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Davis-Besse, Unit 1 - Improved Technical Specification Conversion License Amendment Request Volume 3, Revision 1, ITS Chapter 1.0, Use and Application
	ML082270663
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: ML082270663 (71)
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DAVIS-BESSE NUCLEAR POWER STATION UNIT 1 IMPROVED TECHNICAL SPECIFICATION CONVERSION LICENSE AMENDMENT REQUEST VOLUME 3 (Rev. 1)CHAPTER 1.0 -USE AND APPLICATION Attachment 1, Volume 3, Rev. 1, Page i ofi Summary of Changes ITS Chapter 1.0 Change Description Affected Pages Added TSTF-475.

TSTF-475 added clarifying words Page 57 to Example 1.4-3 concerning the 25% grace allowance.

Modified the definition for SHUTDOWN MARGIN to Pages 7, 8, 30, 37, 62, and 69 not include the statement "However, with all CONTROL RODS verified fully inserted by two independent means, it is not necessary to account for a stuck CONTROL ROD in the SDM calculation." This less restrictive allowance is not included because Davis-Besse does not desire to adopt it.This Change affects the CTS Markup, DOC L04 (deleted), ISTS Markup, JFD 12 (new), and NSHC L04 (deleted).

Page 1 of 1 A Attachment 1, Volume 3, Rev. 1, Page i of i Attachment 1, Volume 3, Rev. 1, Page 1 of 69 ATTACHMENT 1 VOLUME 3 DAVIS-BESSE IMPROVED TECHNICAL SPECIFICATIONS CONVERSION ITS CHAPTER 1.0 USE AND APPLICATION Revision 1 0 Attachment 1, Volume 3, Rev. 1, Page 1 of 69 Attachment 1, Volume 3, Rev. 1, Page 2 of 69 W! LIST OF ATTACHMENTS

1. ITS Chapter 1.0 0 Attachment 1, Volume 3, Rev. 1, Page 2 of 69 Attachment 1, Volume 3, Rev. 1, Page 3 of 69 0 ATTACHMENT 1 ITS Chapter 1.0, Use and Application Attachment 1, Volume 3, Rev. 1, Page 3 of 69 Attachment 1, Volume 3, Rev. 1, Page 4 of 69 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)Attachment 1, Volume 3, Rev. 1, Page 4 of 69 Attachment 1, Volume 3, Rev. 1, Page 5 of 69 ITS Chapter 1.0 ITS 1.0 1.1 1.0 USE AND APPLICATION 1IDEFTNITIONS M The IDEFIN TERS$1o this section appear in capitalized type and are applicable throughout these Technical Specifications,.

THERMAL POVER iT THERMAL POlER shall be the total reactor core heat transfer rate to the reactor coo1ant.A02 RATEDTHERMAL P'OWER4 Oi RRTP 1 V i " orshallbeatotal reactor core heat transfer rate to the reactor coolant of Al 8 0 MODE ITi A P ýI A MODE shall correspond to any one inclusive combination of.ore reactivity condition, power level aLdaverage reactor coolant temperature specified in Table I I.adratrvse with fuel in the head closure bolt 1 1-1 ractor vessel=... ' [tensioning ACTIO1N _I T hall be those addi onal requirements sp cii ied as oroll.a Istatements/to erincipal sp Vciication and shall/be part of/the a ecifica eons]. .A03 Idesi .pucicauodio wat prescrifes mequlrec Actions to be taken under designated Conditions within specified Completion Times whend t/OPERABLE -OPERABILITY y A"4 A system, subsystem, train, component or device shall be OPERABLE or have OPEBILITY hen itIs capableI specified function(sI ic Instrumentation, controls, normall eergency electrecal r a tt t coo seal vater, lubrication a#4 other auxiliary are required for the system, subsystem, train, componentor device to perform its function(s)g]

are alsoacapable of performing theit related support function(s).

U(S specified 1 I/A04 J\DAVIS-BESSE, UNIT .1 1-1 Amendment No. AA,135 0 Page 1 of 14 Attachment 1, Volume 3, Rev. 1, Page 5 of 69 Attachment 1, Volume 3, Rev. 1, Page 6 of 69 ITS Chapter 1.0 ITS 1.1 aEF T NS ... ..CONtAINMENT INGRITY 1.8 ýONTAINMENý INTEGRITY sha exIst when a. All penetrations required to be closed during accident conditions are-either

1. Capable of being closed by the Safety Features Actuation' System, or 2. Closed by manual valves, blind flanges.or deactivated automatic valves secured in their closed positions, except those approved to be open under administrative controls, b. The equipment hatch.is closed, (c. Each air lock is in compliance with the requirements of Specification 3.6.1.3.A06 See ITS-4 3.6.1 )d.The containment leakage rates are within the limits specified in the Containment-Leakage Rate Testing Program,.

and The sealing mechanismassociated with each'penetratdon.(e.g., welds, bellows or O-rinqs)is OPERABLE.See ITS 3.6.2 See ITS3 3. 6.1 0 CHIANNEL CALIBRATION all devices in the channel required in the for channel PRBLT , M9A CHANNEL, CALIBRATION shall be the adjustment, as necessry, of the channel ts t responds.with necessary range and.accuracy.to.known values of the'pa the channel monitors.

The CHANNEL CALIBRATION shall encotopass eefun and_____ shall' udel the CHANNEL FUNCTIONAL TEST. CALIBRAT 0 may be meansofperformedb-yny seres. ofsequential.

oveappnor total channel steps hhE iihre sistance te mperatur detco (D)CHANNEL CHECK-lthermocouple sensors may consist of an in place qualitative assessment of sensor A07...... ' {behvio an nomalcalbraionof he remaining adjustable devices in the channell.

Thele A CHANNEL CHECK shall be the qualitative assossmenlof channel behavior ... ...during operation b obn gvatio This determination shall include, where possble, Ly observaton,j comparison of the channel indication ancdi status[ [ her indications[Oor status derived from Independent instrument channels measurint.h same parameter.

to-DAVIS'BESSE, UNIT 1 1-2 Amendment No. O1, 413, t,2 246 0 Page 2 of 14 Attachment 1, Volume 3, Rev. 1, Page 6 of 69 Attachment 1, Volume 3, Rev. 1, Page 7 of 69 ITS Chapter 1.0 0 ITS 1.1 DEFINITIOS, CHANNEL FUNCTIONAL TEST 11 A CHANNEL FUNCTIONAL TEST shall be or actual Ia. Anal"64channels--he injeton of a simulated signal into the of all devices in the channel as close to the sensor as practicable:

to .ver.i fy channel required OPERABILITY hncl ng ala nd/or trip for channel nA08 I \ .. .....- \ -, .-... .- I OPERABILITY (5DM)j SDM SHtJTDOWi MARGIN Q1.3 SIUD AGNshall 1 be-.the instantaneous amount of reactivity by which the, reactor is subcritical or would be subcritical its, present condition assuming:l-c-j

{ There is no APSR 11_'Kotchange in axl-i powe haping rod position .1 full length CONTR RODS a .iI All kn'to r~b lsfieA safet ad reulat'nq) are fully inserted except for the Single rie v highest reactivi~ty I CONTROL ROD_ nwortwhich is assumed to be. fully withdrawn".

_ INSERT2ýINSERT 3 0}A09 Al DAVIS-BESSE, UNIT I 1-3 Amendment No. 224 0 Page 3 of 14 Attachment 1, Volume 3, Rev. 1, Page 7 of 69 Attachment 1, Volume 3, Rev. 1, Page 8 of 69 ITS Chapter 1.0INSERT I The CHANNEL FUNCTIONAL TEST may be performed by means of any series of sequential, overlapping, or total steps.QINSERT 2 With any CONTROL ROD not capable of being fully inserted, the reactivity worth of these CONTROL RODS must be accounted for in the determination of SDM;INSERT 3 b. In MODES 1 and 2, the fuel and moderator temperatures are changed to the nominal zero power design level; and 0 0 Insert Page 1-3 Page 4 of 14 Attachment 1, Volume 3, Rev. 1, Page 8 of 69 Attachment 1, Volume 3, Rev. 1, Page 9 of 69 ITS Chapter 1.0 p ~ITS0 1.1 DEFINITIONS

[ Reactor 4oolant lystenm through a steam generator to the eeondary ¢ystem (primary to secondary a[1U WIE D LEAKAGE (except RCP seal return flow) that 1 M-5 M hallb, I leaka iclis notlD lD LEAKAGE Fr CON ILLEDGLE GAI RY LEAKAGE[ 6] R SEUNDARY LEAKAGEs a ,eakage (except primary to

),throughanonsisolable fault in afReactor Co.lant yte component body, pipe wallor vessel wall, RMS CONTR LED LEAKA 5E Al10 1.17 CON ROLLED LEAKAGs al be that'seal water flowf the reactor coolant.P imp seats.ýQUADRANT POWER TILT ( QPT 1,8 OWER TILT defined by the following equation and. is.expressed , c '-as a percentage of the RA .... .... E. TILT....Power in any Core*_T U DRA PUJWE I Fl aI Quadrant (Pq,,ad) to the" ' , Power -nit& core g-& arlt I Average Power of all uu ~ ~ ~ ~ ~ 1 Q ~ (P,,,)..Average5wer of all q s DOSE EQUIVALENT 1-131 microcuries M. DOSE EQUIVALENT 1-131 shall be that concentration of 1-131 W gram)tt lone would produce the same thyroid dose as the-quantity and isotopic mixture of 1-131, 1-132,1-133, 1-134 and 1-135 actually present. Tlie thyroid doseconversion factors AEC, 1962, used for this calculation shall be those listed in Tableill of TID-I4844,ýCaculiiation.

f Distance Factors for Power and Test Reactor Sitesý" E -AVERAGE DISINTEGRATION ENERGY MM SAVERAGE DIS1N _.RATION ENERGY shall be the average (2weighted'in pioportion to the concentration of each radionuclide in the-reactor coolant at the time of sampling) of the Aum of the average beta and gamma energies or those listed in Table E-7 of Regulatory Guide 1.109, Rev. 1,! R C , 1977 , or those listed in IC R P 30 , S upplem ent to P a rt 1, page I / , " 192-212, Table titled, " Committed Dose Equivalent in Target LJ, Organs or Tissues per Intake of Unit Activity." DAVIS-BESSE, UNIT 1 1-4 Amendment No.. 276 0 Page 5 of 14 Attachment 1, Volume 3, Rev. 1, Page 9 of 69 Attachment 1, Volume 3, Rev. 1, Page 10 of 69 ITS Chapter 1.0 ITS 1.1 DEFINITIONS isintegratian (in MeVj far isotopes, other than iodines, with halt livesgr le Cý i .minutes, making up at least 95% of.the total norejodine activity in the, coolant.STAGGERED TEST BASIS A STAGGERED TESTBASIS shall consist ofcas test sn e e or n systems, subsysters.

trains ordsignated oother aopo nthebinn ofaieach db~ieva in n pcte',i fvlit e esQ~MYNOAIN

\\ 'IM2 The NOTATIOn specified tor the perlorm .ce of-Su~rveillanceA1 R e qu ir e m e t s .s h o ll c o r r e s p o n d t o i h i n e .4 e f n d i a b .L ! ..AXIAL POWER IMBA__LoAwer AXIAL POWER IMBALANCE shall be the POW ýin the lap halt oc (RTP), Li The-car0 expressed as a percentage of RATED. THERMAL POWER ninus e " ERM PWERin the bottom halt of Ihe~core expressed as;a percentage oi po-we IRATED THE kAA POWER. 17ýRT P LETED (RPS).REACTOR PROTECtION SYSTEM RESPONSE TIME RPS M5 The[REACTOR PR c TIQ SYSTE RESPONSE TIMEshall be tnat time RPS inlervaI from when the monitored parameter exceeds itstr ipselpoint at the-channel esrut power interrupt r at the control rod drive breakers*,\

The response time may be measured by means of any series of sequential, overlapping, or total steps so that the Al3 entire response time is measured.DAVIS-BESSE.

UNIT 1 1 -S Amendment No. 233 Page 6 of 14 Attachment 1, Volume 3, Rev. 1, Page 10 of 69 Attachment 1, Volume 3, Rev. 1, Page 11 of 69 ITS Chapter 1.0 O INSERT4 during the interval specified by the Surveillance Frequency, so that all systems, subsystems, trains, channels, or designated components are tested during n Surveillance Frequency intervals, where n is the total number of systems, subsystems, trains, channels, or designated components in the associated function.0 0 Insert Page 1-5 Page 7 of 14 Attachment 1, Volume 3, Rev. 1, Page 11 of 69 Attachment 1, Volume 3, Rev. 1, Page 12 of 69 ITS Chapter 1.0 0 ITS 1.1* SAFETY RESPONSE T IE (SEAS)[ .~6The SAFET EATURE: RESPONSE TIME shall be that time interval from when the monitored parameter e xce eI its S MSactuation.

setpoint at the ch ain sensor until the Lsafety',(eatures equipment i15capa e of performing.-lts safety function (i.e., the valves travel to their required pas:itions, pumpdiSscharge pressures, realch thefr'required values.. etc.). Times shall- include diesel: generator starting.

and sequence loading delaYWhere applicable Ii Tests _J The response time may be measured by means of any PHYSICS TESTS Section and U series of sequential overlapping, ortotal steps so that the Oper"aio, entire response time is measured.[3 PHYSICS TESTS shal Ibe those tests performed to measure the f;uifae on4Lta. F1 x ercait;istics of te react r are a rd' Iea d itri I M]aton UI)l-eribed in , 14,* 0 f tIeFS j "uthorized under the prcvisioIts or i-wise approvedbyheCiiltti Nuea b, Regulatory0 STTAM AND FEEDWATER RUPTURE CONTROL SYSTEM ESPONSE TIME TheTM AND FE-VDIRAT`

JTRE CONTROL SYST RESPONSE T [ME IsIhall be SR )t at t.imne, airierval r nm when the monitorted parameter exceeds itt SFRCS: actua Ion seCPo.int at the- _rmannel sensor until t-he iquipment is caoabll of performiig its' safety ruhction (e the valves travel to their required positions, pump discharge pressures reach, their required values, SFRCS 0 (The response time'may be measured by means of any series of sequential, overlapping:

or total steps so thatt thee entire response time is measured.DAVIS-BESSE,, UJNIT Iýnmdment Xo. 13S Page 8 of 14 Attachment 1, Volume 3, Rev. 1, Page 12 of 69 Attachment 1, Volume 3, Rev. 1, Page 13 of 69 ITS Chapter 1.0 DEFINITIONS F'FSMITE DOSE CALCULATION MANUAL rODCI)M 132 The OFFSITE DOSE CAICULATION MANUAL (0DCM) shall contain the moethbdloa' and paramtcersused in the calculation ofoffiite doses resulting from radioactive gaseous and liquid effluents, in the calculation ofgas.ous and liquid effluent monitonring AlarriTrip.

