSFRCS Low Pressure Trip bypassed and one or both Main Feedwater Pump(s) capableof supplying Feedwater to any Steam Geneator.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:[d. 625 incheFull Range Level APPLICABILITY: MODES 1,2, 3, and as above, LAO1 ACTION B ,ACTION:*- [ Add proposed ACTIONA With one or more steam generator's water level outside the limits, be in at least HOT STANDBY within 6 hours and in OLD within the next ours L02 A02 SURVEIALLANCE REQkUIREMEzNTS SR 3.7.18.1 4.7.9 The steam generator shall be demonstrated OPERABLE by verifying steam generatorlevel tobe within limits.at least once per 12 hours.ACTIONS

Establish adequate SHU.jTDOWN MARGIN to ensure the reactor will stay subcritical Note during a MODE 3 Main Steam Line Break.DAVIS-BESSE, UNIT I 3/4 7-38 Amendment No.-2-17+

,-l 276 Page 1 of 2 Attachment 1, Volume 12, Rev. 1, Page 400 of 461 Attachment 1, Volume 12, Rev. 1, 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)*~90 6 .0'a'50 LO .Unacceptable Operating Re Siam 0 Acceptable Operating ,Region~0 10 20 30 60 Main Steam Superheat (oF)0 DAVIS-BESSE, UNIT I 3/4 7-39 Amendment No. -192-, 276 Page 2 of 2 Attachment 1, Volume 12, Rev. 1, Page 401 of 461 Attachment 1, Volume 12, Rev. 1, 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 hour 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 Procedural Details 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. 1, Page 402 of 461 Attachment 1, Volume 12, Rev. 1, 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 I -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. 1, Page 403 of 461 Attachment 1, Volume 12, Rev. 1, 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 hours and COLD SHUTDOWN (MODE 5) within the next 30 hours. 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. 1, Page 404 of 461 Attachment 1, Volume 12, Rev. 1, Page 405 of 461 iImproved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)Attachment 1, Volume 12, Rev. 1, Page 405 of 461 Attachment 1, Volume 12, Rev. 1, Page 406 of 461 CTS Steam Generator Level 3.7.18 3.7 PLANT SYSTEMS 3.7,18 Steam Generator Level INSERT 1 3.7.9 LCO 3.7.18 Water level of ýdach steam generat9 shall be less thal or equal to-the maximum w4('r level shown in:Fidure%3.7.18-1. /I and 31 MOD ES 1 *r-ý0 0 0 APPLICABILITY: INSERT 2 ACTIONS CONDITION DOC L02 A. Water level in one or more-steam generators I greater than aximumj notwithin nwaterleve n limits JFigure 3,7118-1 i A-1 REQUIRED ACTION Restore steam generator level to within limit.COMPLETION TIME 15 minutes 0 Action B. Re~quired Action and associated Cornletion Time bfCodition AI not met.B.1 Be in MODE 3.i --- NSR3 6 hours (D2 SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.7.18.1 Verify steam generator water level to be within limits.FREQUENCY 12 hours 4.7.9 BWOG STS 3.7.18-1 Rev. 3,0, 03131/04 Attachment 1, Volume 12, Rev. 1, Page 406 of 461 Attachment 1, Volume 12, Rev. 1, Page 407 of 461 3.7.18 CTS 0 INSERT I 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.INSERT 2 O Footnote *-------------- NOTE -------------------------- 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 hours 0 Insert Page 3.7.18-1 Attachment 1,,Volume 12, Rev. 1, Page 407 of 461 Attachment 1, Volume 12, Rev. 1, Page 408 of 461 3.7.18 Steam Generator Level 3.7.18 L.1 LU-j LU 0~LU 0-mj STEAM SUPERHEAT ('F)Figure 3.7.1841 (page 1 of 1)Maximum Allowable Steam Generator Level BWOG STS 3.7.18-2 Rev. 3.0, 03/31104 0 Insert Page 3.7.18-1 Attachment 1, Volume 12, Rev. 1, Page 408 of 461 Attachment 1, Volume 12, Rev. 1, Page 409 of 461 3.7.18 CTS 0 INSERT 4 Figure 3.7-1 100 90 80 70 60 50 40 (43,96)Unacceptable Operating Region Acceptable Operating Region 0 10 Z0 50'60 Insert Page 3.7.18-2 Attachment 1, Volume 12, Revw 1, Page 409 of 461 Attachment 1, Volume 12, Rev. 1, 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.0 Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 1, Page 410 of 461 r Attachment 1, Volume 12, Rev. 1, Page 411 of 461 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)Attachment 1, Volume 12, Rev. 1, Page 411 of 461 Attachment 1, Volume 12, Rev. 1, Page 412 of 461 Steam Generator Level B 3.7.18.83.7 PLANTSYSTEMS.

