Text

Attachment 4 - Table L - Less Restrictive Changes North Anna, Units 1 and 2, Amendmends 231 and 212
	ML021220067
Person / Time
Site:	North Anna
Issue date:	04/05/2002
From:	; Office of Nuclear Reactor Regulation
To:	;
References
	TAC MB0799, TAC MB0800
	Download: ML021220067 (162)
	v • d • e

ATTACHMENT 4 Table L - Less Restrictive Changes

Table L - Less Restrictive Changes ITS Section 1.0 - Use and Application 11CTS Requirement I liii Category ITS Requirement Change Category Description of Change ITS Requirement CTS Requirement DOC No. 1 1.0 definition ol 1 requires the use of a I 1.1 definitions of 1.1 definitions of 1.0 definition of Note I 1.0 L.I The CTS Section 1.0 definition of CHANNEL FUNCTIONAL TEST COTr and TADOT CHANNEL 1.0 splits the definition of FUNCTIONAL simulated signal when performing the test. ITS Section two definitions, the CHANNEL OPERATIONAL TEST CHANNEL FUNCTIONAL TEST into TEST (TADOT).

TEST (COT), and the TRIP ACTUATING DEVICE OPERATIONAL or simulated signal when The ITS COT and TADOT definitions allow the use of an actual use of unplanned: actuations to performing the tests. This changes the CTS by allowing the is collected to satisfy the surveillance test perform the Surveillance if sufficient information requirements.

1.1 definition of 1.0 definition of Note I to the movement or CORE 1.0 L.2 The CTS Section 1.0 definition of CORE ALTERATION applies CORE reactor vessel with the vessel head removed and .fuel ALTERATION ALTERATION manipulation of any components in the Section 1.1 definition of CORE ALTERATION will only apply to the in the vessel. The ITS in the reactor vessel. This movement of fuel, sources, or reactivity control components CORE ALTERATION the changes the CTS by eliminating from the definition of a that are not fuel, sources, or reactivity movement of any components in the reactor vessel the definition is discussed control components. The elimination of "or manipulation" from in DOC A.5.

requires that all 1.1 definition of 1.0 definition of OPERABLE Note 1 111.0 L.3 The CTS Section 1.0 definition of "OPERABLE - OPERABILITY" OPERABLE power sources be available for the system, OPERABILITY OPERABILITY necessary normal and emergency electrical or device to be OPERABLE. The ITS Section I. I definition subsystem, train, component,

- OPERABILITY" will replace the phrase "normal and emergency of "OPERABLE sources ". This electrical power sources " with "normal or emergency electrical power OPERABLE with either normal or changes the CTS by allowing a device to be considered emergency power available. I I Change Categories:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements No Significant Hazards the categories used for the other Chapiers. A specific Determination of Note I - The Less Restrictive changes for Chapter 1.0 did not fall into 1.0.

Consideration was written for each Less Restrictive Change in Chapter L- 1.0

n I1ý - 9 North Anna Power Station Page i ot z

Table L - Less Restrictive Changes ITS Section 1.0 - Use and Application Change Description of Change ITS Requirement CTS Requirement Category DOC No.

1.1 definition of 1.0 definition of Note I 1.0 L.4 The CTS Section 1.0 definitions of ENGINEERED SAFETY FEATURE RESPONSE TIME ENGINEERED ENGINEERED and REACTOR TRIP SYSTEM RESPONSE TIME require measurement of the response SAFETY FEATURE SAFETY FEATURE time from the sensor through the actuated equipment. The ITS definitions of (ESF) RESPONSE RESPONSE TIME ENGINEERED SAFETY FEATURE (ESF) RESPONSE TIME and REACTOR TRIP TIME and and REACTOR SYSTEM (RTS) RESPONSE TIME are modified to state, " In lieu of measurement, response time may be verified for selected components provided that the components and REACTOR TRIP TRIP SYSTEM methodology for verification have been previously reviewed and approved by the NRC." SYSTEM (RTS) RESPONSE TIME This changes the CTS by eliminating the requirement to include all components in a RESPONSE TIME response time test.

1.0 L.5 DELETED Change Categories:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements A specific Determination of No Significant tHazards Note I - The Less Restrictive changes for Chapter 1.0 did not fall into the categories used for the olther Chapters.

Consideration was written for each Less Restrictive Change in Chapter 1.0.

Page 2 of 2 L- 1.0 North Anna Power Station

Table L - Less Restrictive Changes ITS Section 2.0 - Safety Limits Change Description of Changc ITS Requirement CTS Req uirement CaItegory DOC No.

2.0 L.I CTS 6.7.1 states that when a Safety Limit is violated, the NRC Operations Center must 6.7.1 8 INone be notified within one hour, the Vice President - Nuclear Operations and the MSRC shall be notified within 24 hours1 days 0.143 weeks 0.0329 months , and a Safety Limit Violation Report must be prepared and submitted to the NRC, the Vice President - Nuclear Operations, and the MSRC within 14 days. The ITS does not contain these reporting requirements. This changes the CTS by eliminating the explicit reporting rcquircments and relying on the reporting required by regulations. I I I Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page IOf I L -2.0

"Table L - Less Restrictive Changes ITS Section 3.0 - LCO and SR Applicability Change Description of Change ITS Requirement CTS Requi irenlent Category DOC No.

in the LCO 3.0.4 3.0.4 Note I 3.0 L. I cTS 3.0.4 does not allow entry into a MODE or other specified condition Applicability when an LCO is not mact and while relying on ACTIONS without a specific exception. ITS LCO 3.0.4 contains the same restriction, but eliminates specific exceptions and includes an allowance to entcr a MODE or condition specified in the Applicability "'a) When the associated ACTIONS to be entered permit continued operation in the MODE or other specific condition in the Applicability for an unlimited period of time, b) After performance of a risk evaluation, consideration of the results, determination of the acceptability of the MODE change, and establishment of risk management actions, if appropriate, or c) When a specific value or parameter allowance has been approved by the NRC." CTS 4.0.4 states that entry into a MODE or other specified condition shall not be made unless the Surveillance Requiremcnt(s) associated with the Limiting Condition for Operation have been performed within the stated surveillance interval or as otherwise stated. ITS SR 3.0.4 states that entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the LCO's Surveillances have been met within their specified Frequency. When an [1CO is not met, entry into a MODE or other specified condition in the Applicability'shall only be made: "a) When the associated ACTIONS to be entered permit continued operation in the MODE or other specific condition in the Applicability for an unlimited period of time, b) After performance of a risk evaluation, consideration of the results, determination of the acceptability of the MODE change, and establishment of risk management actions, if appropriate, or c) When a specific value or parameter allowance has been approved by the NRC." This changes the CTS by allowing additional circumstances under which a MODE or other specified condition in the Applicability in DOC A.7.

may be entered when the LCO is not met. ITS LCO 3.0.4.c is addressed Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements Note I - The Less Restrictive changes for Section 3.0 did not fall into the categories used for the other Chapters. A specific Determination of No Significant Hazards Consideration was written for each Less Restrictive Change in Section 3.0.

Page I of 5 L - 3.0 North Anna Power Station

Table L - Less Restrictive Changes ITS Section 3.0 - LCO and SR Applicability Change Description of Change ITS Requirenment CTS Requiii rement Category DOC No.

LCO 3.0.5 None Note I 3.0 L.2 ITS LCO 3.0.5 is added to the CTS. ITS LCO 3.0.5 states, "Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service tinder administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to pcrlorm the testing required to demonstrate OPERABILITY."

LCO 3.0.6 3.0.5 Note I 3.0 L.3 CTS 3.0.5 provides an exception to the definition of OPERABILITY for normal and emergency power and to CTS 3.0.2. ITS LCO 3.0.6 replaces CTS 3.0.5 and expands the concept to apply to all Technical Specifications which support other Technical Specifications equipment, not only normal and emergency power. This changes the CTS in several ways. First, CTS 3.0.5 provides an exception to the definition of OPERABILITY and to the requirement to follow the Required Actions when an LCO is not met when a system, subsystem, train, or component is inoperable due to either (he normal or emergency power source being inoperable. ITS LCO 3.0.6 expands that concept to all Technical Specifications systems supported by other Technical Specifications systems. Second, CTS 3.0.5 allows a system, subsystem, train, or component to be considered OPERABLE if it is inoperable solely because either the normal or emergency power source is inoperable. ITS LCO 3.0.6 does not allow the Technical Specifications system supported by the inoperable system (i.e., the "supported system") to be considered OPERABLE, but the Conditions and Required Actions of the

- only the inoperable system's (i.e., the supported system do not have to be followed Actions "support system") Conditions and Required must be followed. Third, CTS 3.0.5 contains conditions which ensure that, absent a subsequent failure, the system, Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements Note I - The Less Restrictive changes for Section 3.0 did not fall into the categories used for the other Chapters. A specific Determination of No Significant Hazards Consideration was written for each Less Restrictive Change in Section 3.0.

Page 2 of 5 L -3.0 North Anna Power Station

Table L - Less Restrictive Changes ITS Section 3.0 - LCO and SR Applicability r -i CI'S Requirement (Jhange Ch.goange ITS Requirement Category Description of Change CTS Requirement DOC No. J

t also I I I subsystem, train, or component can perform its safety function. ITS LCO 3.0.6 requires an evaluation in accordance with ITS 5.5.14, Safety Function Determination Program, to determine if a loss of safety function exists. This determination is consistent with the evaluations performed under CTS 3.0.5. If a loss of safety function exists, CTS 3.0.5 directs a unit shutdown. ITS LCO 3.0.6 directs that the supported system be declared inoperable and the Conditions and Required Actions followed.

Fourth, CTS 3.0.5 is only applicable in MODES I - 4, as the normal and emnergcncy power requirements are different than in MODES 5 and 6. ITS LCO 3.0.6 is expanded directs to include all MODES. Fifth, ITS LCO 3.0.6 states that if a Required Action that a system be declared inoperable or directs entry into other Conditions or Required Actions Actions, the LCO exception may not be used. In those cases, the Required to ensure that the appropriate actions are taken to address directing entry are necessary the inoperability.

-i LCO 3.0.4 and SR I 3 .t).4 and 4.0.4 I Note I 3.0.4 and 4.0.4 Note I CTS 3.0.4 and CTS 4.0.4 are applicable in all MODES and prevent entry into a MODE L.4 LCO 3.0.4 and SR 3.0 3.0.4 is or other specified condition in the Applicability unless the LCO or SR, respectively, applicable for entry into a MODE satisfied. ITS LCO 3.0.4 and ITS SR 3.0.4 are only addition, or other specified condition in the Applicability in MODES 1, 2, 3 and 4. In ITS LCO 3.0.4 and ITS SR 3.0.4 do not prohibit entry into a MODE or other specified condition if such entry is part of a shutdown of the unit.

-+ i -it SR 3.0.2 4.0.2 Note I 3.0 L.5 CTS 4.0.2 states, "Each Surveillance Requirement shall be performed within the 25 specified surveillance interval with a maximum allowable extension not to exceed interval." ITS SR 3.0.2 states, "The specified Frequency for percent of the surveillance each SR is met if the Surveillance is performed within 1.25 times the interval specified L--

I Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements used for the other Chapters. A specific Note 1 - The Less Restrictive changes for Section 3.0 did not fall into the categories Change in Section 3.0.

Determination of No Significant Hazards Consideration was wriuten for each Less Restrictive Page 3 of 5 L- 3.0 North Anna Power Station

Table L - Less Restrictive Changes ITS Section 3.0 - LCO and SR Applicability Change ITS Requirement CTS Requii remnlct Category DOC No. Description of Change from the in the Frequency, as measured from the previous performance or as measured specified as 'once,'

time a specified condition of the Frequency is met. For Frequencies requires periodic the above interval extension does not apply. If a Completion Timc to each*

performance on a 'once per ... ' basis, the above Frequency extension applies are stated in performance after the initial performance. Exceptions to this Specification a Completion Time the individual Specifications." This changes the CTS by adding, "If extension requires periodic performance on a 'once per...' basis, the above Frequency remaining changes to applies to each performance after the initial performance." The CTS 4.0.2 are discussed in DOC A.10 and DOC M.2.

SR 3.0.3 4.0.3 Note I 3.0 L.6 statement requirements are CFS 4.0.3 states, in part, "The time limits ofethe action requirement has not been applicable at the time it is identified that a surveillance may be delayed for up to 24 hours1 days 0.143 weeks 0.0329 months to performed. The action statement requirements the allowable outage time limits of the permit the completion of the surveillance when less than 24 hours." ITS SR 3.0.3 states in part, "If it action statement requirements are was not performed within its specilied Frequency, then is discovered that a Surveillance requirement to declare the LCO not met may be delayed, from the compliance with the Frequency, time of discovery, up to 24 hours1 days 0.143 weeks 0.0329 months or up to the limit of thc specified greater. This delay period is permitted to allow performance of the whichever is for any Surveillance delayed greater Surveillance. A risk evaluation shall be performed be managed." Tihis changes the CTS by, I) than 24 hours1 days 0.143 weeks 0.0329 months and the risk impact shall up to the specified Frequency to perform the allowing a minimum of 24 hours1 days 0.143 weeks 0.0329 months and for any Surveillance missed Surveillance, provided a risk evaluation is performcd basing the time allowed to perform a missed delayed greater than 24 hours1 days 0.143 weeks 0.0329 months , and 2)

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement Criteria 6 - Relaxation Of Surveillance Requirement Acceptance 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements the categories used for the other Chapters. A specific Note 1 - The Less Restrictive changes for Section 3.0 did not fall into each Less Restrictive Change in Section 3.0.

