ML021220088

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Attachment 5 - Table R - Relocated Specifications and Removed Details North Anna, Units 1 and 2, Amendments 231 and 212
ML021220088
Person / Time
Site: North Anna  Dominion icon.png
Issue date: 04/05/2002
From:
Office of Nuclear Reactor Regulation
To:
References
TAC MB0799, TAC MB0800
Download: ML021220088 (87)
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Text

ATTACHMENT 5 Table R - Relocated Specifications and Removed Details

Table R - Relocated Specifications and Removed Details ITS Section 1.0 - Use and Application

-- III Change Control Change Location PIrocess Category I)escription of Relocated Requirements DOC No. CTS Requirement .- ______I_________ -

I LA.1 Table 1.1 CTS Section 1.0, Table 1.I, "OPERATIONAL MODES." ITS 3.9.1 Bases ITS 5.5.13, Technical 1.0 states that MODE 6 is restricted to reactivity conditions with Specification Bases K&.!< 0.95. ITS Section I..i, Table 1.I 1i,"MODEiS," does Control Progra i not contain that restriction. I I I i I 11 Chatine Category:

- Relmoving Details of System Design and System Description, Including lcsign I.iit.:

2 - Removing Descriptions of System Operation 3 - Removing Procedural Details for Meeting I'S RCquirements and Related ReportingC, InstruIMiIcnlation and Alarns 4 - Removing Performance RequirenIents fr Indication-Only Operating l imils Report Spccification's to h, Cole I

5 - Removal of Cyclc-Spcciflic Param-ierter Limits Io inthe Technical Page I of I R 1.0 North Anna Power Station

Table R- Relocated Specifications and Removed Details ITS Section 2.0 - Safety Limits Eha nge ( )il rol Change ChangceCstol Change -11 PI'occ'Ss CTS Requirement Description of Relocated Requirements I.ocatIion DOC No. -- I COLR t ITS 5.6,5, Core T 5 A

CTS 2.1I. I requires that the combination of THIERMAl. COLR ITS 5.6,5, Core 2.0 IA.I 2. 1.1 and Figure Operating L imits 2.1-1 POWER, pressurizer pressure, and the highest operating loop Report coolant temperature not exceed tie limits in CTS Figure 2. I I.

ITS 2. I. I states that Ihe combination of 'I'lFI.RMAAL POWER, RCS highest loop average temlperalurc, and prcssuri/er pressure shall not exceed the limits specified in(tie COIR and provides specific limits on I)NBR and peak futel centerl in temperature. This changes the CTS by relocating cycle specific parameter limits to the COL.l. The limiting Safety Limit para mtcers are retained in the Si.

I I Change Category:

ll ririr I - Removing Details of System Dcsign and System Dcscription, InchLdringlcDsign 2 - Removing Descriptions of System Operation Reporting 3 - Removing Procedural Details for Mcceing TS RcqirierIcenls and ,Related for Indication-Only Ilnstrumenitiat ion and Alarrs 4 - Removing Performance Requieremnts fromi tile Technical Specifications to the.Cofc Opcraiing Limiis Report 5 - Removal of Cycle-Specific Parameter Limits Page 1 of I R - 2.0 North Anna Power Station

Table R - Relocated Specifications and Removed Details ITS Section 3.0 - LCO and SR Applicability Change Category:

DCsign li miJs I - R*emoving Details of System Design and System Description, Inchlding 2 - Removing Descriptions or System Operation

'I'S Requirements and Related Rcpoli hg 3 - Removing Procedural Details for Mceting Instrunmentation and Alarms 4 - Removing Performance Requircments for lndicatiori-Only from the Technical Specifications to III- Core OperatinglIimits Report 5 - Removal of Cycle-Specific Parameter Limits Page I ol'I1 R - 3.0 North Anna Power Station

Table R - Relocated Specifications and Removed Details ITS Section 3. I - Reactivity Control Systems Lilange Lontrol I ..AIdL1gC I r IIIII.- rll-Ill I r, k,ý . ,,

Chteange 11 Prange Control Process Category CTS Requirement Description of Relocated Requirements Location DOC No. ITS 5.6.5, Core 5 --- i COLR ITS 5.6.5, Core 5 3.1.1 LA.I 3.1.1.1, 3.1.1.2, CTS 3.1.1I.1 states that the SHUTDOWN MARGIN shall be Operating Limits 4.1.1.1.1, and 1.77% Ak/k. CTS 3.1.1 .2 states that the SHUTDOWN Repartee 3.1.1.2 MARGIN shall be > 1.77% Ak/k. The specific value of 1.77% Ak/k also appears in the CTS 3.1. 1.1 and CTS 3.1.1.2 Action, and in Surveillance 4.1.1. 1.1 and 4.1.1.2. ITS 3.1.1 states that SHUTDOWN MARGIN shall be within the limits provided in the COLR. The Actions and Surveillance Requirements of ITS 3.1.1 also reference SDM values locate in the COLR. This changes thc CTS by relocating the SHUTDOWN MARGIN parameter limits to the Core Operating Limits Report (COLR).

-1 Bases I ITS 5.5.13, -T 3 4 Bases ITS 5.5.13, 3.1.1 LA.2 4.1.1.1. L.e and CTS Surveillances .I. 1.l.l.Le, and 4.1.1.2.b require Technical 4.1.1.2.b determination that the SDM is within limit and specifically Specification Bases require the consideration of the following factors: reactor Control Program coolant system boron concentration, control rod position, reactor coolant system average temperature, fuel burnup bas on gross thermal energy generation, xenon concentration, an samarium concentration. ITS SR 3.1. 1.1 requires determination that SDM is within limit but does not describe the factors that must be considered in the calculation. This information is relocated to the Surveillance Bases. This changes the CTS by removing details on how the SDM calculation is performed from the specifications and placing the information in the Bases.

I1i It CTS Surveillances 4.1.1.1.I.2 requires comparison of the Bases ITS 5.5.13, Technical 3.1.2 LA.I

4. 1.1. 1.Le actual and predicted core reactivity balance and specifically Specification Bases requires consideration of at least those factors stated in Control Program Specification 4.l.11I.1. I.e. CTS 4.1.1. 1. L.e requires determination of SDM and require the consideration of the I I I

Change Category:

I - Removing Details of System Design and System Description, Including Design Limits 2 - Removing Descriptions of System Operation Reporting 3 - Removing Procedural Details for Meeting TS Requirements and Related for Indication-Only Instrumentation and Alarms 4 - Removing Performance Requirements Limits from the Technical Specifications to the Core Operating Limits Report 5 - Removal of Cycle-Specific Parameter Page 1 of 9 R-3.1 North Anna Power Station

Table R - Relocated Specifications and Removed Details ITS Section 3.1 - Reactivity Control Systems Change Control Change DOC No. CTS Requirement Description of Relocatcd Requirements Location Process Category following factors: reactor coolant system boron conccntration, control rod position, reactor coolant system average temperature, fuel burnup based on gross thermal energy generation, xenon concentration, and sanmarium concentration. ITS SR 3.1.2.1 requires comparison of the actual and predicted core reactivity balance but does not describe the factors that must be considered in the calculation.

This information is relocated to the Surveillance Bases. This changes the CTS by removing details on how the core reactivity balance comparison calculation is performed from the specifications and placing the information in the Bases.

3.1.3 None N/A N/A N/A N/A N/A 3.1.4 LA.l 3.1.3.1, Actions a, CTS 3.1.3.1, Actions a, b, c.2, and c.2.b) require satisfying the COLR ITS 5.6.5, Core 5 b, c.2, and c.2.b SHUTDOWN MARGIN requirement in accordance with Operating Limits Specification 3. 1.1. 1. In the same conditions, ITS 3.1.4 Report requires verification that the SHUTDOWN MARGIN is within the limit provided in the COLR. This changes the CTS by relocating the SHUTDOWN MARGIN value to be met from the specifications to the Core Operating Limits Report (COLR).

3.1.5 None N/A N/A N/A N/A N/A 3.1.6 None N/A N/A N/A N/A N/A 3.1.7 None N/A N/A N/A N/A N/A 3.1.8 LA. I Unit 2 3.1.1.3.2 Unit 2 CTS 3.1.1.3.2 Action states that with the primary grade COLR ITS 5.6.5, Core 5 Action water flow path isolation valves not locked, sealed, or Operating Limits otherwise secured in the closed position, verify the Report SHUTDOWN MARGIN is greater than or equal to 1.77%

Change Category:

I - Removing Details of System Design and System Description, Including Design Limits 2 - Removing Descriptions of System Operation 3 - Removing Procedural Details for Meeting TS Requirements and Related Reporting 4 - Removing Performance Requirements for Indication-Only Instrumentation and Alarms 5 - Removal of Cycle-Specific Parameter Limits from the Technical Specifications to the Core Operating Limits Report North Anna Power Station Page 2 of 9 R -3.1

Table R - Relocated Specifications and Removed Details ITS Section 3.1 - Reactivity Control Systems r Change Control Change Control

r. Change Change Location Process Category

" CT.SRontiaret'nc:n Description of Relocated Requirements DOC No. F t-I I %- x q u m jt I * " 1 1-1 -

I I Ak/k within 60 minutes. ITS 3.1.8, Action A.3, states this requirement as, "Perform SR 3.1. 1. 1" within I hour. ITS 3.1.1.1 requires verification that the SHUTDOWN MARGIN is within the limit provided in the COLR. This changes the CTS by moving the SHUTDOWN MARGIN value to the I COLR. I1 . --

1I -

i II 1 . -i I 3.1.8 LA.2 3.1.1.3.2 Unit I CTS 3.1.1.3.2 states "The following valves shall be Bases ITS 5.5.13, Technical locked, sealed, or otherwise secured in the closed position Specification Bases except during planned boron dilution or makeup activities: a. Control Program I-CH-217 or b. I-CH-220, I CH-241, FCV II14B and FCV 1I13B." Unit 2 CTS 3.1.1.3.2 states "The following valves shall be locked, sealed, or otherwise secured in the closed position except during planned boron dilution or makeup activities: a. 2-CH-140 or b. 2-CH-160, 2 CH-156, FCV 2114B and FCV-2113B." ITS 3.1.8 states, "Each valve used to isolate primary grade water flow path shall be secured in the closed position." ITS 3.1.8 LCO Note states, "Primary grade water flow path isolation valves may be opened under administrative control for planned boron dilution or makeup activities." This changes the CTS by relocating the list of primary grade water flow path isolation valves to the ITS Bases. The other changes in CTS 3.1.1.3.2 are discussed in DOC A.2.

N/A N/A N/A 3.1.9 None N/A N/A Technical 10 CFR 50.59 N/A CTS 3.1.1.3.1 CTS 3.1.1.3.1 requires a minimum reactor c(:olant system flow of 3000 gpm in all MODES. Various accident analyses Requirements 3.1 . 1.3.1 assume adequate reactor coolant flow for heat removal and Manual R. I boron mixing. However, a specific flow rate is not assumed as an initial condition of any design basis accident or transient Change Categ.ry' I - Removing Details of System Design and System Description, Including Design Limits 2 - Removing Descriptions of System Operation 3 - Removing Procedural Details for Meeting TS Requirements and Related Reporting 4 - Removing Performance Requirements for Indication-Only Instrumentation and Alarms Operating Limits Report 5 - Removal of Cycle-Specific Parameter Limits from the Technical Specifications to the Core Page 3 of 9 R -3.1 North Anna Power Station

Table R - Relocated Specifications and Removed Details ITS Section 3.1 - Reactivity Control Systems Change Control Change DOC No. CTS Requirement Description of Relocated Requirements Location Process Category and is not credited for mitigation of any desirn basis accident or transient. Other specifications in the ITS contains adequate controls to ensure that RCS flow meets the general accident analysis assumption. In MODES I, 2, and 3, at least one Reactor Coolant Pump (RCP) is required to be in operation, which provides flow in excess of 3000 gpm. In MODE 4, either an RCP or Residual Heat Removal (RHR) train is required to be in operation, and in MODES 5 and 6, at least one RHR train is required to be in operation. The ITS Bases state that when an RHR train is required to provide RCS flow, the flow rate must be sufficient for decay heat removal and boron mixing. The LCO does not meet the criteria for retention in the ITS; therefore, it will be retained in the Technical Requirements Manual.

CTS 3.1.3.3 3.1.3.3 CTS 3.1.3.3 provides requirements on the rod position Technical 10 CFR 50.59 N/A R. I indicator channels during shutdown (MODES 3, 4, and 5 with Requirements the reactor trip system breakers in the closed position). The Manual control rod position indicator channels provide indicator of rod position to the operator. This indicator is used by the operator to verify that the rods are correctly positioned, and to verify the rods are inserted into the core following a reactor trip. Rod position indicator is also used during reactor startup. However, no DBA or Transient initiated in MODES 3, 4, or 5 with the reactor trip system breakers in the closed position assumes operator action to manually trip the reactor or to take some alternative action if an automatic reactor trip does not occur. With the reactor critical, rod position indicator is used to verify that the insertion, sequence, and overlap limits are met. These are related to SHUTDOWN MARGIN and core power distribution limits. This LCO does Change Category:

I - Removing Details of System Design and System Description, Including Design Limits 2 - Removing Descriptions of System Operation 3 - Removing Procedural Details for Meeting TS Requirements and Related Reporting 4 - Removing Performance Requirements for Indication-Only Instrumentation and Alarms 5 - Removal of Cycle-Specific Parameter Limits from the Technical Specifications to the Core Operating Limits Report Page 4 of 9 R-3.1 North Anna Power Station

Table R - Relocated Specifications and Removed Details ITS Section 3. 1 - Reactivity Control Systems Change Control Change DOC No. CTS Requirement Description of Relocated Requirements Location Process Category not meet the criteria for retention in the ITS; therefore, it will be retained in the Technical Requirements Manual.

CTS 3.1.2.1 provides requirements on the boration systems Technical 10 CFR 50.59 N/A CTS 3.1.2.1 3.1.2.1 R. I flow paths during shutdown. The boration systems are part of Requirements the Chemical and Volume Control System (CVCS) and Manual provide the means to control the chemical neutron absorber (boron) concentration in the RCS and to help maintain the shutdown margin. The boration system is not assumed to be OPERABLE to mitigate the consequences of a design basis accident or transient. In the case of the boron dilution accident, the accident is addressed by preventing its occurrence or by terminating the event before the required shutdown margin is lost, not by boration. This LCO does not meet the criteria for retention in the ITS; therefore, it will be retained in the Technical Requirements Manual.

CTS 3.1.2.2 provides requirements on the boration systems Technical 10 CFR 50.59 N/A CTS 3.1.2.2 3.1.2.2 R.I flow paths during operation. The boration systems are part of Requirements the Chemical and Volume Control System (CVCS) and Manual provides the means to control the chemical neutron absorber (boron) concentration in the RCS and to help maintain the shutdown margin. The boration system is not assumed to be OPERABLE to mitigate the consequences of a design basis accident or transient. The Emergency Core Cooling System (ECCS) and Refueling Water Storage Tank are credited in the accident analyses. In the case of the boron dilution accident, the accident is addressed by preventing its occurrence or by terminating the event before the required shutdown margin is lost, not by boration. This LCO does not meet the criteria for retention in the ITS; therefore, it will be retained in the Change Category:

I - Removing Details of System Design and System Description, Including Design Limits 2 - Removing Descriptions of System Operation 3 - Removing Procedural Details for Meeting TS Requirements and Related Reporting 4 - Removing Performance Requirements for Indication-Only Instrumentation and Alarms Limits Report 5 - Removal of Cycle-Specific Parameter Limits from the Technical Specifications to the Core Operating Page 5 of9 R- 3.1 North Anna Power Station

Table R - Relocated Specifications and Removed Details ITS Section 3. i - Reactivity Control Systems Change Control Change DOC No. CTS Requirement Description of Rclocated Requirements Location Process Category Technical Requirements Manual.

CTS 3.1.2.3 3.1.2.3 CTS 3.1.2.3 provides requirements on the charging pumps Technical 10 CFR 50.59 N/A R. I during shutdown when used as part of the boration system. Requirements The charging pumps in the boration system arc part of the Manual Chemical and Volume Control System (CVCS) and provide the means to control the chemical neutron absorber (boron) concentration in the RCS and to help maintain the shutdown margin. The charging pumps in the boration system are not assumed to be OPERABLE to mitigate the consequences of a design basis accident or transient. In the case of the boron dilution accident, the accident is addressed by preventing its occurrence or by terminating the event before the required shutdown margin is lost, not by boration. OPERABILITY of the charging pumps is required as part of the Emergency Core Cooling System, which is addressed in other specifications.

This LCO does not meet the criteria for retention in the ITS; therefore, it will be retained in the Technical Requirements Manual.

3.1.2.4 CTS 3.1.2.4 provides requirements on the charging pumps Technical 10 CFR 50.59 N/A CTS 3.1.2.4 R.lI during operation when used as part of the boration system. Requirements The charging pumps in the boration system are part of the Manual Chemical and Volume Control System (CVCS) and provide the means to control the chemical neutron absorber (boron) concentration in the RCS and to help maintain the shutdown margin. The charging pumps in thie boration system are not assumed to be OPERABLE to mitigate the consequences of a design basis accident or transient. The Emergency Core Cooling System (ECCS) is and Refueling Water Storage Tank are credited in the accident analyses. In the case of the boron Change Category:

I - Removing Details of System Design and System Description, Including Design Limits 2 - Removing Descriptions of System Operation 3 - Removing Procedural Details for Meeting 'S Requirements and Related Reporting 4 - Removing Performance Requirements for Indication-Only Instrumentation and Alarms Limits Report 5 - Removal of Cycle-Specific Parameter Limits from the Technical Specifications to the Core Operating North Anna Power Station Page 6 of 9 R-3.1

Table R - Relocated Specifications and Removed Details ITS Section 3. 1 - Reactivity Control Systems Change Control Change CTS Requirement Description of Relocated Requirements Location Process Category DOC No.

dilution accident, the accident is addressed by preventing its occurrence or by terminating the event before the required shutdown margin is lost, not by boration. OPERABILITY of tlhe charging pumps is required as part of ihe Emergency Core Cooling System, which is addressed in other specifications.

This LCO does not meet the criteria for retention in the ITS; therefore, it will be retained in the Technical Requirements Manual.

Unit 1 3.1.2.5 Unit I CTS 3.1.2.5 provides requirements on the boric acid Technical 10 CFR 50.59 N/A Unit I CTS 3.1.2.5 R. I transfer pumps during shutdown. The boric acid transfer Requirements pumps are part of the Chemical and Volume Control System Manual (CVCS) and provides the means to control the chemical neutron absorber (boron) concentration in the RCS and to help maintain the shutdown margin. The boric acid transfer pumps are not assumed to be OPERABLE to mitigate the consequences of a design basis accident or transient. In the case of the boron dilution accident, the accident is addressed by preventing its occurrence or by terminating the event before the required shutdown margin is lost, not by boration.

This LCO does not meet the criteria for retention in the ITS; therefore, it will be retained in the Technical Requirements Manual.

Unit I 3.1.2.6 Unit I CTS 3.1.2.6 provides requirements on the boric acid Technical 10 CFR 50.59 N/A Unit I CTS 3.1.2.6 R. I transfer pumps during operation. The boric acid transfer Requirements pumps are part of the Chemical and Volume Control System Manual (CVCS) and provides the means to control the chemical neutron absorber (boron) concentration in the RCS and to help maintain the shutdown margin. The boric acid transfer pumps are not assumed to be OPERABLE to mitigate the Change Category:

I - Removing Details of System Design and System Description, Including Design Limits 2 - Removing Descriptions of System Operation 3 - Removing Procedural Details for Meeting TS Requirements and Related Reporting 4 - Removing Performance Requirements for Indication-Only Instrumentation and Alarms 5 - Removal of Cycle-Specific Parameter Limits from the Technical Specifications to the Core Operating Limits Report Page 7 of 9 R-3.1 North Anna Power Station

Table R - Relocated Specifications and Removed Details ITS Section 3.1 - Reactivity Control Systems Change Control Change DOC No. CTS Requirement Description of Relocated Requirements Location Process Category consequences of a design basis accident or transient. The Emergency Core Cooling System (ECCS) and Refueling Water Storage Tank are credited in the accident analyses. In the case of the boron dilution accident, the accident is addressed by preventing its occurrence or by terminating thie event before the required shutdown margin is lost, not by boration. This LCO does not meet the criteria for retention in the ITS; therefore, it will be retained in the Technical Requirements Manual.

CTS 3.1.2.7 3.1.2.7 CTS 3,1.2.7 provides requirements on the borated water Technical 10 CFR 50.59 N/A R. I sources during shutdown. The borated water sources - Requirements shutdown are part of the Chemical and Volume Control Manual System (CVCS) and provide the means to control the chemical neutron absorber (boron) concentration in the RCS and to help maintain the shutdown margin. The borated water sources are not assumed to be OPERABLE to mitigate the consequences of a design basis accident or transient. In the case of the boron dilution accident, the accident is addressed by preventing its occurrence or by terminating the event before the required shutdown margin is lost, not by boration.

This LCO does not meet the criteria for retention in the ITS; therefore, it will be retained in the Technical Requirements Manual.

3.1.2.8 CTS 3.1.2.8 provides requirements on the borated water Technical 10 CFR 50.59 N/A CTS 3.1.2.8 R. I sources during operation. The borated water sources - Requirements operating are part of the Chemical and Volume Control Manual System (CVCS) and provide thie means to control the chemical neutron absorber (boron) concentration in the RCS and to help maintain the shutdown margin. The boratcd water Change Category:

I - Removing Details of System Design and System Description, Including Design Limits 2 - Removing Descriptions of System Operation 3 - Removing Procedural Details for Meeting TS Requirements and Related Reporting 4 - Removing Performance Requirements for Indication-Only Instrumentation and Alarms 5 - Removal of Cycle-Specific Parameter Limits fromn the Technical Specifications to the Core Operating Limits Report Page 8 of9 R-3.1 North Anna Power Station

Table R - Relocated Specifications and Removed Details ITS Section 3.1 - Reactivity Control Systems Change Control Change DOC No. CTS Requirement Description of Relocaled Requirements Location Process Category sources are not assumed to be OPERABLE to mitigate the consequences of a design basis accident or transient. The Emergency Core Cooling System (ECCS) and Refueling Water Storage Tank are credited in the accident analyses and are required by other specifications. In the case of the boron dilution accident, the accident is addressed by preventing its occurrence or by terminating the event before the required shutdown margin is lost, not by boration. This LCO does not meet the criteria for retention in the ITS; therefore, it will be retained in the Technical Requirements Manual.