B.3.7.18 .Steam Generator Level BASES BACKGROUND A principal function of the steam generators is to provide superheated steam at a constant pressure O psia) over the power range. Steam generator water inventory is maintained large enough to provide.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.0 IINSERT I The maximum opera g steam generator level isbass d primarily on preserving the initial ondition assumptions for stea generator inventory used in the FSARs 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 primary side cool.h gfollowing an SLB and the ma imum pressure in the reactor building.0 0 For a clean once through steam generator, the mass, inventory in a steam enerator for operating at 100% power is approximately 39, 0Olb to 55,000 O50 b 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 MVVJ. The results were presented as the amount of mass inventory in each steam generator versus operating range level and steam superheat. 0 BWOG STS B 3.7.18-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 1, Page 412 of 461 Attachment 1, Volume 12, Rev. 1, Page 413 of 461 B 3.7.18 (D 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.0 Insert Page B 3.7.18-1 Attachment 1, Volume 12, Rev. 1, Page 413 of 461 Attachment 1, Volume 12, Rev. 1, 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, wen operating, at power levels< 100%..2 The points% displayed in Figure.3.7.18-1. CO are the intercept points, of the 57,000 lb mass value, and the operating range level x and steam superheat values.The steamgenerator 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.0 APPLICABLE The most limiting Design Basis.A6cidentthat Would be affected by steam SAFETY L generator operating level is asteam line failure. This accident is ANALYSES evaluated in Reference