Determination of No Significant Hazards Consideration was written for Page 4 of"5 L - 3.0 North Anna Power Station

Table L - Less Restrictive Changes ITS Section 3.0 - LCO and SR Applicability Change ITS Requirement CTS Requiremcnt Category Description of Change instead Surveillance before taking the Rcquired Actions on the Surveillance Frequency of the allowed outage time.

Change Category:

I- Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requiremcnt Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements used for the other Chapters. A specific Note I - The Less Restrictive changes for Section 3.0 did not fall into the categories 3.0.

in Section Determination of No Significant Hazards Consideration was written for each Less Restrictive Change Page 5 of 5 L - 3.0 North Anna Power Station

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

-i 1 Change Change rrS Requirement CTS Requirement Category DOC No. Description of Change 3.1.1, ACTION A 3.1.1.1 and 3.1.1.2 3 3.1.1 L.I CTS 3.1. 1.1 and CTS 3.1.1.2 Actions state that when the SDM is less than the limit, 3. 1. 1, ACTION A 31. 1.1 and 3.1.1.2 boration must be initiated immediately. ITS 3. I.1 Action A states that when SDM is less than the limit, boration must be initiated within 15 minutes. This changes the CTS by relaxing the Completion Time from "immediately" to 15 minutes. i. i i 3.1.1 L.2 CTS 3.1.1.1 and CTS 3.1 -1.2 Actions state that when the Sl)M is not within its limit, 3. 1. 1, ACTION A 3. 1.1.1 and 3.1.1.2 boration must be initiated and continued at > 10 gpm of 12,950 ppm boric acid solution or equivalent until the required SDM is restored. ITS 3. I. I Action A states that with the SDM not within limit, initiate boration to restore SDM to within limit. This changes the CTS by eliminating the specific values of flow rate and boron concentration that must be usced to restore compliance from the Required Action.

CTS Surveillanc 4,1.1 .1.1 .d requires verification that SDM is within its limit, "Prior to None 4.1I.. I. .d5

3. I.1 L.3 initial operation above 5% RATED THERMAL POWER after each fuel loading, by consideration of the factors of c below, with the control banks at the maximum insertion limit of Specification 3.1.3.6." The ITS does not contain a similar requirement.

3.1.2 Applicability 3.1.1.1 Applicability 2 3.1.2 L.I CTS 3.1.1.1 is applicable in MODES 1, 2,3, and 4. ITS 3.1.2 is applicable in MODES 1 and 2. This changes the CTS by reducing the applicable MODES in which the core be met.

reactivity requirement must Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements Page I of 10 L- 3.1 North Anna Power Station

Table L - Less Restrictive Changes ITS Section 3.1 - Reactivity Control Systems Change Description of Change ITS Requirement CTS Requirement Category DOC No.

3.1.2 ACTIONS None 4 3.1.2 L.2 CTS 3. 1.1.1 does not contain Actions to follow if the core reactivity balance Surveillance is not met. If the core reactivity balance Surveillance was not met, LCO 3.0.3 would be entered. LCO 3.0.3 requires the plant to be in MODE 3 within 7 hours0.292 days 0.0417 weeks 0.00959 months , MODE 4 within 13 hours0.542 days 0.0774 weeks 0.0178 months , and MODE 5 within 37 hours1.542 days 0.22 weeks 0.0507 months . ITS 3.1.2 contains Actions to follow if the core reactivity balance LCO is not met. If the LCO is not met, 7 days is provided to re-evaluate the core design and safety analysis, and determine that the reactor core is acceptable for continued operation and to establish appropriate operating restrictions and SRs. If these actions are not completed within the AOT, the plant must be in MODE 3 within 6 hours0.25 days 0.0357 weeks 0.00822 months . This changes the CTS by providing 7 days to evaluate and provide compensatory measures for not meeting the core reactivity balance requirement and then requiring entry into MODE 3 instead of requiring an immediate shutdown and entry into MODE 5.

CTS Surveillance 4.1.1.1 .2 requires the overall core reactivity balance to be compared SR 3.1.2.1 4. 1.1.1.2 7 3.1.2 L.3 with the predicted value once per 31 EFPD. The CTS also requires the predicted reactivity values to be adjusted (normalized) to the actual core conditions prior to exceeding a fuel burnup of 60 EFPD after each fuel loading. ITS SR 3.1.2.1 also requires the measured core reactivity to be compared to the predicted values every 3 I EFPD, but the ITS SR is only required after 60 EFPD of core burnup. The ITS also allows the adjustment of the predicted values to the actual values prior to exceeding a fuel burnup of 60 EFPD after each fuel loading. This changes the CTS by not requiring the at-power core reactivity comparison until core burnup reaches 60 EFPD.

ChangecCategory I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements Page 2 of 10 L- 3.1 North Anna Power Station

Table L - Less Restrictive Changes ITS Section 3.1 - Reactivity Control Systems Change DOC No. Description of Change ITS Requirement CTS Requirement Category CTS 3.1.1.4 Action a.3 requires that a Special Report he prepared and submitted to the None 3.1.1.4, Action a.3 8 3.1.3 L.I NRC within 10 days if the measured MTC is more positive than tile BOC limit. The Special Report must describe the value of the measured MTC, the interim control rod withdrawal limits, and the predicted average core burnup necessary for restoring the positive MTC to within its limit for the all rods withdrawn condition. ITS 3.1.3 does not include this requirement.

CTS 3.1.1.4, Action a.2, states that when the measured MTC is more positive than the None 3.1.1.4, Action a.2 5 3.1.3 L.2 limit, the control rod withdrawal limits established in Action a. I must be maintained until subsequent measurement verifies that the MTC has been restored to within its limits for the all rods withdrawn condition. ITS 3.1.3 does not contain a requirement that the control rod withdrawal limits be maintained until MTC is confirmed to be within its limit by measurement. However, LCO 3.0.2 states that the Required Actions shall be followed until the LCO is met or no longer applicable. The ITS Bas;es state that physics calculations may be used to determine the time in cycle life at which the calculated MTC will meet the LCO requirement and at this point in core life, the condition may be exited and the control rod withdrawal limits removed. This changes the CTS by eliminating the Surveillance Requirement verifying the MTC to be within its limit before removing the control rod withdrawal limits.

Change CategorX:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 3 of 10 L- 3.1

Table L - Less Restrictive Changes ITS Section 3.1 - Reactivity Control Systems Change Description of Change ITS Requirement CTS Requirement Category DOC No.

CTS LCO 3.1.3.1 states, "All shutdown and control rods shall be OPERABLE and LCO 3.1.4 3.1.3.1 and 3.1.3. 1, 3J1.4 L. I positioned within +/- 12 steps of their group step counter demand position." CTS Action c.2 3.1.3.1, Action c.2, states that a misaligned rod must he declared inoperable. ITS LCO 3.1.4 states, "All shutdown and control rods shall be OPERABLE AND Individual indicated rod position shall he within 12 steps of their group step counter demand position." This changes the CTS by considering shutdown and control rods that are trippable but misaligned to be OPERABLE. The term "untrippable" in CTS 3.1.3. 1, Action a, is replaced with "inoperable" and the requirement to declare a misaligned rod inoperable in CTS 3.1.3.1, Action c.2, is deleted.

3.1.4, Action A. I.1 3.1.3.1, Actions a, 4 3.1.4 L.2 CTS 3.1.3.1, Actions a, b, c.2, and c.2.b require satisfying the SHUTDOWN MARGIN requirement in accordance with Specification 3.1.1.1. In the same conditionis, ITS 3.1.4 b, c.2, and c.2.b requires verification that the SHUTDOWN MARGIN is within the limit providcd in the COLR or initiating boration to restore SDM to within the limit. This changes the CTS by providing the option to initiate action to establish compliance with the SDM requirement within I hour instead of declaring the Required Action not met and following LCO 3.0.3. The change from referencing Specification 3.1.1.1 to referencing a value in the COLR is discussed in DOC LA. 1.

3.1.4, Condition B 3.1.3. 1, Action c.2.a 4 3.1.4 L.3 CTS 3.1.3.1, Action c.2.a, states that when a rod is misaligned, POWER OPERATION may continue if a reevaluation of each accident analysis of Table 3. I- I is performed and Table 3. I -1 within 5 days. This re-evaluation shall confirm that the previous analyzed results of these accidents remain valid for the duration of operation under these conditions. ITS 3.1.4, Condition B, states that when one rod misaligned, re-evaluate the safety analyses and confirm results remain valid for the duration of operation under these conditions.

This changes the CTS by eliminating Table 3. 1-I, which lists the specific events to be re-evaluated, and the Action to evaluate those specific events.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements Page 4 of 10 L- 3.1 North Anna Power Station

Table L - Less Restrictive Changes ITS Section 3.1 - Reactivity Control Systems 1 1 1 titlange Changy ITS Requirement CTS Requirement Category DOC '~NoI Description of Change 1I t 3.1 .4, Required I 3.1.3.1, Action c.2.d 3 3.1.4 L.4 CTS 3.1.3. 1, Action c.2.d, states that with one rod misaligned, reduce the THERMAL 3.1.4, Required Action B.2.1I 3.1.3. 1, Action c.2.d POWER level to < 75% of RATED THERMAL POWER within one hour. ITS 3.1.4, Required Action B.2. I, requires THERMAL POWER to be reduced to < 75% RTP within 2 hours0.0833 days 0.0119 weeks 0.00274 months . This changes the CTS by changing the Completion Time from one hour to two hours.

-I 3.1.4, Required t 3.1.3.1, Action c.2.d 1 4 with one rod misaligned, reduce the THERMAL 3.1.4, Required 3.1.3. 1, Action c.2.dI 4 II3.1.4 L.5 I CTS 3.1.3. 1, Action c.2.d, states that POWER level to 5 75% of RATED THERMAL POWER and reduce the high flux trip setpoint to < 85% of RTP within the next 4 hours0.167 days 0.0238 weeks 0.00548 months . ITS 3.1.4, Required Action neutron Action B.2.1 B.2. I, requires THERMAL POWER to be reduced to 5 75% RTP, but does not require the high neutron flux trip setpoint to be reduced. This changes the CTS by eliminating the Required Action to reduce the high neutron flux trip setpoint.

-I None 4.1.3.4 T 5 -11 time of full length rods to be demonstrated through None 4.1.3.4 113.1.4 L.6 CTS 4.1.3.4 requires the rod drop measurement prior to reactor criticality for specifically affected individual rods following any maintenance on or modification to the control rod drive system which could affect the drop time of those specific rods. The ITS does not include this testing requirement. -i- i None the rod drop time of full length rods to be demonstrated through Nonec 4.1.3.4 3.1.4 L.7 CTS 4.1.3.4 requires measurement prior to reactor criticality at least once per 18 months. The ITS does not include this testing requirement.

I11 Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements Page 5 of 10 L- 3.1 North Anna Power Station

Table L - Less Restrictive Changes ITS Section 3. 1 - Reactivity Control Systems Change Description of Change ITS Requirement CTS Requiremcnt Category DOC No.

SR 3.1.4.1 4.1.3. 1.1 7 3.1.4 L.8 CTS 4.1.3.1 .1 requires the position of each rod to be dctermined to he within the group demand limit by verifying the individual rod positions at leasc once per 12 hours0.5 days 0.0714 weeks 0.0164 months exccpt during time intervals when the Rod Position Deviation Monitor is inoperable, then verify the group positions at least once per 4 hours0.167 days 0.0238 weeks 0.00548 months . ITS SR 3.1.4.1 requires verification that the individual rod positions are within the alignment limit every 12 hours0.5 days 0.0714 weeks 0.0164 months . This changes the CTS by eliminating the requirement to verify the individual rod positions to be within the alignment limit every 4 hours0.167 days 0.0238 weeks 0.00548 months when tile Rod Position Deviation Monitor is inoperable.

3.1.4.3 3.1.3.4 6 3.1.4 L.9 CTS 3.1.3.4 states that the rod drop time must be measured from the 229 step withdrawn position. ITS 3.1.4.3 states the rod drop time must be verified from the fully withdrawn position. This changes the CTS by eliminating the rod step position equivalent to the fully withdrawn position.

LCO 3.1.5 LCO 3.1.3.5, 3.1.3.5 3.1.5 L. I CTS LCO 3.1.3.5 states, "All shutdown rods shall be limited in physical insertion as specified in the CORE OPERATING LIMITS REPORT." CTS 3.1.3.5, Action a, Action a applies when one shutdown rod is inserted beyond the insertion limits and requires, within one hour, restoration of the rod to within the insertion limits or declaration of the rod to be misaligned and application of Specification 3.1.3. I. ITS LCO 3.1.5 states, "Each shutdown bank shall be within insertion limits specified in the COL.R.' ITS 3.1.5 does not contain actions for a single rod inserted below the insertion limit arid single rod misalignment greater than 12 steps would fall under the requirement of ITS LCO 3.1.4.