Change Category:

I - Removing Details of System Design and System Description, Including Design Limits 2 - Removing Descriptions of System Operation 3 - Removing Procedural Details for Meeting TS Requirements and Related Reporting 4 - Removing Performance Requirements for Indication-Only Instrumentation and Alarms 5 - Removal of Cycle-Specific Parameter Limits from the Technical Specifications to the Core Operating Limits Report North Anna Power Station Page 9 of 9 R -3.1

Table R - Relocated Specifications and Removed Details ITS Section 3.2 - Power Distribution Limits Change Control Change DOC No. CTS Requirement Description of Relocatcd Requirements Location Process Category 3.2.1 LA. I 3.2.2, Action a CTS 3.2.2, Action a, states than when FQ(Z) is exceeding its Bases ITS 5.5.13, 3 limit, POWER OPERATION may proceed provided the Technical Overpower AT Trip Sctpoint (value of K4) has been reduced Specifications Bases at least I1%(in AT span) for each 1% FQ(Z) exceeds the limit. Control Program ITS 3.2. I, Required Action A.2.3 states, "Reduce Overpower AT trip setpoints > 1/%for each I1%FQM(Z) exceeds limit."

This changes the CTS by eliminating the parenthetical phrases, "(value of K.)" and "(in AT span)" and placing the information in the Bases.

3.2.1 LA.2 4.2.2.2.a CTS 4.2.2.2.a states that FQ(Z) shall he evaluated to determine Bases ITS 5.5.13, 3 if FQ is within its limit by using the moveable incore detectors Technical to obtain a power distribution map at any THERMAL Specifications Bases POWER greater than 5% of RATED THERMAL POWER. Control Program The ITS does not contain a similar statement and this information appears in the ITS Bases. This changes the CTS by moving information to the Bases.

3.2.1 LA.3 4.2.2.2.b, 4.2.2.3 CTS 4.2.2.2.b states that the measured FQ(Z) must be Bases ITS 5.5.13, 3 increased by 3% to account for manufacturing tolerances and Technical further increased by 5% for measurement uncertainties. CTS Specifications Bases 4.2.2.3 states that when FQ(Z) is measured for reasons other Control Program than meeting the requirements of Surveillance 4.2.2.2, the measured FQ(Z) must be increased by 3% to account for manufacturing tolerances and further increased by 5% for measurement uncertainties, The ITS does not contain this requirement. This information is contained in the ITS Bases.

This changes the CTS by moving information to the Bases.

3.2.1 LA.4 4.2.2.2.c CTS 4.2.2.2.c states that the measured FQ(Z) must meet a Bases ITS 5.5.13, 3 relationship provided in the Surveillance, The values for the Technical Change Category:

I - Removing Details of System Design and System Description, Including Design Limits 2 - Removing Descriptions of System Operation 3 - Removing Procedural Details for Meeting TS Requirements and Related Reporting 4 - Removing Performance Requirements for Indication-Only Instrumentation and Alarms 5 - Removal of Cycle-Specific Parameter Limits from the Technical Specifications to the Core Operating Limits Report North Anna Power Station Page I of 3 R -3.2

Table R - Relocated Specifications and Removed Details ITS Section 3.2 - Power Distribution Limits Change Control Change DOC No. CTS Requirement Description of Relocated Requirements Location Process Category principle components of the relationship, CFQ, K(Z), and Specilications Bases N(Z), are specified in the COLR. ITS LCO 3.2.1 requires that Control Program F0 (Z) meet this same relationship by stating, "FP(Z), as approximated by FQM(Z), shall be within the limits specified in the COLR." The equation for the relationship is located in the ITS Bases. This changes the CTS by moving information to the Bases.

3.2.1 LA.5 4.2.2.2.f CTS 4.2.2.2. r states that with FQM(Z) not within limit, power Bases ITS 5.5.13, 3 operation may continue provided the AFD are reduced 1% Technical AFD for each percent FQ(Z) exceeded its limits or by Specifications Bases complying with the requirements of the specification for FQ(Z) Control Program exceeding its limit by the same percentage. CTS 4.2.2.2 also provides an equation for determining the percent by which FQ(Z) exceeds its limit. ITS 3.2.1 contains the same requirements described for the CTS, but does not contain an equation for determining the percentage by which FQ(Z) exceeds the limit. This equation is relocated to the ITS Bases.

This changes the CTS by moving information to the Bases.

4.2.2.2.g CTS 4.2.2.2.g states that the FQ(Z) limits are not applicable in Bases ITS 5.5.13, 3 3.2.1 LA.6 the lower core region 0 to 15 percent inclusive, and the upper Technical core region 85 to 100 percent inclusive. ITS 3.2.1 does not Specifications Bases contain this information. This information is located in the Control Program ITS Bases. This changes the CTS by moving information to the Bases.

LA.7 3.2.1, Action e.I CTS 3.2.1, Action e.1, states that FQM(Z) shall be increased by Bases ITS 5.5.13, 3 3.2.1 2% over the measured amount when FQM(Z) / K(Z) (maximum Technical over Z) is increasing. ITS SR 3.2.1.1 Note states that FQM(Z) Specifications Bases shall be increased by an appropriate factor when FQM(Z) I Control Program K(Z) (maximum over Z) is increasing. This changes the CTS Change Category:

I - Removing Details of System Design and System Description, Including Design Limits 2 - Removing Descriptions of System Operation 3 - Removing Procedural Details for Meeting TS Requirements and Related Reporting 4 - Removing Performance Requirements for Indication-Only Instrumentation and Alarms 5 - Removal of Cycle-Specific Parameter Limits from the Technical Specifications to the Core Operating Limits Report Page 2 of 3 R-3.2 North Anna Power Station

Table R - Relocated Specifications and Removed Details ITS Section 3.2 - Power Distribution Limits Change Control Change DOC No. CTS Requirement Description of Relocated Requirements Location Process Category by relocating the amount by which FQI(Z) must be increased to tie COLR.

3.2.2 LA. 1 3.2.3 CTS 3.2.3 states that FnAIl shall be limited by an equation, COLR ITS 5.6.5, Core 5 which is contained in the LCO. All of the parameters in the Operating Limits CTS equation are specified in the CORE OPERATING Report LIMITS REPORT (COLR). ITS LCO 3.2.2 states, "FNan shall be within the limits specified in the COLR." This changes the CTS by relocating the equation to the COLR.

3.2.3 None N/A N/A N/A N/A N/A LA.1 4.2.4.2 CTS Surveillance 4.2.4.2 states that the QPTR shall be Bases ITS 5.5.13, 3 3.2.4 determined to be within limit when above 75 % RTP with one Technical Power Range Channel inoperable by using the movable incore Specifications Bases detector to confirm that the normalized symmetric power Control Program distribution, obtained from 2 sets of 4 symmetric thimble locations or a full-core flux map, is consistent with tihe indicated QPTR at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. ITS SR 3.2.4.2 states, "Verify QPTR is within limit using the movable incore detectors." ITS SR 3.2.4.2 is modified by a Note which states, "Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after input from one or more Power Range neutron Flux channels are inoperable with THERMAL POWER > 75% RTP." This changes the CTS by relocating the details of how the movable incore detector system is used to determine QPTR by moving the phrase "the normalized symmetric power distribution, obtained from 2 sets of 4 symmetric thimble locations or a full-core flux map" to the Bases of the Surveillance.

Change Catcgory:

I - Removing Details of System Design and System Description, Including Design Limits 2 - Removing Descriptions of System Operation 3 - Removing Procedural Details for Meeting TS Requirements and Related Reporting 4 - Removing Performance Requirements for Indication-Only Instrumentation and Alarms 5 - Removal of Cycle-Specific Parameter Limits from the Technical Specifications to the Core Operating Limits Report Page 3 of 3 R-3.2 North Anna Power Station

Table R - Relocated Specifications and Removed Details ITS Section 3.3 - Instrumentation CTS Change Control Change DOC No. Requirement Description of Relocated Requirements Location Process Category 3.3.1 LA. I 4.3.1.1.2 CTS Surveillance Requirement 4.3.1.1.2 requires tile RTS trip Bases ITS 5.5.13, 3 functions to be response time tested. This requirement includes Technical the following, "Response of the neutron flux signal portion of the Specifications channel time shall be measured firom the detector output or input Bases Control of the first electronic component in the channel." ITS SR 3.3.1.16 Program requires RESPONSE TIME testing of the RTS functions. This changes the CTS by moving the descriptive wording on how to measure neutron flux for channel response times from the TS to the ITS Bases 3.3.1 LA.2 3.3.1. 1 Note CTS 3.3.1.1 requires two Source Range channels be OPERABLE Bases ITS 5.5.13, (d) in MODE 2 "'. The note ""states that the high voltage to detector Technical may be de-energized above P-6. ITS requirement for the Source Specifications Range channel state that two channels must be OPERABLE in Bases Control MODE 2 1d". Note Id) specifies, "Below the P-6 (Intermediate Program Range Neutron Flux) interlock" and maintains the intent of the CTS requirement. This changes the CTS by moving the allowance that the high voltage detector may be de-energized above P-6 from the TS to the ITS Bases.

3.3.1 LA.3 Table 3.3-I Reactor Trip System Interlocks or "P" functions are required to be Bases ITS 5.5.13, 2 OPERABLE in CTS Table 3.3-I. These functions are designated Technical as P-6, P-7, P-8, P-l0, and P-13. Descriptive information about Specifications the reactor trip logic enable setpoints is contained in the Bases Control Condition, Function, and Setpoint columns for the interlocks. ITS Program 3.3.1 does not include this information in the TS. This changes the CTS by moving the information from the TS to the ITS Bases.

Change Category:

I - Removing Details of System Design and System Description, Including Design Limits 2 - Removing Descriptions of System Operation 3 - Removing Procedural Details for Meeting TS Requirements and Related Reporting 4 - Removing Performance Requirements for Indication-Only Instrumentation and Alarms 5 - Removal of Cycle-Specific Parameter Limits fiorn the Technical Specifications to the Core Operating Limits Report North Anna Power Station Page I of'"17 R - 3.3

Table R - Relocated Specifications and Removed Details ITS Section 3.3 - Instrumentation CTS Change Control Change DOC No. Requirement Description of Relocated Requirements Location Process Category 3.3.1 LA.4 Table 4.3-1 CTS Table 4.3-1 contains surveillance requirements with Notes Bases ITS 5.5.13, which provide information on the undervoltage and shunt trip Technical circuits testing of the Reactor Trip Breakers (RTBs) and for tile Specifications RTB bypass breakers in testing the automatic undervoltage trip Bases Control during CHANNEL FUNCTIONAL TEST. The descriptive Program information to be moved is: CTS Note 8".. shall independently verify the OPERABILITY of the undervoltage and shunt trip circuits for the Manual Reactor Trip Function. The test shall also verify the OPERABILITY of the Bypass Breaker trip circuit(s)."

CTS Note 10 "Automatic undervoltage trip." CTS Note I"I shall independently verify the OPERABILITY of the undervoltage and shunt trip attachment of the Reactor Trip Breaker." This information is contained in the Bases sections for SR 3.3.1.4 and SR 3.3.1.14. ITS retains the necessary SRs for the RTB and bypass RTB to be OPERABLE. This changes the CTS by moving the descriptive information from the TS to the ITS Bases.

3.3.1 LA.5 Table 2.2-1 CTS Table 2.2-1 for the Limiting Safety System Settings specifies COLR ITS 5.6.5, Core 5 the formulas for Overtemperature and Overpower AT functions. Operating limits ITS 3.3.1 in Table 3.3.1I- I lists the formulas for the Report Overtemperature and Overpower AT functions with a reference in each that the specific variables are contained in the Core Operating Limits Report (COLR). This changes the CTS by relocating specific parameters for the Overtemperature and Overpower AT functions from the Technical Specifications to the COLR.

Change Category:

I - Removing Details of System Design and System Description, Including Design Limits 2 - Removing Descriptions of System Operation 3 - Removing Procedural Details for Meeting TS Requirements and Related Reporting 4 - Removing Performance Requirements for Indication-Only Instrumentation and Alarms 5 - Removal of Cycle-Specific Parameter Limits from the 1Technical Specifications to the Core Operating Limits Report North Anna Power Station Page 2 of 17 R - 3.3

"Fable R - Relocated Specifications and Removed Details ITS Section 3.3 - Instrumentation CTS Change Control Change DOC No. Requirement Description of Relocated Requirements Location Process Category 3.3.1 LA.6 Table 4.3-1 CTS 3.3.1.1 Surveillance Requirement in Table 4.3-1 for the Bases ITS 5.5.13, 3 NOTE 12 Intermediate Range channels requires a CHANNEL CHECK on a Technical 2 Specifications refueling basis, and shown by the designation of R( . Note 12 states, in part, "verification that the Permlissives P-6 and P-10 are Bases Control in their required state for existing plant conditions by observation Program of the permissive annunciator window." The requirement of verification for P-6 and P-I 0 is retained in ITS SR 3.3.1.8. This changes the CTS by moving the requirement of "observation of the permissive annunciator window," from the TS to the ITS Bases.

3.3.1 LA.7 2.2.1 Action CTS 2.2. I Action states, "with the RTS instrumentation setpoint Bases ITS 5.5.13, 2,3 less conservative than the Allowable Value, the instrumentation Technical channel must be declared inoperable." With the channels Specifications inoperable, the applicable Action of ITS 3.3.1.1 shall be entered, Bases Control and the channel's trip setpoint shall be adjusted to be consistent Program with the Trip Setpoint value to return the instrument to OPERABLE status. The information provides no specific requirement for each function, but only describes the mechanics of how to adjust the channel to provide the required reactor protection. This changes the CTS by moving the information relating to the Trip Setpoint firom the TS to the ITS 3.3.1 [Bases.

Change Category:

I - Removing Details of System Design and System Description, Including Design Limits 2 - Removing Descriptions of System Operation 3 - Removing Procedural Details for Meeting TS Requirements and Related Reporting 4 - Removing Performance Requirements for Indication-Only Instrumentation and Alarms 5 - Removal of Cycle-Specific Parameter Limits from the Technical Specifications to the Core Operating Limits Report North Anna Power Station Page 3 of']17 R -3.3

Table R- Relocated Specifications and Removed Details ITS Section 3.3 - Instrumentation CTS Change Control Change DOC No. Requirement Description of Relocated Requirements Location Process Category 3.3.1 LA.8 Table 2.2-1 CTS 2.2.1 in Table 2.2-I provides in a footnote for Loss of Flow COLR ITS 5.6.5, Core 5 footnote function, that the design flow per loop is one-third of the Operating Linmits minimnum setpoint allowable value RCS total flow rate Report requirement. The minimum flow rate requirement is stated in CTS Table 3.2- I. The CTS Allowable Value for Loss of Flow is stated in % of design flow per loop. ITS 3.3.1 does not include this information on design flow rate. This changes the CTS by moving the design information from the TS to the COLR, and using the indicated flow rate for the Allowable Value in ITS 3.3.1.

3.3.1 LA.9 Table 2.2-I CTS Table 2.2-I Note 2 provides the calculation for the Bases ITS 5.5.13, Note 2 Overpower AT setpoint, Functional Unit 8. This states that the Technical function generated by the rate lag controller for F,,,*,dynamic Specifications compensation is given by the formula for t, (t- = S/I f-tC S). Also Bases Control specified is the time constant utilized in the rate lag controller for Program Ta,,s.ITS 3.3.1 Function 7, the Overpower AT formula does not include this information. This changes the CTS by moving the OPAT design information firom tile TS to the ITS Bases.

3.3.1 LA. 10 Table 2.2-1 CTS requirements stated in Table 2.2-1 Ibr functions 13 and 14 Bases ITS 5.5.13, 3 describes the span of the instrument used to measure steam Technical generator level to provide the trip setpoint and allowable value. Specifications ITS Table 3.3.1 does not include this information. This changes Bases Control the CTS by moving the information for the function firom the I'S Program to the ITS Bases.

3.3.1 LA. 11 Tables 2.2-1 The CTS lists in Tables 2.2-1 and 3.3-I Allowable Values and Technical 10 CFR 50.59 3 and 3.3-1 Trip Setpoints. ITS 3.3.1 does not specify the Trip Setpoints. Requirements This changes the CTS by moving the Trip Setpoint from the TS to Manual the Technical Requirements Manual (TRM).

Change Category:

I - Removing Details of System Design and System Description, Including Design Limits 2 - Removing Descriptions of System Operation 3 - Removing Procedural Details for Meeting TS Requirements and Related Reporting 4 - Removing Performance Requirements for Indication-Only Instrumentation and Alarms 5 - Removal of Cycle-Specific Parameter Limits from the Technical Specifications to the Core Operating Limits Report Page 4 of 17 R-3.3 North Anna Power Station

Table R - Relocated Specifications and Removed Details ITS Section 3.3 - Instrumentation CITS DOC No. Requirement Description of Relocated Requiremlents 3.3.1 LA.12 "Fable 4.3-1 CTS surveillance requirement listed in Table 4.3-1 for the reactor ITS 5.5.13, Technical NOTE 9 bypass breaker states a Frequency of "M (9)." This requires the Specifications monthly testing of the bypass breaker in conjunction the RTS Bases Control testing. Note 9 states, "Local manual shunt trip the reactor trip Program bypass breaker immediately after placing the bypass breaker into service, but prior to commencing reactor trip system testing or reactor trip breaker maintenance." ITS 3.3.1.4 is required to be performed on the RT1B bypass breaker every 331days on a STAGGERED TEST BASIS. This test would be required when the associated train of RTS is tested or that train RTB requires maintenance. This changes tile CTS by moving the note explaining when to conduct a local manual shunt trip test from the TS to the ITS Bases.

3.3.1 LA. 13 Table 4.3-1 CTS Table 4.3-1 states in Note 13 to the Intermediate Range Bases ITS 5.5.13, Note 13 Surveillance Requirements that the detector plateau curves shall Technical be obtained and evaluated on an R (refueling) Frequency. ITS Specifications Table 3.3.lI-1 states Function 4 Intermediate Range that SR Bases Control 3.3.1.11 is required. This changes the CTS by moving the Program requirement for performing detector plateau curves firom the 'IS to the ITS Bases.

3.3.1 LA. 14 Table 2.2-I CTS Table 2.2-I states the Allowable Value for Function I I UFSAR 10 CFR 50.59 Pressurizer Water LevelI-High is "93)% of instrument span." ITS Table 3.3.1-1 lists the Allowable Value for Function 9 Pressurizer Water Level - High is -93%." This changes the CTS by moving the design portion of the requirement "of instrument span," firom the 'TS to the UFSAR.

Change Category:

I - Removing Details of System Design and System Description, Including Design Limits 2 - Removing Descriptions of System Operation 3 - Removing Procedural Details for Meeting TS Requirements and Related Reporting 4 - Removing Performance Requirements for Indication-Only Instrumlentation and Alarms 5 - Removal of Cycle-Specific Parameter Limits from the Technical Specifications to the Core Operating Limits Report North Anna Power Station Page 5 off 17 R -- 3.3

Table R - Relocated Specifications and Removed Details ITS Section 3.3 - Instrumentation CTS Change Control Change DOC No. Requirement Description of Relocated Requirements Location Process Category 3.3.1 LA.15 Table 2.2-1 CTS Table 2.2-1 for Reactor Trip System (RTS) instrumentation UFSAR 10 CFR 50.59 1 has three columns stating various requirements for each function.

These columns are labeled, "TOTAL NO. OF CHANNELS,"

"CIHANNELS TO TRIP," and "MINIMUM CHANNELS OPERABLE." ITS Table 3.3.1-I states the channel requirement for each RTS function as, "REQUIRED CHANNELS." This changes the CTS by stating all of the channel requirements for each function as the required channels and moving the information of the number of channels to trip and the minimum channels needed to maintain the function OPERABLE to tile UFSAR.

3.3.1 LA. 16 Table 3.3-I CTS 3.3. 1.1 Action 2.d in 'Fable 3.3-1 states that the QUADRANT Bases ITS 5.5.13, 3 Action 2.d POWER TILT RATIO (QPTR) shall be determined to be within Technical limit when reactor power is above 75 percent of RATED Specifications THERMAL POWER (RTP). The moveable incore detectors will Bases Control be utilized to verify the QPTR when a Power Range Channel is Program inoperable. In this condition, the normalized symmetric power distribution is determ'ined by either utilizing 2 sets of4 symmetric thimble locations or a full core flux map. Every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, the results of the flux map must be compared with the indicated QPTR for consistency. The indicated QPTR is provided by the three Power Range Channels that remain OPERABLE. ITS 3.3.1 Action D.2.2 requires the performance of ITS SR 3.2.4.2, which verifies the QPTR is within its limit. This changes the CTS by moving the details of how to determine QPTR from the TS to the ITS Bases for SR 3.2.4.2.

Change Category:

I - Removing Details of System Design and System Description, Including Design Limits 2 - Removing Descriptions of System Operation 3 - Removing Procedural Details for Meeting TS Requirements and Related Reporting 4 - Removing Performance Requirements for Indication-Only Instrumentation and Alarms 5 - Removal of Cycle-Specific Parameter Limits from the Technical Specifications to the Core Operating Limits Report North Anna Power Station Page 6 of 17 R -3.3

Table R - Relocated Specifications and Removed Details ITS Section 3.3 - Instrumentation CTS Change Control Change DOC No. Requirement Description of Relocated Requirements Location Process Category 3.3.1 LA. 17 Table 2.2-1 CTS Table 2.2-1 Functional Unit 7 states the requirement for the Technical 10 CFR 50.59 3 Note I Overternperature (OT) AT as Note 1. The Allowable Value for the Requirements function is calculated with the application of Note 3 to Note I. A Manual portion of Note I states that the gains set for the equation are selected based on measured instrument response obtained during plant startup testing. ITS Table 3.3.1-1 Function 6 requires the O'FA'F Allowable Value to be calculated via the formula stated in ITS Note I. Note I in the ITS combines the CTS Notes 1 and 3 with modifications. ITS Note I does not contain the requirement "with gains to be selected based on measured instrument response during plant startup tests..." This changes the CTS by moving the information of the gain selection from the TS to the Technical Requirements Manual (TRM).

3.3.2 LA. I LCO 3.3.2.1 CTS LCO 3.3.2.1 and Action a contain information about the Technical 10 CFR 50.59 3 and Action a ESFAS channels and interlocks setpoint requirements. The LCO Requirements states the setpoint will be set consistent with tile Trip Setpoints Manual listed in Table 3.3-4. Action a requires the setpoint to be set more conservatively than the value listed in the Allowable Value coluhnm of the same table in order for tile function to be considered OPERABLE. ITS 3.3.2 does not contain this information. DOC LA.8 describes tile relocation oftthe setpoint values to the Technical Requirements Manual (TRM). This changes the CTS by moving the information about determining trip setpoints consistent with the setpoint methodology fi'om the TS to the TRM..