Sectpoints, and in the concdict of the Envit nencral Radiological Monitoring Program. The ODCM shall.alsa contain (i) the Radioactive Effluent Controls and Ridiolo0ieal Environtmental Monivorirg,Programs required by Section 6,.4 and (2),descriptions of the information t1hat should be included in the Annual Radiological Environmental Operating and Radioacttve Effluent Release Reports requird by Specifi-ations 6.9. t.0 and 16.9.1.11.

See ITS 5.5 1.33 Dele ed 1 34D'IjLed 1.3 Del ted.1. 3 Del ted 0 MEMBER(SI 6FTHE PUBLIC i.37NMEM -R(S oF THlE PUBLIC shall nclude all persons who are not cceupationally aisociated ith the plant. This category iles nat include employees ofth utility, its contractors ot" vendor Also excluded from this cate Ory are persons who ent&.the ic to service equipment or to ma ý' deliveries, This category do s include perons who use port' ns ofthe site for reairea-tional, ceupational or other purposes ot issodiated with the plant;A0S SITE B 0UNI ARY I ,38 Te ITE BOUL DARY shall be -n line byond which the land r owned, nor leased. or otherwise controlled bV th icensee,__0 DAVIS-BESSE.

UNIT I 1-6a Amerndment No. Z"7V,#j, 272 Page 9 of 14 Attachment 1, Volume 3, Rev. 1, Page 13 of 69 Attachment 1, Volume 3, Rev. 1, Page 14 of 69 ITS Chapter 1.0 ITS DEFINITIMN UNRESTRICTED iREA//1.39 An UNR STRICTED AREA shall be ny area at or beyond th SITE BOUNDARY access to wh ch is not controlled b the licensee for purpo es of protection of individu s from exposure to rad ation and radioactive m terlals, or any areawithin the SITE BOUNDARY used or'residential quarter or for industrial, commercial Institutional, and/or ecreational purposes.

he definition of UNRESTRICT D AREA used in impleme ing the Radiological E fluent Technical Specifica.

ons has been expanded ver that in 10 CFR 20.3 a)(17). The UNRESTRIC ED AREA boundary may co nclde with the exclusi; (fenced) area iboundary, as defined in 10 CFR I 0.3(a), but the UNRESTR CTED AREA does not include reas over water bodies. The concept of UNREST CIED AREAS, estab-lished a or beyond the SITE 80 DARY, is utilized In t e LIMITING CONDITIONS FOR OPE TION to keep levels of radioactive materials

.1 liquid and gaseous peffluen s as low as is reasona y achievable, pursuant to. 10 CFR 50.36a.CA06 0( e0 edR)CORE OPERATING LIMITS REPORT*-:--

-COLR 1.1 41 The is the unit9ipecific document that provide $ce Pera ing limits for the current reload cycle. These cyclegW specific e in-qlimlUi t e determined for each reloadcy.ken.caccordance with Specification6.91.7 Plan operation within these Lc_6eJ specific limits is addressed in individual Pecifications.

paTEmeter s apriodo .S 71 5d6.3 1 .42 AREFUELING INTERY /Lis a period of /i. ý 730 days. 'I Al 2 0 I/ / / I INSERT 5 A5 DAVIS-BESSE, UNIT I 1-6b Amendment No.-*4+-. " 0,.213 Page 10 of 14 Attachment 1, Volume 3, Rev. 1, Page 14 of 69 Attachment 1, Volume 3, Rev. 1, Page 15 of 69 ITS Chapter 1.0 ITS 1.1 INSERT 5 ALLOWABLE THERMAL POWER AXIAL POWER SHAPING RODS (APSRs)CONTROL RODS NUCLEAR HEAT FLUX HOT CHANNEL FACTOR (F 0)NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR (FNH)PRESSURE AND TEMPERATURE LIMITS REPORT (PTLR)ALLOWABLE THERMAL POWER shall be the maximum reactor core heat transfer rate to the reactor coolant permitted by consideration of the number and configuration of reactor coolant pumps (RCPs) in operation.

APSRs shall be control components used to control the axial power distribution of the reactor core. The APSRs are positioned manually by the operator and are not trippable.

CONTROL RODS shall be all full length safety and regulating rods that are used to shut down the reactor and control power level during maneuvering operations.

FQ shall be the maximum local linear power density in the core divided by the core average fuel rod linear power density, assuming nominal fuel pellet and fuel rod dimensions.

FNH shall be the ratio of the integral of linear power along the fuel rod on which minimum departure from nucleate boiling ratio occurs, to the average fuel rod power.The PTLR is the unit specific document that provides the reactor vessel pressure and temperature limits, including heatup and cooldown rates, for the current reactor vessel fluence period. These pressure and temperature limits shall be determined for each fluence period in accordance with Specification 5.6.4.0 Insert Page 1-6b Page 11 of 14 Attachment 1, Volume 3, Rev. 1, Page 15 of 69 Attachment 1, Volume 3, Rev. 1, Page 16 of 69 ITS Chapter 1.0 ITS Table 1.1-1 MODE 2. A TABLE 1 .-1 (page 1of.) (a)AMODES REACTIVITY -RATED AVERAGE COOLANT CONDITION, Keff THERMJAL POWER TEMPERATURE

> 0.99 > 5%O F 0.9i29NA A16[-] 280°F_ t 0.99 d 280*F , Ta.9 ' 200*Fý 0.* 9'9 <260'F 0 DAVIS-BESSE.

UNIT 1 1-:7 0 Page 12 of 14 Attachment 1, Volume 3, Rev. 1, Page 16 of 69 Attachment 1, Volume 3, Rev. 1, Page 17 of 69 ITS Chapter 1.0 ITS TABLE I 2 MRQUENCY NOTATION N TATITN FREQUENCY S At least once per 12 I urs.D At least once per 24 ho rs.w At least once per 7 day .M At least once per 31 da s.Q At least once per 92 day SA At least once per 6 mont s.A At least once per 12 mont as.E At least once per 18 mon s.R At least once per 24 mont a. *S/U Prior to each reactor start p.N/A Not applicable.

In thes Technical Specifications, 6 m ths is defined to be 184 days, 12 mo ths is defined to be 366 d ys. 18 months is defined to be 50 days, and 24 months is defined to 730 days.Al 0 al DAVIS-BESSE, UNIT I 1-8 Amendment No. 4.R.q, ,e-+., 275 Page 13 of 14 Attachment 1, Volume 3, Rev. 1, Page 17 of 69 Attachment 1, Volume 3, Rev. 1, Page 18 of 69 ITS Chapter 1:0 ITS 3/4.1 REACTIVITYCONTROL SYSTEMS 3/4. 1.1 BORATIONCONTROL.

SHUTDOWN MARGIN I'A Th A T ' ý1C Mlfxllflfl VflU nrOO A rvmnM K See ITS 3.1.1, ITS 3.1,8, and ITS 3.1.9_t See ITS 3.1.1, 3A..1.1 The SHUTDOWN MARGIN shall be > l%.Ak/k. ITS 3.1.2, ITS 3.1.8,[T MODES 1, 2% ,3", 4"and 5ý- ITS 3.1.9, ,and ACTION:ITS 3.2.1 See ITS 3.1.1,'With the SHUTDOWN MARGIN I< 1%a Akk, immediately initiate and continue boration ITS 11:8, ITS 3.1.9,l at >_25 gpr of 7875 ppm-boron or its equivalent, until the requ'ired SHUTDOWN and MARGIN .is restored.

ITS 3.2.1 1.1 SURVEILLANCE REQUIP.EMENT1S

("See '/ITS 3. 1. 11 14ý!L 1:1 !The SH UTTD 0W\N M ARGI -N shall, be'determineld to :be > I1% A&k/k;: and L T 321 Sa. .Within one hour.-Afer~detection of an inoperableecontroltrod(s) and at least onee "_ " per.,12 ho 'urs thereafter'" while the red's) is -inoperable I lf the inoperble contfro ro'a Se .'" m el .4].is~immovable or untrippable~ithe above requi-red SHUTDOWK3 NIARGIN shall be---.." inc reasc dby an' amount at least e u all 'tothe withdrawn wort) of the immovab le or / .[untrippable control' rod(s).[ ' A09 b. Whenmin MODES .1 or ,i2f at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , by verifying that regulating rod groups withdrawal is the limits.of Specification 3A..3.6.c. When in MODE2'# within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months prior to achieving reactor criticalityby

'Verif3,ing that the predicted critical.

control rod posit]on iswithin the limits of, Specification 3.1.3.6.See ITS]d. Prior to initial operation above 5% RATED THERMAL POWER after each fuel loading by consideration of the factors of e.be!ow, with theregulating rod groups at the maximum insertionlimit of Specification-3.:

I3.6.See ITS 3.1.1 I r See "h ITS 3.1.1 and 1 ITS 3.2.19 9See LCO 3".9 Steam Generator Level, for additional MAR ue IW c See ITS Tth < ..1.0{See ITS 3.2.1J L'I~vin-Din,~r..,uLNlI I.,1' 1-1.Aincr"oment 14o. -4 91-k-P t9'-/ I /'Page 14 of 14 Attachment 1, Volume 3, Rev. 1, Page 18 of 69, Attachment 1, Volume 3, Rev. 1, Page 19 of 69 DISCUSSION OF CHANGES ITS CHAPTER 1.0, USE AND APPLICATION 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 1.1 states "The DEFINED TERMS of this section appear in capitalized type and are applicable throughout these Technical Specifications." The Note to ITS Section 1.1 states "The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications and Bases." This changes the CTS by replacing the CTS 1.1 definition of "DEFINED TERMS" with a Note and adds a clarification phrase that the defined terms also apply to the Bases.The ITS Section 1.0 Note serves the same purpose as the CTS 1.1 definition.

ITS Section 1.1 Note clarifies that the defined terms also apply to the Bases. This change is consistent with formatting requirements in the ISTS and is consistent with the current use. This change is designated as administrative because it does not represent a technical change to the Technical Specifications.

A03 CTS 1.4 defines OPERATIONAL MODES and Table 1.1, "OPERATIONAL MODES," provide a listing of the MODES. ITS Section 1.1 includes a definition of MODES and Table 1.1-1, "MODES." This changes the CTS MODE definitions in several ways:* The phrase "Reactor vessel head unbolted or removed" in CTS Table 1.1 Note ** is replaced with "One or more reactor vessel head closure bolts less than fully tensioned" in ITS Table 1.1-1 Note c.This change is acceptable because the revised phrase is consistent with the current interpretation and usage. MODE 6 is currently declared when the first vessel head closure bolt is detensioned.

This change also eliminates a redundant phrase. The reactor vessel head cannot be removed unless the reactor vessel head closure bolts are unbolted.Since "reactor vessel head unbolted" is already specified in the CTS Note, including "or removed" is unnecessary.

The CTS Table 1.1 Note ** condition "fuel in the vessel" is moved to the ITS MODE definition.

This change is acceptable because it moves information within the Technical Specifications with no change in intent. Each MODE in the Table includes fuel in the vessel.Davis-Besse Page 1 of 12 Attachment 1, Volume 3, Rev. 1, Page 19 of 69 Attachment 1, Volume 3, Rev.. 1, Page 20 of 69 DISCUSSION OF CHANGES ITS CHAPTER 1.0, USE AND APPLICATION ITS Table 1.1-1 contains a new Note b, which applies to MODES 4 and 5.Note b states "All reactor vessel head closure bolts fully tensioned." This Note is the opposite of CTS Note ** and ITS Table 1.1-1 Note c.This change is acceptable because it avoids a conflict between the definition of MODE 6 and the other MODES should RCS temperature increase above the CTS MODE 6 temperature limit while a reactor vessel head closure bolt is less than fully tensioned.

This ITS Note is included only for clarity. It is consistent with the current use of MODES 4 and 5 and does not result in any technical change to the application of the MODES.For consistency with the Notes in ITS Table 1.1-1, the ITS definition of MODE adds "reactor vessel head closure bolt tensioning" to the list of characteristics that define a MODE. Currently, the CTS definition does not include this clarification.

This change is acceptable because the definition of MODE should be consistent with the MODE table in order to avoid confusion.

This change is made only for consistency and results in no technical changes to the Technical Specifications.

These changes are designated as administrative because they clarify the application of the MODES and no technical changes to the MODE definitions are made. The clarifications are consistent with the current use and application of the MODES.A04 The CTS 1.6 definition of OPERABLE-OPERABILITY requires a system, subsystem, train, component or device to be capable of performing its "specified function(s)" and all necessary support systems to also be capable of performing their "function(s)." The ITS Section 1.1 definition of OPERABLE-OPERABILITY requires the system, subsystem, train, component, or device to be capable of performing the "specified safety function(s),"-and requires all necessary support systems that are required for the system, subsystem, train, component, or device to perform its "specified safety function(s)" to also be capable of performing their related support functions.

This changes the CTS by altering the requirement to be able to perform "functions" to a requirement to be able to perform "safety functions." The purpose of the CTS and ITS definitions of OPERABLE-OPERABILITY are to ensure that the safety analysis assumptions regarding equipment and variables are valid. This change is acceptable because the intent of both the CTS and ITS definitions is to address the safety function(s) assumed in the accident analysis and not encompass other non-safety functions a system may also perform.These non-safety functions are not assumed in the safety analysis and are not needed in order to protect the public health and safety. This change is consistent with the current interpretation and use of the terms OPERABLE and OPERABILITY.

This change is designated as administrative as it does not change the current use and application of the Technical Specifications.

0 Davis-Besse Page 2 of 12 Attachment 1, Volume 3, Rev. 1, Page 20 of 69 Attachment 1, Volume 3, Rev. 1, Page 21 of 69 DISCUSSION OF CHANGES ITS CHAPTER 1.0, USE AND APPLICATION A05 The CTS 1.6 definition of OPERABLE-OPERABILITY requires that all necessary normal and emergency electrical power sources be available forthe system, subsystem, train, component, or device to be OPERABLE.