1. The parameter of interestis the mass ofwater, 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 an4SLB accident.

A higher inventory causes theleffects of the accident to be more severe.Figure,3.7.18-11, in e acco0ppanying =, is based upon maintaining inventory < 57,000 Ibwhich is 19% less than the inventor/ used in thel E FSAR acciddnt analysis, and tiherefýre is conservative. 0 0 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. 1, Page 414 of 461 Attachment 1, Volume 12, Rev. 1, Page 415 of 461 B 3.7.18 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. 1, Page 415 of 461 Attachment 1, Volume 12, Rev. 1, 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 containment, and excessive cooling (and'irelated core reactivity effects).following anLB. in addition, feedwater nozzle floding. would impair 0 M feedt-er heating and could result in-excessive tube to shell termperature differentials and excessive tubesheet temperature gradients. and 3 APPLICABILITY LJIn MQOES-1~j 2, a maximum steam generatorwater level is required main to preserve the initial condition assumption for steam generator inventory seam generator water -used in the steam line failure accident analysis (Ref. 1). Qllevel (in conjunction withl meeting the requirements In MODE 3,.imits on RCS boron cncentrations will~prevent a return to also Uof LCO 3.1.1, I []criticality in the event of antSLB.Iln MODES 4, 5, and 6, the water in the i"SHUTDOWNDMARGIN/I) steam generator has a low specific enthalpy; therefore, there is no need to limit the steam.generator inventorywhen.the unit is in this condition, ACTIONS A.1 INSERT3 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 waterlevel 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 oyrequal to the marmum level in Figure 3.7.18-1, 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 hour The allowed Completion Tim1`1 ]reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an (D orderly manner and without challenging unit systems. and in IM ODE 45 SURVEILLANCE SR 3.7.18.1 within REQUIREMENTS 12 hours I his b{ venrtes tne steam generator level to De witnin acceptaole limits.The 12 hour Frequency is adequate because the operator will be aware of unit evolutions that can affect the steam generator level between checks. Furthermore, the 12 hour 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 LY1. iFSAR, Section[15.4.4M 00 BWOG STS B 3.7.18-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 1, Page 416'of 461 Attachment 1, Volume 12, Rev. 1, Page 417 of 461 B 3.7.18INSERT 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. 1, Page 417 of 461 Attachment 1, Volume 12, Rev. 1, 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. 1, Page 418 of 461 Attachment 1, Volume 12, Rev. 1, Page 419 of 461 Specific No Significant Hazards Considerations (NSHCs)0 Attachment 1, Volume 12, Rev. 1, Page 419 of 461 Attachment 1, Volume 12, Rev. 1, 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.-j Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 1, Page 420 of 461 Attachment 1, Volume 12, Rev. 1, Page 421 of 461 ATTACHMENT 19 RELOCATED/DELETED CURRENT TECHNICAL SPECIFICATIONS 0 Attachment 1, Volume 12, Rev. 1, Page 421 of 461 Attachment 1, Volume 12, Rev. 1, Page 422 of 461 CTS 3/4.7.2, STEAM GENERATOR PRESSURE/TEMPERATURE LIMITATION 0 Attachment 1, Volume 12, Rev. 1, Page 422 of 461 Attachment 1, Volume 12, Rev. 1, Page 423 of 461 WCurrent Technical Specification (CTS) Markup and Discussion of Changes (DOCs)0 Attachment 1, Volume 12, Rev. 1, Page 423 of 461 Attachment 1, Volume 12, Rev. 1, Page 424 of 461 CTS 3/4.7.2 TO PLANT SYSTEMS 3/4.7:.2 STEAM GENERATOR PESR/EPRTm LIMITING CONDITION FOR OPE 1TION'3.7.2.1 The temperature f the secondary coolant in the steam generators shall be >.110*F vhen the, pres re of the secondary coolant in the team generator is> 237 psig..APPIUCABILITY: At'all tm es.