Change Category:

I - Removing Details of System Design and System Description, Including Design Limits 2 - Removing Descriptions of System Operation 3 - Removing Procedural Details for Meeting TS Requirements and Related Reporting 4 - Removing Performance Requirements for Indication-Only Instrumentation and Alarms 5 - Removal of Cycle-Specific Parameter Limits fiom the Technical Specifications to the Core Operating Limits Report North Anna Power Station Page 7 of 17 R -3.3

Table R - Relocated Specifications and Removed Details ITS Section 3.3 - Instrumentation CTS Change Control Change DOC No. Requirement Description of Relocated Requirements Location Process Category 3.3.2 LA.2 Table 4.3-2 CTS Table 4.3-2 specifies a requirement to perform a CHANNEL Bases ITS 5.5.13, 1 NOTE (2) FUNCTIONAL TEST for the automatic actuation logic on various Technical ESF functions on a monthly basis. The frequency (M) is modified Specifications by notation (2) which states, "Each train or logic channel shall be Bases Control functionally tested at least every other 31 days up to and including Program input coil continuity testing to the ESF slave relays." ITS SRs 3.3.2.2 and 3.3.2.3 require the performance of the ACTUATION LOGIC TEST and the MASTER RELAY TEST every 31 days on a STAGGERED TEST BASIS. This changes the CTS by moving the requirement that the testing include input coil continuity testing to the ESF slave relays fiom the TS to the ITS Bases.

3.3.2 LA.3 I Table 3.3-4 CTS LCO 3.3.2.1 in Table 3.3-4, item 6.c, for the Allowable Bases ITS 5.5.13, I Values requirement contains information relating to the Steam Technical Generator (SG) Water Level - Low Low trip. The requirement Specifications states that the Allowable Value is associated with the narrow Bases Control range instrumentation span for each SG. ITS Table 3.3.2-1 (item Program 6.c) lists the requirements for the SG Water Level - Low Low Allowable Value but does not contain the information about the narrow range instrumentation span. This changes the CTS by moving the information about the narrow range instrumentation span from the TS to the ITS Bases.

3.3.2 LA.4 Table 3.3-3 CTS LCO 3.3.2.1 in Table 3.3-3 for the ESFAS interlocks P-I I Bases ITS 5.5.13, and P-12 contains information in the Condition and Function Technical sections which describes how the interlocks function. ITS Table Specifications 3.3.2-I lists the functions and the necessary requirements to Bases Control ensure OPERABILITY. This changes the CTS by moving the Program description about how the interlocks function firom the TS to the ITS Bases.

Change Category:

I - Removing Details of System Design and System Description, Including Design Limits 2 - Removing Descriptions of System Operation 3 - Removing Procedural Details for Meeting TS Requirements and Related Reporting 4 - Removing Performance Requirements for Indication-Only Instrumentation and Alarms 5 - Removal of Cycle-Specific Parameter Limits from the Technical Specifications to the Core Operating Limits Report North Anna Power Station Page 8 of 17 R -3.3

Table R - Relocated Specifications and Removed Details ITS Section 3.3 - Instrumentation CIS Change Control Change DOC No. Requirement Description of Relocated Requirements Location Process Category 3.3.2 LA.5 Table 3.3-4 CTS LCO 3.3.2.1 in Table 3.3-4 for the ESFAS instrumentation Bases ITS 5.5.13, 1 trip setpoints contains information describing the bus that is Technical monitored to detect a station blackout. ITS Table 3.3.2-1 does not Specifications contain this information. This changes the CTS by moving the Bases Control information describing the bus that is monitored to detect a station Program blackout firom the TS to the ITS Bases.

3.3.2 LA.6 Table 4.3-2 Note 3 of CTS 3.3.2.1 ITable 4.3-2 for the ESFAS containment Bases ITS 5.5.13, 3 Note 3 pressure instrumentation surveillance requirement states that the Technical CHANNEL FUNCTIONAL TEST shall include exercising the Specifications transmitter by applying either a vacuum or pressure to the Bases Control appropriate side of the transmitter. ITS Table 3.3.2-I for the Program testing of Containment pressure requires SR 3.3.2.4 to be performed. This changes the CTS by moving the information on how to conduct the SR from the TS to the ITS Bases.

3.3.2 LA.7 Table 3.3-4 CTS LCO 3.3.2.1 in Table 3.3-4 item 5.a for the Allowable Value Bases ITS 5.5.13, requirement contains information relating to the Steam Generator Technical (SG) Water Level - High High trip. This states that the Allowable Specifications Values are associated with the narrow range instrumentation span Bases Control for each SG. ITS Table 3.3.2-I (item 5.a) lists the requirements Program for the SG Water Level - High I lgh Allowable Values but does not contain the information about the narrow range instrumentation span. This changes the CI'S by moving the information about the narrow range instrumnentation span from the TS to the ITS Bases Change Category:

I - Removing Details of System Design and System Description, Including Design Limits 2 - Removing Descriptions of System Operation 3 - Removing Procedural Details for Meeting TS Requirements and Related Reporting 4 - Removing Performance Requirements for Indication-Only Instrumentation and Alarns 5 - Removal of Cycle-Specific Parameter Limits firom the Technical Specifications to the Core Operating Limits Report North Anna Power Station Page 9 of 17 R -3.3

Table R- Relocated Specifications and Removed Details ITS Section 3.3 - Instrumentation CTS Change Control Change DOC No. Requirement Description of Relocated Requirements Location Process Category 3.3.2 LA.8 Table 3.3 - 3 CTS requirement listed in Table 3.3 - 3, for each ESFAS interlock Technical 10 CFR 50.59 3 function, an Allowable Value and a Setpoint column. ITS Table Requirements 3.3.2-1 includes only an Allowable Value column. This changes Manual the CTS by moving the pressure setpoint setting from the TS to the Technical Requirements Manual (TRM).

3.3.2 LA.9 4.3.2.1.2 Not used. Bases ITS 5.5.13, 3 Technical Specifications Bases Control Program 3.3.2 LA.l10 Table 3.3-3 CTS Action 22 for Table 3.3-3 requires for applicable Bases ITS 5.5.13, 3 Action 22 instrumentation channels that, "With less than the Minimum Technical Channels OPERABLE, within one hour determine by observation Specifications of the associated permissive annunciator window(s) that the Bases Control interlock is in its required state for the existing plant condition." Program ITS 3.3.2 in Table 3.3.2-1 for Action J requires, "One or more channels inoperable, verify interlock is in required state for existing unit condition within one hour." The allowance provided by "determine by observation of the associated permissive annunciator window(s)" is not included in the ITS. This changes the CTS by moving the information for how to conduct the required testing from the TS to the ITS Bases.

Change Category:

I - Removing Details of System Design and System Description, Including Design Limits 2 - Removing Descriptions of System Operation 3 - Removing Procedural Details for Meeting TS Recuirements and Related Reporting 4 - Removing Performance Requirements for Indication-Only Instrumentation and Alarms 5 - Removal of Cycle-Specific Parameter Limits firom the Technical Specifications to the Core Operating Limits Report North Anna Power Station Page 10 of 17 R -3.3

Table R - Relocated Specifications and Removed Details ITS Section 3.3 - Instrumentation Change Control Change CTS Description of Relocated Requirements Location Process Category DOC No. Requirement CTS requirements in 'Fable 3.3-3 for function 2.a, Containment Bases ITS 5.5.13, 3.3.2 LA.] I Table 3.3-3 Spray Manual, lists the total number of channels as 2 sets 2 Technical switches/set. ITS 3.3.2 'Fable 3.3.2-1 for function 2.a, Specifications Containment Spray Manual Actuation, states the channel Bases Control requirements as 2 per train/2 trains. This changes the CTS by Program moving the channel information friom the TS to the ITS Bases.

Table 3.3-3 CTS Table 3.3-3 for Engineered Safety Feature Actuation System UFSAR 10 CFR 50.59 3.3.2 LA.12 Instrumentation has three columns stating various requirements for each function. These columns are labeled, "TOTAL NO. OF CHANNELS," "CHANNELS TO TRIP," and "MINIMUM CHANNELS OPERABLE." ITS Table 3.3.2-1 states the channel requirement for each ESFAS function as, "REQUIRED CHANNELS." This changes the CTS by stating all of the channel requirements for each function as the required channels and moving the information of the number of channels to trip and the minimum channels needed to maintain the function OPERABLE to the UFSAR.

CTS LCO 3.6.4.1 states two independent containment hydrogen Technical 10 CFR 50.59 3.3.3 LA.I LCO 3.6.4.1 NOTE, analyzers (shared with the other unit) shall be OPERABLE. Notes Requirements 4.6.4.1 to CTS 3.6.4.1 Actions and Surveillance Requirement 4.6 4.1 Manual NOTE requires the OPERABILITY of the hydrogen analyzers to include the OPERABILITY of the associated heat tracing system. ITS 3.3.3 PAM Instrumentation requires two channels of hydrogen analyzers to be OPERABLE. This change moves CTS information regarding the hydrogen analyzer heat tracing system firom the TS to the Technical Requirements Manual.

Change Category:

I - Removing Details of System Design and System Description, Including Design Limits 2 - Removing Descriptions of System Operation 3 - Removing Procedural Details for Meeting TS Requirements and Related Reporting 4 - Removing Performance Requirements for Indication-Only Instrumentation and Alarms 5 - Removal of Cycle-Specific Parameter Limits from the Technical Specifications to the Core Operating Limits Report PageIIof 17 R-3.3 North Anna Power Station

Table R - Relocated Specifications and Removed Details ITS Section 3.3 - Instrumentation CIS Change Control Change DOC No. Requirement Description of Relocated Requirements Location Process Category 3.3.3 LA.2 4.6.4.1 CTS SR 4.6.4.1 states each hydrogen analyzer shall be Bases ITS 5.5.13, 3 demonstrated OPERABLE by performing a C14ANNEL Technical CALIBRATION using a sample gas containing a specified gas Specifications concentration for hydrogen mixed with nitrogen. ITS SR 3.3.3.2 Bases Control requires the hydrogen analyzers have a CHANNEL Program CALIBRATION. This change moves the CTS sample gas requirements to the ITS Bases.

3.3.3 LA.3 LCO 3.6.4.1 CTS LCO 3.6.4.1 states two independent containment hydrogen Bases ITS 5.5.13, analyzers (shared with the other unit) shall be OPERABLE. ITS Technical 3.3.3 PAM Instrumentation requires two channels of hydrogen Specifications analyzers to be OPERABLE. This change moves CTS Bases Control information regarding the hydrogen analyzer being shared Program between units firom the lTS to the ITS Bases.

3.3.3 LA.4 Table 3.3-6 CTS Table 3.3-6 Radiation Monitoring Instrumentation lists the Technical 10 CFR 50.59 alarm/trip setpoint and measurement range for the HIigh Range Requirements Area Monitors. ITS 3.3.3 PAM Instrumentation requires two Manual channels of IHigh Range Area monitors but does not state the measuring range or alarm/trip setpoint. This change moves the measurement range and alarm/trip setpoint firom the TS to the Technical Requirements Manual (TRM).

ChangeCategory:

I - Removing Details of System Design and System Description, Including Design Limits 2 - Removing Descriptions of System Operation 3 - Removing Procedural Details for Meeting TS Requiremients and Related Reporting 4 - Removing Performance Requirements for Indication-Only Instrumentation and Alarms 5 - Removal of Cycle-Specific Parameter Limits from the Technical Specifications to the Core Operating Limits Report North Anna Power Station Page 12 of 17 R-3.3

Table R- Relocated Specifications and Removed Details ITS Section 3.3 - Instrumentation GuS Change Control Change DOC No. Requirement Description of Relocated Requirements Location Process Category 3.3.4 LA. I Table 3.3-9 CTS 3.3.3.5 LCO states that the auxiliary shutdown monitoring UFSAR 10 CFR 50.59 instrumentation channels in Table 3.3-9 shall be OPERABLE with readouts displayed external to the control room. CTS requirement in TFable 3.3-9 lists the measuring range for each required channel and the location of the auxiliary shutdown panel where the instrumentation channel is remotely displayed. ITS LCO 3.3.4 states that the Remote Shutdown Instrumentation Functions shall be OPERABLE. This changes the CTS by moving the requirement for readouts displayed external to the control room, the location of the remote readouts (auxiliary shutdown panel) and the instrument channel ranges from the TS to the UFSAR.

3.3.4 LA.2 Table 3.3-9, CTS 3.3.3.5 states that the auxiliary shutdown monitoring Bases ITS 5.5.13, "Fable 4.3-6 instrumentation in Table 3.3-9 shall be OPERABLE. CTS TFable Technical 4.3-6 lists the Surveillance Requirements for the functions in Specifications Table 3.3-9. ITS LCO 3.3.4 states that the Remote Shutdown Bases Control Instrumentation Functions shall be OPERABLE. This changes Program the CTS by moving the list of monitoring equipment Tables 3.3-9 and 4.3-6 from the TS to the ITS Bases.

3.3.5 LA. I 3.3.2.1 CTS 3.3.2.1 Action a requires that with an ESFAS instrumentation Bases ITS 5.5.13, 3 Action a channel trip setpoint found less conservative than the value shown Technical in the Allowable Values column of Table 3.3-4, the channel be Specifications declared inoperable and Action a be entered. ITS 3.3.5 LCO Bases Control requires three channels per function to be OPERABLE and Action Program A requires an inoperable channel to be placed in trip within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. This changes the CTS by moving the discussion of the relationship between the Allowable Value and OPERABILITY from the Technical Specification to the Background section' of the Bases.

Change Category:

I - Removing Details of System Design and System Description, Including Design Limits 2 - Removing Descriptions of System Operation 3 - Removing Procedural Details for Meeting TS Requirements and Related Reporting 4 - Removing Performance Requirements for Indication-Only Instrumentation and Alarms 5 - Removal of Cycle-Specific Parameter Limits from tile Technical Specifications to the Core Operating Lim-nits Report North Anna Power Station Page 13 of 17 R-3.3

Table R - Relocated Specifications and Removed Details ITS Section 3.3 - Instrumentation CTS Change Control Change DOC No. Requirement Description of Relocated Requirements Location Process Category 3.3.5 LA.2 Table 3.3-4, CTS Table 3.3-4 finctional unit 7, Loss of Power, lists the Trip Technical 10 CFR 50.59 3 3.3.2.1 LCO, Setpoints for the undervoltage and degraded voltage on the 4160- Requirements Action a volt emergency bus. CTS 3.3.2.1 LCO and Action a state that the Manual instrumentation channels' trip setpoints will be set, "consistent with the Trip Setpoint values." ITS 3.3.5 LCO and Actions do not contain these requirements. This changes the CTS by moving the Trip Setpoints and the trip setpoint adjustment, "consistent with the Trip Setpoint value," and details for establishing process settings from the Technical Specifications to the Technical Requirements Manual (TRM).

3.3.5 LA.3 Table 4.3-2 CTS Table 4.3-2 requires a quarterly (Q) CHANNEL Bases -TIS 5.5.13, 3 NOTE (5) FUNCTIONAL TEST (CFT) of the Loss of Power function. The Technical Surveillance Requirement is modified by Note (5), which states, Specifications "Each train or logic channel shall be functionally tested up to and Bases Control including input coil continuity testing to the ESF relays." ITS SR Program 3.3.5.1 requires a TADOT to be performed every 92 days. The ITS does not contain the requirements of Note 5. This changes the CTS by moving the components tested by TADOT described in Note 5 to the Bases.

3.3.5 LA.4 4.3.2.1.2 Not used. Bases ITS 5.5.13,3 Technical Specifications Bases Control Program Change Category:

I - Removing Details of System Design and System Description, Including Design Limits 2 - Removing Descriptions of System Operation 3 - Removing Procedural Details for Meeting TS Requirements and Related Reporting 4 - Removing Performance Requirements for Indication-Only Instrumentation and Alarms 5 - Removal of Cycle-Specific Parameter Limits from the Technical Specifications to the Core Operating Limits Report North Anna Power Station Page 14 of 17 R-3.3

Table R- Relocated Specifications and Removed Details ITS Section 3.3 - Instrumentation CTS Change Control Change DOC No. Requirement Description of Relocated Requirements Location Process Category 3.3.5 LA.5 Table 3.3-3 CTS Table 3.3-3 for Engineered Safety Feature Actuation System UFSAR 10 CFR 50.59 (ESFAS) instrumentation has three colunmns stating various requirements for each function. These columns are labeled, "TOTAL, NO. OF CHANNELS," "CHANNELS TO TRIP," and "MINIMUM CHANNELS OPERABI,E." ITS Table 3.3.2-1 states the channel requirement for each ESFAS function as, "REQUIRED CHANNELS." This changes the CTS by stating all of the channel requirements for each function as the required channels and moving the information of the number of channels to trip and the minimum channels needed to maintain the function OPERABLE to the UFSAR.

R. I CTS 3.3.3.1 CT'S 3.3.3.1 states the radiation monitoring instrumentation Technical 10 CFR 50.59 N/A 3.3.3.1 channels shown in Table 3.3-6 shall be OPERABLE with their Requirements alarm/trip setpoints within the specified limits. Portions of the Manual Radiation Monitoring Instrumentation specification, as shown in the CTS markup, are addressed in ITS 3.4.15, RCS Leakage Detection Instrumentation, and ITS 3.3.3, Post Accident Monitoring (PAM) Instrumentation. Those portions are not addressed in this change. The Radiation Monitoring Instrumentation monitors radiation levels in selected plant locations and indicates abnormal or unusually high radiation levels. The radiation monitors are not assumed in the accident analyses to provide signals to prevent initiation of a DBA or transient or to mitigate a DBA or transient. The area radiation monitors do not meet the criteria for retention in the TS; therefore, it will be relocated to the Technical Requirements Manual.

Change Category:

I - Removing Details of System Design and System Description, Including Design Limits 2 - Removing Descriptions of System Operation 3 - Removing Procedural Details for Meeting I'S Requirements and Related Reporting 4 - Removing Performance Requirements for Indication-Only Instrumentation and Alarms 5 - Removal of Cycle-Specific Parameter Limits from the Technical Specifications to the Core Operating Limits Report Page 15 of 17 R-3.3 North Anna Power Station

Table R - Relocated Specifications and Removed Details ITS Section 3.3 - Instrumentation CTS Change Control Change DOC No. Requirement Description of Relocated Requirements Location Process Category 3.3.3.2 R.1 CTS 3.3.3.2 CTS 3.3.3.2 provides requirements onl the Movable Incore Technical 10 CFR 50.59 N/A Detector Instrumentation when required to monitor the flux Requirements distribution within the core. The Movable Incore Detector System Manual is used for periodic surveillance of the power distribution, and for calibration of the excore detectors. The Movable Incore Detector Instrumentation do not meet the criteria for retention in the ITS; therefore, it will be relocated to the Technical Requirements Manual, 3.3.3.3 R. I CTS 3.3.3.3 CTS 3.3.3.3 for Unit Istates the Seismic Monitoring Technical 10 CFR 50.59 N/A Instrumentation shown in Table 3.3-7 shall be OPERABLE. The Requirements Seismic Monitoring Instrumentation is used to record data for use Manual in evaluating the effect of a seismic event. The Seismic Monitoring Instrumentation is not used to mitigate a DBA or transient. The Seismic Monitoring Instrumentation do not meet the criteria for retention in the ITS; therefore, it will be relocated to the Technical Requirements Manual.

3.3.3.4 R.I CTS 3.3.3.4 CTS 3.3.3.4 for Unit Istates the Meteorological Monitoring Technical 10 CFR 50.59 N/A Instrumentation shown in Tables 3.3-8 and 4.3-5 shall be Requirements OPERABLE. The Meteorological Monitoring Instrumentation is Manual used to record meteorological data for use in evaluating the effect of an accidental radioactive release from the plant. The Meteorological Monitoring Instrumentation is not used to mitigate a DBA or transient. The Meteorological Monitoring Instrumentation do not meet the criteria for retention in the ITS; therefore, it will be relocated to the Technical Requirements Manual.

Change Category:

I - Removing Details of System Design and System Description, Including Design Limits 2 - Removing Descriptions of System Operation 3 - Removing Procedural Details for Meeting TS Requirements and Related Reporting 4 - Removing Performance Requirements for Indication-Only Instrumentation and Alarms 5 - Removal of Cycle-Specific Parameter Limits from the Technical Specifications to the Core Operating Limits Report North Anna Power Station Page 16 of 17 R-3.3

Table R - Relocated Specifications and Removed Details ITS Section 3.3 - Instrumentation CTS Change Control Change DOC No. Requirement Description of Relocated Requirements Location Process Category 3.3.3.9 R.l CTS 3.3.3.9 Unit I CTS 3.3.3.9 requires the OPERABILITY of the loose parts Technical 10 CFR 50.59 N/A detection instrumentation which can detect loose metallic parts in Requirements the Reactor Coolant System in order to avoid damage to the Manual Reactor Coolant System components. The Unit 2 Technical Specifications do not contain this Specification. The loose parts detection instrumentation do not meet the criteria for retention in the ITS; therefore, it will be relocated to the Technical Requirements Manual.

3.3.3. 11 R.I CTS 3.3.3.1 I CTS 3.3.3.11 requires the Explosive Gas Monitoring Technical 10 CFR 50.59 N/A Instrumentation be OPERABLE. The Explosive Gas Monitoring Requirements Instrumentation is used to ensure that the oxygen limits of the Manual Waste Gas Holdup System are not exceeded. Tihe oxygen concentration limit in the Waste Gas I loldup Tank ensures that the concentration of potentially explosive gas mixtures in the Waste Gas Holdup Systivm is maintained below the flammability limits.

This instrumentation is not credited in preventing or mitigating any DBA or transient as the safety analysis concerning the Waste Gas Holdup System assumes a storage tank rupture with no mitigation. The Explosive Gas Monitoring Instrumentation dos not meet the criteria for retention in the ITS; therefore, it will be relocated to the Technical Requirements Manual (TRM).

Change Category:

I - Removing Details of System Design and System Description, Including Design Limits 2 - Removing Descriptions of System Operation 3 - Removing Procedural Details for Meeting TS Requirements and Related Reporting 4 - Removing Performance Requirements for Indication-Only Instrumentation and Alarms 5 - Removal of Cycle-Specific Parameter Limits from the Technical Specifications to the Core Operating Limits Report R-3.3 North Anna Power Station Page 17 of 17

Table R- Relocated Specifications and Removed Details ITS Section 3.4 - Reactor Coolant System (RCS)

CTS Change Control Change DOC No. Requirement Description of Relocated Requirements Location Process Category 3.4.1 LA.1 3.2.5 CTS 3.2,5 places limits on RCS 'F,,,,, pressurizer pressure, and COLR ITS 5.6.5, Core 5 RCS total flow rate. ITS 3.4.1 states that tihe limits on RCS T,,,g, Operating Limits pressurizer pressure, and RCS total flow rate shall not exceed the Report limits specified in the COLR or the minimum RCS flow rate specified in the LCO. This changes the CTS by relocating the cycle specific values of RCS T,,, pressurizer pressure, and RCS total flow rate to the COLR.