The ITS Section 1.1 definition of OPERABLE-OPERABILITY will replace the phrase "normal and emergency electrical power sources" with "normal or emergency electrical power sources." This changes the CTS definition of OPERABLE-OPERABILITY by allowing a device to be considered OPERABLE with either normal or emergency power available.

The OPERABILITY requirements for normal and emergency power sources are clearly addressed in CTS 3.0.5. These requirements allow only the normal or the emergency electrical power source to be OPERABLE, provided its redundant system(s), subsystem(s), train(s),, component(s), and device(s) (redundant to the systems, subsystems, trains, components, and devices with an inoperable power source) are OPERABLE.

This effectively changes the current "and" to an "or." The existing requirements (CTS 3.0.5) are incorporated into ITS 3.8.1 ACTIONS for when a normal (offsite) or emergency (diesel generator) power source is inoperable.

Therefore, the ITS definition now uses the word "or" instead of the current word "and." In ITS 3.8.1, new times are provided to perform the determination of OPERABILITY of the redundant systems, et. al. This change is discussed in the Discussion of Changes (DOCs) for ITS 3.8.1. This change is designated administrative since the ITS definition is effectively the same as the CTS definition.

A06 CTS Section 1.0 includes the following definitions:

CONTAINMENT INTEGRITY;

,* CORE ALTERATIONS;

MEMBER(S)

OF THE PUBLIC;* SITE BOUNDARY; and* UNRESTRICTED AREA The ITS does not use this terminology and ITS Section 1.1 does not contain these definitions.

These changes are acceptable because the terms are not used as defined terms in the ITS. Discussions of any technical changes related to the deletion of these terms are included in the DOCs for the CTS sections in which the terms are used. These changes are designated as administrative because they eliminate defined terms that are no longer used.A07 CTS 1.9 defines CHANNEL CALIBRATION and states "The CHANNEL CALIBRATION shall encompass the entire channel including the sensor and alarm and/or trip functions." ITS 1.0 defines a CHANNEL CALIBRATION and states "The CHANNEL CALIBRATION shall encompass all devices in the channel required for channel OPERABILITY." It' also states, "Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an in-place qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. This results in a number of changes to the CTS.Davis-Besse Page 3 of 12 Attachment 1, Volume 3, Rev. 1, Page 21 of 69 Attachment 1, Volume 3, Rev. "1Page 22 of 69 DISCUSSION OF CHANGES ITS CHAPTER 1.0, USE AND APPLICATION

The CTS definition states "CHANNEL CALIBRATION shall encompass the entire channel including the sensor and alarm and/or trip functions." The ITS definition states "The CHANNEL CALIBRATION shall encompass all devices in the channel required for channel OPERABILITY." This change is acceptable because the statements are equivalent in that both require that all needed portions of the channel be tested. The ITS definition reflects the CTS understanding that the CHANNEL CALIBRATION includes only those portions of the channel needed to perform the safety function.The ITS definition adds the statement "Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an in place qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel." This allowance is not specifically stated in the CTS definition.

The purpose of a CHANNEL CALIBRATION is to adjust the channel output so that the channel responds within the necessary range and accuracy to known values of the parameters that the channel monitors.This change is acceptable because RTDs and thermocouples are designed such that they have a fixed input/output response, which cannot be adjusted or changed once installed.

Calibration of a channel containing an RTD or thermocouple is performed by applying the RTD or thermocouple fixed input/output relationship to the remainder of the channel, and making the necessary adjustments to the adjustable devices in the remainder of the channel to obtain the necessary output range and accuracy.

Therefore, unlike other sensors, an RTD or thermocouple is not actually calibrated.

The ITS CHANNEL CALIBRATION allowance for channels containing RTDs and thermocouples is consistent with the CTS calibration practices of these channels.

This information is included in the ITS to avoid confusion, but does not change the current CHANNEL CALIBRATION practices for these typesof channels.These changes are designated as administrative because they do not result in a technical change to the Technical Specifications.

A08 CTS 1.11 defines CHANNEL FUNCTIONAL TEST for "Analog channels" as "the injection of a simulated signal into the channel as close to the primary sensor as practicable to verify OPERABILITY including alarm and/or trip functions." CTS 1.11 also defines CHANNEL FUNCTIONAL TEST for "Bistable channels" as "the injection of a simulated signal into the channel sensor to verify OPERABILITY including alarm and/or trip functions." ITS SectiOn 1.1 defines CHANNEL FUNCTIONAL TEST as "the injection of a simulated or actual signal into the channel as close to the sensor as practicable to yerify OPERABILITY of all devices in the channel required for channel OPERABILITY" and states that the test "may be performed by means of any series of sequential, overlapping, or total channel steps." This results in a number of changes to the CTS. The addition of use of an "actual" signal is discussed in DOC L02 while the allowance 0 Davis-Besse Page 4 of 12 Attachment 1, Volume 3, Rev. 1,i Page 22 of 69 Attachment 1, Volume 3, Rev. 1, Page 23 of 69 DISCUSSION OF CHANGES ITS CHAPTER 1.0, USE AND APPLICATION to inject the signal "as close to the sensor as practicable" in lieu of "into" the sensor is discussed in DOC L03.* The CTS definition states that the CHANNEL FUNCTIONAL TEST shall verify OPERABILITY "including alarm and/or trip functions." The ITS definition states that the CHANNEL FUNCTIONAL TEST shall verify"OPERABILITY of all devices in the channel required for channel OPERABILITY." This change is acceptable because the statements are equivalent in that both require that the channel be verifiedi to be OPERABLE.

The CTS and the ITS use different examples of what is included in a channel, but this does not change the intent of the requirement.

The ITS use of the phrase"all devices in the channel required for channel OPERABILITY" reflects the CTS understanding that the test includes only those portions of the channel needed to perform the safety function.The ITS definition states "The CHANNEL FUNCTIONAL TEST may be performed by means of any series of sequential, overlapping, or total channel steps." The CTS definition does not include this statement.

This change is acceptable because it states current Industry practice, and is not specifically prohibited by the CTS.: This is consistent with the current implementation of the CHANNEL FUNCTIONAL TEST and does not result in a technical change to the Technical Specifications.

These changes are designated as administrative because they do not result in a technical change to the Technical Specifications.

A09 CTS 1.13 provides a definition of SHUTDOWN MARGIN. CTS 4.1.1.1.1 provides an exception to the SHUTDOWN MARGIN definition, such that if a control rod is immovable or untrippable the SDM is modified (increased) by an amount at least equal to the withdrawn worth of the immovable or untrippable control rod(s). The ITS definition of SHUTDOWN MARGIN (SDM) includes a statement that "With any CONTROL ROD not capable of being fully inserted, the reactivity worth of these CONTROL RODS must be accounted for in the determination of SDM." This change revises the Technical Specifications definition of SHUTDOWN MARGIN to include the statement that "With any CONTROL ROD not capable of being fully inserted, the reactivity worth of these CONTROL RODS must be accounted for in the determination of SDM." This change is acceptable because the CTS Surveillance Requirement 4.1.1.1.1 for SDM requires that if an inoperable control rod is immovable or untrippable, the SHUTDOWN MARGIN be increased by an amount at least equal to the withdrawn worth of the immovable or untrippable control rod. This change incorporates this requirement into the Technical Specification definition.

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

0 Davis-Besse Page 5 of 12 Attachment 1, Volume 3, Rev. 1, Page 23 of 69 Attachment 1, Volume 3, Rev. 1, Page 24 of 69 DISCUSSION OF CHANGES ITS CHAPTER 1.0, USE AND APPLICATION A10 CTS Section 1.0 provides definitions for CONTROLLED LEAKAGE, IDENTIFIED LEAKAGE, PRESSURE BOUNDARY LEAKAGE, and UNIDENTIFIED LEAKAGE. ITS Section 1.1 includes these requirements in one definition called LEAKAGE (which includes three categories:

identified LEAKAGE, unidentified LEAKAGE, and pressure boundary LEAKAGE).

This changes the CTS by incorporating the definitions into the ITS LEAKAGE definition with no technical changes. As a result, the ITS will not contain a defined term, "CONTROLLED LEAKAGE." Other changes to the LEAKAGE Specification (related to deleting the CONTROLLED LEAKAGE requirements) will be discussed in the Discussion of Changes for ITS 3.4.13, "RCS Operational LEAKAGE." This change is acceptable because it results in no technical changes to the Technical Specifications.

The deletion of the separately defined CONTROLLED LEAKAGE in the CTS is acceptable because the ITS definitions for identified LEAKAGE and unidentified LEAKAGE have been revised to include references to seal water flow from the reactor coolant seals (i.e., reactor coolant pump seal return flow), replacing the defined term CONTROLLED LEAKAGE in these definitions.

This change is designated as administrative because it does not result in technical changes to the Technical Specifications.

Al1 The CTS 1.21 definition of STAGGERED TEST! BASIS states, "A STAGGERED TEST BASIS shall consist of: a. A test schedule for n systems, subsystems,.trains or designated components obtained by dividing the specified test interval into n equal subintervals, b. The testing of one system, subsystem, train or designated components at the beginning of each subinterval." The ITS Section 1.1 definition states, "A STAGGERED TEST BASIS shall consist of the testing of one of the systems, subsystems, trains, channels, or other designated components during the interval specified by the Surveillance Frequency, so that all systems, subsystems, trains, channels, or other designated components are tested during n Surveillance Frequency intervals, where n is the total number of systems, subsystems, trains, channels, or otheri designated components in the associated function." This changes the CTS to specify the frequency of a Surveillance on one system, subsystem, train, or other designated component in the Frequency column of the ITS instead of specifying the frequency in which all systems, subsystems, trains, or other designated components must be tested.This change is acceptable because the testing frequency of components on a STAGGERED TEST BASIS is not changed. Unlike the CTS definition, the ITS definition allows the Surveillance interval for one subsystem to be specified in the Frequency column of the applicable Surveillance Requirements, independent of the number of subsystems.

As an example, consider a three channel system tested on a STAGGERED TEST BASIS. The CTS would specify testing every three months on a STAGGERED TEST BASIS, which results in one channel being tested each month (three equal subintervals).

Under the ITS definition, the Surveillance Frequency would be monthly on a STAGGERED TEST BASIS and, one channel would also be tested each month. In both the CTS and ITS definitions, all channels are tested every three months" Each test under the CTS definition would be performed at the beginning of the subinterval.

Under the ITS definition, each Surveillance Frequency starts atithe beginning of the CTS definition subinterval.

Thus, there are no net changes in the testing interval.

This 5 change represents an editorial preference in the:ITS. This change is designated Davis-Besse Page 6 of 12 Attachment 1, Volume 3, Rev. 1, Page 24 of 69 Attachment 1, Volume 3, Rev. 1, Page 25 of 69 DISCUSSION OF CHANGES ITS CHAPTER 1.0, USE AND APPLICATION as administrative as no technical changes are made to the Technical Specifications.

A12 CTS 1.22 provides a definition of FREQUENCY NOTATION and includes CTS Table 1.2, which lists these notations.

CTS 1.42 provides a definition for"REFUELING INTERVAL." The ITS will not contain this information in Section 1.1, but will state the requirements in each Surveillance.

This change is acceptable because each ITS Surveillance Requirement (SR).provides the specific frequency without relying on a notation (e.g., "31 days" versus "M"). Providing the specific frequencies' in the Surveillance Requirements eliminates the need for the FREQUENCY NOTATION definition and CTS Table 1.2. Any Surveillance Frequencies altered by the elimination of the definition and table will be addressed in a DOC:for the affected section. This change is designated as administrative because it does not change any SR frequencies.

A13 CTS 1.25 provides a definition of REACTOR PROTECTION SYSTEM RESPONSE TIME, CTS 1.26 provides a definition of SAFETY FEATURE RESPONSE TIME, and CTS 1.28 provides a definition of STEAM AND FEEDWATER RUPTURE CONTROL SYSTEMI RESPONSE TIME. ITS Section 1.1 modifies the definitions to more fully describe how the tests are performed.

The ITS states that the "response time test may be measured by means of any series of sequential, overlapping, or total steps so that ihe entire response time is measured." Currently, the CTS does not describe this manner O of testing.This change is acceptable because the ITS definitions are consistent with current plant practices.

Also, the definitions are consistent with the guidance provided in IEEE 338-1977, Section 6.3.4, "Response Time Verification Tests," although Davis Besse is not committed to this standard.

The results of the test are unaffected by this allowance.

This change is designated as administrative as it does not result in a technical change to the response time tests.A14 CTS 1.13 provides a definition of SHUTDOWN MARGIN. The ITS definition of SHUTDOWN MARGIN includes a statement that "In MODES 1 and 2, the fuel and moderator temperatures are changed to the nominal zero power design level." This change revises the Technical Specifications to includethe statement that "In MODES 1 and 2, the fuel and moderator temperatures are changed to the nominal zero power design level." The CTS 1.13 definition does not provide guidance on the disposition of fuel and moderator temperatures in the calculation of SHUTDOWN MARGIN. The addition of this requirement is considered a clarification of the definition that describes the reactor conditions at which the SHUTDOWN MARGIN is calculated in MODES 1 and 2. The addition of this description is consistent with the standard methods used for calculating SHUTDOWN MARGIN and does not represent a technical change to the calculation of SHUTDOWN MARGIN. As such, this change is consistent with current practice and is acceptable.

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

Davis-Besse Page 7 of 12 Attachment 1, Volume 3, Rev. 1 Page 25 of 69 Attachment 1, Volume 3, Rev. 1, Page 26 of 69 DISCUSSION OF CHANGES ITS CHAPTER 1.0, USE AND APPLICATION A15 ITS Section 1.1 provides definitions of ALLOWABLE THERMAL POWER, AXIAL iPOWER SHAPING RODS (APSRs), CONTROLRODS, NUCLEAR HEAT FLUX HOT CHANNEL FACTOR, (FQ), NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR (FAH). These terms are not defined in the CTS. This changes the CTS by adding the above terms.The purpose of these ITS definitions is to define terms used in various ITS Specifications.

This change is acceptable because the definitions do not impose any new requirements or alter existing requirements.