LCO 3.1.4 requires the rods to be aligned within 12 steps. This changes the CTS by eliminating the CTS 3.1.3.5 requirement to declare a single shutdown rod below the insertion limits misaligned, even if the rod is within 12 steps of the group alignment limits.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements Page 6 of 10 L -3.1 North Anna Power Station

Table L - Less Restrictive Changes ITS Section 3.1 - Reactivity Control Systems Change N one 4Change CTS Requirement Category DOC No. Description of Change ITS Requirement 3.1.5 L.2 CTS Surveillance 4.1.3.5 requires verification that each shutdown rtd is within the None 4.1.3.5 insertion limit specified in the CORE OPERATING LIMITS REPORT within 15 minutes prior to initial control rod bank withdrawal during an approach to reactor criticality. ITS 3.1.5 does not require verification that the shutdown rods are above the insertion limits within 15 minutes prior to initial control bank withdrawal. This changes the CTS by eliminating the requirement that the shutdown banks be verified to be above the insertion limit within 15 minutes prior to withdrawing the first control bank. I- I 1 3.1.5, Condition A 3.1.3.5 3 CTS 3.1.3.5 does not contain an Action for a shutdown bank not within the insertion 3.1.5, Condition A 3.1.3.5 limit except Action b, which contains a number of qualifying conditions. Under the CTS, a shutdown bank not within the insertion limits and not meeting the qualifying conditions in CTS Action b, would result in an CTS 3.0.3 entry. CTS 3.0.3 allows one hour to prepare for a shutdown and requires the plant to be in MODE 3 within 7 hours0.292 days 0.0417 weeks 0.00959 months .

sameshutdown as CTS Action h). Itwithin banks not 2 hours0.0833 days 0.0119 weeks 0.00274 months allowslimits for ITS 3.1.5, Condition A, applies with oneis or themore reasons other than Condition B (which the plant to be in limits and then requires to restore the bank to within the insertion 6 hours0.25 days 0.0357 weeks 0.00822 months . This the allowing an additional hour (from 7 changes3 under thisbycondition.

CTS MODEto 38inhours) to be in MODE be within the hours of each control bank to be determined to position CTS 4.1.3.6 requires the i t Rod 4.1.3.6 3.1.6 L.1 except during time intervals when the SR 3.1.6.2 insertion limits at lease once per 12 hours0.5 days 0.0714 weeks 0.0164 months positions (indicated then verify the individual rod Insertion Limit Monitor is inoperable, the position of each rod group to be within the positions) or the group step counter demand 12 requires 3.1.6.2every hours. This verification changes that each limits at least isonce per the in theSRCOLR limits ITS 4 hours0.167 days 0.0238 weeks 0.00548 months .

insertionbank control insertion within the control hank insertion to be within by eliminating the requirement to verify CTS Monitor is inoperable.

the Rod Insertion Limit limits every 4 hours0.167 days 0.0238 weeks 0.00548 months when I I Changre Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements Page 7 of 10 L -3.1 North Anna Power Station

Table L - Less Restrictive Changes ITS Section 3.1 - Reactivity Control Systems Change Description of Change ITS Requirement CTS Requirement Category DOC No.

3.1.7 L. I CTS 3.1.3.2 states, "The shutdown and control rod position indicating system shall be LCO 3.1.7 3.1.3.2 and 4.1.3.2.2 OPERABLE with . . each demand position indicator, I per group, accurate to within +/

2 steps of demand position" Crs SR 4.1.3.2.2 requires each demand position indicator to be demonstrated OPERABLE by performing CHANNEL CHECKS every 7 (lays and every 92 days. ITS LCO 3.1.7 states, "The Rod Position Indication (RPI) System and the Demand Position Indication System shall be OPERABLE." This changes the CTS by eliminating the specific tolerance requirement and CHANNEL CHECK Surveillances on the demand position indicators.

CTS 3.1.3.2 states, "The shutdown and control rod position indicating system shall be LCO 3.1.7 3.1.3.2 3.1.7 L.2 OPERABLE with .... the Automatic Rod Position Deviation Monitor with the alarm sctpoint < 12 steps." ITS LCO 3.1.7 states, "The Rod Position Indication (RPI) System and the Demand Position Indication System shall be OPERABLE." This changes the CTS by eliminating the requirements on the Automatic Rod Position Deviation Monitor.

CTS 3.1.3.2 Action a. I states that with a maximum of one individual rod position 3.1.7, Action C. I 3.1.3.2 Action a.1 3 3.1.7 L.3 indicator channel per group inoperable, determine the position of the non-indicating rod indirectly by the moveable incore detectors at least once per 8 hours0.333 days 0.0476 weeks 0.011 months and immediately after any motion of the non-indicating rod which exceeds 24 steps in one direction since the last rods determination with of the rod's inoperable position position. ITS 3.1.7, Action C. I states, "One or more indicators have been moved in excess of 24 steps in one direction since the last determination of the rod's position, verify the position of the rods with inoperable position indicators by using the moveable incore detectors within 4 hours0.167 days 0.0238 weeks 0.00548 months . This changes the CTS by allowing 4 hours0.167 days 0.0238 weeks 0.00548 months to verify the rod position instead of requiring the verification immediately.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements Page 8 of 10 L -3.1 North Anna Power Station

Table L - Less Restrictive Changes ITS Section 3.1 - Reactivity Control Systems Change Description oflChange ITS Requirement CTS Requirement Category DOC No.

SR 3.1.7.1 4.1.3.2 5 3.1.7 L.4 CTS 4.1.3.2 requires each rod position indicator to be dctcrmined OPERABLE by performing a CHANNEL CHECK every 12 hours0.5 days 0.0714 weeks 0.0164 months and a CHANNEL FUNCTIONAL TEST and CHANNEL CALIBRATION at least once per 18 months. ITS SR 3.1.7.1 requires a CHANNEL CALIBRATION every 18 months. This changes the CTS by eliminating the CHANNEL CHECK and CHANNEL FUNCTIONAL TEST requirements.

3.1.7, Condition B 3.1.3.2 4 3.1.7 L.5 CTS 3.1.3.2 does not have an action for more than one Rod Position Indicator Channel is inoperable per group. CTS 3.0.3 would be entered in this condition. CTS 3.0.3 requires a shutdown to MODE 3 within 7 hours0.292 days 0.0417 weeks 0.00959 months . ITS 3.1.7, Condition B, applies when more than one RPI per group is inoperable and requires the rods to be placed under manual control immediately, monitoring and recording of RCS T,,, once per hour, verification of rod position using the movable incore detectors once per 8 hours0.333 days 0.0476 weeks 0.011 months , and restoration of all but one RPI to OPERABLE status within 24 hours1 days 0.143 weeks 0.0329 months . This changes the CTS by allowing operation for an additional 24 hours1 days 0.143 weeks 0.0329 months with more than one RPI per group inoperable.

3.1.8 Actions Unit I 3.1.1.3.2 4 3.1.8 L. I Unit I CTS 3.1.1.3.2 states that when the primary grade water flow path isolation valves are not locked, sealed, or otherwise secured in the closed position in MODES 3 and 4, the plant must be in COLD SHUTDOWN within 30 hours1.25 days 0.179 weeks 0.0411 months . If in MODE 5 or 6, all operations involving positive reactivity changes or CORE ALTERATIONS must be suspended, and the valves must be locked, sealed, or secured in the closed position within 15 minutes. ITS 3.1.8 Actions state than when the primary grade water flow path are not isolated, positive reactivity additions must be suspended immediately, the primary grade water flow path must be isolated within 15 minutes and SR 3.1.1.1 must be performed within I hours. This changes the CTS by eliminating the Unit I Action that a unit in MODES 3 or 4 be shutdown to MODE 5 within 30 hours1.25 days 0.179 weeks 0.0411 months . The other changes to CTS 3.1.1.3.2 are discussed in DOCs A.3, M. I, and LA. 1.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 9 of 10 L -3.1

Table L - Less Restrictive Changes ITS Section 3.1 - Reactivity Control Systems Change DOC No. Description of Change ITS Requirement CTS Requirement Category 3.1.8 L.2 Unit 2 CTS 3.1.1.3.2 states (hat when the primary grade water flow path isolation valves 3.1.8 Actions Unit 2 3.1.1.3.2 3 are not locked, sealed, or otherwise secured in the closed position, all operations involving positive reactivity changes or CORE ALTERATIONS must be suspended, the isolation valves must be locked, sealed, or otherwise secured in the closed position within 15 minutes, and SHUTDOWN MARGIN must be verified greater than or equal to 1.77% Ak/k within 60 minutes. ITS 3.1.8 Actions state than when one or more valves are not secured in the closed position, positive reactivity changes must be suspended immediately, the primary grade water flow paths must be isolated within 15 minutes and the boron concentration must be verified per SR 3.1. 1.1 within 4 hours0.167 days 0.0238 weeks 0.00548 months . This changes the Unit 2 CTS by allowing 4 hours0.167 days 0.0238 weeks 0.00548 months to determine the SHUTDOWN MARGIN per SR 3.1.1.1.

3.1.9 L. I CTS 4.10.3.2 requires that tests be performed on each Intcrmediale and Power Range SR 3.1.9.1 4.10.3.2 7 channel within 12 hours0.5 days 0.0714 weeks 0.0164 months prior to initiating PHYSICS TESTS. ITS SR 3.1.9.1 requires that the testing he performed prior to initiation of PHYSICS TESTS. This changes the CTS by eliminating the time period prior to initiation of PHYSICS TESTS within which the testing must be performed.

3.1.9 L.2 ITS 3.9.1 states that the number of required channels for LCO 3.3.1, "RTS LCO 3.9.1 None Instrumentation," Functions 2, 3, 6, and 18.d, may be reduced to "'3"required channels, during the performance of PHYSICS TESTS. CTS 3.10.3 does not contain this allowance. This changes the CTS by reducing LCO requirements for the number of Power Range Neutron Flux channels from "4" to "3" during PHYSICS TESTS initiated in MODE 2.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 10 of 10 L- 3.1

Table L - Less Restrictive Changes ITS Section 3.2 - Power Distribution Limits 1 1 4.Jmngc Cl'S P.equireioent Chlange Category Description of Change ITS Re(luirement CTS RZc(Iuirelenllt DOCCNo. - *13.2.1, Action A.2.2 I 3.2.2, Action a I must bc 3.2.1, Action A.2.2 3.2.2, Action a 3.2.1 L.I CTS 3.2.2, Action a, states the Power Range Neutron Flux - High Trip setpoints FQM(Z) exceeds its limit within 4 hours. ITS 3.2. I,. Action reduced 1% for each 1%

->Io% ,fr A.2.2, requires the Power Range Neutron Flux - High trip setpoints be reduced each 1% FQM(Z) exceeds its limit within 72 hours. This changes the CTS by extending the Completion Time from 4 hours0.167 days 0.0238 weeks 0.00548 months to 72 hours3 days 0.429 weeks 0.0986 months . t 3.2.2, Action h 1 4

- 3.2.!, Action A.2.4 correct the 3.2. 1, Action A.2.4 13.2.2, Action h 3.2.1 L.2 CTS 3.2.2, Action b, states that when FQM(Z) exceeds its limit, identify and POWER above the cause of the out of limit condition prior to increasing THERMAL 4 that F1M (Z) is within reduced power limit. ITS 3.2.1, Action A.2.4, requires verification the reduced power limit. '['his its limit prior to increasing THERMAL POWER above of limit changes the CTS by eliminating the reqtuirement to identify the cause of' the out condition prior to increasing power above the reduced power limit.

-i 3.2.2, Actions A. I t 3.2.3, Action a r 3 3.2.2, Actions A. I 3.2.3, Action ai 3.2.2 L.I CTS 3.2.3, Action a states that when FNAll exceeds its limit, rcduce THERMAL and A.2 POWER to less than 50% RTP within 2 hours0.0833 days 0.0119 weeks 0.00274 months and reduce the Power Range Neutron 3.2.2, Flux - High trip setpoints to less than 55% of RTP within the next 4 hours0.167 days 0.0238 weeks 0.00548 months . ITS Actions A. I and A.2 state than with FNAl not within this limit, reduce THERMAL F'lux POWER to < 50% RTP within 4 hours0.167 days 0.0238 weeks 0.00548 months and reduce the Power Range Neutron This changes the CTS by allowing a High trip setpoints to - 55% RTP within 72 hours3 days 0.429 weeks 0.0986 months .

and 72 hours to reduce the trip 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time to reduce power to < 50% RTP setpoint.

-f 3.2.2, Action B r 3.2.3, Action b -t 3 incore 3.2.2, Action B 3.2.3, Action b) 3.2.2 L.2 CTS 3.2.3, Action b states that when FNAlI exceeds its limit, demonstrate thmouglh THERMAL POWER to less than 5%

mapping that FNA*l is within its limit or reduce Action and within the next 2 hours0.0833 days 0.0119 weeks 0.00274 months . ITS 3.2.2, Action B states that with the Required be in MODE 2 within 6 hours. This changes the associated Completion Time not met, Time to reduce power to < 5% RTP.

CTS by allowing a 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Completion I _____________________________ ___________________

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements Page 1 of 4 L- 3.2 North Anna Power Station

Table L - Less Restrictive Changes ITS Section 3.2 - Power Distribution Limits Change Description of Change ITS Requirement CTS Rcquircemcnt Category DOC No.

3.2.3, Action A. I 3.2.1, Action a 4 3.2.3 L. I CTS 3.2.1, Action a, states that when AFD is not within its limit, reduce THERMAL POWER to less than 50% within 30 minutes and reduce the Power Range Neutron Flux

- High Trip setpoints to <*55% of RTP within the next 4 hours0.167 days 0.0238 weeks 0.00548 months .