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 bie for continued operation pr or to increasing its pressure above 37 psig.SURVEILLANCE REOUI MENTS L 0 4.7.2.1 The tern rature of the secondary coolant in e ch steam generator shall be determined to e > 110OF at least once per hour vh secondary pressure in the steam genera r is > 237 psig and Tavg is .< 2000F.DAVIS-BESSE, IT i 3/4 7-13 Amendment No. 135 I Page 1 of 1 Attachment 1, Volume 12, Rev. 1, Page 424 of 461 Attachment 1, Volume 12, Rev. 1, 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 > 11 0°F 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. 1, Page 425 of 461 Attachment 1, Volume 12, Rev. 1, Page 426 of 461 DISCUSSION OF CHANGES CTS 314.7.2, 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 0 Davis-Besse Page 2 of 2 Attachment 1, Volume 12, Rev. 1, Page 426 of 461 Attachment 1, Volume 12, Rev. 1, Page 427 of 461 Specific No Significant Hazards Considerations (NSHCs)0 0i Attachment-1, Volume 12, Rev. 1, Page 427 of 461 Attachment 1, Volume 12, Rev. 1, 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. 1, Page 428 of 461 Attachment 1, Volume 12, Rev. 1, Page 429 of 461 0 CTS 3/4.7.7, SNUBBERS Attachment, 1, Volume 12, Rev. 1, Page 429 of 461. Attachment 1, Volume 12, Rev. 1, Page 430 of 461*Current Technical Specification (CTS). Markup and Discussion of Changes (DOCs)Attachment 1, Volume 12, Rev. 1, Page 430 of 461 Attachment 1, Volume 12, Rev. 1, 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 APPLICABILITY: HODE I , 2, 3 and 4. (MODES 5 on systems required PPERABLE in those MODES).OPERAB.and 6/or snubbers located ACTION: a. With one or more-snubbers inoperable: I. within 72 hours 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 hours; or 3. declare the supported subsystem inoperable and follow the appropriate ACTION statement for that.system.and jfo snubbers which have failed eit er the visual or fun.ctio aI test: b. Perfor an engineering evaluation withi 90 days to determine if any safety-related System r component has.,been a versely affected by:the inopera ility of the snubbe and if the snubber mode of fai re .has imparted a signif cant effect or degradation on t e supported compon nt or system.' The'provisions f Technical specif cat 'ion 3,0.4 are not, applicable for the component or, sys 'em, : S1JRVIEILLANCE REOUTRE ,NTS 4.7.7 Each snubbe 2 shall be demonstrated OPERAB by the of the following surveillance irograms and pursuant t requirements of Specification 4.0.5.4.7.7.1 Visual Inspection Program'Engineering evaliuat on is not required when a snubb r is removed for surveillance testin provided it is returned to OPE LIE 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 gro ps without a License Amendment. See ITS Section 3.0 LAO DAVIS-BESSE, UNIT I 3/4 7-20 Amendment No. Vg,/Y YY, 161 Page 1 of 8 Attachment 1, Volume 12, Rev. 1, Page 431 of 461 Attachment 1, Volume 12, Rev. 1, Page 432 of 461 CTS 3/4.7.7 Conti nit ad)/PLANT SYSTEMS SURVEILLANCE REQUIREMENTS 0 a. General ReI uirements At least o ce per inspection interval, each roup of snubbers i use in the Plant shall be visually inspected.In accorda cewith Specification 4.7.7.1.b rnd 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 inacc: 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 b established based on physical characteristics andacc ssibility.