Any technical changes due to the addition of these definitions will be addressed in the DOCs for the sections of the Technical Specifications in which the definitions are used. These changes are designated as administrative as they add defined terms that do not involve a technical change to the Technical Specifications.

A16 CTS Table 1.1, OPERATIONAL MODES, is revised. The corresponding table in ITS Section 1.1 is Table 1.1-1, MODES. The changes to the CTS are:* The CTS Table 1.1 minimum average reactor coolant temperature for MODES 1 and 2 is changed from > 280°F to "NA" (not applicable) in ITS Table 1.1-1.This change is acceptable because ITS LCO 3.4.2, RCS Minimum Temperature for Criticality, provides the minimum reactor coolant temperature limits for MODE 1 and MODE 2 with keff > 1.0. Therefore, the 280°F minimum temperature does not provide any useful information in ITS Table 1.1-1, and is deleted from the CTS.The CTS Table 1.1 MODE 6 upper limit on average reactor coolant temperature

(< 140 0 F) is removed. In ITS Table 1.1-1, the MODE 6 average reactor coolant temperature limit is specified as "NA" (not applicable).

This change is acceptable because it eliminates a conflict in the CTS MODE Table. If the average coolant temperature exceeds the upper limit with the reactor vessel head closure bolts less than fully tensioned, the CTS Table could be misinterpreted as no MODE being applicable.

This is not the intent of the CTS or ITS MODE 6, definitions.

By removing the temperature reference, this ambiguity is eliminated.

The RATED THERMAL POWER limit of 0% in CTS Table 1.1 for MODES 3, 4, 5, and 6 is changed in ITS Table 1.1-1 to "NA" (not applicable).

This change is acceptable because the reactivity and plant equipment limitations in MODES 3, 4, 5, and 6 do not allow power operation.

Therefore, it is not necessary to have these restrictions in the MODE Table.These changes are designated as administrative because they result in no technical changes to the Technical Specifications.

0 Davis-Besse Page 8 of 12 Attachment 1, Volume 3, Rev. 1,, Page 26 of 69 Attachment 1, Volume 3, Rev. 1, Page 27 of 69 DISCUSSION OF CHANGES ITS CHAPTER 1.0, USE AND APPLICATION A17 ITS Sections 1.2, 1.3, and 1.4 contain information that is not in the CTS. This change to the CTS adds explanatory information on ITS usage that is not applicable to the CTS. The added sections are:* Section 1.2 -Logical Connectors Section 1.2 provides specific examples of the logical connectors"AND" and "OR" and the numbering sequence associated with their use.Section 1.3 -Completion Times Section 1.3 provides guidance on the proper use and interpretation of Completion Times. The section also provides specific examples that aid in the use and understanding of Completion Times.Section 1.4 -Frequency Section 1.4 provides guidance on the proper use and interpretation of Surveillance Frequencies.

The section also provides specific examples that aid in the use and understanding of Surveillance Frequency.

This change is acceptable because it aids in the understanding and use of the format and presentation style of the ITS. The addition of these sections does not add or delete technical requirements, and will be discussed specifically in those Technical Specifications where application of the added sections results in a change. This change is designated as administrative because it does not result in a technical change to the Technical Specifications.

A18 This change to CTS 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 None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type I -Removing Details of System Design and System Description, Including Design Limits) CTS Table 1.1, "OPERATIONAL MODES," states that MODE 6 is restricted to reactivity conditions with keff < 0.95. ITS Table 1.1-1, "MODES," 0 Davis-Besse Page 9 of 12 Attachment 1, Volume 3, Rev. 1,ý Page 27 of 69 Attachment 1, Volume 3, Rev. 1, Page 28 of 69 DISCUSSION OF CHANGES ITS CHAPTER 1.0, USE AND APPLICATION does not contain this restriction.

This changes the CTS by moving this requirement to the Bases.This change is acceptable because the core reactivity requirements for MODE 6 are covered in ITS 3.9.1, "Boron Concentration," by requiring the boron concentration in the Reactor Coolant System to be maintained within the limits specified in the COLR. The Applicable Safety Analysis section of the 3.9.1 Bases states "The required boron concentration limit and unit refueling procedures that demonstrate the correct fuel loading plan (including full core mapping) ensure the keff Of the core will remain < 0.95 during refueling operation." Moving this detail from the MODE Table to the LCO 3.9.1 Bases eliminates the potential to misinterpret the MODE table and not apply the MODE 6 requirements if the reactor vessel head closure bolts are less than fully tensioned, fuel is in the reactor vessel, and core reactivity exceeds a keff of 0.95. ITS LCO 3.9.1 will ensure that the appropriate reactivity conditions are maintained in MODE 6, so it is not necessary to have this restriction in the MODE Table in order to provide adequate protection of the public health and safety. Once moved to the Bases, any changes to the core reactivity requirement will be controlled by the Technical Specifications Bases Control Program described in Chapter 5 of the ITS. This change is designated a less restrictive movement of detail because it moves information from the Technical Specifications to the Bases.LESS RESTRICTIVE CHANGES L01 The CTS 1.1 definition of CHANNEL FUNCTIONAL TEST requires the use of a"simulated" signal when performing the test. The ITS Section 1.1 CHANNEL FUNCTIONAL TEST definition allows the use of an "actual or simulated" signal when performing the test. This changes the CTS by allowing the use of unplanned actuations to perform the Surveillance if sufficient information is collected to satisfy the surveillance test requirements.

This change is acceptable because the channel itself cannot discriminate between an "actual" or "simulated" signal and, therefore, the results of the testing are unaffected by the type of signal used to initiate the test. This change is designated as less restrictive because it allows an actual signal to be credited for a Surveillance where only a simulated signalwas previously allowed.L02 CTS 1.11 defines CHANNEL FUNCTIONAL TEST for the "Bistable channels" as the injection of a simulated signal "into the channel sensor." ITS Section 1.1 defines CHANNEL FUNCTIONAL TEST as the injection of a simulated or actual signal "into the channel as close to the sensor as practicable." This changes the CTS by allowing a signal to be injected "in the channel as close to the sensor as practicable" instead of "into the channel sensor." The purpose of a CHANNEL FUNCTIONAL TEST is to ensure a channel is OPERABLE.

This change allows a CHANNEL FUNCTIONAL TEST to be performed by injecting a signal "as close to the sensor as practicable" instead of"into the channel sensor." Injecting a signal into the channel sensor would, in some cases, involve significantly increased probabilities of initiating undesired circuits during the test since several logic channels are often associated with a Davis-Besse Page 10 of 12 Attachment 1, Volume 3, Rev. 1, Page 28 of 69 Attachment 1, Volume 3, Rev. 1, Page 29 of 69 DISCUSSION OF CHANGES ITS CHAPTER 1.0, USE AND APPLICATION particular sensor. Performing the test by injection of a signal into the channel sensor could also require jumpering of the other logic channels to prevent their initiation during the test or increasing the scope of the tests to include multiple tests of the other logic channels.

Either method significantly increases the difficulty of performing the surveillance.

Allowing initiation of the signal close to the sensor in lieu of into the sensor provides a complete test of the logic channel while significantly reducing the probability of undesired initiation.

In addition, the sensor is still being checked during a CHANNEL CALIBRATION.

This change is designated as less restrictive because the ITS definition of CHANNEL FUNCTIONAL TEST will allow the test to be performed injecting a signal "into the channel as close to the sensor as practicable" instead of "into the channel sensor." L03 The CTS 1.19 definition of DOSE EQUIVALENT 1-131 requires that the DOSE EQUIVALENT 1-131 be calculated using the thyroid dose conversion factors listed in Table III of TID 14844, "Calculation of Distance Factors for Power and Test Reactor Sites." The ITS allows DOSE EQUIVALENT 1-131 to be calculated using any one of three thyroid dose conversion factors: TID-14844 (1962); Table E-7 of RG 1.109, Rev. 1 (1977); or ICRP 30, Supplement to Part 1, page 192-212, Table Titled "Committed Dose Equivalent in Target Organs or Tissues per Intake of Unit Activity." This changes the CTS by allowing two additional methods, ICRP 30, Supplement to Part 1 or Table E-7 of RG 1.109, Rev. 1 (1977), to be used to calculate DOSE EQUIVALENT 1-131.The purpose of the defined term is to provide acceptable methods for computing DOSE EQUIVALENT 1-131. Using thyroid dose conversion factors other than those given in TID-14844 results in lower doses and higher allowable activity but is justified by the discussion given in the Federal Register (FR page 23360 VI 56 No 98 May 21, 1991). This discussion accompanied the final rulemaking on 10 CFR 20 by the NRC. In that discussion, the NRC stated that they were incorporating modifications to existing concepts and recommendations of the ICRP and NCRP into NRC regulations.

Incorporation of the methodology of ICRP 30 into the 10 CFR 20 revision was specifically mentioned with the explanation that changes being made result from changes in the scientific techniques and parameters used in calculating dose. In a response to a specific question as to whether or not the ICRP 30 dose parameters should be used, the NRC stated "Appropriate parameters for calculating organ doses can be found in ICRP 30 and its supplements..." Lastly, Commissioner Curtis provided additional views of the revised 10 CFR 20 with respect to the backfit rule. In that discussion, he stated that the AEC, when they issued the original 10 CFR 20, had emphasized that the standards were subject to change with the development of new knowledge and experience.

He went on to say that the limits given in the revised 10 CFR 20 were based on up-to-date metabolic models and dose factors. This Federal Register entry shows clearly that, in general, the NRC was updating 10 CFR 20 to incorporate ICRP-30 recommendations and data. Given this discussion, it is concluded that using ICRP thyroid dose conversion factors to calculate DOSE EQUIVALENT 1-131 is acceptable.

In addition, RG 1.109 was developed by the NRC for the purpose of evaluating compliance with 10 CFR 50, Appendix I. The RG 1.109 thyroid dose conversion factors are higher than the ICRP 30 thyroid dose conversion factors for all five iodine isotopes in question.0 Therefore, using RG 1.109 thyroid dose conversion factors to calculate DOSE Davis-Besse Page 11 of 12 Attachment 1, Volume 3, Rev. 1, Page 29 of 69 Attachment 1, Volume 3, Rev. 1, Page 30 of 69 DISCUSSION OF CHANGES ITS CHAPTER 1.0, USE AND APPLICATION EQUIVALENT 1-131 is more conservative than ICRP 30 and is therefore acceptable.

0 Davis-Besse Page 12 of 12 Attachment 1, Volume 3, Rev. 1, Page 30 of 69 Attachment 1, Volume 3, Rev. 1, Page 31 of 69 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)0 Attachment 1, Volume 3, Rev. 1, Page 31 of 69 Attachment 1, Volume 3, Rev. 1, Page 32 of 69 Definitions 1.1 CTS 1.0 USE AND APPLICATION

1.1 Definitions

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

m------ -----------

1.1 Thedefined

terms of this section appear in capitalized'type and are, pplicabl ethroughoutjthese Technical'Specifications and Bases: Term Definition

1.5 ACTIONS

DOC ALLOWABLE THERMAL, A15 POWER.1.23 AXIAL POWER IMBALANCE DOC AXIAL POWER SHAPING A15 RODS (APSRs)1.9 CHANNEL CALIBRATION 1.10 CHANNEL CHECK ACTIONS..shall be that part ofla Specification that prescribes" Required Actions to be taken und6(dP4ignatedC6nditions within Specified Completi.on Times.ALLOWABLE THERMAL POWER shall be tIhe maximum reactor core heattransfer rate to the reactor coolant permitted by consideration of the numbdr and coniguration of reactor coolant pumps (RCPS) in operation.

AXIAL POWER IMBALANCE sh.!ilb'e the power inthe top half of tfhe core, -express.edas a:per~ceh`tage 1of R ATED THERMAL.POWER the.power .in the bottom half of the cord, expressed as'a percentage:`of.RTP.

APSRs shall be control compon'ents Used to control the axial power.distribution.of the reactor, core. The APSRs are.positioned manually by the operator and are not trippable.

A CHANNEL CALIBRATION, shall be the adjustment, as necessary,.

of the channel output such that it responds within the necessary ran ge and accuracy to known values of the parameter that the channe~lmonitors.

The CHANNEL CALIBRATION shall encompass all devices.in the channel required for channel OPERABILITY and the CHANNEL FUNCTIONAL TEST. Calibration of instrument channels with resistance temperature' detector (RTD) orth ermocouple.sensors mayýconsist of an in pace. quaitative assessment of sensor behavior and normal calibration of the.remaining adjustable devices in the.channel.

TheCHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps.A.CHANNEL CHECK shall be the qualitative assessment, by observation, of channel behavior during operation.

This.determination shall include,.where possible, comparison of BWOG.:STS 1.1-1 Rev. 3.1,12/01/05 Attachment 1, Volume 3, Rev. 1, Page 32 of 69 Attachment 1, Volume'3, Rev. 1, Page 33 of 69 Definitions 1.1: CTS 1.1 :Definition's 1.10 CHANNEL CHECK (continued) the chan nel indication and status to other indications or status derived from independent.

instrument channels measu ringjthe same parameter.

1.11 CHANNEL FUNCTIONAL TEST A CHANNEL FUNCTIONAL TEST sha!l be.the injection of a simulated or actual signal'into the channel as close to the.sensor as practicable to verify OPERABILITY ,of all devices in the channel required for channiel OPERABILITY.

he ESFAS CHA EL FUNCTION L TEST shall iso include testing of EySFAS aety related by ss functions or each fhn l affectedly b pass operatfo .- The CHANNE FUNCTIONAL TEST may be.perormed by rneans of:ahy series of sequential,,overlapping, .ortotal:steps,.

0 0 DOC A15 CONTROL RODS CONTROL RODS shall be all full length safety and regulating:

rods that-areeused to shut d' ' nthe'riactr ad control1pdwer level during maneuvedn g operation s, CORE AL ERATION"CO E ALTERATION shall be the;m vement of'any fuel,.sourd s, or reactivity control compoh ts. within the reactor vessellwith the, vessel head.removed a d fuel in the vessel..Suspen ion of CORE ALTERATIONS s all notpreclude compteti n.of movement of a component o a safe position.(2)1.41 CORE OPERATING LIMITS REPORT(COLR), The COLR is the unit specific document~thatprovidescycle.specific parameter limits for thecurrent reload cycle. These cycle specific limits shall be determined for each reload cycle in.accordance with Specification

5.6.3. Plant

operation within these limits is addressed in individual .Specifications.