ITS 3.2.3, Action A.!I, requires THERMAL POWER to be reduced to less than 50% within 30 minutes when AFD is outside of its limit. This changes the CTS by eliminating the requirement to reduce the High Flux Trip Setpoint to < 55% within 4 hours0.167 days 0.0238 weeks 0.00548 months .

SR 3.2.3. 1 4.2.1.1 7 L.2 CTS 4.2.1.1 requires the indicated AFD for each excore channel to be determined to be 113.2.3 at least within its limits once per 7 days when the AFD Monitor is OPERABLE, and once per hour for the first 24 hours1 days 0.143 weeks 0.0329 months after restoring the AFD Monitor Alarm to OPERABLE status, and once per hour for the first 24 hours1 days 0.143 weeks 0.0329 months and once per 30 minutes thereafter when the AFD Monitor Alarm is inoperable. ITS SR 3.2.3. I rquires AFI) to be verified within its limits for each OPERABLE excore channel every 7 days. This changes the CTS by eliminating all AFD Surveillance Frequencies based on the Monitor.

OPERABILITY of the AFD 3.2.4 3.2.4 4 3.2.4 L. 1 CTS 3.2.4 states that the QPTR shall not exceed 1.02. CTS Action a provides actions for QPTR > 1.02 and < 1.09 and CTS 3.2.4 actions b and c provide actions for QPTR >

1.09. CTS action b applies when QPTR > 1.09 due to misalignment of a RCCA and requires a power reduction of 3% RTP for every 1% QPTR exceeds 1.0 within 30 minutes and reduce power to < 50% RTP within 2 hours0.0833 days 0.0119 weeks 0.00274 months i" QPTR is not restoied to within limits. CTS action c applies when QPTR > 1.09 for any other reason and requires reducing power to < 50% RTP within 2 hours0.0833 days 0.0119 weeks 0.00274 months . ITS LCO 3.2.4 states that QPTR shall be < 1.02. ITS 3.2.4 contains actions for QPTR > 1.02, but does not contain additional actions for QPTR > 1.09. This changes the CTS by eliminating

> 1.09.

additional actions for QPTR Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements L- 3.2 T...l.,

INorhAn

,,i.

o'll lll.l*wer r.....

3muotnt 1PC&6ý 2oo t

ý ". - I

Table L - Less Restrictive Changes ITS Section 3.2 - Power Distribution Limits Change Description of Change ITS Requirement CTS Requirement Category DOC No.

SR 3.2.4.1 4.2.4.1 7 CTS 4,2.4.1 requires the QPTR to be verified to be within limit every "7days with the 1ý 3.2.4 L.2 QPTR alarm is OPERABLE and every 12 hours0.5 days 0.0714 weeks 0.0164 months with the QPTR alarm is inoperable.

ITS SR 3.2.4.1 requires verification that the QPTR is within limit every 7 days. This changes the CTS by eliminating the requirement to verify QPTR more frequently when the QPTR alarm is inoperable.

3.2.4, Action A. 1 3.2.4, Action a. I.h) 4 3.2.4 L.3 CTS 3.2.4, Action a. I.b) (Unit 1) and Action a.2.(b) (Unit 2), states that whwn QPTR is not within its limit, reduce THERMAL POWER by at least 3% RTP fbr every I% of (Unit 1) and Action indicated QPTR in excess of 1.0 and reduce the Power Range Neutron Flux - High Trip a.2.(b) (Unit 2) setpoints within the next 4 hours0.167 days 0.0238 weeks 0.00548 months . ITS 3.2.4, Action A. I, rcquires THERMAL POWER to be reduced > 3% RTP for each 1% QPTR > 1.00. This changes the CTS by eliminating the requirement to reduce the High Flux Trip Setpoint.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7.- Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements Page 3 of14 L-3.2 North Anna Power Station

Table L - Less Restrictive Changes ITS Section 3.2 - Power Distribution Limits Change Description of Change ITS Requireiflent CTS Requirement Category DOC No.

3.2.4, Action B 3.2.4, Action a.2, 4 3.2.4 L.4 CTS 3.2.4, Action a.2 (Unit I) states that with QPTR > 1.02 and < 1.09, verify that QPTR is within its limit within 24 hours1 days 0.143 weeks 0.0329 months or reduce THERMAL. POWER to less than a.3 (Unit I), and 50% RTP within the next 2 hours0.0833 days 0.0119 weeks 0.00274 months and reduce the Power Range Neutron Flux - High Trip Action a. I(a), a.3, and a.4 (Unit 2) setpoints to < 55% RTP within the next 4 hours0.167 days 0.0238 weeks 0.00548 months . CTS 3.2.4, Action a. I1(a) and a.3 (Unit

2) states that with QPTR > 1.02 and < 1.09, calculate QPTR at least once per hour until THERMAL POWER is reduced to less than 50% of RTP and verify that QPTR is TP within its limit within 24 hours1 days 0.143 weeks 0.0329 months or reduce THERMAL POWER to less than 50% R, within the next 2 hours0.0833 days 0.0119 weeks 0.00274 months and reduce the Power Range Neutron Flux - High Trip setpoints to < 55% RTP within the next 4 hours0.167 days 0.0238 weeks 0.00548 months . CTS 3.2.4, Action a.3 (Unit I) and a.4 (Unit 2) state that the cause of the out of limit QPTR must be identified and corrected prior to increasing THERMAL POWER and subsequent operation above 50% RTP can proceed provided that the QPTR is verified to be within its limit at least once per hours for 12 hours0.5 days 0.0714 weeks 0.0164 months or until verified acceptable at 95% or greater RTP. ITS 3.2.4, Action B, states that with the Required Actions and Associated Completion Times ol Condition A not met, reduce THERMAL POWER to < 50% RTP within 4 hours0.167 days 0.0238 weeks 0.00548 months . This changes the CTS by eliminating requirements to be < 50% RTIP within a specified time of exceeding the LCO and substituting compensatory measures in Condition A, which il not met, result in a reduction in power.

SR 3.2.4. 1, Note 2 4.2.4.1 6 3.2.4 L.5 CTS Surveillance 4.2.4.1 states that QPTR shall be determined to be within the limit by calculating the ratio at least once per 7 days. ITS SR 3.2.4.1, Note 2, states that SR 3.2.4.2, which requires verification of QPTR using the movable incore detcctors, may be performed in lieu of SR 3.2,4. I. This changes the CTS by allowing the movable incore detectors to be used to determine QPTR instead of the cxcore detectors.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 4 of 4 L 3.2

Table L - Less Restrictive Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS Requirement CTS Requirement Change Type 3.3.1 L.I CTS Table 3.3-1 requires for various functions that Action 15 be entered for an Table 3.3. 1-1 Note Table 3.3-I Action 4 inoperable channel in MODES 3*, 4*, and 5*. Note

states, "With the reactor trip (a) 15 Note

system breakers in the closed position and the control rod drive system capable of rod withdrawal." Action 15 states that an inoperable channel shall be returned to OPERABLE status within 48 hours2 days 0.286 weeks 0.0658 months or open the Reactor Trip Breakers (RTBs) within the next hour. ITS Table 3.3. 1-1 for these functions requires ITS Action C to be entered. Action C states with one channel or train inoperable, restore the function to OPERABLE status in 48 hours2 days 0.286 weeks 0.0658 months or initiate action to fully insert all rods.

The Rod Control System must be placed in a condition incapable of rod withdrawal within the next hour. The applicable MODES or other specified conditions for MODES 3, 4, and 5 are modified by Note 1". Note Wa) states, "With Rod Control System capable of rod withdrawal or one or more rods not fully inserted." This changes the CTS by not requiring the RTBs to be opened but allowing an alternative action to disable the Rod Control System.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4- Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page I of 28 L -3.3

Table L - Less Restrictive Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS Requirement CTS Requirement Change Type 3.3.1 L.2 CTS 3.3.1.1 requires for an inoperable Power Range channel that Action 2 be 3.3 1 Required 3.3.1.1 Action 2 4 entered. This Action requires the inoperable channel to be placed in trip within 72 Action D.I hours, and both the THERMAL POWER < 75 % and the Power Range Neutron Flux trip setpoint < 85 % within the next 4 hours0.167 days 0.0238 weeks 0.00548 months . The Action also provides an alternate option to reducing power and decreasing the trip setpoints. The option requires the channel to be placed in trip within 72 hours3 days 0.429 weeks 0.0986 months and the performance of a QPTR measurement every 12 hours0.5 days 0.0714 weeks 0.0164 months . ITS 3.3.1 Condition D. I requires for one Power Range Neutron Flux - High channel inoperable, the channel will be placed in trip within 72 hours3 days 0.429 weeks 0.0986 months and the THERMAL POWER will be reduced to < 75 %

within the next 6 hours0.25 days 0.0357 weeks 0.00822 months . An alternative to this requirement is to place the channel in trip and perform a QPTR every 12 hours0.5 days 0.0714 weeks 0.0164 months . This changes the CTS requirements by eliminating the requirement to reduce the Power Range Neutron Flux trip setpoint to < 85 % within 78 hours3.25 days 0.464 weeks 0.107 months .

3.3.1 L.3 CTS 3.3.1.1 Action 2 provides an option to reduce power and decrease the trip 3.3.1 Required None 4 setpoints when a Power Range channel is inoperable. The option requires the Action D.2.2 Note channel to be placed in trip within 72 hours3 days 0.429 weeks 0.0986 months or a QPTR measurement is performed every twelve hours. ITS 3.3.1 Required Action D.2 maintains the requirement for placing the channel in trip and performing the QP1TR measurement. A Note is added to Required Action D.2.2 that allows the Power Range channel to be considered OPERABLE, for the purpose of calculating the QPTR, if the portion of the channel continues to provide the necessary input for the QPTR calculation.

This modifies the CTS by allowing the Power Range to be considered OPERABLE, for the purposes of QPTR calculation, if the channel continues to provide a valid signal to determine the power distribution. This changes the CTS by allowing an action that is not contained in the CTS.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 2 of 28 L -3.3

Table L - Less Restrictive Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS Requirement CTS Requirement Change Type 3.3.1 L.4 CTS 3.3.1.1 Functional Unit 5, Neutron Flux Intermediate Range channels, in Table 3.3.1 -I1 Table 3.3-1 4 Table 3.3-1 states the Applicability for the instruments as Modes I.." and 2. The ..

requires the channels to be OPERABLE, "Below the P-10 (Power Range Neutron Flux) setpoint." Ifra channel becomes inoperable, Action 3 must be entered. CTS Action 3.b states with an inoperable Intermediate Range channel above P-6 but below P-10 restore the inoperable channel to OPERABLE status prior to increasing THERMAL POWER above tile P-10 setpoint. CTS Action 3.c allows continued operation with an inoperable Intermediate Range channel if THERMAL POWER is greater than P- 10. ITS 3.3.1 Function 4 Intermediate Range Neutron Flux in Table 3.3. 1-1 lists the Applicable Modes or other specified conditions as MODE 1 b) and 21c). The superscript letters for the MODES denote the specified conditions. The Intermediate Range channels are required to be OPERABLE whenever reactor power is between MODE 2")>(Intermediate Range Neutron Flux interlock, P-6) and MODE 1 (b) (the Power Range Neutron Flux interlock, P-10). If an Intermediate Range channel becomes inoperable when reactor power is between P-6 and P-10, either ITS Required Actions F. I or F.2 must be met. Required Action F.I states that THERMAL POWER must be reduced to < P-6 within 24 hours1 days 0.143 weeks 0.0329 months . Required Action F.2 requires that THERMAL POWER be increased to >

P-10 within 24 hours1 days 0.143 weeks 0.0329 months . This changes the CTS by allowing the reactor power to be increased to > P-16 (approximately 10% RTP) with an inoperable Intermediate Range channel with reactor power above the P-6 setpoint. This also changes the MODES of Applicability from MODE I ...and 2 to specific values of the Power Range and Intermediate Range interlocks (P-10 and P-6).

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4- Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 3 of 28 L- 3.3

Table L - Less Restrictive Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS Requirement CTS Requirement Change Type 3.3.1 L.5 CTS Table 3.3-1 Functional Unit 5 Neutron Flux Intermediate Range channels 3.3.1 ACTION G None 4 states if a channel becomes inoperable Action 3 must be entered. CTS Action 3.a states that when below P-6 restore the inoperable channel to OPERABLE status prior to increasing THERMAL POWER above the P-6 setpoint. CTS Action 3.b states with an inoperable Intermediate Range channel above P-6 but below P-10 restore the inoperable channel to OPERABLE status prior to increasing THERMAL POWER above P-10. No allowance is provided for two inoperable channels, therefore LCO 3.0.3 must be entered in this condition. ITS Table 3.3.1 I Function 4 Intermediate Range Neutron Flux states that Action G must be entered for two inoperable channels. ITS Action G states, "Two Intermediate Range channels inoperable," Required Actions G. I and G.2 must be completed.