Inaccessible 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. to the chedule determined by Table 4.7- .The visual inspection interval for each snubber gro p shall be determined based upon the criteria provii ed in Table 4.7-5, and th first inspection interval determ ned using the criter a shall be based upon the pre.viou inspection interval as est blished by the requirements in e fect before amend-ment 11 DAVIS-BESSE, UNIT 3/4 7-21 Ame dment No. 0, 161 (next page is 3/4 7-21a)LAO1 Page 2 of 8 Attachment 1, Volume 12, Rev. 1, Page 432 of 461 Attachment 1, Volume 12, Rev. 1, Page 433 of 461 CTS 3/4.7.7 TABLE 4.7-5 SNUBB VISUAL INSPECTION INTERVAL NUMBER OF UNACCEPTABLE SNUBBERS Population Column A Column B Col C or Group Extended terval Repeat Interval Reduced I terval (Notes 1 and 2) (Notes 3 d 6) (Notes 4 and 6) (Notes.5 d 6)1 0 0 80 0 0 100 0 1 150 0 3 200 2 5, 31 300 5 12 5 400 a 18 36 500 1 24 48 750 2 40 78 1000 or greater 2 56 109 Note 1: The next visua -inspection interval for a snubber pop lation or: group size sha I be determined based upon the previo inspection interval and t e.number of unacceptable snubbers fo d during that interval. Snu bers may be grouped, based upon their accessibility. during pover erstion, as accessible or Inaccessibl .These categories ma be examined separately or jointly. H wever, the licensee must make and document that decision befor any inspection andeshall usethat decision as, the basis upon vhich to determine the next inspecti n interval for that group.Note 2: Interpolatio betveen population or group sizes an the number of unacceptable snubbers is permissible. Use next lo er integer for the valueof the limit for Columns A, B, or C if that nteger includes a fractional v ue of unacceptable snubbers as dete ned by interpolati Note 3: If the numb r of unacceptable snubbers is equal t or less than the number in luma A, the next inspection interval y be twice the previous in erval but not greater than 48 months.Note A: If the nun r of unacceptable snubbers is equal or less than the number in lumn B but greater than the number I (olumn A, the next inspection interval shall be the same as the pre ious interval.DAVIS-BESSE, UNIT. 3/4 7'21a Am ndment No.1 6 1 Page 3 of 8 Attachment 1, Volume 12, Rev. 1, Page 433 of 461 Attachment 1, Volume 12, Rev. 1, Page 434 of 461 CTS 3/4.7.7 Noe 5.: If the number of unacce table snubbers is equal to or: gr ater than the number in Column C, th next Inspection interval shall e tvo-thirds of the previous interv 1. Hovever, if the number of un eceptable 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, then ist the previous interval shall be reduced by a factor that is one-th rd of the ratio of the different betveen the number of unacceptab snubbers found during the previ us interval and the number in Column 8 to the difference in the numbe in Columns B and C.Note 6: The provisions of S ectftcation 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 shutdovni when plan conditions allow five days for I spectlon, DAISBEE 13/4 7-21b -161 DAVIS-BESSE, l " (next page is 7-22) Amendment No.Page 4 of 8 Attachment 1, Volume 12, Rev. 1, Page 434 of 461 Attachment 1, Volume 12, Rev. 1, Page 435 of 461 CTS 3/4.7.7 REQUIREMENTS IC ntinued)PLANT SYSTEMS SURVEILLANCE Sc. Acceptance C~iteria A-snubber sh Il.be considered OPERABLE as a esult 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 e visual inspection acceptance criteria of Specific tion 4.7.7..1.c: I. Dete 'mne 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 rly, establish and remedy the cau e of the rejection for that particular snubber and for other snubbers that ma be generically susceptible; and 3. Cl ssify the snubber as acceptable or the purpose of es ablishing the next visual inspe tion interval.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 hav.e 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.SE, UWIT 1 3/4 7-22 Amendment No. #,ý,04 1,161 ,1 eAO DAV!S-BESS Page 5 of 8 Attachment 1, Volume 12, Rev. 1, Page 435 of 461 Attachment 1, Volume 12, Rev. 1, Page'436 of 461 CTS 3/4.7.7 PLArNT SYSTEMS /SURVEILLANCE REOUIRFMENTS Ctnud* /SURVELLANE REUIREENTS(C7tnued 4ý7.7.2 Functional Test p ogram a. General: Requ reients At least on e per inspection interval a represent tive sample of e h group of snubber in use :in the Pla t shall be functio ally ,tested in accordance with Specifications 7.2 Id 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,.be ch testing or in-place testing;b. ~Inspecti A Interval and Criteria'The snub ers may be categorized into groups ba ed on physica characteristics and accessibility. E ch group nmay be 4:ested independently from the standpoin of perform ng-additional tests if failures are di covered.DAVIS-BESSE Unit 1 3/4 7-22a Ame ent No. 117,/I.ArA 1 (Next page is 3/4 7-23)LAO1 61 0 Page 6 of 8 Attachment 1, Volume 12, Rev. 1, Page 436 of 461 Attachment 1, Volume 12, Rev. 1, Page 437 of 461 CTS 3/4.7.7 PLANT SYSTEMS SURVEILLANCE-REQUIREMENTS Cont nued The- inspection nterval for functional testing shal be each REFUELiNG INTER AL.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 tt 10 percent (rou ded off to Tnext highest integer) of ach group of sn bers in use in the Plant. The sele'tion process sha I ensure that all snubbers, regardle s, of their acces ibility classification, are functi aly tested: at east once every ten inspection intert al s, c. ce tanc Criteria For hydr lir snubbers (either inplace testing or bench testing) the test: shall verify that: 1. Sn bber, piston will allow the ýhydraul.ic fluid to"b passl" fromone -side of the piston to the other toýa sure unrestrained action is achieved ithin the s ecified .range of velocity or acceler tion in both 0nsion and compression./