1.19 DOSE EQUIVALENT 1-131 DOSE EQUIVALENT 1-131 .shall be that concentration of 1-131 (microcuries/gram)thatalone would produce the same thyroid dose as the quantity and isotopic mixture of 1-131, 1-132, l1-33, 1-134,.and actually present. The.thyroid dose conversion:

factors used for this calculation shall be those listed in kTable III of TID-14844, AEC, 1962, "Calculation of Distancd Factors for Power and Test Reactor Sites, "or those listed in Table. E-7 of Regulatory Guide 1.109, Rev. 1, NRC, 1977, or teted in ICRP 30, Supplement to Part 1, page 192-212, table-titled,"'Committed Dose Equivalent in. Target Organs or Tissues per Intake of 0 BWOG STS 1.1-2 Rev. 3.1, 12/01105 0 Attachment 1, Volume 3, Rev. 1, Page 33 of 69 Attachment 1, Volume 3, Rev. 1, Page 34 of 69 Definitions I :1 CTS 1.1 Definitions 1.20 E --AVERAGE DISINTEGRATION ENERGY STEAM AND FEEDWATER RUPTURE CONTROL SYSTEM 1.28 E shall be the average (weighted in proportion tothe-concentration of each radionuclide in the reactor coolant at the.time of sampling) of the sum of the ,average beta and gamma, energies per disintegration (in MeV) for isotopes, other than iodines, withhalf lives >I15Mminutes, making up at least 95%.of thetotal noniodine'activity in the coolant.rTF ýSSFRCS Th elt9R RESPONSE, TIME shall, be that time intferval fr, when the monitoredparameter exceeds its E C ctuation _i setpoint at the channel sensor until the emerge edwater equipment is capable of perfoirming itsj unction (i.e., valves safety travel to0their required positions, pumpsdischarge pressures reach their required values,.et Ic:). Tir es shall

[geeraor tarin aýFd SequenCe Idad/ng delays, her 1ap6plicable.

The responlse time, may be measured bymeans of ,any.series of sequential, overlapping, or total steps so that the entire response time is. measured The F RESPONSaETIME sall be that timeihterval fr.om when the monitored:parameter exeedsi F actuation SEAS setpoint at the:channel sensor until the F equipment is capable of performing its safety function (ie., the valves travel to their required positions, pump discharge pressures reach their required values; etc.). Times shall include, diesel generatorstarting and sequence loading delays% where applicable.

The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured.LEAKAGE shall be" (D 0 0 0D 1.26 " ESAFETy FEATURE(E_ ) ESPONSE TI ME S SACTUATION movedS to page 1.1-6 0 DOC A10 1.14 LEAKAGE 1.14.a 1.14.b BWOG STS a. Identified LEAKAGE 1. LEAKAGE, such as.that from pump seals or valve packing.(except RCP seal water ion or return flow e that is captured and conducted'to collection systems or a sump or collecting tank 2. LEAKAGE into the containment atmosphere fromr sources that are both specificallylocated and known either not to interfere with the operation.of leakage detection systes or not tobe pressure boundary LEAKAG or 1.1-3 Rev. 3.1, 12/01/05 Attachment 1, Volume 3, Rev. 1, Page 34 of 69 Attachment 1, Volume 3, Rev. 1, Page 35 of 69 Definitions 1:1 CTS DOC A10 1.14.c 1.15 1.1 Definitions LEAKAGE (continued)

3. Reactor Coolanht system (RCS) LEAKAG.Ethr6ugh a:steam generator to the Secondary System (primary to :secondary.

LEAKAGE)-.b. Unidentified LEAKAGE AI LEAKAGE (excepf:RCP seal water, ionor return flow 0that is not identified LEAKAGF_.and

c. Pressure Boundaryv LEAKAGE 1.16 1.4 MODE DOC NUCLEAR HEAT FLUX HOT A15 CHANNEL FACTOR R(mH DOC NUCLEAR ENTHALPY RISE A15 HOT CHANNEL FACT.RF2N 1.6 OPERABLE -OPERABILITY LEAKAGE (except primary to secondary LEAKAGE)'through a non isolable fauIt in an RCS component body, pipe wall,, or vessel wall.A MODE.shall correspond toary one inclusive combination

ýof core re.diivitMy.condition, po'wer level, average reactor coolant temperature, and reactor vessel head closure bolt -tensioning, specified in Table 1.-1:with fuel in the reactor %vessel.FQcKl shall be the maximum local linear power density in the.core divided bythe core ,average fuel, rod linear power density, assuming nominal fuel pellet and fuel rod dimensions.shall be the ratio of the integral of linear power along the fuel rod on which minimum departure from nucleate boiling ratio occurs, to the average fuel rod power.A~system, subsystem, train, component, or.device shall, be.OPERABLE or have OPERABILITY when it is capableof performingits specified safety function(s) and when all necessary attendant:instrumentation, controls, normal or emergency electrical power, cobling and seal water, lubrication,;and other auxiliary equipment that are required for the system, subsystem, train, component, or device to perform its specified safety function(s) are also capable of performing their related support function(s).

0)0)BWOG STS 1.1-4 Rev. 3.1, 12/01/05 Attachment 1, Volume 3, Rev. 1, Page 35 of 69 Attachment 1, Volume 3, Rev. 1, Page 36 of 69 0 Definitions 1.A CTS 1.1 Definitions 1.27 PHYSICS TESTS PHYSICS TESTS shall-be those tests performed to measure, the: fundamental nuclear characteristics of the reactor core and related instrumentation.

Thesetestsare:

FScdon S Descrbed n te 14, Initial Test. ro a .of the FSARI~ F s and Operation," b. Authorized under the provisions of 10 CFR 50.5£ or c. Otherwise approved by the Nuclear Regulatory Commission.

DOC A15 PRESSURE AND: TEMPERATURE LIMITS, REPORT (PTLR)QUADRANT POWER TILT The PTLR is the unit specific document that provides theýreactor vessel pressure and temperature ,imits, including heatup and cooldown 'rates, forthe current reactor vessel fluence period.. These pressure and temperature limits shall be'detertmihed for each fluenceoperiod in~accordancewith Specification 5:6.4..QPT shallbe'defined by the following equation andis: expressed as a percentage of the Power in any Core Quadrant (Pqua'd) to the Average Power of all Quadrants (P, 3 j).0 1.18 0 QPT =.100 [ (Pquad:/'Pavg),-

1]1.3 RATED THERMAL.POWER (RTP)1.25 REACTOR PROTECTION SYSTEM (RPS) RESPONSE TIME RTP shall be a total reactor core heat transfer rate to the reactor coolant of -2M4L ' r.. 2817 The RPS RESPONSE TIME shall. be that.time interval from when the monitored parameter exceeds its RPS trip setpoint at the channel sensor until electrical power is interrupted at the control rod drive trip breakers:

The response time maybe measured by means of any series of sequential, overlapping, or total steps so thatth.e entire response time is measured.0 0 BWOG.STS 1.1-5.Rev. 3:1,.12/01/05 Attachment 1, Volume 3, Rev. 1, Page 36 of 69 Attachment 1, Volume 3, Rev. 1, Page 37 of 69 CTS Definitions 1 .i SFAS definition (from page-.1 Definitions 1.13 SHUTDOWN MARGIN (SDM)0 SDM shall be the instantaneous amount of reactivity by which the reactor is subcritical orwould be subcritical from its present condition assuming: a. All full length CONTROL RODS (safety and regulating) are fully inserted except for the single CONTROL ROD of highest reactivity worth, which is assumed to be fully wit Ihdrawn H Hev~er, 'with all CONTROL RODS~ver~ified.fully inserted/

y twonindependlent m,,ans, it is not necessary t£ account for a' suck C DNTROL ROD in theI SDM calcul tion. With-any CONTROL ROD not capable of being fully inserted, the reactivity worth ,of these CONTROL RODS must be accounted for in the determination of SDM_._b. In MODES I1 and 2, the fuel andmoderator temperatures; arechanged to theRnominal zero power~design levelI ,and*c. There is no change in APSR position.A STAGGERED TESTBASIS shall consist of the testing of one of theisystems .subsystems§,hannels, or other designated components during the interval specified by the Surveillance Frequency,.so that all systems, subsystems, channels, or other designated components are tested during n: Surveillance Frequency intervals, where n is the.total number of systems, subsystems,,channels, or other designated trains, components in the associated function.THERMAL POWER shall be the total reactor. core heat transfer rate to the reactor coolant.0 00 1.21 STAGGERED TEST BASIS SFR05 definition (from page 1.1-3)1.2 THERMAL POWER 0 BWOG STS 1.1-6 Rev. 3.1t 12/01/05 Attachment 1, Volume 3, Rev. 1, Page 37 of 69 Attachment 1, Volume 3, Rev. 1, Page 38 of 69 0 Definitions

'1.1 CTS Table 1.1 Table1;1-1 (page 1 of 1)MODES REACTIVITY

% RATED: AVERAGE MODE, TITLE CONDITION THERMAL REACTOR COOLANT (keff) POWER(aý-

TEMPERATURE (OF)1 Power Operation

_> 0.99 > 5. NA 2 Startup >0.99 <5 NA 3 Hot Standby <'0.99 NA: ' [ 0]4 Hot Shutdown(b)

< 0.99 NA [ 0 Tývg P2001q 5 Cold Shutdownb)

<0.99 .NA ý2004 6 Refueling(c)

NA NA NA 0 0 0 i0 (a).(b)(c)Excluding decay. heat.All reactor vessel head closure bolts fully tensioned.

One or more reactorvessel head closure bolts less than fullytensioned.

0 BWOG.STS 1.1-7 Rev. 3.1,12/01/05 Attachment 1, Volume 3, Rev. 1, Page 38 of 69 Attachment 1, Volume 3, Rev. 1, Page 39 of 69 0 CTS Logical Connectors 1.2 1.0 USE AND APPLICATION DOC A17 0 0 1,.2 Logical Connectors PURPOSE The purpose of this section is to explain the meaning of logical connectors.

Logical connecltors~are, used in Technical specifications (Ts)to discriminate between, and yet connect,, discrete Conditions, Required Actions,*Completion Times, Surveillances, and Frequencies.

The only logical connectors that appear in TS' are AND and OR. The physical arrangement

'f these connectors constitutes logical conventiornswith specific meanings.BACKGROUND Several levels.of logic may be used to state Required Actions. These levels are idlentified by the placement (or nesting)of the logical connectors

and by. the number assigned to each Required Action. The first level'of logic is identified by the first: digit of thenumber assignedto.a Required Action and:the placement of the logical connector in the first level6f inesting (i.e., left justified with the number of. the Required Action).Thesuccessive levels of logic are identified by additional digits of the Required Action number-and by successive, indentations of the logical connectors:

When logical connectors are used to state a Condition, Completion Time, Surveillance, or Frequency,.

only the first level of logic is used, and the logical connector is left justified with the statement of the Condition, Completion Time,. Surveillance, or Frequency.

EXAMPLES The following examples illustrate the use of logical connectors.

BWOG STS 1.2-1 Rev. 3.0, 03131/04 Attachment 1, Volume 3, Rev. 1, Page 39 of 69 Attachment 1, Volume 3, Rev. 1, Page 40 of 69 0 Logical Connectors 1:2 CTS DOC A17 1.2 Logical Connectors EXAMPLES (continued)

EX AMPLE ;.2-1 ACTIONS CONDITION REQUIRED'ACTION COMPLETION TIME A. LCO notmet. A. I Verify.AND: A.2 Restore..:

In'this example the logical cohnnectr"AND is usedto indiate 6that Nwheh in Condition A, both Required Actions A. ,and A.2 must be completed.

0 0 BWOG STS 1.2-2 Rev. 3.0' 03/31104 Attachment 1, Volume 3, Rev. 1, Page 40 of 69 Attachment 1, Volume 3, Rev. 1, Page 41 of 69 Logical Connectors 1.2 CTS DOC A17 1.2 Logical Connectors EXAMPLES .(continued)

EXAMPLE 1.2-21 ACTIONS ..CONDITION REQUIRED:ACTION COMPLETION TIME A. LCO not.met. Al trip:..ýOR A.2.1 Verify.AND Ai2&.2.1 Reduce....

OR:A:2 .2 2. Per'form....

OR A.3Align.This *example represents a more complicated us4e of logical6onnectos.

Required Actions A.l, A.2, land A.3 are alternative choices, only one. of which must be performed as indicated by the. use of the logical connector bR and the left justified placement.

Any one of these-three Actions may be chosen. If A.2 is chosen, then both A.2.1 and A.2.2 must be performed as indicated by the logical connector AND. Required Action A.2.2 is.met by performing A.2.2.1 or A.2.2.2: The indented position .of the logical connector OR indicates that A.2.2.1 and A.2.2.2 are.alternative .choices,.

only one of which must be performed.

BWOG. STS 1.2-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 3, Rev. 1, Page 41 of 69 Attachment 1, Volume 3, Rev. 1, Page 42 of 69 Completion Times 1.3 CTS 1.0 USE AND APPLICATION DOC A17 1.3 Cpompletion Times.PURPOSE The purpose of this'section islto establish the Completion Time, convention and;.tb provide guidance for its use.BACKGROUND Limiting Conditions for Opration (LCOs) specify minimum requirements for ensuring safe operation Iof the unit. TheACTiONS associated with an LCO state;Conditions that typically, describe the waysin which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required A6tion(s) and Completion Time(s).DESCRIPTION:

The CbCnp.Ition Timeisth' n munt'oftimealowed

`for completing~a Required Action. It is referenced to the. time'of,.discovery of a-situatibn: (e~g., inoperable equipmenor, variable nof-within-limits) that-requires entering an:ACTIONS.!

Condition unless otherwise specified, providing the unit is in a MODE:or specified ccndition

ýstated in the Applicability of the LCO. RequiredActions rmst be c'mpletedpdriortot.the-expiratio6n.of.the specifiedlCompleti.oniTe.

An ACTIONS Condition remains in effect ahd the Required.Actions apply until the Condi.tion no.longer.exists.or the .unit is:notwithin the LCO Applicability., if situations are discoveredtithat require entry into, more'than one Condition atia time'within

sihrgle LCO'(multiple Conditions)., the Required.Actions forieachCo`ndition must be performed within the associated Completion Time. When in multiple Conditions, separate Completion Times are tracked f6r each Condition starting from the time of discovery of the situation .that.required entry into the Condition.