Required Action G. I states, "Suspend operations involving positive reactivity additions." Required Action G.2 states, "Reduce THERMAL POWER < P-6,"

within 2 hours0.0833 days 0.0119 weeks 0.00274 months . A Note modifies the Required Actions that states "Limited plant cooldown or boron dilution is allowed provided the change is accounted for in the calculated SDM." This changes the CTS by allowing Required Actions with two Intermediate Range channels inoperable that are not currently allowed.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 4 of 28 L -3.3

"Fable L - Less Restrictive Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS Requirement CTS Requirement Change Type 3.3.1 L.6 CTS Table 4.3-1 lists for the Power Range Low Setpoint and Intermediate Range SR 3.3.1.8 Table 4.3-1 7 channels, the surveillance requirements for a CHANNEL FUNCTIONAL TEST (CFT). The Frequency of the CFT for these functions is S/U "). S/U requires the surveillance must be performed prior to a reactor startup. Note ( states, "If not performed in previous 31 days." The Source and Intermediate Ranges additionally 2

require a quarterly test to be performed (Q (`)). Note 11)states, "Quarterly Surveillance in MODE 3*, 4*, and 5* shall also include verification that Permissives P-6 and P-10 are in their required state for existing plant conditions by observation of the permissive annunciator window." The movement of the phrase, "by observation of the permissive annunciator window," is addressed by DOC LA.6. The deletion of quarterly surveillance in MODES 3*, 4, and 5* is addressed by DOC L. 10. The movement of the verification of Permissives P-6 and P-10 is addressed by DOC A.29. ITS SR 3.3.1.8 for the Source, Intermediate, and Power Range Neutron Flux Low Setpoint channels require a CHANNEL OPERATIONAL TEST (COT) to be performed every 92 days. Additionally, a COT must be performed for these instrument channels prior to reactor startup if not performed within the previous 92 days. The COT must be performed for the Source Range within 4 hours0.167 days 0.0238 weeks 0.00548 months after reducing power below the P-6 setpoint and the Power Range Low Setpoint and Intermediate Range channels must perform the COT within 12 hours0.5 days 0.0714 weeks 0.0164 months after power is reduced below the P- 0 setpoint. This changes the CTS by allowing 4 hours0.167 days 0.0238 weeks 0.00548 months for the Source Range and 12 hours0.5 days 0.0714 weeks 0.0164 months for the Power and Intermediate Ranges to perform the required test after entry into the applicable MODES or other specified conditions.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 5 of 28 L-3.3

Table L - Less Restrictive Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS Requirement CTS Requirement Change Type 3.3.1 L.7 CTS surveillance requirements for the Power Range Neutron Flux High Setpoint SR 3.3.1.2 NOTE 2 None 6 are listed in Table 4.3-1. This requires a CHANNEL CALIBRATION to be performed daily. The requirement is modified by Note (2). Unit I Note (2) states, "Heat balance only, above 15 % of RATED THERMAL POWER." Unit 2 Note (2) states, "Heat balance only, above 15 % of RATED THERMAL POWER.

Adjust channel if absolute difference > 2 percent." ITS SR 3.3.1.2 is required for the Power Range Neutron Flux High Setpoint every 24 hours1 days 0.143 weeks 0.0329 months . The SR states, "Compare results of calorimetric heat balance calculation to power range channel output. Adjust power range output if calorimetric heat balance exceeds power range channel output by more than +2 % RTP." This changes the CTS by only requiring an adjustment of the Power Range channel if the calorimetric exceeds the power range channel output by more than +2% RTP.

3.3.1 L.8 CTS requirements for RTS interlocks (P-6, P-8, P-b10, and P- 13) provide specific Table 3.3. 1-I Table 3.3-1 numbers for the Allowable Values. T[le Allowable Values for the P-7 function come from the requirements of P-10 and P-13. ITS requirements for these functions are provided with appropriate >_or < symbols to specifically state the limits for each RTS interlock value. This changes the CTS by allowing the values of the RTS interlocks to be set to a limit not currently allowed.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 6 of 28 L -3.3

Table L - Less Restrictive Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS Requirement CTS Requirement Change Type 3.3.1 L.9 CTS Table 4.3-I lists the surveillance requirements for the Power Range Neutron SR 3.3.1.3 NOTE 2 None 7 Flux CHANNEL CALIBRATION as Mt1116). Note (3) states, "Compare incore to excore axial offset above 15 % RATED THERMAL POWER (RTP). Adjust channel if absolute difference >Ž 3 percent." ITS Table 3.3.1-1 specifies SR 3.3.1.3 for the Overtemperature AT function. SR 3.3.1.3 states, " Compare results of the incore detector measurements to NIS AFD. Adjust NIS channel if absolute difference >3%." A Note modifies the SR which states, "Not required to be performed until 72 hours3 days 0.429 weeks 0.0986 months after THERMAL POWER is > 15 % RTP." The change from monthly to every 31 EFPD is addressed by DOC L. 16. This changes the CTS by specifically stating that 72hours is allowed before requiring the completion of a comparison after THERMAL POWER equals or exceeds 15 % RTP.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 7 of 28 L -3.3

Table L - Less Restrictive Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS Requirement CTS Requirement Change Type 3.3.1 L.10 CTS Table 4.3-1 list for the Power Range (Low Setpoint), Intermediate Range, and SR 3.3.1.8 TFable 4.3-1 NOTE 7 the Source Range channels S/U I') requirements for a CHANNEL FUNCTIONAL 12 TEST (CFT). This also requires the CFT be performed prior to a reactor start up if not completed within tile previous 31 days (Note ")). The Source and Intermediate Ranges additionally require Q(12) requirement. Note (12) states, "Quarterly Surveillance in Modes 3*, 4, and 5* shall also include verification that Permissive P-6 and P-10 are in their required state for existing plant conditions by observation of the permissive annunciator window." ITS SR 3.3.1.8 for the Source, Intermediate and Power Range Neutron Flux channels requires a COT be performed every 92 days. In addition, ITS SR 3.3.1.8 allows the COT to be performed within 12 hours0.5 days 0.0714 weeks 0.0164 months after reducing power below P-10 for the Power and Intermediate ranges of instrumentation. The COT must be performed for tile Source Range channels within 4 hours0.167 days 0.0238 weeks 0.00548 months after reducing power below P-6. This changes the CTS by allowing Source Range channels to perform a COT within 4 hours0.167 days 0.0238 weeks 0.00548 months after power is reduced below the P-6 and Intermediate and Power Ranges within 12 hours0.5 days 0.0714 weeks 0.0164 months after power is reduced below P-10 setpoint.

3.3.1 L.1 I CTS testing requirements listed in Table 4.3-1 require the Source, Intermediate, SR 3.3.1.7, SR table .3-1 7 and Power Range channels to perform a CHANNEL FUNCTIONAL TEST at S/U 3.3.1.8 (I). Note (1) states, "If not performed within the previous 31 days." ITS SRs for these ranges of instrumentation channels are listed as SR 3.3.1.7 and 3.3.1.8. The frequency of these SRs is 92 days. A Note in the Frequency column of SR 3.3.1.8 states, "Only required when not performed within previous 92 days." This changes the CTS requirement by increasing the time from 3 1 to 92 days for the required testing.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 8 of 28 L -3.3

Table L- Less Restrictive Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS Requirement CTS Requirenment Change TIype 3.3.1 L.12 Not used. N/A N/A N/A 3.3,1 L.13 CTS 3.3.1.1 in Table 3.3-1 lists the required number of channels for Reactor Trip 3.3.1 ACTION P Table 3.3-1 Action 3 Breakers (RTBs) to be OPERABLE. Action I must be entered if one train of either 1 function becomes inoperable. Action I states, "with the number of channels OPERABLE one less than required by the minimum Channels OPERABLE requirement, be in HOT STANDBY within 6 hours0.25 days 0.0357 weeks 0.00822 months ;" ITS 3.3.1 in Table 3.3.1I-I states for the function a specific number of trains that are required to be OPERABLE. If a train of RTB becomes inoperable, Condition P must be entered.

The Required Actions for Conditions P allows one hour to return an inoperable train to OPERABLE status, or six additional hours to reach MODE 3. This changes the CTS requirements by allowing one additional hour to return the inoperable train to OPERABLE status.

3.3.1 L. 14 CTS 3.3.1.1 requirements listed in Table 3.3-1 for P-6, P-8, and P-13 specifies two None Table 3.3-1 limits for the Allowable Values. The P-6 function lists the setpoint as lx 10"* and allowable value as < 3x 10-` for increasing power. The P-8 interlock for decreasing power lists the setpoint and allowable value as 28% and >27%, respectfully.

Decreasing power for the P-13 interlock, the setpoint and allowable value are stated as 8% and 7%. ITS 3.3.1 requirements in TFable 3.3.1I-1I for the Reactor Trip System interlocks P-6, P-8, and P-13 do not list the reset setpoints and allowable values in the specifications. This changes the CTS by not requiring these specific interlocks to state the reset values for Allowable Values.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 9 of 28 L -3.3

Table L - Less Restrictive Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS Requirement CTS Requirement Change IType 3.3.1 L.15 CTS surveillance requirements for the Power Range Neutron Flux CHANNEL SR 3.3.1.2 Note 2 None 7 CALIBRATION are listed in Table 4.3-1 as D12). This requires the four Power Range channels to be compared to the heat balance of the RCS (calorimetric) on a daily basis. Note (2) state that the heat balance is required to be performed above 15 % RTP. ITS SR 3.3.1.2 for the Power Range Neutron Flux must be performed every 24 hours1 days 0.143 weeks 0.0329 months . The requirement is modified by a Note , which states, "Not required to be performed until 12 hours0.5 days 0.0714 weeks 0.0164 months after THERMAL POWER is >_ 15 %

RTP." This changes the CTS by allowing 12 hours0.5 days 0.0714 weeks 0.0164 months to perform a CHANNEL CALIBRATION after THERMAL POWER of the Power Range channels exceeds 15 % RTP for the initial surveillance testing.

3.3.1 L. 16 CTS Table 4.3-I lists a CHANNEL CALIBRATION requirement for the Power SR 3.3.1.3 Table 4.3-17 Range channels as MW). This requires CHANNEL CALIBRATION to be performed every 31 days. ITS SR 3.3.1.3 requires a comparison of the incore measurements to the excore indication every 3 1 effective full power days (EFPD).

Other changes associated with this requirement are addressed in DOC L.9 and A.28. This replaces the CTS with an incore to excore comparison, to be performed on an EFPD basis instead of calendar days.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 10 of 28 L -3.3

Table L - Less Restrictive Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS Requirement CTS Requirement Change Type 3.3.1 L. 17 The CTS requires a CHANNEL FUNCTIONALTEST for the Source Range SR 3.3.1.7 Note Table 3.3-1 6 Neutron Flux channels on a quarterly basis. Normally, if the reactor has been operating in MODE I for greater than 92 days, the surveillance should be performed prior to entering the MODE of Applicability on a reactor shutdown.

The MODES of Applicability for these channels are listed as 2, 3, 4, and 5. To not perform the required surveillance prior to entry into the MODE of Applicability requires an exception to Surveillance Requirement 4.0.4. The CTS requirements do not contain the required exception. ITS SR 3.3.1.7 for the Source Range Neutron Flux channel requires a COT be performed every 92 days. This surveillance requirement is modified by a Note, which states, "Not required to be performed for source range instrumentation prior to entering MODE 3 firom MODE 2 until 4 hours0.167 days 0.0238 weeks 0.00548 months after entry into MODE 3." The applicable MODES for this requirement are listed as 2"d), 3"), 4"), and 5a) . Note (d)states, "Below the P-6 (Intermediate Range Neutron Flux) interlocks. Note (a) states, "With Rod Control System capable of rod withdrawal or one or more rods not fully inserted." This changes the CTS by allowing 4 hours0.167 days 0.0238 weeks 0.00548 months , after entering MODE 3 from MODE 2, to perform the COT on the Source Range channels.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6- Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page I11 of 28 L -3,3

Table L - Less Restrictive Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS Requirement CTS Requirement Change Type 3.3.1 L. 18 CTS Table 3.3-1 requires for various functions that Action 15 be entered for an 3.3.1 ACTION J Table 3.3-I Action 4 inoperable channel in MODES 3*, 4*, and 5*. Note

states, "With the reactor trip 15 system breakers in the closed position and the control rod drive system capable of rod withdrawal." Action 15 states that an inoperable channel be returned to OPERABLE status within 48 hours2 days 0.286 weeks 0.0658 months or open the Reactor Trip Breakers (RTBs) within the next hour. ITS Table 3.3.1-1 for Source Range function requires ITS Action J to be entered. Action J states with one channel inoperable, restore the function to OPERABLE status in 48 hours2 days 0.286 weeks 0.0658 months or initiate action to fully insert all rods in 48 hours2 days 0.286 weeks 0.0658 months and place the Rod Control System in a condition incapable of rod withdrawal within 49 hours2.042 days 0.292 weeks 0.0671 months . The applicable MODES or other specified conditions for MODES 3, 4, and 5 are modified by Note (". Note ta) states, "With Rod Control System capable of rod withdrawal or one or more rods not fully inserted." This changes the CTS by not requiring the RTBs to be opened but allowing an alternative action to disable the Rod Control System.