2. hen the snubberis 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, 'where 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-tompression within t e specified range.DAVIS-BESS UNIT 1 3/4 7-23 endment No. -5, 217 0 Page 7 of 8 Attachment 1, Volume 12, Rev. 1, Page 437 of 461 Attachment 1, Volume 12, Rev. 1, Page 438 of 461 CTS 3/4.7.7 9 PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Con /inued)dý Resparnse to Failures For each mnop rable snubber per Specification.4.7.7.2.c:.

1. Perform the ACTIONS specified in 3,7.7a an I3 T7.7b; and 2. Within the specified inspection.

interval, f ctionally ,test a additional sample of at.least 10 per ent of the s ubber units from the group that the' in perable snubb r unit is in.The unctional testing of an additional

sam le of at lea 10 percent from the .inoperable snubb r's group.is equired for each snubber unit determind to.hbe ino erable in subsequent functional tests, or until al snubbers in that gr oup 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, I 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. 15,94 Tables 3. 1-3 and 4.7-4 deleted. Next Page is 3/4 7-368.Page 8 of 8 Attachment 1, Volume 12, Rev. 1, Page 438 of 461 Attachment 1, Volume 12, Rev. 1, Page 439 of 461 DISCUSSION OF CHANGES CTS 314.7.7, 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. 1, Page 439 of 461 Attachment 1, Volume 12, Rev. 1, Page 440 of 461*Specific No Significant Hazards Considerations (NSHCs)0 Attachment 1, Volume 12, Rev. 1, Page 440 of 461 Attachment 1, Volume 12, Rev. 1, Page 441 of 461 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS CTS 3/4.7.7, SNUBBERS There are no specific NSHC discussions for this Specification. 0 0 Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 1, Page 441 of 461 Attachment 1, Volume 12, Rev. 1, Page 442 of 461 CTS 3/4.7.8, SEALED SOURCE CONTAMINATION 0 Attachment 1, Volume 12, Rev. 1, Page 442 of 461 Attachment 1, Volume 12, Rev. 1, Page 443 of 461 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)Attachment 1, Volume 12, Rev. 1, Page 443 of.461 Attachment 1, Volume 12, Rev. 1, Page 444 of 461 CTS 3/4.7.8 0"A N T .SY S T E M S/3/4'.7.8 SEALED SOURCE CONTAMIN ION LIMITING CONDITION FOR OPERATIiN 3.7.8.1 Each sealed source c ntaining radioactive, material ei her 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 /ACTION;a. Each sealed sour e with removable contamination i excess of the: above limit sha 1 be immediately withdrawn from e and: 1. Either dec ntaminated and repaired, or 2. Disposed f in accordance with Commission egulatiouns.-b. The provision of.Specifications 3.0.3 and 3.0. are not applicable. SURVEILLANCE REQUIRE NTS 4.7.8.1.1 Test Requircements -Each sealed source shall 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 -Eacb category of seal d sources shall be,, tested.at the fr quency described below.a. Sourc4s in use (excluding startup source and fission detectors previbusly subjected to core flux) -At least once per six moat s for all sealed sources contaiain ra dioactive material: DAVIS-BESSE, IT 1 3/' 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. 1, Page 444 of 461 Attachment 1, Volume 12, Rev. 1, Page 445 of 461 CTS 3/4.7.8 ROI 0 0 PLANT SYSTEMS SUMILLANCE REQUIREMINTS (C ntinued)1. With a half, ife greater than 30 days (excluding ydrogen 3) and 2. In any fo 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 fiýsion detectors transferred witbhout a ertificate-inicating.hed last test date shall be 'tested prior o being pla~ced, into u ,., Sta Irtup sourc ss and fission detectors 'Each sealed startup-source and fIssion" 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. to6 the source.4.7.8.l.3 Reports.- report shall be prepared and submitte to the Commission on an annu 1 basis if sealed source or fission d ector leakage tests reveal he presence .of >,0.005 microcuries of removable c Iontamination'. DAVIS-BESSE 'UNIT 1 3/4 7-37 Page 2 of 2 Attachment 1, Volume 12, Rev. 1, Page 445 of 461 Attachment 1, Volume 12, Rev. 1, 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. 1, Page 446 of 461 Attachment 1, Volume 12, Rev. 1, 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. 1, Page 447 of 461 Attachment 1, Volume 12, Rev. 1, Page 448 of 461 Specific No Significant Hazards Considerations (NSHCs)0 Attachment 1, Volume 12, Rev. 1, Page 448 of 461 Attachment 1, Volume 12, Rev. 1, 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. 0 Davis-Besse Page 1 of 1 Attachment 1, Volume 12, Rev. 1, Page 449 of 461 Attachment 1, Volume 12, Rev. 1, Page 450 of 461 U ATTACHMENT 20 Improved Standard Technical Specifications (ISTS) not adopted in the Davis-Besse ITS 0 0 Attachment 1, Volume 12, Rev. 1, Page 450 of 461 Attachment'1, Volume 12, Rev. 1, Page 451 of 461 ISTS 3.7.4,, ATMOSPHERIC VENT VALVES 0 0 Attachment 1, Volume 12, Rev. 1, Page 451 of 461 Attachment 1, Volume 12, Rev. 1, Page 452 of 461 WImproved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)Attachment 1, Volume 12, Rev. 1, Page 452 of 461 Attachment 1, Volume 12, Rev. 1, Page 453 of 461 AWs 3.7,.4 3.7 PLANT SYSTEMS 3.7.4 Atmospheric Veni Valves (AVNs)LCO 3.7.*4 [Two] AWs [lines per step neratorl shal be OPERABLE.APPLICABILITY: M 1, 2, and 3, ODE 4 when steam generator is relied upon for heat removal.CONDITION A. One required AW [line] , A.1 inoperable. REQUIRED ACTION COMPLETION TIME>[7da Restore required AW [line]to OPERABLE status.B. [ Two or more required B.1 Restore all one AW 24 hours]AW [lines] inoperable. [n PERABLE status.*e al * .__-0 CA C. Required.Action and. .1 associated Co ion C Time, not AND C.2 Be in MODE 3.Be in MODE 4 without reliance upon steam generator for heat removal.6 hours[24] hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.4.1 Verify one cmp each AW.[181 months BVWOG STS 3.7.4-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 1, Page 453 of 461 Attachment 1, Volume 12, Rev. 1, Page 454 of 461 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE SR 3.74.2 [Verify one complete cycle c valve.FREQUENCY: [18J months ]AVV block, 3.7;4-2 Rev. 3.0, 03/31/04 0 Attachment 1, Volume 12, Rev. 1, Page 454 of 461 Attachment 1, Volume 12, Rev. 1, Page 455 of 461 JUSTIFICATION FOR DEVIATIONS ISTS 3.7.4, ATMOSPHERIC VENT VALVES (AVVs)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. 1, Page 455 of 461 Attachment 1, Volume 12, Rev. 1, Page 456 of 461 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)Attachment 1, Volume 12, Rev. 1, Page 456 of 461 Attachment 1, Volume 12, Rev. 1, Page 457 of 461 B 3.7 PLANT SYSTEMS B 3.7.4 Atmospheric Vent Valves (AWs)BASES AV~s B 3.