3.4.2 None N/A N/A N/A N/A N/A 3.4.3 LA. 1 3.4.9.1 CTS 3.4.9.1 states that the RCS (except the pressurizer) Bases ITS 5.5.13, I temperature and pressure shall be limited. The LCO also contains Technical limits on RCS heatup and cooldown rates. ITS 3.4.3 states that Specifications the RCS pressure, temperature, and RCS heatup and cooldown Bases Control rates shall be maintained within limits. This changes the CTS by Program moving the exclusion of the pressurizer f'rom tile LCO to the Bases.

Change Categoriy._

I - Removing Details of System Design and System Description, Including Design Limits 2 - Removing Descriptions of System Operation 3 - Removing Procedural Details for Meeting 'TS Requirements and Related Reporting 4 - Removing Performance Requirements for Indication-Only Instrumentation and Alarms 5 - Removal of Cycle-Specific Parameter Limits from the Technical Specifications to the Core Operating Limits Report North Anna Power Station Page I of I11 R -3.4

Table R- Relocated Specifications and Removed Details ITS Section 3.4 - Reactor Coolant System (RCS)

CTS Change Control Change DOC No. Requirement Description of Relocated Requirements Location Process Category 3.4.9.1 CTS 3.4.9.1 Action states that with any of the P/T limits exceeded, Bases ITS 5.5.13, 3 3.4.3 LA.2 restore tile temperature and/or pressure to within the limit within Technical 30 minutes; perform an engineering evaluation to determine the Specifications effects of the out-of limit condition on the structural integrity of Bases Control the RCS; determine that the RCS remains acceptable for continued Program operations or be in at least hot standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and reduce the RCS T,,g and pressure to less than 200'F and 500 psig, respectively, within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. ITS 3.4.3, Conditions A and C state that with the requirements of the LCO not met, restore the parameter(s) to within limit(s) and determine tile RCS is acceptable for continued operation. This changes the CTS by moving the requirement to perform an engineering evaluation to determine the effects of the out-of limit condition on the structural integrity of the RCS to the Bases.

I CTS Surveillance 4.4. 1. I states that the required reactor coolant Bases ITS 5.5.13, 3 loops shall be verified to be in operation and circulating reactor Technical coolant at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. ITS SR 3.4.4.1 states that each Specifications reactor coolant loop shall be verified to be in operation every 12 Bases Control hours. This changes the CTS by moving the Surveillance Program requirement to verify that the reactor coolant loops are circulating reactor coolant to the Bases.

CTS 3.4.1.2 states that two reactor coolant loops shall be Bases ITS 5.5.13, OPERABLE and contains a description of what constitutes an Technical OPERABLE loop. ITS 3.4.5 requires two RCS loops to be Specifications OPERABLE. This changes the CTS by moving the details of Bases Control what constitutes an OPERABLE loop to the Bases. Program Change Category I - Removing Details of System Design and System Description, Including Design Limits 2 - Removing Descriptions of System Operation 3 - Removing Procedural Details for Meeting 'I'S Requirements and Related Reporting 4 - Removing Performance Requirements for Indication-Only Instrumentation and Alarms 5 - Removal of Cycle-Specific Parameter Limits from the Technical Specifications to the Core Operating Limits Report North Anna Power Station Page 2 of I11 R- 3.4

"Fable R - Relocated Specifications and Removed Details ITS Section 3.4 - Reactor Coolant System (RCS)

CTS DOC No. Requirement Description of Relocated Requirements 3.4.5 LA.2 4.4.1.2.2 CTS Surveillance 4.4.1.2.2 states that at least one required reactor coolant loop shall be verified to be in operation and circulating reactor coolant at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. ITS SR 3.4.5.1 states that the required reactor coolant loop shall be verified to be in operation every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. This changes the CTS by moving the requirement to verify that the reactor coolant loops are circulating reactor coolant to the Bases.

3.4.6 LA. I 3.4.1.3.a CTS 3.4.1.3 states that two coolant loops consisting of any combination of RCS loops and RHR loops shall be OPERABLE and contains a description of what constitutes an OPERABL.E Reactor Coolant loop and Residual Heat Removal loop. ITS 3.4.5 requires two loops consisting of any combination of RCS loops and RI IR loops to be OPERABLE. This changes the CTS by moving the details of what constitutes an OPERABLE loop to the Bases.

3.4.6 LA.2 4.4.1.3.4 CTS Surveillance 4.4.1.3.4 states that at least one Reactor Coolant pump or RIHR loop shall be verified to be in operation and circulating reactor coolant at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. ITS SR 3.4.6.1 states that an RHR or RCS loop shall be verified to be in operation every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. This changes the CTS by moving the requirement to verify that the coolant loop is circulating reactor coolant to the Bases. Other changes to CTS Surveillance 4.4.1.3.4 are described in LA.3.

Change Caitegory:.

I - Removing Details of System Design and System Description, hicluding Design Limits 2 - Removing Descriptions of System Operation 3 - Removing Procedural Details for Meeting TS Requirements and Related Reporting 4 - Removing Performance Requirements for Indication-Only Instrumentation and Alarms 5 - Removal of Cycle-Specific Parameter Limits from the Technical Specifications to the Core Operating Limits Report North Anna Power Station Page 3 of I11 R- 3.4

Table R - Relocated Specifications and Removed Details ITS Section 3.4 - Reactor Coolant System (RCS)

Change Control Change CTS Description of Relocated Requirements Location Process Category DOC No. Requirement 3.4.6 LA.3 4.4.1.3.4.b CTS Surveillance 4.4.1.3.4 states that at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> it Technical 10 CFR 50.59 Requirements must be verified that at least one coolant loop is in operation and Manual circulating reactor coolant by verifying at least one RCP is in operation or at least one RIIR loop is in operation. It goes on to provide minimum RHR flow rates dependent on RCS temperature or time since entry into MODE 3. ITS Surveillance 3.4.6.1 requires verification that one R1HR or RCS loop is in operation every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. This changes the CTS by moving the RtIR minimum flow requirements to the Technical Requirements Manual.

4 CTS Surveillance 4.4.1.3. states that at least one Reactor Coolant Bases "ITS 5.5.13, 3.4.7 LA.l1 4.4.1.3.4 pump or RHIR loop shall be verified to be in operation and Technical circulating reactor coolant at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. ITS SR Specifications 3.4.7.1 states that anl RHR loop shall be verified to be in operation Bases Control every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. This changes thle CTS by moving the requirement Program to verify that the RI-IR loop is circulating reactor coolant to the Bases. Other related changes are described in LA.3 and L. I.

4.4.1.3.4.b CTS Surveillance 4.4.1.3.4.b states that at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Technical 10 CFR 50.59 3.4.7 LA.2 it must be verified that one RHIR loop is in operation. It goes on Requirements to provide minimum RIIR flow rates dependent on RCS Manual temperature or time since entry into MODE 3. ITS Surveillance 3.4.7.1 requires verification that one RHR loop is in operation every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. This changes the CTS by moving the RttR minimum flow requirements to the Technical Requirements Manual.

Change Category:

I - Removing Details of System Design and System Description, Including Design Limits 2 - Removing Descriptions of System Operation 3 - Removing Procedural Details for Meeting TS Requirements and Related Reporting 4 - Removing Performance Requirements for Indication-Only Instrumentation and Alarms 5 - Removal of Cycle-Specific Parameter Limits from the Technical Specifications to the Core Operating Limits Report Page 4 of I11 R - 3.4 North Anna Power Station

Table R - Relocated Specifications and Removed Details ITS Section 3.4 - Reactor Coolant System (RCS)

CTS Change Control Change DOC No. Requirement Description of Relocated Requirements Location Process Category 3.4.8 LA. 1 4.4.1.3.4 CTS Surveillance 4.4.1.3.4 states that at least one Reactor Coolant Bases ITS 5.5.13, 3 pump or RUtR loop shall be verified to be in operation and Technical circulating reactor coolant at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. ITS SR Specifications 3.4.8.1 states that a required RVIR loop shall be verified to be in Bases Control operation every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. This changes the CTS by moving the Program requirement to verify that the RHIR loop is circulating reactor coolant to the Bases. Other related changes are described in LA.2 and A.2.

3.4.8 LA.2 4.4.1.3.4.b CTS Surveillance 4.4.1.3.4.b states that at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Technical 10 CFR 50.59 3 it must be verified that one R[IR loop is in operation. It goes on Requirements to provide minimum RHR flow rates dependent on RCS Manual temperature or time since entry into MODE 3. ITS Surveillance 3.4.8.1 requires verification that one RHR loop is in operation every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. This changes the CTS by moving the RHR mininmm flow requirements to (he Teclmical Requirements Manual.

3.4.9 None N/A N/A N/A N/A N/A 3.4.10 LA. I 3.4.3.1 and CTS LCO 3.4.3.1 and LCO 3.4.2 are modified by a note that Bases ITS 5.5.13, 3 3.4.2 states that the pressurizer lift setting pressure shall correspond to Technical ambient conditions of the valve at nominal ternperature and Specifications pressure. The ITS does not contain this information and it is Bases Control moved to the ITS Bases. Program Change Category" I Removing Details of System Design and System Description, Including Design Limits 2 - Removing Descriptions of System Operation 3 - Removing Procedural Details for Meeting TS Requirements and Related Reporting 4 - Removing Performance Requirements for Indication-Only Instrumentation and Alarms 5 - Removal of Cycle-Specific Parameter Limits fi'om the Technical Specifications to the Core Operating Limits Report North Anna Power Station Page 5 of I11 R -3.4

Table R - Relocated Specifications and Removed Details ITS Section 3.4 - Reactor Coolant System (RCS)

CTS Change Control Change DOC No. Requirement Description of Relocated Requirements Location Process Category 3.4.11 LA. I 4.4.3.2.1 .b. 1 CTS 4.4.3.2. l.b. I states that at least once per 18 months each Bases ITS 5.5.13, 3 PORV must be operated through one complete cycle of full travel Technical during MODES 3 and 4. ITS SR 3.4. 11.3 states that a complete Specifications cycle of each PORV must be made at a Frequency of 18 nmonths. Bases Control This changes the CTS by relocating the requirement to perform Program the testing in MODES 3 and 4 to the Bases.

3.4.12 LA.I 3.4.9.3 CTS 3.4.9.3, Action d, states that when tile RCS is vented, the Bases ITS 5.5.13, 2 Action d vent pathway must be verified at least once per 3 1 days when the Technical pathway is provided by a valve(s) that is locked, sealed, or Specifications otherwise secured in the open position; otherwise, the vent Bases Control Program pathway must be verified every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. ITS SR 3.4.12.4 states that an RCS vent must be verified open every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for unlocked open vent valve(s) and every 31 days for other vent paths. This changes the CTS by moving the detail that a vent valve may be considered locked open if it is sealed or otherwise secured in position to the Bases.

3.4.13 LA. I 3.4.5 CTS 3.4.5 states, "Each steam generator in a non-isolated reactor Bases ITS 5.5.13, coolant loop shall be OPERABLE." The ITS does not contain a Technical similar requirement. However, the Bases for the RCS loop Specifications specifications which require one or more steam generators, Bases Control Specifications 3.4.4, 3.4.5, 3.4.6, and 3.4.7, define an Program OPERABLE steam generator as one which is OPERABLE in accordance with the Steam Generator Tube Surveillance Program.

This changes the CTS by moving the definition of an OPERABLE steam generator to the ITS Bases.

Change Category:

I - Removing Details of System Design and System Description, Including Design tLimits 2 - Removing Descriptions of System Operation 3 - Removing Procedural Details for Meeting TS Requirements and Related Reporting 4 - Removing Performance Requirements for Indication-Only Instrumentation and Alarms 5 - Removal of Cycle-Specific Parameter Limits from the Technical Specifications to the Core Operating Limits Report North Anna Power Station Page 6 of I11 R - 3.4

Table R - Relocated Specifications and Removed Details ITS Section 3.4 - Reactor Coolant System (RCS)

CTS Change Control Change Requirement Description of Relocated Requirements Location Process Category DOC No.

LA.lI 3.4.6.2.f and CTS 3.4.6.2 contains a list of the RCS PlVs and their associated Bases ITS 5.5.13, 3.4.14 leakage limits. ITS 3.4.14 does notincontain a list of the RCS PlVs Technical Table 3.4.1 and the leakage limits are located SR 3.4.14. 1. This changes Specifications the CTS by relocating the list of PlVs to the Bases. Bases Control Program Unit I CTS 4.4.6.2.2 is modified by a footnote that states that, to Bases ITS 5.5.13, 3 3.4.14 LA.2 4.4.6.2.2 satisfy ALARA requirements, leakage may be measured indirectly Technical (as firom the performance of pressure indicators) if accomplished Specifications in accordance with approved procedures and supported by Bases Control computations showing that the method is capable of Program demonstrating valve compliance with the leakage criteria. ITS SR 3.4.14.1 does not contain this information. This changes the CTS by moving this information on how the Surveillance may be performed to the Bases.

3.4.15 LA. I Table 3.3-6 CTS 3.3.3.1 Table 3.3-6 includes Measurement Ranges for the UI7SAR 10 CFR 50.59 1 RCS Leakage Detection instrumentation. ITS does not include these details. This changes the CTS by moving these details to the UFSAR.

N/A N/A N/A N/A N/A 3.4.16 None N/A N/A N/A N/A N/A 3.4.17 None N/A N/A N/A N/A N/A 3.4.18 None N/A N/A N/A N/A N/A 3.4.19 None Change Category:

I - Removing Details of System Design and System Description, Including Design Limits 2 - Removing Descriptions of System Operation 3 - Removing Procedural Details for Meeting TS Requirements and Related Reporting 4 - Removing Performance Requirements for Indication-Only Instrumentation and Alarms 5 - Removal of Cycle-Specific Parameter Limits from the Technical Specifications to the Core Operating Limits Report Page 7 of I11 R- 3.4 North Anna Power Station

"Fable R - Relocated Specifications and Removed Details ITS Section 3.4 - Reactor Coolant System (RCS)

CTS Change Control Change DOC No. Requirement Description of Relocated Requirements Location Process Category CTS 3.4.6.3 3.4.6.3 CTS 3.4.6.3 provides limits on primary to secondary leakage in Technical 10 CFR 50.59 R R.lI addition to the limits in CTS 3.4.6.2 and ITS 3.4.13. These Requirements additional limits lower the amount of allowed primary to Manual secondary leakage when the reactor is operating above 50% power and were implemented to reduce the probability of a steam generator tube rupture following the Unit 1 steam generator tube rupture event at North Anna Unit I on July 15, 1987. The CTS 3.4.6.2 leakage limits were continued to be used in tile accident analysis, not the addition limits in CTS 3.4.6.3. The North Anna Units I and 2 steam generators have been replaced with models that are not susceptible to the fatigue induced cracks which resulted in the tube rupture. As a result, these additional limits are not needed to lower the probability of a steam generator tube rupture. This LCO does not meet the criteria for retention in the ITS; therefore, it will be retained in the Technical Requirements Manual.

Change Category:

I - Removing Details of System Design and System Description, Including Design Limits 2 - Removing Descriptions of System Operation 3 - Removing Procedural Details for Meeting TS Requirements and Related Reporting 4 - Removing Performance Requirements for Indication-Only Instrumentation and Alarms 5 - Removal of Cycle-Specific Parameter Limits from the Technical Specifications to the Core Operating Limits Report R-3.4 North Anna Power Station Page 8 of 11

Table R - Relocated Specifications and Removed Details ITS Section 3.4 - Reactor Coolant System (RCS)

II Change Control Change

_ _ _ _ _ _ T Category CTS Process Description of Relocated Requirements Location DOC No. Requirement Technical 10 CFR 50.59 CTS 3.4.6.4 3.4.6.4 CTS 3.4.6.4 states requirements on primary to secondary leakage Requirements R.I detection systems. These leakage detection systems are in Manual addition to those systems required by CTS 3.4.6.1 and ITS 3.4.15 and were installed to monitor the stringent primary to secondary leakage limits in CTS 3.4.6.3. These additional primary to secondary leakage detection systems were added to the Technical Specifications following the Unit I steam generator tube rupture (SGTR) event at North Anna Unit I on July 15, 1987.

Subsequently, the North Anna Units 1 and 2 steam generators have been replaced and steam generator primary to secondary leakage is insignificant. As a result, the requirements in ITS 3.4.15 are sufficient to indicate significant abnormal RCS leakage.

This LCO does not meet thie criteria for retention in the ITS; therefore, it will be retained in the Technical Requirements Manual.

Technical 10 CFR 50.59 CTS3.4.7 j3.4.7 CTS 3.4.7 provides limits on the oxygen, chloride and fluoride Requirements R.I content in the RCS to minimize corrosion. Minimizing corrosion Manual of the RCS will reduce tile potential for RCS leakage or failure due to stress corrosion, and ultimately ensure the structural integrity of the RCS. This LCO does not meet the criteria for retention in the ITS; therefore, it will be retained in the Technical I Requirements Manual.

I I - I Change Category:

I - Removing Details of System Design and System Description, Including Design Limits 2 - Removing Descriptions of System Operation 3 - Removing Procedural Details for Meeting TS Requirem*nts and Related Reporting 4 - Removing Performance Requirements for Indication-Only Instrumentation and Alarms Core Operating limits Report 5 - Removal of Cycle-Specific Parameter Limits from the Technical Specifications to tile Page 9 of I11 R-3.4 North Anna Power Station

Table R - Relocated Specifications and Removed Details ITS Section 3.4 - Reactor Coolant System (RCS)

CTS Change Control Change DOC No. Requirement Description of Relocated Requirements Location Process Category CTS 3.4.9.2 3.4.9.2 CTS 3.4.9.2 states that the pressurizer temperature shall be limited Technical 10 CFR 50.59 R R. I to a maximum licatup of I100'F or cooldown of200'F in any one Requirements hour period and a maximum spray water temperature and Manual pressurizer temperature differential of 320 0F. The pressurizer temperature limits are placed on the pressurizer to prevent non ductile failure. The limits meet tile requirements given in the ASME Boiler and Pressure Vessel Code, Section 111, Appendix G.

This LCO does not meet the criteria for retention in the ITS; therefore, it will be retained in the Technical Requirements Manual.

CTS 3.4.10. I 3.4. 10.1 CTS 3.4. 10.1 provides requirements for the ASME Code Class 1, Technical 10 CFR 50.59 R R. I 2 and 3 components to ensure their structural integrity. These Requirements requirements are in addition to the requirements in CTS 4.0.5. Manual This LCO does not meet the criteria for retention in the ITS; therefore, it will be retained in the Technical Requirements Manual.

CTS 3.4.11.1 3.4.11.1 CTS 3.4.11.1 provides requirements on the reactor vessel head Technical 10 CFR 50.59 R R.I vents. The reactor coolant head vents are provided to exhaust Requirements noncondensible gases or steam, which could inhibit core cooling, Manual from the Reactor Coolant System. The reactor vessel head vents are not credited in any UFSAR accident analysis. The reactor vessel head vents are included in the Emergency Operating Procedures for mitigation of beyond design basis accidents. This LCO does not meet the criteria for retention in the ITS; therefore, it will be retained in the Technical Requtirements Manual.

Change Categoiy-:

I - Removing Details of System Design and System Description, Including Design Limits 2 - Removing Descriptions of System Operation 3 - Removing Procedural Details for Meeting TS Requirements and Related Reporting 4 - Removing Performance Requirements for Indication-Only Instrumentation and Alarms 5 - Removal of Cycle-Specific Parameter Limits from the Technical Specifications to the Core Operating Limnits Report Noi.h Anna Power Station Page 10 of I11 R -3.4

Table R - Relocated Specifications and Removed Details ITS Section 3.4 - Reactor Coolant Systern (RCS)

_ I__ - . I Change CTS Change Control Location Process Category DOC No. Requirement Description of Relocated Requirements 3.7.9.1 CTS 3.7.9.1 states that two residual heat removal (RHR)

- I -I Technical 1 ý 10 CFt" A

50.5)9 n i R CTS 3.7.9.1 Requirements R.I subsystems shall be OPERABLE in MODES 1, 2, and 3. The Manual RHIR System is used to remove decay heat from the reactor in MODES 4, 5, and 6. The RHIR does not operate in MODES 1, 2 and 3 and must be isolated firom the reactor coolant system in those MODES to prevent overpressurization of the RHIR components. The RHIR System serves no accident mitigation function in any MODE. This LCO does not meet the criteria for retention in the ITS; therefore, it will be retained in the Technical Requirements Manual.

II- V LU LtK U.J')

i ________

CTS Surveillance 4.7.9.2.c. I requires cycling of each remote or I Technical IIO 10 - rrD

- i ri CF <n <o 5.59' CTS 3.7.9.2 4.7.9.2.c. I Requirements LA. I automatically operated valve in the RIHIR subsystem flowpath Manual through at least one complete cycle of full travel every 18 months.

1IS 3.4.6, 3.4.7, and 3.4.8 do not contain this requirement. This changes the CTS by relocating these Surveillances to the TRM.

________ 1_______ ________________________________

Change Category:

I - Removing Details of System Design and System Description, Including Design Limits 2 - Removing Descriptions of System Operation 3 - Removing Procedural Details for Meeting TS Requirements and Related Reporting 4 - Removing Performance Requirements for Indication-Only Instrumentation and Alarms Limits Report 5 - Removal of Cycle-Specific Parameter Limits from the Technical Specifications to the Core Operating PagelIlIofll R-3.4 North Anna Power Station

Table R - Relocated Specifications and Removed Details ITS Section 3.5 - Emergency Core Cooling Systems (ECCS)

CTSlChange Control Change IDOC No. N C/LA cN/A De liremlnl:* ___sc-riptio-oN/AlOCated [ Location Process Category 3.5.1I None / N/A N/A N/A N/A 3.5.2 LA. I 3.5.2, CTS LCO 3.5.2 states that two ECCS subsystems shall be Bases ITS 5.5.13, I 4.5.2.e.2 OPE'RABLE and contains a description of what const iutes an Technical OPERABLE subsystem. The Unit I LCO also describtcs the Specifications capability of tie outside recirculation spray punip to dischbarge to Bases Control the ECCS subsystems (acting as a backup to1 lhe .ow Head Safelty Program injection pump) during the recirculation phase of'a LOCA. CTS Surveillance 4.5.2.e.2 lists the pumps that are included in an OPERABLE subsystem. ITS 3.5.2 requires two ECCS trains to be OPERABLE, but the details of what constitutes an OPERABLE train are moved to the Bases. ITS SR 3.5.2.6 does not list the pumps which comprise an ECCS train. This changes thc CTS by moving the details of what conslitutcs an OPFiRABI 1' systcnm to the Bases.

_____________ I I 3.5.2 LA.2 j14.5.2.g CTS Surveillance 4.5.2.g rcquircs verification thaft a specified Bases ITS 5.5.13, grO tip of. mlamal valves requiring adjustnmni to preyer! piunp Tcchnical "ru 1OU" tland subseqLie nt cotmpolne nt daliiage aiel sece i'u]I ill Ic Spccifications proper position for injectio%. ITS SR 3.5.2.7 requires verification Bases Control that the samie group of valves are secured in the coirCClt position. Progra in This changes tMe CTS by moving the dcscription of lhc purpose of the valves and what constitutes thc proper position to the Bases.