3.3.1 L.19 CTS Table 2.2-I, Notes I and 2, provide the RTS instrumentation trip setpoints Table 3.3. 1-1 Notes Table 2.2-I, Notes formulas for the calculation of Overtemperature (OT) and Overpower (OP) AT I and 2 1 and 2 functions. The values used for various constants specify exact number for each constant to be adjusted. ITS Table 3.3.1-1 Notes I and 2 provide the formulas for the calculation of Overtemperature and Overpower AT functions. The values for constants P', K1, K,, K3. K,, K5,K, -rC,1T2, and t3 are modified with less than or equal to (_<),or greater than or less to (>_)symbols to allow a tolerance. This changes the CTS by allowing the values of the constants to be set to a limit not currently allowed.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4- Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 12 of 28 L-3.3

Table L - Less Restrictive Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS Requirement CTS Requirement Change Type 3.3.1 L.20 CTS 4.3.1.1.2 states, "The REACTOR TRIP SYSTEM RESPONSE TIME of each SR 3.3.1.16 4.3.1.1.2 5 reactor trip function shall be demonstrated to be within its limit at least once per 18 months." ITS Table 3.3.1-1 under the Surveillance Requirements column lists SR 3.3.1.16. This SR states, "Verify RTS RESPONSE TIME is within limits." This SR is required for all RTS Functions except the following: (1) Manual Reactor Trip, (3.a) Power Range Neutron Flux High Positive Rate, (4) Intermediate Range Neutron Flux, (7) Overpower AT, (15) Steam/Feed Flow Mismatch and Low Steam Generator Water Level, (16) Turbine Trip, (17) SI input from ESF, (1I)

Reactor Coolant Pump Breaker Position Trip, (19) Reactor Trip Breakers, (20)

RTB Undervoltage and Shunt Trip Mechanisms, and (21) Automatic Trip Logic.

This changes the CTS by deleting the Response Time Testing requirements for the listed functions.

3.3. 1 L.21 DELETED 3.3.1 L.22 Unit I CTS Table 4.3-1 Function 18, Turbine Trip on Low Auto Stop Oil Pressure Table 3.3. 1-I Table 4.3-I Note 2 or Turbine Stop Valve Closure states the related Surveillance is required as NOTE g (I)

MODES I and 2. The Surveillance required is a CHANNEL FUNCTIONAL TEST with a listed frequency of S/U (I). S/U requires the surveillance to be performed prior to each reactor start up. Note (I) states, "If not performed within the previous 31 days." The applicable MODES or other specified conditions for ITS Table 3.3.1-1 Function 16, Turbine Trip on Low Auto Stop Oil Pressure or Turbine Stop Valve Closure is 1(g) with SR 3.3.1.15 as one of the required Surveillances. Note (g) states, "Above the P-8 (Power Range Neutron Flux) interlock." This changes the CTS by changing the applicability of the Surveillance from MODES I and 2 to MODE I above the P-8 interlock.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 13 of 28 L -3.3

Table L - Less Restrictive Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS Requirement CTS Requirement Change Type 3.3.1 L.23 CTS Table 3.3-I Function 2 Power Range Neutron Flux (PRNF) and Function 3 3.3.1 ACTION F Table 3.3-1 Action 4 PRNF High Positive and Negative Rate trips state that Action 2 is to be entered for 2, Part d an inoperable channel. Action 2, Part a states that an inoperable channel must be placed in the tripped condition within 72 hours3 days 0.429 weeks 0.0986 months . Action 2, Part b allows tile testing of additional channel with one channel inoperable. Action 2, Part c states that THERMAL POWER is to be limited to < 75 % Rated Thermal Power (RTP) and the PRNF trip setpoints are to be reduced to < 85% RTP within 78 hours3.25 days 0.464 weeks 0.107 months . Action 2, Part d provides instructions for determining the QUADRANT POWER TILT RATIO (QPTR) with an inoperable PRNF channel. ITS Function 3 PRNF rate trips, high positive or high negative states that Condition E be entered for an inoperable channel. Condition E. I states "Place channel in trip," within 72 hours3 days 0.429 weeks 0.0986 months , or Condition E.2 requires that the unit be placed "in MODE 3," within 78 hours3.25 days 0.464 weeks 0.107 months .

Condition E.2 is addressed by DOC M.2. A Note modifies the Required Actions of Condition E. This Note allows the testing of an additional channel with one channel inoperable. This changes the CTS by not requiring the performance of a QPTR and not requiring power and flux trip setpoints to be reduced for an inoperable PRNF rate trip channel.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 14 of 28 L-3.3

Table L - Less Restrictive Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS Requirement CTS Requirement Change Type 3.3.1 L.24 CTS Table 4.3-1 requires a CHANNEL FUNCTIONAL TEST for Function 6 SR 3.3.1.7 NOTE Table 4.3-I 7 Source Range Neutron Flux channels at a frequency of S/U ('. S/U requires the Note(I) surveillance to be performed prior to each reactor start up. Note ") states, "If not performed within the previous 31 days." This requirement is applicable in MODES 3, 4, and 5'. The

states, "With the reactor trip system breakers closed and the control rod drive system capable of rod withdrawal." ITS Function 5 Source Range Neutron Flux channels are required in MODES 3 a), 4 (a) and 5(') to perform SR 3.3.1.7. Note (a) states, "With Rod Control System capable of rod withdrawal or one or more rods not fully inserted." The change from Note " to Note (a)is addressed by DOC L. I. The ITS SR requires a COT to be performed every 92 days. It is modified by a Note that states, "Not required to be performed for source range instrumentation prior to entering MODE 3 from MODE 2 until 4 hours0.167 days 0.0238 weeks 0.00548 months after entering MODE 3." The change fiom 31 to 92 days is addressed by DOC L. II. This changes the CTS surveillance requirement by providing an allowance to perform the SR 4 hours0.167 days 0.0238 weeks 0.00548 months after entering the applicable MODE.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 15 of 28 L -3.3

Table L - Less Restrictive Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS Requirement CTS Requirement Change Type 3.3.1 L.25 CTS Surveillance Requirements in Table 4.3-1 for Function 21..B, reactor trip SR 3.3.1.4 NOTE Table 4.3-1 Note 5 bypass breaker, require a CHANNEL FUNCTIONAL TEST to be performed at a (10) refueling (R) Frequency. The Frequency is modified by a Note (") that states, "Automatic undervoltage trip." Note (o0)is addressed by DOC LA.4. ITS Table 3.3.1-1 Function 19, Reactor Trip Breakers (h) requires the performance of SR 3.3.1.4. Note (h) states, "Including any reactor trip bypass breakers that are racked in and closed for bypassing an RTB." SR 3.3.1.4 requires the monthly testing (TADOT) on a Staggered Test Basis for the trip and bypass breakers. A Note that states, "This Surveillance must be performed on the trip bypass breaker immediately after placing the bypass breaker in service" modifies SR3.3.1.4. This changes the CTS by deleting the surveillance requirement performed on a refueling basis for the RTB bypass breaker.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7- Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 16 of 28 L -3.3

Table L - Less Restrictive Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS Requirement CTS Requirenment Change Type 3.3.1 L.26 CTS Table 3.3-1 Functions 18.a (Low Auto Stop Oil Pressure) -nd 18.b (Turbine 3.3.1 Condition N Table 3.3-1 Action 4 Stop Valve Closure) requires the functions to be OPERABLE in MODE I and Note 9 Action 9 to be entered for an inoperable channel. Action 9 requires an inoperable channel be placed in trip within 72 hours3 days 0.429 weeks 0.0986 months or reduce power to less than P-8 setpoint within the next 4 hours0.167 days 0.0238 weeks 0.00548 months . ITS Table 3.3.1-1 Function 16 Turbine Trip with Low Auto Stop Oil Pressure (16a) and Turbine Stop Valve Closure (16b) lists the applicable MODES as MODE 1191. Note 18)states, "Above the P-8 (Power Range Neutron Flux) interlock." The Table lists Condition N to be entered for an inoperable channel. Condition N states, "One Turbine Trip channel inoperable, Place channel in trip," within 72 hours3 days 0.429 weeks 0.0986 months , or "Reduce THERMAL POWER < P-8,"

within 76 hours3.167 days 0.452 weeks 0.104 months . A Note modifies Condition N that states, "The inoperable channel may be bypassed for up to 12 hours0.5 days 0.0714 weeks 0.0164 months for surveillance testing of other channels." This changes the CTS by adding an allowance that an inoperable channel may be bypassed for up to 12 hours0.5 days 0.0714 weeks 0.0164 months for surveillance testing of other channels.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4- Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 17 of 28 L -3.3

Table L - Less Restrictive Changes ITS Section 3.3 - Instrumentation 1 1 1 an ge -11 Vt'S Requirement (JIS Requirement (ii DOC Nc I. Description of Change ITS RequireCment CTS Requirenment CTayge Type I ii i I 3.3. I L.527 Table 3.3-I NOTE Tables 3.3-1 and CTS Tables 3.3-1 and 4.3-1 list the MODES of applicability for the Intermediate (c) 4.3-1 Range function 5 as MODE I below the P-10 setpoint and MODE 2. Action 3 must be entered for an inoperable channel. Action 3-part b states "Above the P-6 setpoint, but below the P-10 setpoint, restore the inoperable channel to OPERABLE status prior to increasing THERMAL POWER above the P-10 setpoint." ITS Table 3.3.1--1 Function 4 Intermediate Range lists the Applicable 2(c). Note (b)states, MODES or other specified conditions as MODES V(') and "Below the P-10 (Power Range Neutron Flux) interlocks," and Note (0)requires, "Above the P-6 (Intermediate Range Neutron Flux) interlocks." Conditions F and G must be entered for an inoperable channel(s). Required Actions F.2 and G.2 limit THERMAL POWER for the unit to < P-6 setpoint. This changes the CTS by decreasing the applicability from MODE 2 to MODE 2 above the P-6 setpoint. I - I I4 I

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 18 of 28 L -3.3

Table L - Less Restrictive Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS Requirement CTS Requirement Change Type 3.3.1 L.28 CTS Table 3.3-I Functions 9.) Pressurizer Pressure - Low, 11.) Pressurizer Water Table 3.3.1-1 TFable 3.3-1 2 Level - High, 12.) Loss of Flow, 16.) Undervoltage - RCP Buses, 17.)

Underfrequency - RCP Buses, 18.) Turbine Trip, and 20.) RCP Breaker Position are required to be OPERABLE. Functions 9 and I I have applicable MODES of I and 2, and Functions 12, 16, 17, 18, and 20 have an applicability of MODE I.

Action 8 must be entered for an inoperable channel on Functions 9, II, 12, 16, 17, and 20. Action 8 requires the inoperable channel to be placed into trip within 72 hours3 days 0.429 weeks 0.0986 months or the unit is required to be placed below P-7 interlock within 78 hours3.25 days 0.464 weeks 0.107 months .

Action 9 requires an inoperable channel for function 18, Turbine Trip, to be placed into trip within 72 hours3 days 0.429 weeks 0.0986 months or the unit is required to be placed below P-8 interlock within 76 hours3.167 days 0.452 weeks 0.104 months . ITS Table 3.3.1-1 Functions 8.a) Pressurizer Pressure-Low, 9.)

Pressurizer Water Level- High, 10.) Reactor Coolant Flow- Low, 1I.) RCP Breaker Position, 12.) Undervoltage RCPs, and 13.) Underfrequency RCPs require the functions to be OPERABLE in MODE I above the P - 7 setpoint. ITS Note (1 states, "Above the P-7 (Low Power Reactor Trips Block) setpoint." The Turbine Trip, Function 16 is required to be OPERABLE in MODE I above P-8 setpoint.

ITS Note W states, "Above the P-8 (Power Range Neutron Flux) interlock."

Condition L is required to be entered for an inoperable channel for functions 8.a, 9, 10, 12, and 13. Condition L states for one channel inoperable, "Place channel in trip," within 72 hours3 days 0.429 weeks 0.0986 months , or "Reduce THERMAL POWER to < P-7." in 78 hours3.25 days 0.464 weeks 0.107 months .

Function II RCP Breaker Position requires Condition M to be entered for an inoperable channel. Condition M states, "Place channel in trip," within 72 hours3 days 0.429 weeks 0.0986 months , or "Reduce THERMAL POWER to < P-7," in 78 hours3.25 days 0.464 weeks 0.107 months . Condition N is required to be entered if one Turbine Trip channel becomes inoperable. Condition N states, "Place channel in trip," within 72 hours3 days 0.429 weeks 0.0986 months , or "Reduce THERMAL POWER < P-8,"

within 76 hours3.167 days 0.452 weeks 0.104 months . This changes the CTS by stating the applicability for these functions so that they are compatible with their Required Actions.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7- Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 19 of 28 L -3.3

Table L - Less Restrictive Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS Requirement CTS Requirement Change Type 3.3.1 L.29 CTS 3.3. 1.1 requirements for Functional Unit 6.C, Source Range Neutron Flux Table3.3.1l--1Table 3.3.1.1 2 Shutdown, are stated in CTS Table 3.3-I. This requirement is applicable in MODES 3, 4, and 5 with the RTBs open and requires one source range channel to Note (e) Function 6(c) be OPERABLE. When the RTBs are closed and the rod control system is capable of rod withdrawal, the CTS requires two source range channels to be OPERABLE.

ITS 3.3.1 requirement for the Source Range Neutron Flux, Function 5, is stated in ITS Table 3.3.1 -I. The Table lists the applicability or other specified conditions as MODES 3(e), 4(e), and 5(e). Note (e) states, "With the Rod Control System incapable of rod withdrawal. In this condition, source range Function does not provide reactor trip but does provide indication." When the rod control system is capable of rod withdrawal, the CTS and the ITS require two source range channels to be OPERABLE. When the rod control system is not capable of rod withdrawal, the ITS requires one source range channel to be OPERABLE. This changes the CTS by requiring ITS Function 5 in MODES 3, 4, and 5 when the rod control system is incapable of rod withdrawal instead of MODES 3, 4, and 5 when the RTBs are open, This allows only one source range channel to be OPERABLE in conditions when the CTS would require two source range channels to be OPERABLE.