Once. a Condition has been entered, subsequenttrains,.

subsystems, components, or variables expressed in the Condition, discovered to be inoperable-or not within limits, will not'result in separate entry into the Condition, unless specifically stated. The Required Actions of the Condition continue toapply to each additional failure, with Completion Times based oninitial entryinto.

the Condition.

However, when a subsequent train, subsystem, component, or variable, expressed in the Condition, is discovered to be inoperable or not within limits, the Completion Time(s),may be extendce.d.

To apply this Completion Time extension, two criteria.

must first be met. The subsequent inoperability:

a. Must exist .concurrent with the first inoperabilityand

b. Must remain inoperable or not within limits after the first inoperability is resolved.Q'K BWOG STS 1.3-1 Rev. 3.1, 12/01/05 Attachment 1, Volume 3, Rev. 1, Page 42 of 69 CTS DOC A17 Attachment 1, Volume 3, Rev. 1, Page 43 of 69 Completion Times 1.3 1.3' Completion Times, DESCRIPTION

,(continued)

The total :Completion Time allowed for completingý-aRequired::Action to address the subsequent inoperability shall be limited'.to the more re strictive'

a. The stated CompletiqnoTime, as measured from. the initial:entry intoýthe, Condition, plus-lan additional 24'.hioursyor

b. The'stated Completion Time as measured from'discoveryof the.subsequent inopere'ability.

Theabove.

Completion Time extensions do not apply tothose Specifications.

that have exceptions that allow completely separate.-re-entry into the-Condition (for each. train,.subsystem, component, :or.variable expressed in th6eCondition):and separate:.tracking of Completion Times based on this rfe-e-it'ty.

These exceptions are- stated in individual Specifications.

The above Completion Time extension does.not apply to a Completion Time with a modified "time zero:"' This modified: "time zero" may be expressed as a repetitive.

time(i e., "once per 8hours,"where the: Completion Time is referenced from a previous completion of the Required Action versus the time of Condition entry) or as a time modified by the, phrase "'from. discovery.

0 EXAMPLES The following examples illustrate the.use'of:

Completion Times with different types of Conditions and :changing.

Conditions.

EXAMPLE 1.3-1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. Required B.1 Be in MODE 3. :6 hours Action and associated AND Completion Time not met. B.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Condition B has twoRequired Actions. Each Required Action has its.own.separate Completion.Time.

Each Completion Time is referenced to the time that.Condition B is entered.BWOG STS 1.3-2 Rev. 3.1, 12/01/05 Attachment 1, Volume 3, Rev. 1, Page 43 of 69 Attachment 1, Volume 3, Rev. 1, Page 44 of 69 Completion Times 1.3 CTS DOC A17 1.3ý Completion Times EXAMPLES (continued)

The Required Actions of;Condition B are to be in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months AND in MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . A total of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is allowed for reaching MODE 3 and a t6tal of 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (net.42 hours4.861111e-4 days 0.0117 hours 6.944444e-5 weeks 1.5981e-5 months ) is allowed fo'reachingMODE5 from the time that Cbn*dition B was entered. If MODES-3 is reached within,3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months , the time allowed for reaching MODE 5is the next 33 hours3.819444e-4 days 0.00917 hours 5.456349e-5 weeks 1.25565e-5 months because the tota Itime. allowed, fbr reaching MODE,'5 1i's 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .If Condition B. is entered whilelin MODE 3, 'the time allowed for reaching MO&DE 5 is the next SO hours.EXAMPLE 1.3-2 0 ACTIONS.CONDITION REQUIREDUACTION COM PLETION TIME A.. 'One pumip A1. Restore puinp to 7 days inoperable.

OPERABLE, status.B. Required B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Action and associated AND Completion Time not met. B.2 Be in MODE 5. '36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months When a pump is declared inoperable, Condition A is entered. If the pump is not restored to.OPERABLE status within 7 days, Condition B is also entered and the Comp!6tion Time clocks for Required Actions BA and B.2 start. If the inoperable pump is restored to OPERABLE statusýafter Condition B is entered, Conditions.A and B are exited, and therefore, the Required Actions of Condition B may be terminated.

When a second pump is declared inoperable while the first pump isstill inoperable, Condition A is not re-entered for the second pump.LCO 3.0.3 is entered, sincethe ACTIONS do not include a Condition for more than one inoperable pump. The Completion Time clock for Condition A does not stop after LCO 3.0.3 is entered, but continues tobe tracked from the time Condition A was initially entered.BWOG STS 1.3-3 Rev. 3.1, 12101105 Attachment 1, Volume 3, Rev. 1, Page 44 of 69 CTS DOC Al 7 Attachment 1, Volume 3, Rev. 1, Page 45 of 69 Completion Times 1.3 1.3 Completion, Times EXAMPLES (continued)

While in LCO 3.0.3, if one of,the inoperable, pumps is;reSt6red to OPERABLE status and the Completion Time for Condition A has expired, LCO,3.0.3 may be exited and operation contirued in accordance.with C.6nditio"nB.

The Completiobi Time for Condition B is 'tracked frrom: the time the Condition A CQompletion Time expired.On'restoring one of the pumps to OPERABLE status,.the:

ConditiOn A.Comnpletiorn Time is not reset, but continues from the'time the first'pump ws declared inop6rable6:

This Completiori Time.my b'e"xtended if the" I pump',e6tored t.;o PERAB LEstatusas-W the, first inoperable pump. A.24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months extension to the stated 7 days is allowed, provided this does not result in the second pump- being ihoperable for.> 7 days.BWOG STS 1.3-4ýRev. 3.1, Attachment 1, Volume 3, Rev. 1, Page 45 of 69 Attachment 1, Volume 3, Rev. 1, Page 46 of 69 Completion Times 1.3 CTS 1.3 Completion Times DOC A17 EXAMPLES (continued)

EXAMPLE 1.3-3 ACTIONS _ _._ .... ..... .:CONDITION REQUIRED ACTION COMPLETION TIME A. One AJI Restore Function X 7 days Function X .train to OPERABLE train status.ýihoperable.

B. :One, B.1 Restore Function¥Y 72'hours: Function Y train to OPERABLE 4train status;inoperable.

C. One 0C1 Restore Function X '72: hours.Function X train to OPERABLE train status.inoperable.

OR AND: C.2 Restore:.Function Y 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .One train to OPERABLE Function Y status.train inoperable.

0 BWOG STS 1.3-5 ,Rev. 3.1, 12/01105 Attachment 1, Volume 3, Rev. 1, Page 46 of 69 CTS DOC A17 Attachment 1, Volume 3, Rev. 1, Page 47 of 69 Completion Times 1.3 1.3 Completion Times,.EXAMPLES

(continued)

When one Function X train and ore:Function Y train are inoperable;', Condition A and Condition B are concurrently applicable.

The Completion Times for Condition A and Condition B are tracked separately for each train starting from ihe time- each train was declareid inoperable and the Condition was entered. A separate Completion Time is~established for Conditiion C. and tracked-fro m.the time.:theisecond train~was' declared inoperable(i.e., the. time the situation described in. Condition C.was discovered)..

If Required Action C0.2 is completed within the specfied Co0npletion Time, Conditions Band C are exited. If the'Cpmpletion Time for Required Action A.1 has:not expired,.operation may continue in accordance with ConditionA.

The remaining Completion Time in ConditionA is measured from the time the affected train was declared inoperable'(i.6,:

initial entry into Conditioh A).Itis possible to alternate

'between Conditions A, B., andC'.in sucha manner that operation could continue indefinitely without ever restoring systems to meet the LCO.. However, doing so would be inconsistentvwith the basis~of the Completion Times: Therefore, thereshall be administrative controls to'liniit the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCO. These administrativecontrols shall ensure that the.Completion Times for:those Conditions are not inappropriately extended.0 BWOG STS 1.3-6 Rev. 3.1, 12101/05 Attachment 1, Volume 3, Rev. 1, Page 47 of 69 Attachment 1, Volume 3, Rev. 1, Page 48 of 69 Completion Times 1 1.3 CTS DOC A17 1.3 Completion Times, EXAMPLES. (continued)

EXAMPLE 1.34 ACTIONS*CONDITION REQUIRED ACTION COMPLETION TIME*A. One or more A.1 Restore valve(s) to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months valves OPERABLE status, inoperable.Required B1 Be in MODE 3.0 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Action and, associated

'AND,'Completionr I Time not m'et,. B'.2 Be in MODE 410~ :12 hours'A single Completion Time is used for any number of valves inoperable at the same time. The Completion Time associated with Condition A is based on the initial entry into Condition A and.is not tracked on a per valve basis. Declaring subsequent valves inoperable, while Condition A is still in effect, does not:trigger the tracking:of separate Completion Times.Once:one of the Valves has.been restored to OPERABLE status, the Condition A Completion Time isnot reset, but continues from the time the first valve was declared inoperable.

The Completion Time may be extended if the valve restored to OPERABLE status was the first inoperable valve. The Condition A Completion Time may be extended for up to.4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months provided this does not result in any: subsequent valve being inoperable for > 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .If the Completion Time of.4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months (plus the extension) expires while one or more valves are.still inoperable, Condition B is entered.0)0 BWOG STS 1.3-7 Rev. 3.1,;12/01/05 0 Attachment 1, Volume 3, Rev. 1, Page 48 of 69 Attachment 1, Volume 3, Rev. 1, Page 49 of 69 Completion Timesý1 3 CTS DOC A17 1.3 Completion Times;EXAMPLES (continued)

EXAMPLE 1.3-5 ACTIONS S------------

NOTE ------Separate Condition entry is allowed for each inoperable -valve.CONDITION REQUIRED ACTION COMPLETION TIME A. One.or more A.1 Restore valve, to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Valves OPERABLE status.-inoperable, B. Required B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .Action and ,associated AND Completion Timet not met. B62 Be in MODE 4., 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months The Note above the ACTIONS Table is a method of modifying how the Completion Time is.tracked.

If this method of modifying how the Completion Time. is tracked was applicable only. to a specific Condition, the Note would appear in that Condition rather than at the top. of the ACTIONS Table.The Note allows Coridition A to be entered separately for each inoperable valve, and Completion Times tracked on a per valve basis, When a.valve is declared inoperable, Condition A is entered-and its Completion Time starts. If subsequent valves are declared inoperable, Condition Ais entered for each valve and separate Completion Times. start and are tracked for each Valve.If the Completion Time associated.

with a valve in Condition A expires, Condition B is entered for that'valve.

If the Completion Times associated with subsequent valves in Condition A expire, Condition B is entered separately for each valve and separate Completion Times start and are tracked for each valve. If a valve that. caused entry into Condition B is restored to OPERABLE status, Condition B is exited for-that valve.BWOG STS 1.3-8 Rev. 31, 12101/05 Attachment 1, Volume 3, Rev. 1, Page 49 of 69 Attachment 1, Volume 3, Rev. 1, Page 50 of 69 Completion Times 1.3 1.3 Cýompletion Times CTS DOC A17 EXAMPLES (continued)

'Since the:Note in this- example allows multiple Condition entry and tracking of separate Completion Times, CompletionjTime extensions do, not apply.EXAMPLE 1.3-6;ACTIONS CON DITION REQUIRED ACTION COMPLETION TIME A.. One channel A..11 Perform SR 3.x.x.x. Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months inoperable.

OR A.2 ReduceaTHERMAL 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months POWER to<50% RTP.B., Required B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Action and associated Completion Time not met.Entry into Condition A offers a choice.between Required Action A.1.or A.2. Required Action A..1 has a "once per" Completion Time, which.qualifies for the 25% extension, per SR 3.02, to each performance after.the initial performance.

The initial.8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months interval of Required Action A.1 begins when Condition A is entered and the initial performance of Required ActionA.1 must be complete within the first8 hour interval.

If Required Action A.1 is followed and the Required Action is not met within the Completion Time (plus the extension allowed by SR 3.0.2), Condition B is entered. If Required Action A.2 is followed and the:Completion Time:of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months is not met, Condition B is entered.If after entry into Condition B, Required Action A.1 or A.2 is met, Condition B.is exited and operation may then continue in Condition A.BVVOG STS 1.3-9 Rev. 3.1, 12/01/.05 Attachment 1, Volume 3, Rev. 1, Page 50 of 69 Attachment 1, Volume 3, Rev. 1, Page 51 of 69 Completion Times 1.3 CTS 1.3 'ComPletion Times.*DOC A17 EXAMPLES ý(continued)

EXAMPLE 1.3"7 ACTIONS .___.CONDITION REQUIRED ACTION COMPLETION TIME A. One A-1 Verify affected I hour subsystem subsystem isolated.inoperable.

AND.Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter AND, A.2 Restore subsystem

72 hoursýto OPERABLE status.B. Required 813 Be in MODE 3. .6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Action and associated

..ANDýCompletion Time not met. B.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months ..Required Action A.1 has two Completion Times. The ihour Completion Time begins at the.time the Condition is entered and each "Once per 8.hours thereafter" interval begins upon performance of Required Action A.1.If after Condition A is entered, Required Action XI is not met within either the initial -1 hour or any subsequent.8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months interval from the previous performance (plus the extension allowed by.SR 3.0.2), Condition B is entered. TheCompletion Time clock for Condition A does~not stop after Condition B is entered, but continues from the time Condition.A was initially entered. If Required Action A.1 is met after Condition B is entered, Condition'B is exi.ted and operati6n may continue in accordance with.Condition A, provided'the Completion Time for Required Action A.2 has not expired.BWOG STS 1.3-10 Rev. 3.1,12101/05 0 Attachment 1, Volume 3, Rev. 1, Page 51 of 69 Attachment 1, Volume 3, Rev. 1, Page 52 of 69 Completion Times 1.3 CTS 1.3 Comop letion Tim"es DOC IMMEDIATE When 'Immediately" is used as a Completion Time, the Required Action A17 C0MPLETrION TIME should be pursued without delay and in a controlled manner.BWOG STS 1.3,11 Rev. 3.1, 12101/05 0 Attachment 1, Volume 3, Rev. 1, Page 52 of 69 Attachment 1, Volume 3, Rev. 1, Page 53 of 69 Frequency 1.4 CTS 1.0 USE AND.APPLICATION 1.4 Frequency.