__________________ ________________ I ________________________________________________________ ______ ________________ _____________________

Change Category I Removing Details ol'Systcm Design and SystCeim Description , Iichlioing I)CSigen I imils 2 - Renioving Descriptions ol System Operation 3 - Removing Procedural Details for Meeting TS RCquiremcnts and Relatcd Rcporting 4 - Removing Pceformancc Requtirements for Indication-Only Instrunmentalion and Al"ar is 5 - Removal of Cyclc-Specitic Parameter Limitts from tile Technical Specifications to the Core Operating Limits Report North Anna Power Station Page I of"3 R - 3.5

Table R - Relocated Specifications and Removed Details ITS Section 3.5 - Emergency Core Cooling Systems (ECCS)

Change Control Change CT'S Dcscripfionl of' Relocated Requirements Process Category Location DOC No. RcquiCemCnlt FCTSSu ri-v c il hnc e 4 .55.2 .1"spe,)

c i f'ic s th latth e 1H H S I p u mtp a n d IL l -IS

] IS T ITS 5.5.7, 3 LA.3 4.5.2.f punmps be tested ill accordance with 4.0.5 (tile lnservice 'I est Inservice Testing 3.5.2 Pro grail) and that1 a specific developed head (i.e., developed hlead Program equals the dischlargC pressure minuts the suction prcssiire) hb..mlelt.

ITS SR 3.5.2.4 rcquirCs the samlc testing, but the specific limils on developed head for each type of' p uti1p a rc 1aemaintair*ed hy the Inservice Test Program. This changes the CTS by moving tile procedural details for meeting tie Surveillance to the1ISIIST Program.

10 CFR 50.59 i Technical 3.5.2 LA.4 4.5.2.c CTS Surveillance 4.5.2.c Irequiriesaivisual inspection For loose RCquiricnmel ots debris in containment prior t estahlishing containinln .nl integriy Manual and within affected areas of the Containment at the completion of each containment entry when coniainmnlct integrity is established.

ITS does not include this requirement. This changes the CTS fly moving this requirement to tile Technical Requir-nieIs Manltal.

'IT'S 5.5.13, Bases 3.5.2 IA.5 4.5.2.c. 1and CTS Surveillance 4.5.2.c. 1 and 4.5.2.c.2 require verificaition of the Technical 4.5.2.e.2 automatic actuation of the [F'CCS conomponents every i X Iltoill hs Speci ficat ions 3-during shutdown. [ITS SR 3.5.2.5 and SR 3.5.2.6 requirie thi., Bases Control testing every 18 nmonths. T'his chlanges CI'S by inov!nge the PiOgi am requireime nt that this testing be pcifor liled d riig tu s lhutdowi tWttlie Bases.

ITS 5.5.13, 3.5.2 Bases IA.6 4.5.2.c. I1and CTS 4.5.2.e. I and 4.5.2.e.2 require verification of the utiomatic Technical 4.5.2.e.2 actuation of ECCS coilmponents oil a safely injection test signal. Specifications ITS SR SR 3.5.2.5 and SR 3.5.2.6 do not specify tilt' signal, but Bases Control only specify ail actuation signal. This changes CTS by moving tile Program designated actuation signal to) the Bases.

Change CatcgorI g Details of System Design and System Iescription, nchtidirg Design Limits

- Removing 2 - Removing t)escriptions of System Operation 3 - Removing Procedural Details for Meeting 1TS Requiiemcnls ai111Related Reporlritg Instrumentation and Alarm; 4 - Removing Perflormance Requirements Ior Indication-Only Specifications to tile Core Olperating limits Report 5 - Removal of Cycle-Specific Parameter Limits from the Technical Page 2 of 3 R - 3.5 North Anna Power Station

Table R - Relocated Specifications and Removed Details ITS Section 3.5 - Emergency Core Cooling Syslems (ECCS)

Change Control Change Location Process Category 7 CTS lRcqtfiI CIICII Description of Relocated Recluircilcims FDOC No. Bases ITS 5.5.13,1 3.5.3 CTS L.CO 3.5.3 states that an FCCS subIsystemISh1:'*., be 3.5.3 LA. I OPFERABI-Eand on~ *tains it description of what constitutes allTechlnical Fa ol OPFRABLF- subsystem. ITS 3.5.3 requires an E.C(S train beSpc Bases Convol OPERABLE, the details o1 what conilStiltCSI an OPERABLE train are movedbutto (lie Bases. Program N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A 3.5.5 None COLR ITS 5.6.5, Core 3 3.5.6 1LA. I 3.5.4.1 CTS 3.5.4. I states that when the boron injection tank is

isiatus within Operating Limits inoperable, tile tank must be erstored to OPERABI in 1lOT STANDBY and boraited to Rcport one hour or tile reactor must be at 200) -1.

a Shutdown Margin (SDM) equivalent to 1.77%; Ak/k within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. ITS 3.5.6, Actions A and 13, coiltain.

to similar requirements, butIhe specific value of SI)NM is r,1ocattd the COLR.

heat 'I'chnical 10 CFR 50.59 R CTS 3.5.4.2 3.5.4.2 CTS 3.5.4.2 states, "At least two independent channels of n1i1ctiO'w Itnk an.1lioltI'W- Requirements R. I tracing shall be OPIjRABI3t Iforr thCe boron0 rl I(ow patlhs'.- Thc ITS Manual lhe lieat traced po ions o1"ilthe associatedd and it will be rclocaicd to the will not contain this rcquirement

'Technical Reqquirements Manual.

Chanie Cate go'y IDesign I.imois I - Removing Details of System IDesign and System l)cscription, Including 2 - Rcmoving Descriptions of Systcm Operation and Reclatcd lReporting 3 - Recmoving ProcedLi'al Details for Meeting TS RcequirClmCnts for Indication-Only Instrumentation and Alamos 4 - Removing Pcrformance Requirements to tile Corc Operating liimits Report Limits from the Technical Speciflications 5 - Removal ol'Cycle-Specific Parameter R -3.5 Page 3 of 3 North Anna Power Station

Table R - Relocated Specifications and Removed Details ITS Section 3.6 - Containment Systems I Change Control I Change Change Control CTS Location Process Category DOC No. RequiIi re menit Description of'Relocated lR),equiremenIt.

Bases ITS 5.5.13, 2 3.6.1 L A. I 1.6.2 CTS 1.6 states, "CONTAINMIENT INTEGRI'I'Y shall exist Technical when:... 1.6.2 All equipment hatches are closed and sealed." 3.6. I Specification states, "Containment shall be OPERABLE." 'Thischanges the Bases Control CTS by moving the reference to the cqu,ipmcnt hatch being closed Program to the Bases. The change (deleting the phrase "and sealed" is addressed by DOC L. I.

Bases ITS 5.5.13, 2 3.6.1 LA.2 1 1.6.1 CTS 1.6 states, "CONTAINMlENT INTHGIIY shall exist Technical when:... 1.6.1 All penetrations required to be closed during Specification accident conditions are either: a. Capable of being closed hy an Bases Control OPERABLE containment automatic isolation valve system, or b. Program Closed by manual valVeS, blinld Ihanges, or deactivatedI ant oma tic valves secured in their closed positions, except for valves that are open under administrative control as permin itted by S"gec iii catioll 3.6.3.].L" CTS 1.6.5 states, "The sealingmechanism associated with each penetration (e.g. welds, bellows, or 0-rings) is OPERABIE." This changes the CTI'S by moving thr !.6. 1 and 1.6.5 portions of the definition to the 3.6.1 Bases.

Bases ITS 5.5.13, 3.6.2 LA.!I 3.6.1 .3.a and CTS ICO 3.6.1.3 parts a and b state what constitutes all Technical hi OPERABLE containment ,air lock. I'S ITCO 3.6.2 does no! Specification include this level of (etail. Part a of this detail is mov,.d to the Bases Control Bases of the ITS. This changes the CTS by moving details I Plrogia nm concerning what constittes an OPE:ABI3E, containmc': air lock I to the Bases.

I - I Change Catcgo,-M-t I - Removing Details olf Syslcm Design and System eI)scripton, Inchluding Design limits 2 - Rcmoving Descriptious of System Operation elated Reporting R,1 3 - Removing Procedural Details f0r Meeting TS R[?equireCments and for Indication- Only Instrumentation and Alaril;:;

4 - Removing Performance RequLiireiments Limits from the Technical Specifications to thý ('ore Operating LIimits Report 5 - Removal of Cycle-Specific Parameter Page 1 of 8 R-3.6 North Anna Power Station

Table R - Relocated Specifications and Removed Details ITS Section 3.6 - Contaiimcnt Systems t I Chance CTS I Change Control I Change Process Category Requirement l)escription of Relocated Requiremenieits Loc atiion DOC No. 3 ITS 5.5.13, 4.6.3.1.2 CTS 4.6.3. 1f.2 states, "Each containment isolationi valve shall be Bases 3.6.3 LA. I Technical dcmonstrated OPERABLE during COIL.) SHUTDOWN or Specification REFUELING MODE at least once per 18 months..,." by means Bases Control that include actuation of specified automatic valves and cycling of Program weight or spring loaded check valves not testable during unit operation. ITS Frequency of SR 3.6.3.5 and SR 3.6.3.6 is 18 months, and does not include the phrase, "'...during COLi)

SHUTDOWN and REFUELING MODIE..." This changes tlhe CTS by moving the rekfrencc to the 18 monlllh Frequency being based on the need to performmIthis Surveillancc ulld.r the.

conditions that apply during a unit ouLtage Io the Bases.

i Bases ITS 5.5.13, 3.6.3 1.A.2 4.6.5. 1.1 CTS 4.6.5. I. I states, "The steani jet air ejector suction Ilinc outside Technical isolation valve shall lie determined to be in the closed position by Spec ification visual (ilservation..." ITS SR 3.6.3. I does not include the Bases Control reference to vi:,ual inspection. This changes ihc CTS by moving Program the detail of how thie eriflication is performed to tlie B,ascs.

Change Category:

I - Removing Details of System eDesign and System Description, Including Design Limit-.

2 - Removing Descriptions of System Operation 3 - Removing Procedural Details for Mecting 'TS Requirecnnts and Related Reporting 4 - Removing Performance Requirements for Indication-Only Instrumcntation and Alarms Operating Limits Recport 5 - Removal of Cycle-Specific Parameter Limits from the Tcchnical Speci]fications to th,- Core Page 2 ol18 R - 3.6 North Anna Power Station

Table R - Relocated Specifications and Removed Details ITS Section 3.6 - Containment Systems I Change Change Control I C'T'S Process Category l)escription of Relocated Requirellments Location D)OC No. I Requirement

--- -------- _ t ITS 5.5.13, 3.6.3 IA.3 ýl 4.6.3.1.2 CTS 4.6.3.1.2 states, "Each containlment isolation valve shall be demonstrated OPERABLE... by: a. Verifying that on a Phase A Bases Technical Specification containment isolation test signal, each Phase A isolation valve Bases Control actuates to its isolation position. b. Verifying that on a Phase B Program containment isolation test signal, each Phase B isolation valve actuates to its isolation position." ITS SR 3.6.3.4 states, "Verify each automatic power operated containment isolation valve that is not locked, sealed or otherwise securedl in position, actuates to thie isolation position on an actual or simulatedIactuation signal." This changes the CTS by moving the detail concerning which signals are used to conduct the Surveillance Requirement to the LBas s.

Changes associated with not requiring the Sturveillhace Requirement be conducted on valves locked, sealed, i ollherwise scut, red in posilion arc addressed by DOC I. 11. Ch:Ini"es associated with allowing tie use of an actual signal for nduct ling the Surveillance Requirement are addressed by I)OC. L. 12.

Bases ITS 5.5.13, 3.6.3 LA.4 4.6.[I.,1 CTS 4.6. I. I .d states, "Each time containment inltegriy is Technical established alter vacuum has been broken by pressure itstingg tile Specification butterfly isolation valves in tile contaimlent purge lines and tile Bases Control containment vacuum ejector line." ITS SR 3.6.3.4 states, Prograni "Perform leakage rate testing for containment pl p gi valvews with resilient seals." This changes tile CTS by moving Oi!g tcl iils specifically niam inig butterfly vavIexCs and tihe coiintainilu ent xvacuunmii air ejector line to the Bases.

I II. I I N/A I -

N/A N/A N/A 3.6.4 None N/A N/A IL

_________ I________ I _______________________________

Changc Cate*My:

I - Removing DetailIs of System Design and System icDescription, Including Design Limius 2 - Removing Descriptions of System Operation 3 - Removing Procedural l)ctails l-r Meeting TS *RcquiremCnts and Related Reporting and Alarms 4 - Removing Performance Requirements for Indication-Only Instrutnentalion Parametcer imits from the Technical Specifications to the Core OpCIeating Ltimits Report 5 - Removal of Cyclc-Spcciflic Page 3 cf 8 R -3.6 North Anna Power Station

Table R - Relocated Specifications and Removed Details ITS Section 3.6 - Containment Systems Change Control Change CTS LIocation Process Category Requirement Description of Relocated Requiremcnts DOC No. 10 CFR 50.59 3 U-SSAR 3.6.5 ILA. 1 4.6.1.5.1 CTS 4.6.1.5.1 includes specilric locations where containment temperatures are to be measured. ITS SR 3.6.5. I does not include these details. This changes the CTS by moving the dcestription of how compliance with the 'Technical Speci fication LCO is determined to the UFSAR.

ITS 5.5.13, 3 1A.2 4.6.5.1 CTS 4.6.5. I states, "The primary containment aevragle, Vi Bases Technical 3.6.5 temperature shall be the weighted average of at least the mkininmuml Specification number ob temnfperatures..." ITS SR 3.6.5. I states, "Verity Bases Control containment average air temperature is within limits."' This Program changes thle CTS by moving thei rcquircmenl to take a weighted average of' tellperaltucs to perforl the Surveillance Requirement to the Bases.

ITS 5.5.13, Bases 3.6.6 IA. I ILCO 3.6.2.1 CTS I.CO 3.6.2.1 states that two indelpedent contai'melnt quench Technical spray subsystems shall be OP'ERABLE'. ITS 3.6.6 also -cquircs Specification two quench spray trains (i.e., subsystems) to be OPERABIF. 'This Bases Conitrol changes tihe CTS by moving Ihe (letaiIhatl the trains must be Program independent to the Bases.

Inservice Test ITS 5.5.7, 3 3.6.6 .LA.2 4.6.2. .b CTS SR 4.6.2. I.b states, "Verifying thatOiln Iccireula !ion flow, Progrlallm Inservicc 'lesting each pumlp develops a diischWarge pressurc of _ 123 psig wheni Progranil tested pursuant to Specification 4.0.5.' ITS SR 3.6.6.2 states, "Verify each OS punip's developed head at the flow test point is greater thall or equal to the required developed head." This changes the CTS by moving the required developcd head limnil I'roni the Technical Specifications to the Inservicc Tc'.t. Prmograrn, The change to the description o" ithe test being periornite'd using recirculation flow is discussed in LA.5.

__________________I Change Category:

Design 1l.imits I - Removing Details of Sysem IIDesign and SystemlDescription, Including 2 - Removing Descriptions of System Orperation and Related Reporting 3 - Rcmnoving Proccdural lDetails for Mccting TS Requirements and Alarimis 4 - Removing Pc rformancc Rcquirements for Indication-Only Instrumentation Specifications to (hv Coice Operating Limits Report 5 - Removal of Cycle-Speciflic Parametcr limits from ihe Technical Page 4 of 8 R-3.6 North Anna Power Station

Table R - Relocated Specifications and Removed Details ITS Section 3.6 - Containment Systems Change Control Change CTS Location Process Category DOC No. Rl.equiremcnt Description of Relocated Requiremcnts Bases ITS 5.5.13, 3 3.6.6 LA.3 4.6.2.1.c.1, CTS Surveillances 4.6.2. I.e. I and 4.6.2. I.c.2 require verification Technical 4.6.2. 1 .c.2 oQS c tponr cnts0iton a conitainiiment 1f lie alitomatic actuation o" Specification high-high pressure signal. ITS SR 3.6.6.3 and SR 3.6.6.4 (to not Bases Control specify the name of' the signal, hut only specily an actuation signal. Program This changes tile CTS by moving the type of actuatiomi signal to the Bases.

Bases ITS 5.5.13, 3

3l6.6 LA.4A 4.6.2.1I.d CTS Surveillance 4.6.2. I.d states, "At least once per 10 years by Technical perlorming an air or smoke flow test thirough each spray header Specification and yerilying each spray nozzle is unobstructed." ITS SR 3.6.6.5 Bases Control states, "Veri fy each spray nioZZle is unobstructed." This Thafifcs Pro gram the CI'S by moving the details of the tcst to tile Bas:...

Bases ITS 5.5.13, 3.6.6 I.A.5 4.6.2. 1.1 CI'S SR 4.6.2.1 I. states, "Verifying that on recirculai.ioi flow, Technidkal each pump develops a discharge pressure of">'123 p-ig whicni Specifrication tested pursuant to Specification 4.0.5.- ITS SR 3.6.6.2 stales, Bases Control "Verily each QS pump's developed head at thie flow test point is Progran greater than or equal toi the required developed bead." This changes the CTS by moving the desciption thal tile test is perfo-rmed using' ecir'culationlflow to the Bases ol tie Surye illhnce. '['lie change inovin g Ihle requiiireld dcvxloped head limitlfroni the 'echinical Specifications is discussed i; I.A.2.

I Bases ITS 5.5.13, 3.6.7 LA.I 3.6.2.2 CTS 3.6.2.2 states that two trains ol containnment RS shall he Technical OPERABLELB and contains a descrilp1tion ol subsystlls- Iat eacti Specification train consists of'. ITS 3.6.7 states that four RS sullstens shali be Bases Control OPERABLE, but the details of what constitutes ain OPERABI.I] Progl'an subsysteni al-c moved to the Bases. This changes the CTS by moving the details of what constiltutes a subsystem to the Bases.

Clhange Catcgqry I Removing I)etails of' System I)esign and System Description, Including Design L iiiits 2 - Removing Descriptions of System Operation 3 - lRcnov in g Procedural Details for Mecting T'S Require'ints and Related Reporting and Alarms 4 - Rcmoving Performance Requirements for Indication-Only Instrumenlation Parameter I.imits from( the Technical Specifications to the ( -r Operating Limfits Report 5 - Removal of Cycle-Specific Page 5 of 8 R-3.6 North Anna Power Station

Table R - Relocated Specifications and Removed Details ITS Section 3.6 - Containrment Systems Change Control Change DOC No. Req

- IsI

. 36 irenen Description o Relocatedl Requirements Location Process Category Bases ITS 5.5.13, 3.6.7 L.A.2 3.6.2.2. b CTS 1.CO 3.6.2.2.b slates that one casing cooling tank shared with Technical both trains of RS shall be OPERABI.E. ITS 3.6.7 stato a casing Specification cooling tank shall be OPERABLI, but the details regiarding b)th Bases Control trains sharing the tank are moved to the Bases. This changes the Program CTS by moving the detail that that .1 casing cooling lank is shared by both trains of RS to the Bascs.

Bases ITS 5.5.13, 3 LA.3 4.6.2.2.I.c.I CTS 4.6.2.2.1 .. I requires each containment RS subsystem and Technical 3.6.7 casing cooling subsystem hb (demonstrated OPERABLI by Specification verifying that the casing cooling pump, and inside and oLutside RS Bases Control pumps start automatically after a specified time delay. ITS SR Program 3.6.7.6 requires yerification that the RS System punps start automatically Oan l actll at ion signal, anid OCS not cntltain thie specific delay times. This changes CTS 4.6.2.2. I.c. !by rmoving the specific delay times to the Bases. [TS 5.5.13, 3

Bases 3.6.7 I-A.4 4.6.2.2. I.c. I, CTS 4.6.2.2. I.c. I and 4.6.2.2. I.c.2 require verification l' the Technical 4.6.2.2. I.c.2 automatic actuation of RS Comliponents oni a cOlntainmenit high-highl Specification pressure signal. ITS SR 3.6.7 does not specify the si.gnal, but only Bases Control specifies an actualion signal. This changes CTS by ilmoving the Progr am designated actuation signal to the Bases. 3 Bases ITS 5.5.13, IA.5 4.6.2.2. I.d CTS 4.6.2.2. I.A requires each containnlt RS subsystcmind Technical 3.6.7 casing cooling subsystemn be demonstrated OPF,RAIII[, At least Specilfication once per 10 years by performing an air or smoke I',,w icst through Bases Control each spray header and verifying each spray nozzle i,, Programll unobstructed.'" ITS SR 3.6.7.7 states, "Ver'ify each -,,;pray noz/A.c is unobstructed." This changes the CTS by moving tile details regarding tile test method to tei Bases.

I I Change Calegory:

I)csign Init s I - Removing l)etails of System Design and System I)escription, Including 2 - Rcmoving Descriptions of System Operation Related Reporting 3 - Removing Proccdural D)etails for Mceting TS Requirements and Instrumentation and AlarMos 4 - Removing Performancc Requirements morIndication-Only Specifications to he r(',, Onc.ating Limits Report 5 - Remnoval of Cycle-Specific Paramteter Linlits froml the Technical R -3.6 Page 6 of'8 North Anna Power Station

Table R - Relocated Specifications and Removed Details ITS Section 3.6 - Containment Systems

7 CTS DOC No. Requifr-celi tI Description of Relocated Rcquirel mnls 3,.6.8 LA.I 4.6.2.3.1).2 CTS Surveillance 4.6.2.3.b.2 IrcquireCs \vCfiication o th4W concenitration of NaOH solutiont in the chemical addition tank by chemical analysis. ITS SR, 3.6.8.3 also rCquires vSertilcation of thc NaO H Solot i0on cotncenrtIration but does not specify !howthat verification is performed. This changes the CTS by moving tihe tethod of vehification to Ile Bases.

3.6.8 lA.2 4.6.2.3.c CTS Surveillance 4.6.2.3.c requiiCS verification of tl!c automatic actualtion oft he Chemical Addition Sys(l aitOllmat ic valves ecvcry 18 110onths during shutdown. IVTS SR 3.6.8.4 requires this testing every 18 ionttlis. This changes the CTS by moving tile rCquir'etiietnt that this testing be perTorimed during silutdowl to tile Bases.

r36.8 IA.3 ,1.6.2.3.c CT'S Surveillance 4.6.2.3.c requires verification of the automatic actuatiotn of the Chemical Addition Systemiautotmatic valves on a containment high-high pressure lest signal. ITS SR 3.6.8.4 will tlot specify the name ot the signal, but will only spec-ily an.

actuation signal. This changes tile CTS by moving tilie type(of acttatioti sigtial to the Bases.