3.3.2 L.1 CTS 3.3.2.1 requires the ESFAS instrumentation channels shown in Table 3.3-3 to None Table 3.3-3 be OPERABLE. Table 3.3-3 states for function 6(a), Auxiliary Feedwater Pump function 6(a) starts on manual initiation that the total number of channels is 2. The function is required to be OPERABLE in MODES 1, 2, and 3. For an inoperable channel, Action 21 must be entered. ITS 3.3.2 in Table 3.3.2-1 does not require the manual initiation function for AFW pump starts. This changes the CTS by deleting the requirements for manual initiation ofAFW pump starts.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7- Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 20 of 28 L-3.3

Table L - Less Restrictive Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS Requirement CTS Requirement Change Type 3.3.2 L.2 CTS requirement 3.3.2.1 for Steam Line Isolation, Functional Unit 4 in Table 3.3- Table 3.3.2-I Table 3.3-3 2 3, requires the function to be OPERABLE with the capabilities to perform a Main NOTE (d)

Steam isolation. The isolation may be initiated from Manual, Automatic Actuation Containment Pressure- Intermediate High-High, and Steam Flow in Two Steam Lines - High coincident with either Ta,,e Low-Low or Steam Line Pressure Low.

The steam line isolation functions are required to be OPERABLE in MODES 1, 2, and 3". ITS LCO 3.3.2 in Table 3.3.2-1 lists the requirement for Steam Line Isolation as Function 4. This requires the function to be OPERABLE with initiation by Manual, Automatic Actuation Logic and Actuation Relays, Containment Pressure Intermediate High-High, H]igh Steam Flow in Two Steam Lines with either Ta,, Low-Low or Steam Line Pressure Low. These initiators are required to be OPERABLE in MODES I, 2(d), and 3 "'. Notation d)states, "Except when all MSIVs are closed and de-activated." This changes the CTS by not requiring the instrumentation channels to be OPERABLE in MODES 2(") and 3"".

3.3.2 L.3 CTS SR 4.3.2.1.3 provides for the Response Time Testing (RTT) of the ESF SR 3.3.2.9 NOTE 4.3.2.1.3 6 functions. This is applicable to the steam turbine driven pump start requirement of the CTS function 6 for the automatic start requirements. The AFW pumps are required to start on Steam Generator Water Level Low - Low, Loss of Offsite Power, the Trip of all Main Feedwater Pumps, and any SI signals. ITS SR 3.3.2.9 requires the verification of RTT to be within specific limits. A Note is added to the requirement that provides an exception for the turbine driven AFW pump. The allowance delays the required verification by 24 hours1 days 0.143 weeks 0.0329 months after Main Steam pressure reaches 1005 psig. This changes the CTS by allowing the RTT verification to be delayed for 24 hours1 days 0.143 weeks 0.0329 months after the unit reaches a stable condition for testing.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 21 of 28 L-3.3

Table L - Less Restrictive Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change SR 3.3.2.7 Table 4.3-2 NOTE 3.3.2 L.4 CTS Table 4.3-2 notation (I) is associated with the manual initiation switclhcs for (1)

Safety Injection, Containment Spray, Containment Isolation (Phase A and B),

Steam Line Isolation, and the start of the AFW pumps. The notation requires that each manual actuation switch be tested to actuate the required function at least once per 18 months during shutdown. In ITS Table 3.3.2-1, for each of the listed functions, SR 3.3.2.7 states that a TADOT must be performed at a frequency of eighteen months. This changes the CTS by deleting the "during shutdown" requirement and recuires the test be performed every 18 months.

A v141 1. ....-......- - - --- -

CTS 3.3.2.1 requirements listed in Table 3.3-3 for P-Il specifies two limits for the Table 3.3.2-1 Table 3.3-3 3.3.2 L.5 Allowable Value. The P-Il function allowable value of: _<2010 psig prevents manual block of Safety Injection (SI) on Low Low Pressurizer Pressure; and <

1990 psig allows the manual block of SI on Low Low Pressurizer Pressure. ITS 3.3.1 requirements in Table 3.3.1 -1 for Reactor Trip System interlock P-1I lists only the allowable value that prevents manual block of the function. This value is

_< 2010 psig. This changes the CTS by eliminating the P-Il interlock value for allowing manual function block.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements Page 22 of 28 L-3.3 North Anna Power Station

Table L - Less Restrictive Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS Requirement CTS Requirement Change Type 3.3.2 L.6 CTS Table 3.3-3 for Functional Units 5.a and 5.b, Turbine Trip and Feedwater Table 3.3.2-I Table 3.3-3 Note 2 Isolation on Steam Generator (SG) Water Level - High-High and Automatic NOTE (3) #0#

Actuation Logic and Actuation Relays, requires for each an applicability of MODES 1, 2, and 3'#. Notation A states, "Except when all MFlVs, MFRVs, and associated bypass valves are closed and de-activated or isolated by a closed manual valve." ITS Table 3.3.2 - I for Function 5, Turbine Trip and Feedwater Isolation, requires that Functions 5.a and 5.b, Automatic Actuation Logic and Actuation Relays and SG Water Level - High High, be OPERABLE in MODES 1, 2(0), and 3(e). Note (e) states, "Except when all Main Feedwater pump discharge valves or all MFIVs, MFRVs, and associated bypass valves are closed and de-activated or isolated by a closed manual valve." This changes the CTS by modifying the MODES 2 and 3 applicability with the addition of the Main Feedwater (MFW) pump discharge valves to the list.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 23 of 28 L -3.3

Table L - Less Restrictive Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS Requirement CTS Requirement Change Type 3.3.2 L.7 CTS Table 3.3-3 for Functional Units 5.a and 5.b, Turbine Trip and Feedwater Table 3.3.2- I Table 3.3-3 2 Isolation on Steam Generator (SG) Water Level - High-Hligh and Automatic Function 5 Actuation Logic and Actuation Relays, requires for each an applicability of MODES 1,2, and 3"'. Notation ""'states, "Except when all MFIVs, MFRVs, and associated bypass valves are closed and de-activated or isolated by a closed manual valve." ITS Table 3.3.2 -1 for Function 5, Turbine Trip and Feedwater Isolation, requires that Functions 5.a and 5.b, Automatic Actuation Logic and Actuation Relays and SG Water Level - High High, be OPERABLE in MODES 1, 2"), and 3(c). Note (c)states, "Except when all Main Feedwater pump discharge valves or all MFIVs, MFRVs, and associated bypass valves are closed and de-activated or isolated by a closed manual valve." The Main Feedwater pump discharge valves addition is addressed by DOC L.6. This changes the CTS by stating the Functions 5.a and 5.b are not applicable in MODE2 when appropriate valves are closed and provide the required safety function.

3.3.3 L.lI CTS 3.3.3.6 Action a requires the restoration of PAM instrumentation channels None 3.3.3.6 Action a 3,4 within seven days whenever one required channel is inoperable or the unit to be 3.6.4.1 Action a shutdown within the next 12 hours0.5 days 0.0714 weeks 0.0164 months . CTS 3.6.4.1 Action a requires the restoration of an inoperable hydrogen analyzer within thirty days with one analyzer inoperable. ITS 3.3.3 Conditions A and B require the restoration of post accident instrumentation channels within thirty days or the initiation of a special report.

This changes the CTS by deleting the requirements for the unit to be in HOT SHUTDOWN within the next 12 hours0.5 days 0.0714 weeks 0.0164 months with one inoperable channel for a Function that has two required channels, allowing an additional restoration time, and instead requiring a report to be made in accordance with Specification 5.6.6.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 24 of 28 L -3.3

Table L - Less Restrictive Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS Requirement CTS Requirement Change Type 3.3.3 L.2 CTS 3.3.3.6 Action b requires the restoration of inoperable PAM instrumentation 3.3.3 Condition C 3.6.4.1 Action b 3 channels within forty-eight hours whenever both required channels for a Function are inoperable. CTS 3.6.4.1 Action b. allows 7 days to restore one hydrogen analyzer to OPERABLE status when both are inoperable. ITS 3.3.3 Condition C requires the restoration of inoperable PAM instrumentation channels within seven days. This changes the CTS by allowing an additional five days for restoration of an inoperable instrumentation channel for a Function that has two inoperable channels.

3.3.3 L.3 CTS SR 4.6.4.1 states, in part, "Each hydrogen analyzer shall be demonstrated SR 3.3.3.2 SR 4.6.4.1 7 OPERABLE at least once per 92 days on a STAGGERED TEST BASIS by performing a CHANNEL CALIBRATION." Under the CTS definition of STAGGERED TEST BASIS, both hydrogen analyzer channels must be tested every 92 days in equal subintervals. ITS SR 3.3.3.2 states a CI4ANNEL CALIBRATION must be performed at a frequency of every 92 days. This changes the CTS for the hydrogen analyzer by eliminating the STAGGERED TEST BASIS (STB) requirement that the hydrogen analyzers be tested in equal subintervals of the Frequency.

3.3.3 L.4 Not used. N/A N/A N/A 3.3.3 L.5 CTS 3.3.3.6 in Table 3.3-10 requires the following functions to be OPERABLE: 8) None TFable 3.3-10 I Refueling Water Storage Tank, 9) Boric Acid Tank Solution Level, 10) Auxiliary functions 8, 9, 10, Feedwater Flow Rate, 12) PORV Position Indicator, 13) PORV Block Valve 12, 13, 14 and 16 Position Indication, 14) Safety Valve Position Indication, and 16) Containment Water Level. ITS 3.3.3 does not require these functions to be OPERABLE. This changes the CTS by deleting these functions firom the post accident monitoring functions.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 25 of 28 L,- 3.3

Table L - Less Restrictive Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS Requirement CTS Requirement Change IType 3.3.3 L.6 CTS Table 3.3-6 requires 2 channels of the Containment High Range Area Table 3.3.3-1 'Fable 3.3-6 2 Monitors to be OPERABLE in MODES 1, 2, 3, and 4. ITS LCO 3.3.3 Function I1, Containment Area Radiation (High Range), requires 2 channels to be OPERABLE in MODES 1,2, and 3. This changes the CTS by deleting the function in MODE 4.

3.3.3 L.7 CTS Table 3.3-6 requires 2 channels of the Containment High Range Area 3.3.3 ACTION A 'Fable 3.3-6 Action 3 Monitors to be OPERABLE. Table 3.3-6 specifies Action 35 is to be entered when 35 a channel becomes inoperable. This action requires inoperable channels to be returned to OPERABLE within 7 days. ITS LCO 3.3.3 Function 11, Containment Area Radiation (High Range), requires 2 channels to be OPERABLE. ITS Condition A is required to be entered for an inoperable channel for a period of 30 days. This changes the CTS by allowing 23 additional days for one channel of Containment High Range Area Monitors to be inoperable.

3.3.3 L.8 CTS Table 3.3-6 requires 2 channels of the Containment High Range Area 3.3.3 ACTION A Table 3.3-6 Action 3,4 Monitors to be OPERABLE. Table 3.3-6 specifies Action 35 is to be entered when 35 a channel becomes inoperable. This action requires inoperable channels to be returned to OPERABLE within 7 days or a special report be made within 14 days.

ITS LCO 3.3.3 Function 11, Containment Area Radiation (fligh Range), requires 2 channels to be OPERABLE in MODES 1, 2, and 3. ITS Condition A allows one channel to be inoperable for a period of 30 days before a report is required. ITS Condition B required with 2 channels inoperable that one channel must be restored to OPERABLE status within 7 days or the plant must be shutdown. This changes the CTS by allowing 2 channels of Containment IHigh Range Area Monitors to be inoperable and providing a period of7 days to restore one inoperable channel.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 26 of 28 L-3.3

Table L - Less Restrictive Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS Requirement CTS Requirement Change Type 3.3.3 L.9 CTS Table 3.3-6 requires 2 channels of the Containment High Range Area None Table 4.3-3 5 Monitors to be OPERABLE. Surveillance Requirements of a CHANNEL CHECK, CHANNEL FUNCTIONAL TEST, CHANNEL CALIBRATION are required to be performed per CTS Table 4.3-3. The ITS includes Surveillance Requirements for a CHANNEL CHECK and a CHANNEL CALIBRATION to be performed on PAM function II. This changes the CTS by eliminating the CHANNEL FUNCTIONAL TEST for the PAM instrument.

3.3.4 L. I CTS 3.3.3.5 states that the auxiliary shutdown panel monitoring instrumentation None Table 3.3-9 listed in Table 3.3-9 shall be OPERABLE. Function 9 of the table lists the Relay Function 9 Room Positive Ventilation requirement. This requires one channel to be OPERABLE and indicate fr'om 0 to 0.5 inches of water pressure. A CHANNEL CHECK is required once a month and a CH4ANNEL CALIBRATION is required each refueling. ITS 3.3.4 in Table 3.3.4-1 does not require the Relay Room Positive Ventilation instrumentation channel to be OPERABLE. This changes the CTS requirements by eliminating the Relay Room Ventilation pressure from the required channel requirements.