DOC PURPOSE The purpose. of this-section:

is' toqdefine theproper use and -application of A17 Frequencyrequirements.

DESCRIPTION' Each Suiveillance Requirem6ent(SR) has a specified FregqLiency inwhich the Surveillance must be met in order to .meet the associated LCO. An understanding 0of-the correctappli cation of the specified Frequency is necessary -fot compliance with the SR.The "specified&Frequency" is referred to throughout.

this sebtion and each r-df the Specifications of Section Requirement (SR) LJ Applicabiiity.,\The

!specified Frequency" consists of the requirements of*the Frequency column of each SR, as well as certain Notes in the: Surveillance column:that modify performance requirements.

Sometimes special situations dictate when the requirements of a Sdrveillahe yare toabe :met. Thenyeare "otherwise stated"-conditions allowed ýby SR 3.0.31. 'they may be stated as'clarifying Notes in the Surveillance, 'as part ofthe:Surveillance, or both.Si tuations where a',Surveil anc6 could berequired (i.e, its Frequency could expire), but'where it is n6t pdssible or not desired that it be preformed untilsometimen after thelassociated LCO is within its Appicabii~ity, represent potentiaI SR3.0.4 conflicts.

To avoid these conflicts, the-SR (i.e., the Surveillance or the Frequency) is stated such that it is only "required" when it can be and should be performed.

With an SR.satisfied, SR 3.0.4 imposes no restriction.

The use of"met'! or "performed" in these instances conveys specific meanings.

A Surveillance is "met" only when the acceptance criteria are satisfied.

Known failure of the requirements of a Surveillance, even without a.Surveillance specifically being "performed," constitutes a Surveillance not "met." "Performance" refers only to the requirement to specifically determine the:ability to meet the acceptance criteria.Some Surveillances contain 0otes.that modify the Frequency of 0 performance-or the conditions.

during which the acceptance criteria must be satisfied.

For-these Surveillances, the MODE-entry.restrictions'of SR 3.0.4 may not apply. Such a Surveillance is not required to.be performed prior to entering a MODE or Other specified condition in the Applicability:of the associated LCO if any of the following three conditions are satisfied:

BWOG STS 1.4-1: Rev. 31, Attachment 1, Volume 3, Rev. 1, Page 53 of 69 Attachment 1, Volume 3, Rev. 1, Page 54 of 69 Frequency 1..A CTS DOC A17-

1.4 DESCRIPTION

(continued)

a. The.Surveillance is not retuired to'be met in the MODE ..or -other specified condition lobe entered; W b. The Sureeillance is reqtiiredt b met h the MODEeor other specifiedconditiQn to be entered, but has been performed within the specified Frequency'(i.e., it'is, current) and is knownnot tb be'failed; or d, The Surveillance is requiredtotbe m etb, but not tperfdrmed, in the MODE or othler speci ied condition to be:entpred nd is known not to be failed.Examples 1.4-3, 1.44,1: 4-5,, and 1.4-B6,discuss theseispecial'situations.

0 EXAMPLES The following exniples illustrata the variou.sWays that Frequencies are sPecified..

IteheSeexahiplesp, the Appl-dabiity of the LCO (LCO ndt shown), is. MODES 1,. 2, ,.and 3, BWOG STS 1.4-2 Rev. 3.1,12101105 Attachment 1, Volume 3, Rev. 1, Page 54 of 69 Attachment 1, Volume 3, Rev. 1, Page 55 of 69 Frequency 1.:4'CTS DOC A17 1.4 Frequency EXAMPLES (continued)

EXAMPLE 1:4-1 SURVEILLANCE REQUIREMENTS

.....SURVEILLANCE FREQUENCY Perform CHANNEL CHECK. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .Example 1.4-1 containsthe type of SR most often encountered in the Technical Specifications (TS). The Frequency specifies aninterval (12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ).during Which the associated Surveillanice must beperforime&at leas tone time. Perfoimance of the Surveillance' initiates the ýsubsequient.

interval.

Alfi6pgh the Frequent-iy isstate6d as 12'houyrs; an extension of the time interval to 1.25 times the stated 'Frequency is allowed by SR 3.0.2 for operational flexibility.

The measurement of this interval continues-at all times, even when the SR isý not. required Ao b]e ,met per SR 3.0.1 (such as when the equipment is inoperable,la variable is outside specified limits,'o4 the uinit is-utside the Applicabilitylof theOLCO).

If the intervIal specified by SR,3.0.2 is exceeded while the unit is in a MODE or other specified, conditio'n in the Applicability of the LCO, and: the performance of the Surveillance is not otherwise modified(refer-to:

Example 1.4-3)i then SR 3.0.3becomes applicable.

If the interval as specified by SR 3.0.2 is 6xceeded while the unit is not in aMODE ortotherspecified condition in the"Applicab I lity of the LCO for Which performance of the SR is required, then SR 3.0.4 becomes applicable.

The,:Surveillance must be performed within the Frequency requirements of SR .10.2, as modified by SR 3.0.3, prior to entryintob the MODE or other specified condition or the LCO is considered not met:(in accordance with SR 3.0,1) and LCO 3.0.4 becomes applicable.

BWOGýSTS 1'.4-3 Rev. 3.1, 12/01/05 Attachment 1, Volume 3, Rev. 1, Page 55 of 69 Attachment 1, Volume 3, Rev. 1, Page 56 of 69 Frequency 1;.4 CTS DOC A17 1.4 Fi(,equen6y EXAMPLES (continued)

EXAMPLE 1;4-2.SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY Verifyiflow is within limits. Once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after> 25% RTP AN._D 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months sthereafter Example' .4-2 has two Frequencies., The first is a one time performance Frequency, and the second is of the type shownin Example;1.A4-1.

The logilcal conn'ector "AND" indicates that both Frequency requirements must be met. Each time rreactor power, is a po6we'r evel<25%" RTP to 25% RTP,.the Surveillance must be performed within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , The use of "once" indicates a single perf6rmande will satisfy the. specified Frequency (assuming no other Frequencies, are connected by "AND").This type of Frequency does not qualify for the extension allowed by SR 3.02. "Thereafter" indicates future performances must be established per SR, 0.2, but.only after.a. specifiedcondition is firstmet (i.e., the"once" performance in this example).

If reactor power decreases to< 25% RTR, the measurement of both intervals stops. New intervals start upon reactor power reaching 25% RTP.BWOG STS 1.4-4 Rev. 3.1, 12/01/05 0 Attachment 1, Volume 3, Rev. 1, Page 56 of 69 Attachment 1, Volume 3, Rev. 1, Page 57 of 69 Frequency 1.4 CTS DOC A17 1.4 Frequency EXAMPLES (continued)

EXAMPLE 1.4-3 SURVEILLANCE REQUIREMENTS SURVEILLANCE' FREQUENCY-- ---------------------------

NOTE-----

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after_> 25% RTP.Perform channel adjustment.

7 days The interval continues whether or not the unit operation is < 25% RTP between performances.

As the'Note modifies therequired performance.of the 'SurveiIlance, it is construed to be part of the "specified Frequency." Should the 7 day.interval be exceeded while operation is *< 25% RTP, this Note allows 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .after power.reaches

_ 25% RTP to perform the Surveillance.

The Surveillance is stillconsidered to be performed within the "specified Frequency." Therefore, if the Surveillance,[ýit performed within.the 7 day (plus.the extension-allowed by SR'3.0.2) interval, but operation was< 25%'RTP, it'would not constitute a failure of the SR or failure to meet the LCO. Also, no Violation of SR 3.0.4 occurs when changing MODES, even with the. 7 day Frequency not met, provided operation does not exceed 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months s+with power >;25%.RTP.us the extension allowed by SR 3.0.2)j Once the unit reaches 25% RTP, 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ,would be allowed for completing the Surveillance., If the Surveillance 61t performed within this 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months interva , there woul d then be a failure to perform a Sur~ve.lance within the specified Frequency,, and'the provisions of SR3.0..3 would apply.0 TST-47 0 I (plus the extension allowed by SR I BWOG STS 1.4-5 Rev. 3.1, 12/01/05 0 Attachment 1, Volume 3, Rev. 1, Page 57 of 69 Attachment 1, Volume 3, Rev. 1, Page 58 of 69 Frequency 1;4.CTS DOC A17 1.4 Frequency EXAMPLES (continued)

EXAMPLE 1.4-4 SURVEILLANCE REQUIREMENTS

_SURVEILLANCE FREQUENCY S---------NOTE---------

Only required to be met'in'MODE 1.Verify leakage rates are Wvithin limhits: 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Example 1.4-4 specifies thatthe requiremehts of this Surveillance do:not have to be met, until the unit is in MODE 1. The interval measurement fo"r the Fbequency of this'Surveillance continuesat, allijtimes, asdescribed in Example 14-1. However, the Note:constitutesan "otherwise stated".exceptioneto the Applicability of this.Surveillance:

Therefore if the Surveillance w ot perfoirmed within the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months inter val.(plus the extensionallowed by. SR 3.0.2), but the unit was not in MODE 1., there would be no failure of the SR'nor failure to meet the LCO. Therefore, no violation of SR 310.4 occurswhen changing MODES, even withthe-24 hour Fre quency exceeded, provided the MODE changewas not rmade into MODE1. Prior to entering MODE 1 (assuming againthat the 24 hourrwa Frequency[w r otmet)ý SR 3.0.4 would require satisfying the:SR.0 0 BWOG STS 1.4-6 Rev. 3.1, 12/01/05 0 Attachment 1, Volume 3, Rev. 1, Page 58 of 69 Attachment 1, Volume 3, Rev. 1, Page 59 of 69 Frequency 1.4 1.4 Frequency CTS DOC A17 EXAMPLES (continued)

EXAMPLE 1.4-5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY---------NOTE ---- ....------

Only required to beFT Jh MODE 1.performed (jj)Perform complete cycle:of the valve.7 days The interval continues, whether or not the unit operation is in"MODE 1, 2 or 3 (the assumed Alpplicability of the associated LCO) between performances.

As the'Note modifiesthe required performance of the Surveillance, the Noie.is construed to be~part of the "specified Frequency." Should the 7 day interval be exceeded while-operation is not in MODE , ,this Note allows entry into and operation in MODES 2 and 3 to perform the Surveillance.

The Surveillance is still 6onsidered to be performed within the "specified Frequency" if completed prior to entering MODEl.Therefore, if the Surveillancelwlfiot performedwithin the 7 day (plus the~extension allowed by SR 3.0.2) interval, but operation was not in MODElj it would not constitute a failure of the SR or failureato meet.the LCO: Also, no violation of SR 3.0.4 occurs when changingMODES, even with the 7 day Frequency not met, provided 1operation does not result in entry into MODE 1.Once the unit reaches MODE 1, the requirement for the Surveillance to be performed within its specified Frequency applies and would require was that the Surveillance had been performed:

If the Surveillance e0not performed prior to entering MODE 1, there would thenbe a failure to perform a Surveillance-within the specified Frequency, and the provisions of SR.3.0.3 would apply.0 0 BWOGSTS 1.4-7 Rev. 3.1, 12101105 0 Attachment 1, Volume 3, Rev. 1, Page 59 of 69 CTS DOC A17 Attachment 1, Volume 3, Rev. 1, Page 60 of 69 Frequency 1.4 1.4 Fiequedcy EXAMPLES (continued)

EXAMPLE 1.4-6 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY----------------------------------------

NOTE-Not required to be met.in MODE 3;parameter is within li1its.: .24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Example 1.4-J61 specifies that the requirementsof this Surveillance do not (1 have to be rm'et while theunit is in MODE 3 (the assumed Applicability of Ithe associated LCo is MO. DES 1. 2, and 3). The interval rne~asur"ement for the Frequency of this .Surveillance continues at all times, as described in Example. 1:4-1.. However,,the Note constitutes an "otherwise stated" exception to the Applicability of this Surveillance.

Therefore if the Surveillance w tre t performed within the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months interval.(plus the extension allowed b SR 3.0.2), and the-unitwas in MODE.3, there would be no.failure of the SR nor failure to meet the LCO. Therefore, no violation of SR 3.0.4 occurs when changing.

MODESto enter MODE 3, even with the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency exceeded, provided the MODE change does not result in entry into MODE 2. Prior to entering MODE 2 (assuming again that the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency

[ not met), SR 3.0.4'would require satisfying the SR.was BWOG STS 1..4-8 Rev. 3.1, 12J01/05 0 Attachment 1, Volume 3, Rev. 1, Page 60 of 69 Attachment 1, Volume 3, Rev. 1, Page 61 of 69 JUSTIFICATION FOR DEVIATIONS ITS CHAPTER 1.0, USE AND APPLICATION O 1. The brackets are removed and the proper plant specific information/value is provided.2. These punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, TSTF-GG-05-01, Section 5.1.3.3. Typographical/grammatical error corrected.

4. ISTS Section 1.0 definitions for identified LEAKAGE and unidentified LEAKAGE include an exception that states "except RCP seal water injection or leakoff." The purpose of this exception is to exclude this type of leakage from being part of the ITS 3.4.13, "RCS Operational LEAKAGE," requirements.

Previously this exception was covered by its own definition, CONTROLLED LEAKAGE, as shown in Davis-Besse CTS definition 1.17. This exception has been changed in the ITS for both the identified and unidentified LEAKAGE definitions to "except RCP seal return flow." These revised words are consistent with the current Davis-Besse definition of CONTROLLED LEAKAGE ("seal water flow from the reactor coolant pump seals") and are more accurate.

Seal water flow from the RCP seals (i.e., RCP seal return flow) is the normal controlled RCP seal leakoff that is returned to the makeup tank. The ISTS words "or leakoff" imply that the identified and unidentified LEAKAGE exception includes RCP upper seal leakoff, which is not returned to the makeup tank and is actual identified LEAKAGE.5. The definition of EMERGENCY FEEDWATER INITIATION AND CONTROL (EFIC)RESPONSE TIME has been changed to STEAM AND FEEDWATER RUPTURE CONTROL SYSTEM (SFRCS) RESPONSE TIME consistent with plant terminology.

Due to the definition title change, it has been moved-to the correct alphabetical location.6. The definition of ENGINEERED SAFETY FEATURE (ESF) RESPONSE TIME has been changed to SAFETY FEATURES ACTUATION SYSTEM (SFAS)RESPONSE TIME consistent with plant terminology.