3.6.8 1,A.4 4.6.2.3.d CTS Surveillance 4.6.2.3.d requires verification (, flow .'totit tie RWST and the chemical addition tank cvery 5 year.; using tile drain lines in the cross connection between thie tanks. ITS SR 3.6.8.5 also requires verificatioti of the flow from ca, .soition's flow path every 5 years. h'bis changes CTS by moving the snecilice requitriteniment to verify the low rouitghi thIi ttlie idrtainli nes .i litheOWrss connection between the respective tanks to the Base-;.

________ 4_______ _________________________

Cb, y: ndSyCattem_

- Remtoving l)etails of System l)esign and System Description, Incldirg I)csigt Liittt 2 - Remnoving Descriptions of System Operation IReporting 3 - Removing Procedural Details for Meeting 'S Requirements anrd Related Requirements for Indicatiolt-Only InstrittMIltltiorn and AlarM'..

4 - Removing Performance to tlic Core Operating L..imits Report 5 - Reno valof Cycle-Specific Parameter L.imits lti'ol tile Technical Specifications Page 7 of X R - 3.6 North Anna Power Station

Tablc R - Relocated Specifications and Removed Details ITS Section 3.6 - Containment Systems CTS DOC No. Recquirement I)escript-ion f(IR, lIocated Req u irenIen ts 3.6.9 LA.!I 3.6.4.2 CTS 3.6.4.2 states, 'Two separate and independent containment hydrogen recombiner systems," shared with Unit 2 Or Unit I for the Unit I or Unit CTS, respectively, 'shall bc OPERABI.E." ITS 3.6.9 states, "'Two hydrogen recombiners shall be OPIERABLE3.."

This changes the CTS by moving the Metail, "sepafate and indecpecndent and the rcfrefce to te shearing or the systems between units to the Bases.

I 3.6.9 LA.2 4.6.4.2.a, CTS 4.6.4.2.a, CTS 4.6.4.2.b, CI'S 4.6.4.2.c, and ("'1S 4.6.4.2.d 4,.6.4.2.b, include detail olir perIl'iorlnce of' a fInnction al test, resistanice to 4.6.4.2.c, ground test, and visual examilation. [IS SR 3.6.9. !,l[TS SR 4.6.4.2.d 3.6.9.2, and ITS SR 3.6.9.3 togetherIrequire that each of these three tests be performed. This changes CTS by moving the detail of how these tests are perflrmed to the Bases.

________ I _______ I ________________________

Change Catcg_*y.

I - Removing Details of System Design and System )cesscrpion, Including D)esign IWihy!,

2 - Remnoing Descriptions of System Operation 3 - Removing Procedural I)etails krwMeeting TS Requirements and Related Reporting 4 - Removing Paherlorrnalnce Requiremenis for Indication-Only InmistrinuurenIitatioon and Al arms tdo Cmve .".)i ating lhinits Report 5 - Rem wvaI of Cycle-Specific Parameter LOimis from the Technical Specifications to R -3.6 North Anna Power Statione Page 9 of"8

Table R - Relocated Specifications and Removed Details ITS Section 3.7 - Plant Systems CTS Change Control Change Requirement Description of Relocated Requirements Location Process Category DOC No.

CTS 3.7. 1.1, Table 3.7-2 ,is modified by a footnote that states, UFSAR 10 CFR 50.59 3 3.7.1 LA.l1 3.7.1.1 Table 3.7-2 "The lift setting pressure shall correspond to ambient conditions of the valve at nominal operating temperature and pressure. ITS 3.7.1 does not contain this information. This changes the CTS by eliminating details on setting the lift pressure.

N/A N/A N/A N/A 3.7.2 None N/A N/A N/A N/A N/A 3.7.3 None N/A N/A N/A N/A N/A 3.7.4 None N/A 3.7.5 LA. I 3.7.1.2 CTS LCO 3.7.1.2 requires three independent AFW pumps and Bases ITS 5.5.13, I Technical associated flow paths to be OPERABLE. This includes the motor Specifications driven AFW pumps powered from separate emergency buses, and Bases Control the steam turbine driven AFW pump capable of being powered Program from an OPERABLE steam supply system. ITS LCO 3.7.5 will require "Three AFW trains to be OPERABLE"; it does not include design details or define the components that comprise an OPERABLE AFW train. This changes the CTS by removing description of the AFW system from the Technical Specifications (TS).

3.7.5 LA.2 4.7.1.2.c CTS SR 4.7.1.2.c requires the testing of the automatic valves in Bases ITS 5.5.13, the AFW flow path and the starting of the AFW pumps during Technical shutdown. ITS SRs 3.7.5.3 and 3.7.5.4 require the testing for the Specifications pumps and a valve to ensure OPERABILITY is maintained. This Bases Control change moves the requirement to perform the testing "during Program shutdown" from the Technical Specifications (TS).

Change Category:

I - Removing Details of System Design and System Description, Including Design Limits 2 - Removing Descriptions of System Operation 3 - Removing Procedural Details for Meeting TS Requirements and Related Reporting 4 - Removing Performance Requirements for Indication-Only Instrumentation and Alarms 5 - Removal of Cycle-Specific Parameter Limits from the Technical Specifications to the Core Operating Limits Report Page I of 14 R-3.7 North Anna Power Station

Table R - Relocated Specifications and Removed Details ITS Section 3.7 - Plant Systems CTS Change Control Change Requirement Description of Relocated Requirements Location Process Category DOC No.

3.7.1.3 CTS ACTION b states the Condensate Storage Tank (CST) acts as Bases ITS 5.5.13, 1 3.7.6 LA. 1 a backup supply to the AFW pumps with a capacity of 300,000 Technical gallons. ITS 3.7.6 requires tile CST to be OPERABLE when the Specifications Emergency Condensate Storage Tank (ECST) is inoperable. This Bases Control changes the CTS by deletion of specific tank capacity and restates Program the functional requirements.

N/A N/A N/A N/A N/A 3.7.7 None 3.7.4.1 CTS 3.7.4.1 states that two service water loops shall be Bases ITS 5.5.13, 1 3.7.8 LA. 1 OPERABLE and contains a description of what constitutes an Technical OPERABLE loop. ITS 3.7.8 requires two service water (SW) Specifications System loops to be OPERABLE, but does not contain these Bases Control details. This changes tile CTS by moving tile detail of what Program constitutes OPERABLE SW System loops to the Bases.

4.7.4.1l.b CTS Surveillance 4.7.4.I.b requires the measurement of any Technical 10 CFR 50.59 3 3.7.8 LA.2 movement of the SW pumphouse and wing walls every 6 months. Requirements CTS 4.7.4.1 .b gathers information used in evaluating compliance Manual with CTS 3.7.12, "Settlement of Class I Structures." ITS 3.7.8 does not contain this requirement. This changes the CTS by moving the procedural detail of measuring SW pumphouse and wing wall movement to the Technical Requirements Manual (TRM).

Change Category:

I - Removing Details of System Design and System Description, Including Design Limits 2 - Removing Descriptions of System Operation 3 - Removing Procedural Details for Meeting TS Requirements and Related Reporting 4 - Removing Performance Requirements for Indication-Only Instrumentation and Alarms 5 - Removal of Cycle-Specific Parameter Limits from tile Technical Specifications to the Core Operating Limits Report Page 2 of 14 R-3.7 North Anna Power Station

Table R - Relocated Specifications and Removed Details ITS Section 3.7 - Plant Systems I

Change Control nange I CTS Changessontrol Change Location Process Category DOC No. Requirement Description of Relocated Requirements

___________ I. Bases 115 5.5.13, T -,

3.7.8 LA.3 4.7.4.I.c CTS 4.7.4. I.c requires verification of the automatic actuation of Bases 11-S 5.5.13, Technical SW System valves every 18 months during shutdown. ITS SR Specifications 3.7.8.2 requires verification of the automatic actuation of SW Bases Control System valves every 18 months, but not tile requirement that this Program testing be performed during shutdown. This changes tile CTS by moving the reference to performing the SR when the plant is shutdown to the Bases.

Bases [IS 5.5.13, I 3.7.8 LA.4 4.7.4. 1.c.I CTS 4.7.4.1 .c. I requires verification that each automatic valve Bases ITS 5..5.13, Technical actuates to its correct position on an actual or simulated safety Specifications injection signal. CTS 4.7.4.1 .c.2 requires verification that each "Bases Control automatic valve actuates to its correct position on an actual or Program simulated containment high-high signal. ITS SR 3.7.8.2 requires verification that each automatic valve actuates to its correct position on an actual or simulated actuation signal. This changes I tile CTS by moving the name of the actuation signals to the Bases.

I.1- If i I ITS- 5.5.1 ---

Bases Bases ITS 5.5.13, I 3.7.8 LA.5 3.7.4.1 CTS 3.7.4.1 Action d contains a reference to a footnote which Technical Action d describes those activities that are considered service water system Specifications upgrades. ITS 3.7.8 does not contain the information in the Bases Control footnote. This changes the CTS by moving tile description of Program what constitutes service water system upgrades to the Bases.

__________ ________ I I. 1 bases ITS 5.5.13, CTS 4.7A4.1.c. I requires that each valve servicing safety related i

4.7.4.1 .c. I Bases 3.7.8 LA.6 Technical equipment actuate to its correct position on an actual or simulated Specifications signal. ITS SR 3.7.8.2 does not reference the servicing of safety Bases Control related equipmeit. This changes CTS by moving the reference to Program safety related equipment to the Bases.

_______ I _______

Change Category:

I - Removing Details of System Design and System Description, Including Design Limits 2 - Removing Descriptions of System Operation 3 - Removing Procedural Details for Meeting TS Requirements and Related Reporting 4 - Removing Performance Requirements for Indication-Only Instrumentation and Alarms Limits Report 5 - Removal of Cycle-Specific Parameter Limits from the Technical Specifications to the Core Operating Page 3 of 14 R-3.7 North Anna Power Station

Table R - Relocated Specifications and Removed Details ITS Section 3.7 - Plant Systems CTS Change Control Change DOC No. Requirement Description of Relocated Requirements Location Process Category LA.7 4.7.4. Id CTS 4.7.4. .d requires each SW pump to be tested in accordance IST ITS 5.5.7, 3 3.7.8 with Specification 4.0.5. ITS 5.5.8, "Inservice Testing Program," Inservice Testing provides controls for inservice testing of ASME Code Class 1, 2, Program and 3 components. ITS 3.7.8 does not contain the specific Surveillance to test each SW pump in accordance with the Inservice Testing Program. This changes the CTS by removing a detailed listing of the components required to be tested in accordance with the Inservice Testing Program.

LA.1 4.7.5.2 CTS 4.7.5.2 states data for calculating the leakage from the Technical 10 CFR 50.59 3 3.7.9 Service Water Reservoir shall be obtained and recorded at least Requirements once per 6 months. ITS 3.7.9 does not contain this requirement. Manual This changes the CTS by moving the requirement to the Technical Requirements Manual (TRM).

LA.2 3.7.5.1 CTS 3.7.5.1 requires that mIinilnum water level for the ultimate Bases ITS 5.5.13, 3 3.7.9 heat sinks be measured to USGS datum, and average water Technical temperature of the Service Water Reservoir be measured at the Specifications SW pump outlet. ITS SR 3.7.9.1 and SR 3.7.9.2 require Bases Control verification of the parameters. This changes the CTS by not Program specifying the datum for mean sea level, or where the average Service Water Reservoir water temperature is measured.

Change Category:

I - Removing Details of System Design and System Description, Including Design Limits 2 - Removing Descriptions of System Operation 3 - Removing Procedural Details for Meeting TS Requirements and Related Reporting 4 - Removing Performance Requirements for Indication-Only Instrumentation and Alarms 5 - Removal of Cycle-Specific Parameter Limits firom the Technical Specifications to the Core Operating Limits Report Page 4 of 14 R-3.7 Nor'h Anna Power Station

Table R - Relocated Specifications and Removed Details ITS Section 3.7 - Plant Systems r .Jnange LonIIoI.

.. . f II dl Ch.angc 11 CTS PrcangessOntO Category Location Process DOC No. Requirement Description of Relocated Requirements i

i ---- r i3ases r II 1.J. I 3g' 3.7.10 LA.1 4.7.7. 1.a CTS 4.7.7. I states, "Each control room emergency ventilation Bases Technical system shall be demonstrated OPERABLE: a. At least once petr Specifications 31 days on a STAGGERED TEST BASIS by initiating, from the Bases Control control room, flow through the HIEPA filters and charcoal Program adsorbers and verifying that the system operates for at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> with the heaters on." ITS SR 3.7.10.1 states, "Operate each required MCR/ESGR EVS train for>Ž 10 continuous hours with the heaters operating." The Frequency is every 3 1 days. This changes the CTS by moving the detail of how the surveillance is conducted to the Bases. The change deleting the STAGGERED TEST BASIS reference is addressed in DOC L. I.

CTS 4.7.7.1 states, "Each control roomn emergency ventilation Bases ITS 5.5.13, 3 3.7.10 LA.2 4.7.7. I.d system shall be demonstrated OPERABLE:...d. At least once per Technical 18 months by:...2. Verifying that the normal air supply and Specifications exhaust are automatically shutdown on a Safety Injection Bases Control Actuation Test Signal." ITS SR 3.7.10.3 states, "Verify each LCO Program 3.7. 10.a MCR/ESGR EVS train actuates on an actual or simulated actuation signal." The Frequency is every 18 months. This changes the CTS by moving the detail of what is verified by the Surveillance to the Bases. The change adding the, "actual or simulated actuation," phrase is addressed DOC L.2.

N/A N/A N/A N/A 3.7.11 None N/A Change Category:

I - Removing Details of System Design and System Description, Including Design Limits 2 - Removing Descriptions of System Operation 3 - Removing Procedural Details for Meeting TS Requirements and Related Reporting 4 - Removing Performance Requirements for Indication-Only Instrumentation and Alarms 5 - Removal of Cycle-Specific Parameter Limits from the Technical Specifications to the Core Operating Limits Report Page 5 of 14 R- 3.7 North Anna Power Station

Table R - Relocated Specifications and Removed Details ITS Section 3.7 - Plant Systems I

r Change Control unange I CTS Change Control i~aange Process I2ýategory DOC No. Requirement Description of Relocated Requirements Location

_________ I I- II ITS 5.5.13, The Unit I CTS 3.7.8.1 states, "Two safeguards area ventilation I Bases ITS 5.5.13, I 3.7.12 LA. I 3.7.8.1 Technical I systems (SAVS) shall be OPERABLE with: a. one SAVS exhaust Specifications fan b. one auxiliary building IJEPA filter and charcoal adsorber Bases Control assembly (shared with Unit 2)." In the Unit 2 CTS, the reference Program to the other unit states, "(shared with Unit I)." ITS 3.7.12 states, "Two ECCS PREACS trains shall be OPERABLE." This changes the CTS by moving the details of what the subsystems consist of and the fact that the two units share portions of the system to the Bases.

______ 1 ______ 4. 4 .f. t -3 3.7.12 LA.2 4.7.8.1.a. I CTS 4.7.8. I.a. I states that each SAVS system shall be Bases ITS 5.5.13, Technical demonstrated OPERABLE by, "Initiating, from the control room, Specifications flow through tile auxiliary building 1IEPA filter and charcoal Bases Control adsorber assembly and verifying that the SAVS operates for at Program least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> with the heater on." ITS 3.7.12.2 states, "Actuate each ECCS PREACS train by aligning Safeguards Area exhaust flow and Auxiliary Building Central exhaust system flow through tile Auxiliary Building HEPA filter and charcoal adsorber assembly." This changes the CTS by moving the fact that the system is actuated from the control room to the Bases. The changes associated with adding Auxiliary Building Central I exhaust system components and flow are addressed by DOC M. I I ______ I ___________________________

Change CateQory:

I - Removing Details of Systen Design and System Description, Including Design Limits 2 - Removing Descriptions of System Operation 3- Removing Procedural Details for Meeting TS Requirements and Related Reporting 4- Removing Performance Requirements for Indication-Only Instrumentation and Alarms 5 - Removal of Cycle-Specific Parameter Limits from the Technical Specifications to the Core Operating Limits Report R-3.7 North Anna Power Station Page 6 of 14

Table R - Relocated Specifications and Removed Details ITS Section 3.7 - Plant Systems Change Control Change Description of Relocated Requirements Location Process Category

. I. CTS 4.7.8.l.d.2 requires that part of demonstrating SAVS Bases 1-S 5.5.13, 3.7.12 LA.3 1 4.- Technical OPERABILITY is, "Verifying that on a Containment Hi-Hi Test Specifications Signal, the system automatically diverts Safeguards Area exhaust Bases Control flow through the Auxiliary Building HEPA filter and charcoal Program adsorber assembly." ITS SR 3.7.12.4 states, "Verify Safeguards Area exhaust flow is diverted and each Auxiliary Building filter bank is actuated on an actual or simulated actuation signal." This changes the CTS by moving the detail regarding the specific signal used and flow paths to the Bases. The change adding the option of using an actual signal is addressed in DOC L.2.

3.7.13 LA.I Unit 2 CTS 3.7.7.1 states, "The following control room Bases ITS 5.5.13, emergency habitability systems shall be OPERABLE:... b. Tile Technical bottled air pressurization system*..." CTS 3.7.7.1 "*"states, Specifications "Shared with Unit 1." ITS 3.7.13 requires two MCR/ESGR Bases Control bottled air system trains to be OPERABLE. This changes tile CTS Program by moving the fact that the two units share the bottled air system to the Bases.

Bases ITS 5.5.13, 3 3.7.13 1,A.2 14.7.7.1 CTS 4.7.7.1 states, "Each control room emergency ventilation Technical system shall be demonstrated OPERABLE:...d. At least once per Specifications 18 months by:...2. Verifying that the normal air supply and Bases Control exhaust are automatically shutdown on a Safety Injection Program Actuation Test Signal." ITS SR 3.7.13.3 states, "Verify each MCR/ESGR bottled air system train actuates on an actual or simulated actuation signal." The Frequency is every 18 months.

This changes the CTS by moving the detail of what is verified by the Surveillance to the Bases. The change adding the, "actual or simulated actuation," phrase is addressed DOC L.2.

_______ ______ 1_________________________ .L ______

Change Category:

I - Removing Details of System Design and System Description, Including Design Limits 2 - Removing Descriptions of System Operation 3 - Removing Procedural Details for Meeting TS Requirements and Related Reporting 4 - Removing Performance Requirements for Indication-Only Instrumentation and Alarms 5 - Removal of Cycle-Specific Parameter Limits firom the Technical Specifications to the Core Operating Limits Report Page 7 of 14 R-3.7 North Anna Power Station

Table R - Relocated Specifications and Removed Details ITS Section 3.7 - Plant Systems CTS Change Control Change DOC No. Requirement Description of Relocated Requiremlents Location Process Category 3.7.13 LA.3 4.7.7.2 The Unit I CTS 4.7.7.2 states, "The bottled air pressurization Bases ITS 5.5.13, 3 system shall be demonstrated OPERABLE: a. At least once per Technical 31 days by verifying that the system contains a minimum of 102 Specifications bottles of air (shared with unit 2) each pressurized to at least 2300 Bases Control psig." In the Unit 2 CTS, the reference to tile other unit states, Program "shared with unit I." ITS SR 3.7.13.3 states, "Verify each required MCR/ESGR bottled air bank is pressurized to >_2300 psig." ITS SR 3.7.13.4 states, "Verify each MCR/ESGR bottled air bank manual valve not locked, sealed, or otherwise secured and required to be open during accident conditions is open." The Frequency is every 31 days. This changes the CTS by moving the detail that the bottles are shared with tile other unit and the number of bottles required to the Bases.

3.7.14 None N/A N/A N/A N/A N/A 3.7.15 None N/A N/A N/A N/A N/A 3.7.16 None N/A N/A N/A N/A N/A 3.7.17 None N/A N/A N/A N/A N/A 3.7.18 None N/A N/A N/A N/A N/A 3.7.19 LA.I 3.7.3.1 CTS LCO 3.7.3.1 states that three CC subsystems, shared with the Bases ITS 5.5.13, I Technical other unit, shall be OPERABLE and contains a description of Specifications what constitutes an OPERABLE subsystem. Footnote "'"

Bases Control provides further details on what constitutes an operable Program subsystem. ITS 3.7.19 requires three CC subsystems to be OPERABLE. This changes CTS by moving the details of what constitutes an OPERABLE subsystem, including that the subsystems are shared between the units, to the Bases. I I I Change Category:

I - Removing Details of System Design and System Description, Including Design Limits 2 - Removing Descriptions of System Operation 3 - Removing Procedural Details for Meeting TS Requirements and Related Reporting 4 - Removing Performance Requirements for Indication-Only Instrumentation and Alarms 5 - Removal of Cycle-Specific Parameter Limits from the Technical Specifications to the Core Operating Limits Report North Anna Power Station Page 8 of 14 R-3.7

Table R - Relocated Specifications and Removed Details ITS Section 3.7 - Plant Systems CTS Change Control Change DOC No. Requirement Description of Relocated Requirements Location Process Category CTS 3.7.1.6 3.7.1.6 CTS 3.7.1.6 states that the structural integrity of the steam turbine Technical 10 CFR 50.59 R R. I assembly shall be maintained in MODES I and 2. The steam Requirements turbine assembly is used to provide the motive force for the main Manual electrical generator. This LCO does not meet the criteria for retention in the ITS; therefore, it will be retained in the Technical Requirements Manual.

CTS 3.7.1.7 3.7.1.7 CTS 3.7.1.7 states that at least one turbine overspeed protection Technical 10 CFR 50.59 R R.lI system shall be OPERABLE in MODES 1,2, and 3. The turbine Requirements overspeed protection system is used to prevent a turbine overspeed Manual condition that could result in turbine damage. The turbine overspeed protection system serves no accident mitigation function in any MODE. This LCO does not meet the criteria for retention in the ITS; therefore, it will be retained in the Technical Requirements Manual.

CTS 3.7.2.1 3.7.2.1 CTS 3.7.2.1 states that the temperature of both the primary and Technical 10 CFR 50.59 R R. I secondary coolants in the steam generators shall be greater than Requirements 700 when the pressure of either coolant in the steam generator is Manual greater than 200 psig at all times. The Steam Generator Pressure/Temperature Limitation serves no accident mitigation function in any MODE. This LCO does not meet the criteria for retention in the ITS; therefore, it will be retained in the Technical Requirements Manual.

CTS 3.7.3.1 3.7.3.1 Not used.