7.4 BACKGROUND

The AWs prov *a thod for cooling the unit to decay heat removal (DHR).e conditions, should the preferred heat sink via the Turbine*B System to the condenser not be available, as discussed in the S 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 AVVs are equipped with pneumatic con ers to permit control of the cooldown rate,,[The AVVs are provided a pressurizedgas supplyof bottled nitrogen that, on loss of pre e in the normal instrument air supply, automatically supplies nitr to operate the AV\/s The nitrogen supply is sized to provid icient pressurized gas to operate the AVVs for the time red 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 the AVVs are assumed to be used by the operator to cool do e uni to MODE 3 for accidents accompanied by a loss of offsit wer. Prior to operator actions to cool down the unit, the AWs he main steam safety valves (MSSVs) are assumed to operat tomnatically to relieve steam and maintain the---0 BWOG STS B 3.7.4-1 Rev. 3.0, 03131/04 Attachment 1, Volume 12, Rev. 1, Page 457 of 461 Attachment 1, Volume 12, Rev. 1, Page 458 of 461 AWs B 3.7.4 BASES APPLICABLE SAFETY ANALYSES (continued) steam generator's pressure and te ature belowthe design value.This is about 30 minutes folio initiation of an event; however, this may be less for a stea erator tube rupture (SGTR). event. Some initiating events f' g into this category are a main steam line break.upstream o emain steam isolation valves, a feedwater line break, and an 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 A-.. he number of AWs required to be OPERABLE to satis e SGTR accident analysis requirements depends upon the cons' ation of any single failure assumptions regarding the failur one AVV to open on demand.[The design must accommo the single failure of one AW to open on demand, thus each sm generator must have at least one AVV, The AWs are equi with manual block valves in the event an AW spuriou ils open, or fails to close during use.]he AVVs satisfy Criterion 3 of 10 CFR 50,36(c)(2)(ii). [Two] AWs [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,-_0 LCO APPLICABILITY In MODES 1, 2, and 3, and in MODE 4 hen steam generator is being relied upon for heat removal the 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. 1', Page 458 of 461 Attachment 1, Volume 12, Rev. 1, Page 459 of 461 AWs B 3.7.4 BASES ACTIONS .Ai.'Wth one AW [line] -inoperable, acti ust be taken'to restore the inoperable AW to atus. The 7 day:Completion Time ,allows for redundant i fty afforded by the remaihing OPERABLE AW and a nons grade backup in the Steam Bypass System and[B.1 With more than one AW [line] inoperable, action must be taken to restore[all but one]1AVV [lines] to OPERABLE status, As the block valve can be closed to isolate an AW, some repairs maybe possible with the unit at power. The 24 hour Completion Time is reasonable to repair inoperab AW [lines], based on the availability~of the Steam Bypass Syste nd MSSVs, and the low probability of~an event occurring duri sis period that would require the AW [lines]. ]CA and C.2 If the AVV [lines] ca e restored to OPERABLE status within the associated C etion Timehe unit must be placed in a MODE in which the LC es ot apply. To achieve this status, the unit must be placed east MODE 3 within 6 hours, and in MODE 4 within [24] hours, without reliance upon the steam generator for heat removal. The allowed Completion Times are reasonable, baseidon operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.__0 SUR PVFIL LANCEF SR REQUIREMENTS To perform a controlled cooldown of the RCS, the AVVs must b eto 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 ce testing or use of an AWV during a unit cooldown may satisf s requirement. Operating experience has shown that these ponents usually pass the Surveillance when perfor at 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. 1, Page 459 of 461 Attachment 1, Volume 12, Rev. 1, Page 460 of 461 AWs B 3.7.4 BASES S*UR\/EILLANCE REQUIREMENTS (6ontinued)' The function ofthe blo a ye is to isolate aafailed openAVV. Cycling the blockvalvec dand'open demonstrates its ability to perform this"function. Pornmance of inservice testing or use of the block valve dur nit cooldown may satisfy this requirement. Operating experience sshown that these components usually pass the, Surveillance when performed at the [18] month Frequency. Thereforethe Frequency is acceptable from a' reli~ability standpoint.] REFERENCES