Due to the definition title change, it has been moved to the correct alphabetical location.7. The definition of STAGGERED TEST BASIS has been modified to include the term"trains" in the discussion.

This change is consistent with the current definition in CTS 1.21.8. The definition of EMERGENCY FEEDWATER INITIATION AND CONTROL (EFIC)RESPONSE TIME states "Times shall include diesel generator starting and sequence loading delays, where applicable." The Davis-Besse definition in CTS 1.28 does not include this statement and it has not been included in the STEAM AND FEEDWATER RUPTURE CONTROL SYSTEM (SFRCS)RESPONSE TIME definition in the ITS. The SFRCS RESPONSE TIME specified in the Technical Requirements Manual does not include any allowance for emergency diesel generator starting and sequence loading delays. Response of the timed equipment is not dependent on the presence of AC electrical power, with the exception of the main feedwater stop valves (MFSVs). The main feedwater control valves (MFCVs) and the startup feedwater control valves (SFCVs) are credited for main feedwater isolation.

The MFCVs and SFCVs are air operated Davis-Besse Page 1 of 2 Attachment 1, Volume 3, Rev. 1, Page 61 of 69 Attachment 1, Volume 3, Rev. 1, Page 62 of 69 JUSTIFICATION FOR DEVIATIONS ITS CHAPTER 1.0, USE AND APPLICATION with no reliance on AC electrical power. Therefore, the SFRCS safety function is not dependent on the emergency diesel generator response.9. This statement has been deleted consistent with TSTF-124.

This TSTF was previously approved and was incorporated into NUREG-1430, Rev. 2. However, this portion of the TSTF was inadvertently not incorporated.

A similar deletion in the CHANNEL CALIBRATION definition was properly incorporated.

10. Editorial change made consistent with plant specific terminology.

11. The word "met" has been changed to "performed" consistent with TSTF-284, Rev. 3. This TSTF was previously approved and was incorporated into NUREG-1430, Rev. 2. However, this portion of the TSTF was inadvertently incorporated incorrectly.

12. The definition for SHUTDOWN MARGIN has been modified to not include the statement "However, with all CONTROL RODS verified fully inserted by two independent means, it is not necessary to account for a stuck CONTROL ROD in the SDM calculation." Davis-Besse does not desire to adopt this less restrictive allowance.

0 Davis-Besse Page 2 of 2 Attachment 1, Volume 3, Rev. 1, Page 62 of 69 Attachment 1, Volume 3, Rev. 1, Page 63 of 69 Specific-No Significant Hazards Considerations (NSHCs)0 0 Attachment 1, Volume 3, Rev. 1, Page 63 of 69 Attachment 1, Volume 3, Rev. 1, Page 64 of 69 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS CHAPTER 1.0, USE AND APPLICATION 10 CFR 50.92 EVALUATION FOR LESS RESTRICTIVE CHANGE L01 Davis-Besse is converting to the Improved Technical Specifications (ITS) as outlined in NUREG-1430, Rev. 3.1, "Standard Technical Specifications, Babcock and Wilcox Plants." The proposed change involves making the Current Technical Specifications (CTS) less restrictive.

Below is the description of this less restrictive change and the determination of No Significant Hazards Considerations for conversion to NUREG-1430.

The CTS 1.1 definition of CHANNEL FUNCTIONAL TEST requires the use of a"simulated" signal when performing the test. The ITS Section 1.1 CHANNEL FUNCTIONAL TEST definition allows the use of an "actual or simulated" signal when performing the test. This changes the CTS by allowing the use of unplanned actuations to perform the Surveillance if sufficient information is collected to satisfy the surveillance test requirements.

This change is acceptable because the channel itself cannot discriminate between an"actual" or "simulated" signal and, therefore, the results of the testing are unaffected by the type of signal used to initiate the test. This change is designated as less restrictive because it allows an actual signal to be credited for a Surveillance where only a simulated signal was previously allowed.An evaluation has been performed to determine whether or not a significant hazards consideration is involved with these proposed Technical Specification changes by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below: 1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response:

No.The proposed change adds an allowance that an actual as well as a simulated signal can be credited during the CHANNEL FUNCTIONAL TEST. This change allows taking credit for unplanned actuations if sufficient information is collected to satisfy the surveillance test requirements.

This change is acceptable because the channel itself cannot discriminate between an "actual" or "simulated" signal, and the proposed requirement does not change the technical content or validity of the test. This change will not affect the probability of an accident.

The source of the signal sent to components during a Surveillance is not assumed to be an initiator of any UFSAR Chapter 15 analyzed event. The consequence of an accident is not affected by this change. The results of the testing, and, therefore, the likelihood of discovering an inoperable component, are unaffected.

As a result, the assurance that equipment will be available to mitigate the consequences of an accident is unaffected.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

0 Davis-Besse Page 1 of 6 Attachment 1, Volume 3, Rev. 1, Page 64 of 69 Attachment 1, Volume 3, Rev. 1, Page 65 of 69 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS CHAPTER 1.0, USE AND APPLICATION

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response:

No.The proposed change adds an allowance that an actual as well as a simulated signal can be credited during the CHANNEL FUNCTIONAL TEST. This change will not physically alter the plant (no new or different type of equipment will be installed).

The change also does not require any new or revised operator actions. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?Response:

No.The proposed change adds an allowance that an actual as well as a simulated signal can be credited during the CHANNEL FUNCTIONAL TEST. The margin of safety is not affected by this change. This change allows taking credit for unplanned actuations if sufficient information is collected to satisfy the surveillance test requirements.

This change is acceptable because the channel itself cannot discriminate between an "actual" or "simulated" signal. As a result, the proposed requirement does not change the technical content or validity of the test. Therefore, the proposed change does not involve a significant reduction in a margin of safety.Based on the above, it is concluded that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, there is a finding of "no significant hazards consideration." 0 Davis-Besse Page 2 of 6 Attachment 1, Volume 3, Rev. 1, Page 65 of 69 Attachment 1, Volume 3, Rev. 1, Page 66 of 69 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS CHAPTER 1.0, USE AND APPLICATION 10 CFR 50.92 EVALUATION FOR LESS RESTRICTIVE CHANGE L02 Davis-Besse is converting to the Improved Technical Specifications (ITS) as outlined in NUREG-1430, Rev. 3.1, "Standard Technical Specifications, Babcock and Wilcox Plants." The proposed change involves making the Current Technical Specifications (CTS) less restrictive.

Below is the description of this less restrictive change and the determination of No Significant Hazards Considerations for conversion to NUREG-1430.

CTS 1.11 defines CHANNEL FUNCTIONAL TEST for the "Bistable channels" as the injection of a simulated signal "into the channel sensor." ITS Section 1.1 defines CHANNEL FUNCTIONAL TEST as the injection of a simulated or actual signal "into the channel as close to the sensor as practicable." This changes the CTS by allowing a signal to be injected "in the channel as close to the sensor as practicable" instead of"into the channel sensor." The purpose of a CHANNEL FUNCTIONAL TEST is to ensure a channel is OPERABLE.This change allows a CHANNEL FUNCTIONAL TEST to be performed by injecting a signal "as close to the sensor as practicable" instead of "into the channel sensor." Injecting a signal into the channel sensor would, in some cases, involve significantly increased probabilities of initiating undesired circuits during the test since several logic channels are often associated with a particular sensor. Performing the test by injection of a signal into the channel sensor could also require jumpering of the other logic channels to prevent their initiation during the test or increasing the scope of the tests to include multiple tests of the other logic channels.

Either method significantly increases the difficulty of performing the surveillance.

Allowing initiation of the signal close to the sensor in lieu of into the sensor provides a complete test of the logic channel while significantly reducing the probability of undesired initiation.

In addition, the sensor is still being checked during a CHANNEL CALIBRATION.

This change is designated as less restrictive because the ITS definition of CHANNEL FUNCTIONAL TEST will allow the test to be performed injecting a signal "into the channel as close to the sensor as practicable" instead of "into the channel sensor." An evaluation has been performed to determine whether or not a significant hazards consideration is involved with these proposed Technical Specificationchanges by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below: 1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response:

No.Testing of instrument channels such that the test signal does not include the"1sensor" will significantly reduce the complications associated with performance of a surveillance on a sensor that provides input to multiple logic channels.

The sensor will still be checked during a CHANNEL CALIBRATION.

This reduction of complication will not affect the failure probability of the equipment but may reduce the probability of personnel error during the surveillance.

Such 0 Davis-Besse Page 3 of 6 Attachment 1, Volume 3, Rev. 1, Page 66 of 69 Attachment 1, Volume 3, Rev. 1, Page 67 of 69 0 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS CHAPTER 1.0, USE AND APPLICATION reductions will not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibilityof a new or different kind of accident from any accident previously evaluated?

Response:

No.The possibility of a new or different kind of accident from any accident previously evaluated is not created because the proposed change does not introduce a new mode of plant operation and does not involve physical modification to the plant.3. Does the proposed change involve a significant reduction in a margin of safety?Response:

No.This change does not involve a change to the limits or limiting condition of operation; only the method for performing a surveillance is changed. Since the proposed method affects only a single logic channel rather than potentially affecting multiple logic channels simultaneously, and the sensor is adequately tested during a CHANNEL CALIBRATION, the change does not involve a significant reduction in a margin of safety.Based on the above, it is concluded that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, there is a finding of "no significant hazards consideration." 0 Davis-Besse Page 4 of 6 Attachment 1, Volume 3, Rev. 1, Page 67 of 69 Attachment 1, Volume 3, Rev. 1, Page 68 of 69 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS CHAPTER 1.0, USE AND APPLICATION 10 CFR 50.92 EVALUATION FOR LESS RESTRICTIVE CHANGE L03 Davis-Besse is converting to the Improved Technical Specifications (ITS) as outlined in NUREG-1430, Rev. 3.1, "Standard Technical Specifications, Babcock and Wilcox Plants." The proposed change involves making the Current Technical Specifications (CTS) less restrictive.

Below is the description of this less restrictive change and the determination of No Significant Hazards Considerations for conversion to NUREG-1430.

The CTS 1.19 definition of DOSE EQUIVALENT 1-131 requires that the DOSE EQUIVALENT 1-131 be calculated using the thyroid dose conversion factors listed in Table III of TID 14844, "Calculation of Distance Factors for Power and Test Reactor Sites." The ITS allows DOSE EQUIVALENT 1-131 to be calculated using any one of three thyroid dose conversion factors: TID-14844 (1962); Table E-7 of RG 1.109, Rev. 1 (1977); or ICRP 30, Supplement to Part 1, page 192-212, Table Titled "Committed Dose Equivalent in Target Organs or Tissues per Intake of Unit Activity." This changes the CTS by allowing two additional methods, !CRP 30, Supplement to Part 1 or Table E-7 of RG 1.109, Rev. 1 (1977), to be used to calculate DOSE EQUIVALENT 1-131.The purpose of the defined term is to provide acceptable methods for computing DOSE EQUIVALENT 1-131. Using thyroid dose conversion factors other than those given in TID-14844 results in lower doses and higher allowable activity but is justified by the discussion given in the Federal Register (FR page 23360 VI 56 No 98 May 21, 1991).This discussion accompanied the final rulemaking on 10 CFR 20 by the NRC. In that discussion, the NRC stated that they were incorporating modifications to existing concepts and recommendations of the ICRP and NCRP into NRC regulations.

Incorporation of the methodology of ICRP 30 into the 10 CFR 20 revision was-specifically mentioned with the explanation that changes being made result from changes in the scientific techniques and parameters used in calculating dose. In a response to a specific question as to whether or not the ICRP 30 dose parameters should be used, the NRC stated "Appropriate parameters for calculating organ doses can be found in ICRP 30 and its supplements..." Lastly, Commissioner Curtis provided additional views of the revised 10 CFR 20 with respect to the backfit rule. In that discussion, he stated that the AEC, when they issued the original 10 CFR 20, had emphasized that the standards were subject to change with the development of new knowledge and experience.

He went on to say that the limits given in the revised 10 CFR 20 were based on up-to-date metabolic models and dose factors. This Federal Register entry shows clearly that, in general, the NRC was updating 10 CFR 20 to incorporate ICRP-30 recommendations and data. Given this discussion, it is concluded that using ICRP thyroid dose conversion factors to calculate DOSE EQUIVALENT 1-131 is acceptable.

In addition, RG 1.109 was developed by the NRC for the purpose of evaluating compliance with 10 CFR 50, Appendix I. The RG 1.109 thyroid dose conversion factors are higher-than the ICRP 30 thyroid dose conversion factors for all five iodine isotopes in question.

Therefore, using RG 1.109 thyroid dose conversion factors to calculate DOSE EQUIVALENT 1-131 is more conservative than ICRP 30 and is therefore acceptable.

An evaluation has been performed to determine whether or not a significant hazards consideration is involved with these proposed Technical Specification changes by 0 Davis-Besse Page 5 of 6 Attachment 1, Volume 3, Rev. 1, Page 68 of 69 Attachment 1, Volume 3, Rev. 1, Page 69 of 69 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS CHAPTER 1.0, USE AND APPLICATION focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below: 1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response:

No.The proposed use of Regulatory Guide 1.109 or ICRP 30 thyroid dose conversion factors to calculate DOSE EQUIVALENT 1-131 is a change in analysis methodology which does not include a physical change to the plant, a new mode of plant operation, or a change in surveillance frequency.

Therefore, the probability of a previously analyzed accident would not increase.

Dose consequences in the applicable accident analyses were evaluated utilizing an iodine activity associated with 1% failed fuel. Since the reactor coolant activity used in the accident analyses is significantly higher than the Technical Specification limit, the method for determining DOSE EQUIVALENT 1-131 does not affect consequences of previously evaluated accidents.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response:

No.The proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated because the proposed change does not introduce a new mode of plant operation and does not require physical modification of the plant. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?Response:

No.The proposed change only refines the method of calculating thyroid doses and DOSE EQUIVALENT 1-131 activity.

Using these methods would not result in the thyroid doses changing significantly, since the same dose factors would be used to calculate the thyroid doses and DOSE EQUIVALENT 1-131 activity.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.Based on the above, it is concluded that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, there is a finding of "no significant hazards consideration." 0 Davis-Besse Page 6 of 6 Attachment 1, Volume 3, Rev. 1, Page 69 of 69

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]

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