Change Category:

I - Removing Details of System Design and System Description, Including Design Limits 2 - Removing Descriptions of System Operation 3 - Removing Procedural Details for Meeting TS Requirements and Related Reporting 4 - Removing Performance Requirements for Indication-Only Instrumentation and Alarms 5 - Removal of Cycle-Specific Parameter Limits from the Technical Specifications to the Core Operating Limits Report North Anna Power Station Page 9 of 14 R -3.7

"Fable R - Relocated Specifications and Removed Details ITS Section 3.7 - Plant Systems Change Control Change CTS Description of Relocated Requirements Location Process Category DOC No. Requirement CTS 3.7.3.2 states that two component cooling water system (CC) Technical 10 CFR 50.59 R CTS 3.7.3.2 3.7.3.2 R. I loops shall be OPERABLE. It is applicable when both units are in Requirements MODES 5 or 6. The primary function of the CC System is to Manual provide cooling water to the Residual Heat Removal (RHR) heat exchangers, but does not warrant its own LCO. If insufficient CC is available for RHR, RHR is declared inoperable and the Conditions and Actions for CC in CTS are the same as those for RHR. Unlike other Westinghouse plants, RHR does not share components with the Emergency Core Cooling System (ECCS),

and thus does not play a role in DBA mitigation in MODES 1,2, 3, and 4. Other plants use CC for DBA mitigation functions other than ECCS in MODES I, 2, 3, and 4, but the CC system at NAPS does not. This makes the CC System at NAPS different from the CC System described in the ISTS, and retaining the CC requirement for MODES 5 and 6 for supporting RHR or any other components not assumed in DBA analysis is inappropriate. This LCO does not meet the criteria for retention in the ITS; therefore, it will be retained in the Technical Requirements Manual.

Change Category:

I - Removing Details of System Design and System Description, Including Design Limits 2 - Removing Descriptions of System Operation 3 - Removing Procedural Details for Meeting TS Requirements and Related Reporting 4 - Removing Performance Requirements for Indication-Only Instrumentation And Alarms 5 - Removal of Cycle-Specific Parameter Limits from the Technical Specifications to the Core Operating Limits Report Page 10 of 14 R-3.7 North Anna Power Station

"Fable R - Relocated Specifications and Removed Details ITS Section 3.7 - Plant Systems Iun I I ecoto i -fdiI gl I

CTS C range Control Category Location Process DOC No. Requirement Description of Relocated Requirements 4 . _____________________________________

CTS 3.7.4.2 states that one service water loop shall be t

Technical 10 C[I(

10 CF"I 50*.59 7

I IR CTS 3.7.4.2 3.7.4.2 R. 1 Requirements OPERABLE when both units are in MODES 5 or 6. The Service Manual Water (SW) System in MODES 5 or 6 is used to provide cooling water to various safety and nonsafety related systems. Its principal safety function is to cool the Recirculation Spray (RS) heat exchangers which are not required to be OPERABLE in MODES 5 or 6. It also provides cooling water to the Component Cooling Water system (which supports no accident loads), the main control room coolers, instrument air compressors, and charging pump gearbox coolers. This LCO does not meet the criteria for retention in the ITS; therefore, it will be retained in the Technical Requirements Manual. I I

I 1

.1__________________________ --

Change Category:

I - Removing Details of System Design and System Description, Including I)esign Limits 2 - Removing Descriptions of System Operation 3 - Removing Procedural Details for Meeting TS Requirements and Related Reporting 4 - Removing Performance Requirements for Indication-Only Instrumentation and Alarms 5 - Removal of Cycle-Specific Parameter Limits from the Technical Specifications to the Core Operating Limits Report PagellIof 14 R-3.7 North Anna Power Station

Table R- Relocated Specifications and Removed Details ITS Section 3.7 - Plant Systems CTS Change Control Change Requirement Declcription of Relocated Requirements Location Process Category DOC No.

3.7.5.1.b CTS 3.7.5.l.b states that one of the ultimate heat sinks that shall Technical 10 CFR 50.59 R CTS 3.7.5.l.b R. I be OPERABLE is the North Anna Reservoir with a minimum Requirements water level at or above elevation 244 Mean Sea Level, USCG Manual Datum, and average water temperature of* 950 as measured at the condenser inlet. The North Anna Reservoir provides makeup to the Service Water Reservoir for 30 days after a Design Basis Accident (DBA) as necessary to maintain cooling water inventory, ensuring a continued cooling capability. The Service Water Reservoir is credited as the ultimate heat sink for the DBA. The Service Water Reservoir contains adequate water to provide at least 30 days of cooling to support simultaneous safe shutdown and cooldown of both units and their maintenance in a safe shutdown condition. The Service Water Reservoir also provides sufficient cooling for at least 30 days in the event of an accident in one unit, to permit control of that accident and permit simultaneous safe shutdown and cooldown of the remaining unit and maintain them in a safe-shutdown condition. The North Anna Reservoir serves as a backup to the Service Water Reservoir. This LCO does not meet the criteria for retention in the ITS; therefore, it will be retained in the Technical Requirements Manual.

CTS 3.7.6.1 states the maximum elevation of the North Anna Technical 10 CFR 50.59 R CTS 3.7.6.1 3.7.6.1 R.] Reservoir. Ifth;s limit is exceeded, flood control measures are Requirements required to protect safety related equipment. This LCO does not Manual meet the criteria for retention in the ITS; therefore, it will be retained in the Technical Requirements Manual.

Chane Category I - Removing Details of System Design and System Description, Including Design Limits 2 - Removing Descriptions of System Operation 3 - Removing Procedural Details for Meeting TS Requirements and Related Reporting 4 - Removing Performance Requirements for Indication-Only Instrumentation and Alarms 5 - Removal of Cycle-Specific Parameter Limits from the Technical Specifications to the Core Operating Limits Report Page 12 of 14 R-3.7 Norlh Anna Power Station

Table R - Relocated Specifications and Removed Details ITS Section 3.7 - Plant Systems CTS Change Control Change DOC No. Requirement Description of Relocated Requirements Location Process Category CTS 3.7. 10 3.7. 10 CTS 3.7.10 states that snubbers shall be OPERABLE. The Technical 10 CFR 50.59 R R. I OPERABILITY of snubbers ensures that the Reactor Coolant Requirements System and other safety related fluid systems are adequately Manual restrained and supported during an earthquake and are free to expand and contract during normal operation as the system temperature changes. This LCO does not meet the criteria for retention in the ITS; therefore, it will be retained in the Technical Requirements Manual.

CTS 3.7.11. I 3.7.11 . I CTS 3.7.11.1 states each sealed source containing radioactive Technical 10 CFR 50.59 R R. I material either in excess of 100 microcuries of beta and/or gamma Requirements emitting materials or5 microcuries of alpha emitting material, Manual shall be free of greater than or equal to 0.005 microcuries of removable contamination. This LCO does not meet the criteria for retention in the ITS; therefore, it will be retained in the Technical Requirements Manual.

CT'S 3.7.12.1 3.7.12.1 and CTS 3.7.12.1 and Table 3.7-5 provide limits on the total and Technical 10 CFR 50.59 R R.lI Table 3.7-5 differential settlement of Class 1 structures. This LCO does not Requirements meet the criteria for retention in the ITS; therefore, it will be Manual retained in the Technical Requirements Manual.

Change Category:

I - Removing Details of System Design and System Description, Including Design Limits 2- Removing Descriptions of System Operation 3 - Removing Procedural Details for Meeting TS Requirements and Related Reporting 4 - Removing Performance Requirements for Indication-Only Instrumentation and Alarms 5 - Removal of Cycle-Specific Parameter Limits firom the Technical Specifications to the Core Operating Limits Report North Anna Power Station Page 13 of 14 R -3.7

Table R - Relocated Specifications and Removed Details ITS Section 3.7 - Plant Systems CTS Change Control Change DOC No. ReqUirement Description of Relocated Requirements Location Process Category CTES 3.7.13 3.7.13 CTS 3.7.13 requires periodic measurement of the groundwater Technical 10 CFR 50.59 R R. I level at locations around the Service Water Reservoir. The Requirements groundwater level of the Service Water Reservoir is used to Manual monitor long-term performance of the Service Water Reservoir dike. Failure to meet the requirements of the LCO does not result in the inoperability of the Service Water System. The ACTIONS direct that evaluations be performed to determine cause and consequences of the high groundwater level. This LCO does not meet the criteria for retention in the ITS; therefore, it will be retained in the Technical Requirements Manual.

Change Category:

I - Removing Details of System Design and System Description, Including Design Limits 2 - Removing Descriptions of System Operation 3 - Removing Procedural Details for Meeting TS Requirements and Related Reporting 4 - Removing Performance Requirements for Indication-Only Instrumentation and Alarms 5 - Removal of Cycle-Specific Parameter Limits firom the Technical Specifications to the Core Operating Limits Report

. North Anna Power Station Page 14 of 14 R -3.7

Table R - Relocated Spccifications and Removed Details ITS Section 3.8 - Electrical Power Systems CI'S Change Control Change Rcquircment Description ol Relocated Requircments Location Process Category DOC No.

3.8.1 LA. I 4.8.1 I.12.d.5. CTS SR 4.8.1. 1.2.d.5.c states that all non-critical EDG trips will Bases ITS 5.5.131 C be bypassed on a loss of voltage on the emergency bus and/or a Technical sale ty irijeCtion actuation signal. The no n-critical trlips (d0 not Specifications include engine overspeed, generator diflerential, and EI)G output Bases Control bieaker ovIcrtcurent. ITS 3.8.9. 12 states, "Verify each EDG's Program automlatic tiip are bypassed on actual o01r siiulatcd autOllinat iC Stalrt signal except engine overspecd and generator difflerential current.

This changes the CTS specifically staling that the non-critical EDG trips are bypassed on any automatic start signal. The specific auto i atic starl signals of a Salfety injection, a loss of, voltage on the emergency bus, and a loss of voltage on the cmergecncy bus with a saf.ety injection actuation arecmoved to the ITS Bases.

4.8. I. 1.2.a.5 CTS SR 4.8.1. I .2.a.5 requires the verification that each EIDG is Bases ITS 5.5.13, 3.8.1 LA.2 aligned to provide standby powver to the associated emcrgency bus. Technical ITS 3.8. I SRs do not contain this requirement. This changes the Specifications CTS by deleting the requirement firom the Technical Specilicatiois Bases Control anol moving it to the ITS Bases. Program Not used. N/A N/A N/A 3.8.1 LA.3 N/A CTS Surveillance Requirement 4.8. I.1.2.d1.2 states at least once Technical 10 CFIR 50.59 3 3.8.1 IA.4 4.8. I.1.2.d.2 per 18 montlhs during shutdown, verify dhat the load scquencing Requirements timers are OPERABLEI with times within thc tolerances shown in Manual Table 4.8- 1. ITS SR 3.8.1.16 requires the verification of each seqtuenced load block is within the design tolerance Ir each emergency load sequencing timer. This changes the CI'S by moving the list of required selpoints, tolerances, and initiating signals from the Technical Specificalions to tTheIRM.

Not usCeL. N/A N/A N/A 3.8.1 LA.5 N/A Change Category:

I - Removing Details of System Design and System Description, Including Design Limits 2 - Removing Descriptions ot System Operation 3 - Removing Procedural Details for Meeting TS Requirements and Related Reporting 4 - Removing Performance Requirements for Indication-Only Instrunmntation and Alarms 5 - Removal of Cycle-Speci tic Parameter Limits Flrom the Technical Specifications to the Core Operating Limits Report Page I of 8 R-3.8 North Anna Power Station

Table R - Relocated Specifications and Removed Details ITS Section 3.8 - Electrical Power Systems Change Control Change CTS Process Category Description of Relocated Requirements Location DOC No. Requirement Technical 10 CFR 50.59 3 3.8.1 LA.6 4.8.1.1.2.(1.9 CTS Surveillance Requirement 4.8.1.1 .2.d.9 requires at least once per 18 months, during shutdown, the verification that the EDG Requircments lockout features of the remote local sclection switch and the Manual emergency stop switch prevent (tie EDG from starting. This changes tei CTS by moving the requirement For verifying lockout Feature requirlmen ts fiFom the Technical Spec ifications to the TRM.

Technical 10 CU-R 50.59 3 3.8.1 I,A.7 4.8. I. 1.2.1 CTS requirement 4.8.1.1.2.1 states once pcr 24 iontlhs during any mode of operation, each EDG will be subjected to a preventive Requirements mainitenaance inspecnion, in accordance with maintenance Manual procedures appropriate for the diesel used for this class of service.

The requirement is not appropriate For fhe Technical Specifications and is imloved to the TRM.

Bases ITS 5.5.13, 3 3.9.1 LA.8 LCO 3.8. 1. I CTS LCO 3.8.1..1 describes the two required offsite circuits as, "physically independent" and the emergency diesel gencrators Technical Specifications (EDGs) as "separate and independent.' ITS LCO 3.8.1 describes Bases Control the two of fsite circuits as '"qualified" and states the requirenmnts ally Progri am for the EI)Gs as "two." The descriptive inflOrniation, "-physic independent" aand "separate and independent" is not appropriate for the Technical Specification and is mnoved to the Bases.

Bases ITS 5.5.13, 3.8.1 I.A.9 4.8.1.1.2.d.] CTS Surveillance Requirement 4.8.1.1..2.d. I requires vei'ification Technical ihat oil a load rejection of 610 kW, the EIG frequency remains <

Specifications 66 Hertz, and recovers to a steady state voltage and frequency Bases Control within specified limits. ITS SR 3.8.1.9 utilizes the phrase "single Program largest post-accident load" and the specific value of1"10 kW is moved to the 'ITSBases.

N/A N/A N/A 3.8.2 None N/A N/A Change Catego'rv:

Including Design Iimil:u I - Removing Details of System Design and System lDMscription, 2 - Removing Descriptions of System Operation Related Reporting 3 - Removing Procedural Details for Meeting 'S Requirements and Requirements for Indication-Only Instrumentation and Alarls 4 - Removing Performance Specifications to thit Core Operating Limits Report 5 - Removal of Cycle-Specilfic Pariameter limits froml the Technical

- . . 1... pn  ? ,-fR- 3.8 North Anna Power Station rag zltwoi to

Table R - Relocated Specifications and Removed Details ITS Section 3.8 - Electrical Power Systems Change Control Change CTS Location Process Category 1)OC No. Requi remnenit Description of Relocated Rcquircellents Bases ITS 5.5.13, 3 3.8.3 LA. I LCO CTS LCO 3.8. I. I .b.2 and 3 and LCO 3.8.1.2.b.2 and 3 statc a fucl Technical 3.8.1.1.b.2, oil system consisting of two underground lanks each containing a Specifications LCO mninimumn of 45,000 gallons of fuel (T'his is a sharcd systcm with Bases Control 3.8. ..I b.3, the other unit), and a separate fuel oil transfcr system. ]'he Program LCO inoperability of the fue l oil system afflets hothun i ts and both units 3.8.1.2.1,.2, would be required to shutdown if an inopelrable ful oil system I.CO were not restored to OPERABLI status within allowed outage 3.8.1.2.b.3 times. ITS 3.8.3 does not state the specifics of the fuel oil system, such as the fact that the tanks are underground and that it is a shared system. 'This inl'orniation is contained in the ITS Bases.

ITS 5.5.13, 3 3.8.3 LA.2 3.8.1.1 CTS 3.8. I.1 Action ['and 3.8.1.2 Action b rcquire, with one Technical Action f, and underground fuel oil storage tank ol 3.8. I. I.b.2 inoperable, thie Speci lications 3.8.1.2 performance of Surveillance 4.8.1.1.4 or tank repairs, and that Bases Control Action 1) i-cplaccmnCnt fuel oil mLust yvcieicd as available. This includes the Program verification of availability o0 50,000 gallons of fuel oil and transportation that can deliver it within a 48-hour period. ITS 3.8.3 Condition A states, "Onc fuel oil storage tank not within liimits, veyrify repllacemmcit oil is available, prior to removing tank from service. This changes the CTS by moving the details of transportation of 50,000 gallons of fuel oil within a 48-1hour period from tlhe[echnical Specifications to the ITS Bases. 3 Bases ITS 5.5.13, 3.8.3 1,A.3 4.8.1.1.2.b CTS Surveillance Requirement 4.8. I. 1.2.b states that the fucl oil TFechnical tank is within the acceptable limits specificd in Table I of AS'T'M Specifications D975when checked For viscosity, water, and sediment. ITS SR 13ascs Control 3.8.3.2 verifies fuel oil properties and SR 3.8.3.4 che.ks for and Program removes accumulated water from each stored fuel oil tank. The Bases for SR 3.8.3.2 discusses viscosity and sedimnect. This changes the CTS by moving the rcquirements of viscosity and sediment fiom the Technical Specifications to the ITS Bases.

I _________ I Change Cat cory I - Recmoving Details of System Design and System l)cscriptiO n, Including l)esign Linmits 2 - Removing t)escriptions of System Operation Reporting 3 - Removing Procedural Details for Meeting 'I'S Rcquiremcnts and Related 4 - Removing Pecrlormance Requirements for Indicationi-Only Instrumentation and Alarms Limits from the Technical Specifications to thle Core Operating Limits Report 5 - Removal of Cycle-Specific Parameter Page 3 of 8 R-3.8 North Anna Power Station

Table R - Relocated Specifications and Removed Details ITS Section 3.8 - Electrical Power Systems ChanIlge Control Chiangc CTS L.ocation Process Category DOC No. Rcquiireiciint I)cscripltion of Relocated Requirements

'TecIinical 10 CFR 50.59 3 3.8.3 LA.4 3.8.1.1 CTS 3.8. I. I Action f allows tile inn pcrability of oe undergrou nd Requirements Action f1, I'ucIOil tank for the perforrmancC of SurIvye ill ance Rcq uirid nent Manual 4.8.1.1.4 4.8. I. 1.4 or tank repairs. CTS SR 4.8. 1.1.4 requires each Underground EDG I'el oil storage tank every 10 years to be drained, the sediment to be removed, and the tank to be inspected for integrity, and cleaned. ITS 3.8.3, Condition A. allows one fuel oil storage tank to be inoperable to perform inspection or repair.

This changes the CTS by nIoving these rcluircmcnlts from the specif'ication to the Tecnicainlea I irCements Manuii al (TRMI).

lReq I I I I ITS 5.5.13, I I Bases C'T'S LCO 3.8.2.3 describes the specific 125 volt DC( buscs and Bases 3.8.4 LA.I L(CO 3.8.2.3 Technical batteries, and associated chargers tIhat define Trains H- and J Specifications requirements. ITS LCO 3.8.4 does not contain these speciflic Bases Control rcquiirmcints and states that the Train I- and J DC electrical power Prograill subsystems shall be OPI£RABLIi. 'This changes the CTS by moving in forimation from Ihe Spec ificat ions to the Bases.

I IL -I. -I Bases ITS 5.5.13, I 3.8.4 iA.2 4.8.2.3.2 1, CTS surveillance requirements 4.8.2.3.2 f. and 4.8.1. 1.3 C.

Technical 4.8,1.1 .3.c describe tihe limits of degradation of balleries in terms of capacity.

ITS SR 3.8.4.9 does not contain these specific requiremens', but Specificat ions

'Vc battcry Bases Control continues to require specific testing requirements 1* nSto changes the CTS by moving intormatio n Prograill OPERABILITY. This from the Speci hcations toithe Bases. I - I Change Categorw Limiis I - Removing Details of System Dcsign and System l)escriplion, Inchluling Dcsign 2 - Rcmoving Descriptions of System Operation 3 - Removing Procedrial elctails for Meeting I'S Requirements and Related Reporting 4 - Removing Performance Rcqu,iremnlts for Indication-Only Instrumcntation and Alarms to the Core Operating L imits Report 5 - Removal of Cyclc-Speiciefic Parameter limits from the Technical Specilications Page 4 of'8 R - 3.8 North Anna Power Station

Table R - Relocated Specifications and Removed Details ITS Section 3.8 - Electrical Power Systems CTI'S Requiremlent Description ol Relocated Requiremlents "1)OC No.

ITS 5.5.13, 3.8.4 IA.3 3.8.2.3, CTS Action 1. states that when the 125 volt D.C. battery and/or its Technical

/'.ction b charger is inoperable, that they must be restored to OPIRABLE Speci lications status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or the Unit must be in at least HOT Bases Control STANDBY within (he next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTI)OWN Program within th lfollowing 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. Surveillance rCquiretments for station and EDG batteries specify requirement for the batteries and chargers. ITS Action A requires hoth Trains of DC Sourcus to be OPERABI,.E and if one becomes inoperable, it tnmtust be restored within 2 houls o01- tlhe tUnit he placed in MODE 3 in the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 5 in the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. This changes the CT'S by moving the rc Iloiences to batteries and chargers hroinIthe specifications to the ITS Bases.

3.' 5 I

,LA. CO 3.8.2.2 CTS I CO 3.8.2.2 lists the specific Train' ii and J requirements.

ITS 5.5.13, "Technical r-T-11 "These consist of the 4160-volt emergency buses, 480-volt l)Lises, Specifications 120-volt AC buses, and 125-volt DC buses. ITS LCO 3.8.5 states Bases Control that the DC electriical pIIowCer suhsystin(s) requhird by LCO 3.8. 10, Ptogmailln "Distribution Systems - Shutdtown," shall Ibe OPFRAIABII". ITS 3.8.5 Loes not conltain the list of huses that makeup anO cclccml train. "l'his changes the CTS by moving the makeup offlie electrical tIrain fromthele Technical Specifications to Ihc t !TSI ases of ITS LCO 3.8.9, "Distribution Systems-Operating."

ITS 5.5.13, 3.8.6 lA. I 4.8.2.3.2 b.13 C'T'S SurCvillance rCquirement 4.8.2.3.2 b.3 states."A/Vra-.; Technical electrolyte temperature of a least 10 connected cells is abowv 60 Speci ficat i oils

'F.' ITS Action B and SR 3.8.6.3 requite the "eClectrolyte Bases Con tr)ol tenlierature of representative cells" to be > 60 OF. This changes Program the CTS by replacing "'10" cells with '"representative" cells and moving the 10 cell requireinolt fi'ron the Specification to tihe ITS Bases.

Change Categoiry:

I - lRcenmving Details of System Design and System l)cscription, Inchlding Design liAits 2 - Remmovi nDI)cscriptions o1 System OpCeation Related Reporting 3 - R*eoving Procedural Details for Meeting 'FS Requirenients and and Alaris 4 - Removing Perl'orma*nce Rquiremntns lor Indication-Oily Instrumntnation limits from the Technical Specifications to tile Core Operating Limits Report 5 - Removal of Cycle-Specific Paranmetr Page 5 of 8 R - 3.8 North Anna Power Station

Table R - Relocated Specifications and Removed D)etails ITS Section 3.8 - Electrical Power Systems Change Control Change CTS Calegory Location Process DOC No. Requirement IJescription of Relocated Requirements N/A N/A N/A 3.8.6 LA.2 N/A Not used.

Bases ITS 5.5.13, 1 3.8.7 LA. I LCO 3.8.2. I A footnote to CTS LCO 3.8.2. I states, "Two inverters may be Technical footnote disconnected from their D.C. Busses for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> as Specifications necessary, for the purpose ol performing an equalizing charge on Bases Control their associated batteries provided (I) their vital busses aie Program energized, and (2) the remaining vital busses are cncrgized from their associated inverters and connected to their associated D.C.