1. FSAR, Section (10.3].--0 BWOG STS B 3.7.4-4 Rev. 3'0, 03/31/04 0 Attachment 1, Volume 12, Rev. 1, Page 460 of 461 Attachment 1, Volume 12, Rev. 1, 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. 1, Page 461 of 461}}

v t e Letter Sequence Other
TAC:MD6398, Increase Flexibility in Mode Restraints, Addition of LCO 3.0.8, Inoperability of Snubbers, Deletion of E BAR Definition and Revision to RCS Specific Activity Tech Spec, Changes to Reflect Revision of 10 CFR 50.55A, Limit Inservice Testing Program SR 3.0.2 Application to Frequencies of 2 Years or Less, Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO, Correct Example 1.4-1, Containment Structural Integrity, TSTF-28, Correct LCO 3.0.6 Bases, Add Restriction for Lowest LOOP Tave During Mode 2 Physics Testing (Approved, Closed)
Initiation Request, Request, Request, Request, Request, Request, Request Acceptance, Acceptance, Acceptance, Acceptance Supplement, Supplement Administration Meeting, Meeting, Meeting Questions 18 June 2008 20 June 2008 Answers 23 July 2008 3 September 2008 Results Approval Other: L-08-161, Copy of Applicable Portions of the NRC and Davis-Besse Improved Technical Specifications Conversion Website - Sections 3.0, 3.1, 3.2, 3.4, and 3.6 and Chapter 4.0, L-08-241, Attachment 1, Applicable Portions of the U.S. Nuclear Regulatory Commission (NRC) and Davis-Besse Nuclear Power Station (DBNPS) Improved. Technical Specification (ITS) Conversion Website, Section 3.5 RAIs, L-08-338, Copy of Improved Technical Specifications (ITS), L-08-378, Implementation of Improved Technical Specification Amendment No. 279, ML073531253, ML081350505, ML082000451, ML082270661, ML082270662, ML082270663, ML082270664, ML082270665, ML082270666, ML082270667, ML082270669, ML082270670, ML082600577, ML082840099, ML082900630, ML082900882, ML082910125
MONTHYEAR2008-02-04 [Table View]

ML082270669

Text

3.5 hours

6.0 REFERENCES

1.0 REFERENCES

7.4 BACKGROUND

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