Busses." ITS LCO 3.8.7 Notes to the Actions state that inverters may be disconnected from their associated DC bus lfr .<_ 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to pIerform ant equalizing charge on their associated battery runder two conditions. Condition one, the associated AC vital bus is energized From its constant voltage sourice tranlslortnv.r. Con0dition two, all other AC vital buses arc energized from their associated OPERABLE invcrters. This changes the CTS by moving the requirement that the remaining vital buses ale "concnected to thliir associated D.C. Busses," from the Specification to Ihe Bases.

N/A N/A N/A 3.8.8 None N/A N/A Changce Category:

Limits I - Removing Details of System D)esign and System Description, Including Design 2 - Removing Descriptions of System Operation 3 - Removing Proccdural Details for Meeting 'S R*equirements and Related Reporting and Alarms 4 - Removing Performance Requirements for Indication-Only Instrumentation from the Technical Specifications to the Core Operating Limits Report 5 - Removal of Cycle-Specific Parameter Limits Do,..r...UiR R - 3.8 North Anna Power Station radge tooi o

Table R - Relocated Specifications and Removed Details ITS Section 3.8 - Electrical Power Systems f t I CTS Change Control Change ILocation Process Category DOC No. lzcRquirclent I)escription of Relocated Requircments I. I-3.8.9 L.A. I LCO 3.8.2.1, CTS LCO 3.8.2.1 states, "The following A.C. electrical busses Bases ITS 5.5.13, shall be OPERABLE and energized ...... CTS LCO 3.8.2.3 Technical I.CO 3.8.2.3, states, "The following D.C. bus trains shall be energized and Spcci fications 4.8.2.3.1 Bases Control OPERABLF.... " CTS 3.8.2. I Actions a and b state, " With one Program of the required AC or AC Vital Buses not energized, re-energized bus," within specific allowed outage times. Simihlary, CTS SR 4.8.2.3. I states, "Each D).C. bus train shall be determiincd OIFRABLE and energized..'.-ITS LCO 3.8.9 states, "The Train 14and Train J AC, DC, and AC vital bus electrical p wci distribution subsystems shall be OPERABIE." ITS SR 3.8.9 1 states, "Verify correct breaker alignments and voltage to required AC, l)C, and AC vital bus electrical power distribution subsystems." This changes the CTS by moving the reqluirement for the buses to be energized with tic breakers open between redundant buses from the SSpecification to the 1Bases.

I I 3.8.9 I.A.2 LCO 3.8.2.1, CTS LCO 3.8.2.1 states, "The following A.C. clectrical busses Bases ITS 5.5.13, Technical ICO 3.8.2.3 shall be OPERABILE ... 1-I and J A.C. emergency busses," with 4160, 480, and 120 VAC buses specified. CI'S LCCO 3.8.2.3 states Spcci fications Bases Control that the Train A and Train B DC buses wvith specific designations.

Program ITS 3.8.9 states, "Train H and Train J AC, I)C, and AC vital bus electrical power distribution subsystems shall be OPEIRABLF

This changes the CTS by moving the specific names of the buses fIron the Specification 11othe Bases.

Change Cate gory:

I Removing Details of System Design and System Description. Including Design Limits 2- Removing Dcscriptions of System Operation 3- Removing Procedural Details for Meeting 'TS Requirements and Related Reporting 4 - Removing Pelrformance Rcquiicinlets for ImnIndication-Only Instrumentation and Al arrm's 5 - Removal oflCycle-Specific Parameter Limits from tih lTechnical Specifications to tle Core Operating Iimits Report Pagec 7 of 8 R - 3.8 North Anna Power Station

'Fable R - Relocated Specifications and Removed Details ITS Section 3.8 - Electrical Power Systems CTS Change Control Change DOC No. Requircnmrlt Descriptioni of Relocated Re?,cquirCeents Location Process Category 3.8.10 I.A. I LCO 3.8.2.2 CTS LCO 3.8.2.2 states, "The following A.C. electrical huses Bases ITS 5.5.13, 1 shall be OPERABLE-...1H and J A.C. emergency busses," with Technical 4 160, 480, and 120 VAC buses specified. ITS 3.8.10 states, "The Specifications necessary portion of AC, DC, and AC vital bus electrical power Bases Control distribution subsystcms shall he OPERABLE, to support equipment Program required to be OPERABLE." This changes the CTS by moving description of Lhe buses 1lom the Specificalion to the Bases.

CTS 3.8.2.5 Unit 2 3X8.2.5 Unit 2 CTS 3.8.2.5 states the primary and backup containment Tcchiiical 10 CFR 50.59 N/A R.. I penetration conductor overcuIrl'elt protective devices associated Requirements with each conltain1 mcut clectrical penetrationi circuit Shall be Manual OPERABLE. This LCO does not meet the criteria for rretcntion in the ITS; therefore, it will he retained in the Tl'eclincal Requirements Manual.

(C'TS 3.8.2.6 Unit 2 3.8.2.6 Unit 2 CTS 3.8.2.6 states the thcrmal overload piotectioni devices, Tcclhnical 10 CFR 50.59 N/A R. I integral with thie eietor starter, of each valve ill the sa felty systemn RCq nil e mei t s shall he OPIERAB3LE. This ICO does not mccl the critcria for Manual retention in the ITS; thereflore, it will be rclained in tlle 'echnical ReqIuiremeints Manual.

CTS 3.8.2.7 Unit 2 3.8.2.7 Unit 2 CTS 3.8.2.7 states that all circuils that have containment Tlechnical 10 CiR 50.59 N/A R. I pctrtctations and arc not requiii red during reactor opcratlions shall he Rcluiictile uts de-cnergized. This LCO (loes not nieet the criteria fOr rectnlitio( in Manual the ITS; therefore, it will be retained inlthe l'cchnical Requirements Manual.

Change Catelor)-:

I - Removing Details of System Design and System Dtescription, Inchtliding Design Li nits 2 - Removing Descriptions ol System Operation 3 - Removing PFroccdural Details for Meeting TS Requirements and Related Reporting 4 - Removing Performance Requirements For Indication-Only Instrumentation and Alarms 5 - Removal of Cycle-Specific Paratie ter Limits froin tlhe Technical Spec ifications to thI'.' Core Opt ratirg litilts Report North Anna Power Station Page 8 of 8 R -3.8

Talblc R - Relocated Specifications and Removed Details ITS Section 3.9 - Refueling Operations Change Control Change I)OC No. CTS Rcqoirieient Dcscription of Relocated Requircilients ILocation Process Category CTS 3.9.1 states that thie boron concentration in MODE 6 COLR ITS 5.6.5, Core 5 3.9.1 IA. I 3.9. I shall he the more restrictive ol a K, 1of" 0.95 ora horon Operating Limits concentration ol' >2600 ppmn or Unit I and > 2300 ppml [or Report Unit 2. ITS LCO 3.9. I states that tife boron con11centration shall he within the Ihinlit speCilied in the COI.R. This changes

[he CTS by relocating the MODIE 6 boron concentration lil1it to the Core Operating lnilts Report (COLIR).

COI .R ITS 5.6.5, Core 5 3.9.2 IA. I Unit 2 3. I. 1.3.2 Unit 2 CTS 3.1.1.3.2 Action states that with the prinlary grade Action water flow path isolation valves not lockcd, sealed, or' Operating Limits otlherwise secured in the closed position, verify the Report SHUTDOWN MARGIN is grealr Ihtl-iI or equal to i.771h.

Ak/k. ITS 3.9.2, Action A.4, states this requirCeinil tll as, "Perl'orm SR 3.9.1.LI." ITS SR 3.9.1.1 requires verification that the RCS boron concentration is within the liniit lriovided in the COIR. This clangcs the CTS hy iOloving the SHUTDOWN MARGIN value Io the COLR.

3.1.1.3.2 Unit I CTS 3.1.1.3.2 states "The Following valves shall he Bases ITS 5.5.13, 3.9.2 IA.2 locked, sealed, or otherwise secured in tihe closed position Technical except during planned boron dilution or tinake up aclivitiics: a. Specifications Bases I-CH-217 or b. I-CH-220, I CH-241, FCV 111413 :nd [-CV- Control Program I 13B." Unit 2 CTS 3.1.1.3.2 states "'The I'Ollowinl1 valves shall be locked, sealed, or otherwise secuirerl d ill the losed osit ion except during planned boron dilulti(1 r ioniakeoi activities: a. 2-CH-]140 or b. 2-CH- 160, 2 CIf1-156, 11,V 2114B and FCV-2113B." ITS 3.9.2 states, "Primary grade water flow patls shall he isolated Flromll the RCS." ITS 3.9.2 LCO Note states, "Primary grade waterf low path is-.latio,11) valves may be opened tinder adminillistrativ CIontroll !"r planned boron dilution or makeulp activities." This' changes Chiange Category."

I- Remnoving Details of SystemLDesign and Systeml)eseriptiiln, Ihcluding Design LinllilS 2 - Removing Descriptions (o System Operation 3- Remloving Procedural Details for Meeting I'S Requirements and Related Reporting 4- Removing Perfornmance Requirements for Indication-Only lnstrumeiltation and Alarms ilmits Rcport Ing 5- Reioval or Cycle-Slicific Parameter Limintis romnthlie Technical Spccil'ications to the Core Operratini North Anna Power StationP Page I of 4 R - 3.9

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Table R- Relocated Specifications and Removed Details ITS Section 3.9 - Refceling Operations asse inhi y and a Rod( Control Cluste r Assembnhly, and that an automatic load limiting device is available to preven! (&mniagc to tlhe fuel 1aSSemlbly durlin~g FUel O1( ye men 1. 'Lbhis 50CC ilic at ion also ensures that tile auxiliary hoist onlthle Manipulator C;- 'llane has adequate capacity for latching and onlIat chin g conttrolI rod dIrivye shafIts. This I CO does not mnee title Criite r ia Ir rete ntIion il the ITS; t heref ore, it will be ret ained ll inlte 'c~h nic a Requ~irementIIs. Manual.1

,_Categ Chance :_ry I - Removing l)etails of System l)csign and Systlem l)escription, IncludingIl)esign II nit'z 2 - Removing Descriptions of System Operation 3- Removing Procedural Dletails f0r Meeting TS Requ,ir'emenls anl Related Reporting 4- Removing Ierlformance Rcquirements for Indication-Only Instrumentation and Alarms 5 - Removal of Cycle-Spccl lic Parameter i imits fro inthe Techmical Speciflications to thie Core Operating Limits Report North Anna Power Station Page 4 of 4 R - 3.9

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Table R - Relocated Specifications and Removed Details Irs Section 4.0 - Design Features Change Control Change DOC No. CIS Rcquircmelt I Desciription of RhIiocatcd Rcqujiicnmelts I 1...

t.OCI1IO1l L=ocati)n I Process 10 CFR 50(.59(9 Category J1'FSAIZ 4.0 LA.5 5.2 CTS 5.2 describes the reactor cooliat system. The ITS does not contain this informnation. This changes the CIS hy elilinating the description of the ieactor lcoolant systeil.

U-SAR 10 CFR 50.59 4.0 LA.6 5.5 CTS 5.5 describes the location of tie meteorological tower.

Ile ITS does not contain tis inkrination. This changes the CTS by elimint ing the location of the meteorological towelr.

I I ChangeCatc gory.

- Renoving I)etails of System Design and System I)escriptoiAl Including Design IWEioi.

2. Removing Descriptions of System Opcration and Related Reporting 3 - Removing Procedural Dctails for Mecting IS Rcquircmcnts ments for Indicalion-Only Instrumentaion and Alains 4 - Removing Performance Rcq, i c 5 - Rewmoal o[ Cycle-Specific Paramcter Li mits ofrom the Technical Specifications to the Core OperatingtLimits Rceport Pagc 2 of"2 R - 4.0 North Anna Power Station

Table R - Relocated Specifications and Removed Details ITS Section 5.0 - Administraiive Controls Change Control Change DOC No. CTS .equircniient Description ol Relocated Reqtuirements Location Process Category 5.0 LA. 1 6.8. I.i CTS 6.8. I.i requires written procedures hc established, UFSAR 10 CFR 50.59 3 implemented and maintained covering, "Quality Assurance ProgramI for fcluent and environncntal monnitori ng, using the guidance in Regulatory Guide 1.21, , evision I, June 1974 and Regulalory Guide 4. 1, Revision I, April 1975." ITS 5A4. I.x does not includc tile Recgulalory Guidc relCrences. ']'[its changes the CTS by moving the ieflerences t the egulalory R Guides to the UISAR.

5.0 IA.2 5.7. I CTS 5.7. I states, "The components identified in 'Table 5.7-1 UFSAR 10 CFR 50.59 arc decsigncd and sihall be mainlai ned Within tlie cyclic or transient limits ol Table 5.7-I." CTS Table 5.7-I contains ith limits Imr componernt cyclic or transient limits and d1:.,;ig .:scycle or transient limits. ITS 5.5.5 states, "'T'he ,componeIlls identified itl the UFSAR, Section 5.2, are dcsigned arid shall be naintaitned within the cyclic or transient design limit."

Thiis changes the CTS by moving the limits spccilted inlTable 5.7-1 to tie UFSAR and calling them the cyclic or itransiclt design li itits.

5.0 I.A.3 6.8.4. Ib CTS 6.8.4.J, "li-Plant Radiation Monitoring,"' dscs Ihcs a UF'SAR 10 CFR 50.59 Note I progralm vwhich will ensuret lie capability to accuratcel.!

determin e lieairborne iodine c concent ration Iiin vital are1as tdIr accident conditions. ITS 5.0 does not require such a p,,.,n, This clihatge nioves the requiretuetits of C'ITS 6.8.4.h to the UFSAR.

Change CIavIteIry:

I - Retmoviing Details of SystemiDesign and System Description, Including l)esignt Limits 2 - Removing l)escriptions of Systeni Operation 3 - Removing Procedural l)etails for Mcci tg TS Rcq ircicnetS and Related Reporting 4 - Removing Perltormance RequinirementIs flr I-nd icatiiriO-OtlIy Intis;t ru roentaltiO riaMiAlarms 5 Removal of CycleISpecific Parameter Limits fromi the Technical Specifications to illh 'ore o)Operating Iniluts Report Note I - Certain Relocated Specifications and Removed Details changes for CChapter 5.0 did not fkll into tie categon icS used For the other Chapters. A specific I)etcrmination oL No Significant IHazards Consideration was Written for eachti on-cat 'gorized change.

North Anna Power Station Page I o1'4 R - 5.0

Table R - Relocated Specifications and Removed Details ITS Section 5.0 - Administrativc Controls

_________________ __________________________ - 1 1 Change CoiitI(Il

- . I CII lll CPangerControl Change Process Category Description of Rclocatld Rcquirenllents Locat ion DOC No. CTS IC.cquirement I - , " --- I....

........ 1 1 i - . ---t 7QA -Topical It) CFR 10 50.59 (YR 50.59 I Note I 5.0 LA.4F6.2.3 CTS 6.2.3 specifies thie function, composition. responsibility, Report and authority of the Station Nuclcar Safety (SNS). ITS 5.2 does not contain this requirement. This changces the CTS by deleting the requirements of CTS 6.2.3 and relocating them (IOthe QA Topical Report.

I -t T VH'lT ITS 5.5.10, 3 5.10 L A.5 4.7.7.1 and CTS 4.7.7. I (Control Room Emergency Ventilation System)

Ventilation F'ilter 4.7.8.1 and 4.7.8.1 (Salfeguards Area Ventilation System) specify thie Testing FProgram Surveillance Requiremlents and( 'lrc(lucncics for dcmonstrating (VI'ltP)

OFRIRABILITY. ITS 5.5. 10, "Ventilation Filter Testing Programn (VIrFP) does not include someifo the Surveillance Requirements and Frequencies spccil'icd in the CTS. This changes the CTS by moving these details I tIhe VIII'.

I4. I I I....... Note I 5.0 1,A.6 6.5, 6.6.1 .b, 6.8.2, CTS 6.5, 6.6. I.1, 6.8.2, 6.8.3, and 6.15.b specify the functiui, QA Topical 10 CFR, 50.59 Report 6.8.3, and 6.15.1 Comsli)tSion, use oCaltrllates, meeting frequency, quorum, responsihilities, authority, and records of the Station Nuclear Safety and Operating Committee (SNSOC) and the Management Safcly Review CommittCe (MSRC). CTS 6.5 ,lst) specifics tile use of'consulltants, rcvicws and audits imrthe MSRC. ITS 5.0) doCs not containitheserquircnlcnts. "This changcs the CTS by relocating tile rcquirements for the SNSOC and MSRC to tiCt QA Topical Report.

I I -L __________________________________

Chairgc atecory I - Removing Details of System Design and Syslem Description, Inchuding Designi1.imin 2 - Removing Descriptions ol Systeml Operation 3 - Removing Procedurial l)cails for Mecting 'TS Requirements and Rclatcd Reporting 4 - Removing Perforimancc Rc(lqirci Crts for Ilrication-Only Instrumentation and Alarms Limits Report 5 - Rcmoval of Cycle-Specific Paramctcr Iimits from thc Technical Specifications to the 'Corc Operating not fall iinto the" categories used for the otlier Chapters. A specific Note I1- Ccrtain Relocated Specifications and RemovedD)ctails changcs Ior Chapter 5.0 did DctcrnIi nation of No Significant I lazards Consideration was written fo1r each. ion-categorizlch ange.

F'age 2 of 4 R - 5.0 North Anna Power Station

Table R - Relocated Specifications and Removed Details ITS Section 5.0- Administrative Controls 1 1 I (iltange Ehange (iontrol I Change Control ChaInge Category Process CTS Requirement Dcscription of Relocatcd Rcequirciictnls Location DOC No.

T'echnical 10 CFR 50.59 3 5.( 1I.A.7 3.11.1.4,3.11.2.5 CTS 3.11 .I .4, L1,iquid Holdup ['Tanks, imposes limits on the Require ictcnts and 3.11.2.6 quantity o"fradioactive material contained in each tank .C'TS Manual 3.1 1.2.5, Explosive Gas Mixture, limits the oxygen concentration in the Waste Gas Decay Tanks to ensuc that tihe conccntration of' potentially explosive gas mixtures in tile Waste Gas 1)ecay Tanks is maintained below the Ilammability limits for hydrogen and oxygen. CTS 3. I1.2.6, Gas Storage l'anks, imposes lilIits oi the quanltity OF1 adioactive material conltained in each tank. ITS 5.5.1 I, "Fxplosive Gas and Storage Tank Radioactivity Monitoring Program," does not conltain tile spIecific ru(JLtircments, Applicability, Actions, and Surveillance Requirements in CTS 3.11.1 .4, CTS 3.11.2.5, and ("I'S

3. 1I.2.6. This changes the CTS by moving this inliormalion to the T'RM.

IJILSAR 10(t IBR 50.593 6.8.4.g CTS 6.8.4.g contains the requirements for the Conitiguiralio(n Risk Management Program. ITS 5.0(ldoes not include requ irccnen ts for theConfIigu rat ion Risk Management Prograit. Th is cItanges the C'S by in viing tIci renic*uirenilts (Ior the Conlf'igoLratlionrRisk Ma nagectell l Program I iithe UI'SAR.

6.9.1.7.e CTS 6.9.1.7.e specilics t(le revisions and dates otl(' Iciferenced methodologies, and tlhe LCOs Ior which the refercnced COLR ITS 5.6.5, Core Operating Linlits T--,-I Report methodologies are used. ITS 5.6.5.b does not contain this level ofl detail. This changes the CTS by moving thetspecilic methodology referetnces for revisions, dates, and L(Os to tIhe It ,COER.

Change Catecgorq.

I - RemovinglDetails ol1 Systci Design and Systcni Description, IIIncliuding I)csign Linils 2 - Removing I)escriptions of System Operation 3 - Removing Procedural D)etails [for Meeting 'I'S Requirements and Related Reporting 4 - Rentmoving PerlIormance Requirementes for hIdWcat ionC-1-Oyln slruimcIltat itiOn and Alarnis 5 - Rentoval of Cycle-Specific Paranceter Limits from theT echnical Spccilications to thcGto i UOprrating Iimits Rcpoit Note I - Certain Relocated Specifications and Removed Details changes for Chapter 5.0 Mid not fall into tlhe categories used for the other Chapters. A specific D)teermnination of No Signiflicanlt Hazards Consideration was writtenlfor each nonl-categorized change.

Page 3 of 4 R - 5.0 North Anna Power StationP

Table R - Rclocated Specifications and Rcmoved Details ITS Section 5.0 - Administrative Controls Change Control Changc CTS Rcquircienlt Description ol Relocated Requirefmenils ILocation Process Category DOC No.

6.8.4.1' CTS 6.8.4.1f, "'Radiological Environmental Monitoring ODCM 10 CFR 50.59 Note I 5.0 LA.10 Program," describes a programn to o111 itor the radialion and radio( ic(idcs it) tihen cvifions of the plnMt. ITS 5.0 dioes not Ic~quiC such a program. 'Ilis changes the CTS by moving tIe nil MoitlOring rcq iircrmentls f1-r the RIad i(ological I nvi ron i iental Program to tle ODCM.

5.0 I.A. II 1)E IETEiD 4.6.1. I.c CTS 4.6.1. I.c states, "After each closing of the Cqtuipnlilt CLRTP 10 CFR 50.59 3 5.0 LA. 12 hiatch, by leak rate testii ng Ilie eCq Liplu e iii hatcIi seals, with gIas at P;,, greater than or equ0al to 44.1 psig. RCsulls shall he evaluated against the ritieri a of Specification 3.6. i.2.1h as required by 10 CFR 50, Appendix J, option B, as modified by approvecd exemptions, and in accordance with the guidelines contained in Regula tory (10Guide I. 163, dated Sepi c*ii ber 1995.'"

ITS 5.0 does not includc such a spec ii reIuirci or ie 0-eIlt equipment hatch. This changes the CTS by moving th' reference leak rate testing for (lie equiplent hatch !, tohe Containment Ieak Rate Testing lProgramn (CLRIz,).

Change CCategory:

I - Removing Details of System Design and Systcil l)escription, Including Design l.iilii.

2 - R*lovinig )cscriptiois ol Systciii Operatiol 3 - Renioviiig Procedforat Dctails for Meeting 'T IRequhielincnlts anid Related Reporting 4 - Removing Prformance Requiric for hd111(icallion-O nly InstiunMCniittlion and Al ai ms Ineonts a ov'Cycle-S peci lic Paramleter Liinits fron hlieTechnical Specilications to tile Core Operating imiitiits Report 5 - RemionwI Chapters. A speciflic Not t I Ceftlain Relocated Specifications and Remioved Details changes for Chapter 5.0(ldid not fall iiio tile categories usedl for tile other Deteriinationi of No Signiliicant Hazards Considerationoi was written for eachl noti-calce !olizcd change.

North Anna Power Station Page 4 o f 4 R - 5.0

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