3.3.4 L.2 Unit 2 CTS 3.3.3.5 requires in Action a, that an inoperable channel(s) will either be 3.3.4 Action A CTS 3.3.3.5 Action 3 returned to OPERABLE status within 7 days, or the unit must be shutdown. Unit 1 a CTS 3.3.3.5 requires in Action a, that an inoperable channel(s) will either be returned to OPERABLE status within 30 days, or the unit must be shutdown. ITS LCO 3.3.4 Action A states that with one or more required functions inoperable, the required function will be restored to OPERABLE status within 30 days. This changes the Unit 2 CTS requirements for restoring a required function from 7 to 30 days.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 27 of 28 L-3.3

Table L - Less Restrictive Changes ITS Section 3.3 - Instrumentation DOC No. Description of Change ITS Requirement CTS Requirement Change Type 3.3.5 L.lI CTS Table 3.3-3 for ESFAS instrumentation states the total number of channels as 3.3.5 ACTION B 3.3-3 Action 19 4 three for the loss of power (LOP) functions (loss of voltage and degraded voltage).

CTS Action 19 is required to be entered for an inoperable channel, and the inoperable channel is required to be placed in the tripped condition within 72 hours3 days 0.429 weeks 0.0986 months . ITS LCO 3.3.5 states the total number of required channels as three for each function. ITS Condition B states, "One or more Functions with two or more channels per bus inoperable, restore all but one channel to OPERABLE status in I hour." This changes the CTS to allow more than one channel for the functions to be inoperable 3.3.5 L.2 CTS 3.3.2, Action 19, states that with the number of OPERABLE channels one 3.3.5 ACTION C 3.3.2 Action 19 4 less than the total number of channels, STARTUP and POWER OPERATION may proceed provided the inoperable channel is placed in trip within 72 hours3 days 0.429 weeks 0.0986 months . ITS 3.3.5 Action C states, "When the Required Action and associated Completion Time not met," immediately enter applicable Condition(s) and Required Action(s) for the associated EDG made inoperable by LOP EDG start instrumentation. This changes the CTS by allowing the associated EDG to be declared inoperable instead of the declaring the LOP function inoperable, entering LCO 3.0.3, and shutting down the unit.

3.3.5 L.3 CTS Table 3.3-4 for function 7.a, Loss of Power 4160 Volt Emergency Bus SR 3.3.5.2 Table 3.3-4 Undervoltage (Loss of Voltage) states an Allowable Value of > 2989 volts. SR 3.3.5.2 states that a CHANNEL CALIBRATION is performed with an Allowable Value for the Loss of Voltage set to 2935 volts. This changes the CTS by decreasing the Allowable Value for the Loss of Voltage from 2989 to 2935 volts.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 28 of 28 L -3.3

Table L - Less Restrictive Changes ITS Section 3.4 - Reactor Coolant System (RCS)

DOC No. Description of Change 1TS Requirement CTS Requirement 3.4.1 L. I CTS 4.2.5.2 states that the Reactor Coolant System total flow rate shall be SR 3.4.1.4 4.2.5.2 determined to be within its limit by measurement at least once per 18 months. ITS SR 3.4.1 .4 requires measurement of the RCS total flow rate every 18 months and is modified by a Note which states, "Not required to be performed until 30 days after

> 90% RTP." This changes the CTS by relaxing the Surveillance Frequency in order to allow entry into MODE I to perform the test and requires the test to be performed within 30 days after exceeding 90% RTP.

3.4.2 L.1 CTS Surveillance 4.1.1.5 states that the RCS T,,,g shall be determined to be> SR 3.4.2.1 4.1.1.5 541 'F within 15 minutes prior to achieving reactor criticality and every 30 minutes when the RCS T,,,g < 547°F and the Tý,g - Tr, Deviation Alarm is not reset.

ITS Specification 3.4.2 requires RCS Ta,,gin each loop to be verified to be >_541 'F every 12 hours0.5 days 0.0714 weeks 0.0164 months . Under ITS SR 3.0.4, a Surveillance must be performed within the specified Frequency prior to entering the MODE or other specified condition in the Applicability. This changes the CTS Surveillance Frequency by requiring that the RCS T,,*g for each loop be verified every 12 hours0.5 days 0.0714 weeks 0.0164 months 3.4.3 None N/A N/A 3.4.4 L. I CTS 3.4.1.1 states that when the reactor coolant loop requirements are not met, the unit must be in HOT STANDBY within I hour. ITS 3.4.4 states that when the reactor coolant loop requirements are not met, the unit must be in MODE 3 within 6 hours0.25 days 0.0357 weeks 0.00822 months . This changes the CTS by relaxing the Completion Time from I hour to 6 hours0.25 days 0.0357 weeks 0.00822 months .

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page I of 24 L - 3.4

"Fable L - Less Restrictive Changes ITS Section 3.4 - Reactor Coolant System (RCS)

DOC No. Description of Change ITS Requirement CTS Change Type Requirement 3.4.5 L. I CTS 3.4.1.2, Note "*" states that all reactor coolant pumps may be deenergized for LCO 3.4.5 Note I 3.4.1.2 Note " 4 up to I hour provided no operations are permitted that would cause dilution of the and Action C and Action b reactor coolant system boron concentration. CTS 3.4.1.2, Action b, states that when no reactor coolant loops are in operation, all operations involving a reduction in boron concentration of the RCS must be suspended and action must be initiated to return the required loop to operation. ITS LCO 3.4.5 Note 1 states that all reactor coolant pumps may be removed from operation provided no operations are permitted that would cause introduction into the RCS, coolant with boron concentration less than required to meet the SDM of LCO 3.1. I. ITS 3.4.5, Action C states that if two required RCS loops are inoperable or the required RCS loop(s) are not in operation, operations that would cause introduction into the RCS, coolant with boron concentration less than required to meet the SDM of LCO 3.1,.1 must be suspended, and action must be immediately initiated to restore one RCS loops to operable status and operation. This relaxes the CTS Required Actions by revising the action from suspending reductions in boron concentration to suspending introduction of coolant with a boron concentration less than required to meet LCO 3.1.1.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 2 of 24 L -3.4

Table L - Less Restrictive Changes ITS Section 3.4 - Reactor Coolant System (RCS)

DOC No. Description of Change ITS Requirement CTS Change Type Requirement 3.4.5 L.2 CTS 4.4.1.2.1 states that the required RCPs, ifnot in operation, shall be SR 3.4.5.3 Note 4.4.1.2.1 7 determined to be OPERABLE once per 7 days by verifying correct breaker alignment and indicated power availability. ITS SR 3.4.5.3 requires verification of correct breaker alignment and indicated power availability to the required pump not in operation every 7 days. It is modified by a Note which states, "Not required to be performed until 24 hours1 days 0.143 weeks 0.0329 months after a required pump is not in operation." This changes the CTS by not requiring the SR to be performed until 24 hours1 days 0.143 weeks 0.0329 months after a pump is taken out of operation.

3.4.6 L. I CTS 3.4.1.3, Action a, states that with less than the two required coolant loops 3.4.6 Action A 3.4.1.3 Action a 4 OPERABLE, action must be immediately initiated to return the required loops to OPERABLE status as soon as possible and to be in COLD SHUTDOWN within 20 hours0.833 days 0.119 weeks 0.0274 months . ITS 3.4.6, Action A, states that when one required loop is inoperable, action must be initiated immediately to restore the required loop to OPERABLE status. Action A also requires the plant to be in MODE 5 within 24 hours1 days 0.143 weeks 0.0329 months , but only if an RHR loop is OPERABLE. This changes the CTS by providing an exception to the requirement to be in MODE 5 and allowing 24 hours1 days 0.143 weeks 0.0329 months instead of20 hours0.833 days 0.119 weeks 0.0274 months to reach MODE 5.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 3 of 24 L -3.4

Table L - Less Restrictive Changes ITS Section 3.4 - Reactor Coolant System (RCS)

DOC No. Description of Change ITS Requirement CTS Change Type Requirement 3.4.6 L.2 CTS 4.4.1.3.2 states that the required pumps, if not in operation, shall be SR 3.4.6.3 Note 4.4.1.3.2 7 determined to be OPERABLE once per 7 days by verifying correct breaker alignment and indicated power availability. ITS SR 3.4.6.3 requires verification of correct breaker alignment and indicated power availability to the required pump that is not in operation every 7 days. It is modified by a Note which states, "Not required to be performed until 24 hours1 days 0.143 weeks 0.0329 months after a required pump is not in operation."

This changes the CTS by not requiring the SR to be performed until 24 hours1 days 0.143 weeks 0.0329 months after a pump is taken out of operation.

Change Category:

I - Relaxation of LCO Requirements 2- Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 4 of 24 L - 3.4

Table L - Less Restrictive Changes ITS Section 3.4 - Reactor Coolant System (RCS)

DOC No. Description of Change ITS Requirement CTS Change Type Requirement 3.4.6 L.3 CTS 3.4.1.3, Note "*" states that all reactor coolant pumps and RHIR pumps may LCO 3.4.6 Note 1 3.4.1.3 Note "*" 4 be deenergized for up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months provided no operations are permitted that would and Action B and 3.4.1.2 cause dilution of the reactor coolant system boron concentration. CTS 3.4.1.2, Action b Action b , states that when no coolant loop is in operation, all operations involving a reduction in boron concentration of the RCS must be suspended and action must be initiated to return the required loop to operation. ITS LCO 3.4.6 Note I states that all reactor coolant pumps and RHR pumps may be removed fiom operation provided no operations are permitted that would cause introduction into the RCS, coolant with boron concentration less than required to meet the SDM of LCO 3.1. 1. ITS 3.4.6, Action B states that if two required loops are inoperable or the required loop(s) are not in operation, operations that would cause introduction into the RCS, coolant with boron concentration less than required to meet the SDM of LCO 3.1.1 must be suspended, and action must be immediately initiated to restore one loop to operable status and operation. This relaxes the CTS Required Actions by revising the action from suspending reductions in boron concentration to suspending introduction of coolant with a boron concentration less than required to meet LCO 3.1.1..

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 5 of 24 L - 3.4

Table L - Less Restrictive Changes ITS Section 3.4 - Reactor Coolant System (RCS)

DOC No. Description of Change ITS Requirement CTS Change Type Requirement 3.4.7 L. I CTS 3.4.1.3 states that a coolant loop used to satisfy the LCO requirements must None 3.4.1.3, 4.4.1.3.3 1 consist of an RHR subsystem or a reactor coolant loop, its associated steam and 4.4.1.3.4 generator, and reactor coolant pump (RCP). CTS Surveillance 4.4.1.3.4 requires verification that one RHR loop or reactor coolant pump is in operation every 12 hours0.5 days 0.0714 weeks 0.0164 months . ITS 3.4.7 states that a steam generator with a secondary side water level of 17% may be used to satisfy the LCO requirements. CTS SR 4.4.1.3.3 also states this requirement. This changes the CTS by eliminating the requirement that an RCS loop used to meet the LCO must have an OPERABLE RCP. ITS Surveillance 3.4.7.1 does not require verification than a reactor coolant pump is in operation.

3.4.7 L.2 ITS 3.4.7 contains a Note which allows one required RIIR loop to be inoperable LCO 3.4.7 Note 3.4.1.3 for up to 2 hours0.0833 days 0.0119 weeks 0.00274 months for surveillance testing provided that the other RHR loop is OPERABLE and in operation. This allowance does not exist in CTS 3.4.1.3.

3.4.7 L.3 CTS 4.4.1.3.2 states that the required pumps, if not in operation, shall be SR 3.4.7.3 Note 4.4.1.3.2 7 determined to be OPERABLE once per 7 days by verifying correct breaker alignment and indicated power availability. ITS SR 3.4.7.3 requires verification of correct breaker alignment and indicated power availability to the required pump that is not in operation every 7 days. It is modified by a Note which states, "Not required to be performed until 24 hours1 days 0.143 weeks 0.0329 months after a required pump is not in operation."

This changes the CTS by not requiring the SR to be performed until 24 hours1 days 0.143 weeks 0.0329 months after a pump is taken out of operation.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 6 of 24 L-3.4

Table L - Less Restrictive Changes ITS Section 3.4 - Reactor Coolant System (RCS)

DOC No. Description of Change ITS Requirement CTS Change Type Requirement 3.4.7 L.4 CTS 3.4.1.3, Note "" states that all reactor coolant pumps and RHR pumps may LCO 3.4.7 Note I 3.4.1.3 Note "* 4 be deenergized for up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months provided no operations are permitted that would and Action C and Action b cause dilution of the reactor coolant system boron concentration. CTS 3.4.1.2, Action b , states that when no coolant loop is in operation, all operations involving a reduction in boron concentration of the RCS must be suspended and action must be initiated to return the required loop to operation. ITS LCO 3.4.7 Note I states that all reactor coolant pumps and RHR pumps may be removed from operation provided no operations are permitted that would cause introduction into the RCS, coolant with boron concentration less than required to meet the SDM of LCO 3.1.1. ITS 3.4.7, Action C states that if no required loops are OPERABLE or the required RHR loop is not in operation, operations that would cause introduction into the RCS, coolant with boron concentration less than required to meet the SDM of LCO 3.1.1 must be suspended, and action must be immediately initiated to restore one loop to operable status and operation. This relaxes the CTS Required Actions by revising the action from suspending reductions in boron concentration to suspending introduction of coolant with a boron concentration less than required to meet LCO 3.1. 1.

3.4.8 L. I ITS 3.4.8 contains a Note which allows one required RIIR loop to be inoperable LCO 3.4.8 Note 3.4.1.3 for up to 2 hours0.0833 days 0.0119 weeks 0.00274 months for surveillance testing provided that the other RIHIR loop is OPERABLE and in operation. This allowance does not exist in CTS 3.4.1.3.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 7 of 24 L - 3.4

'[able L - Less Restrictive Changes ITS Section 3.4 - Reactor Coolant System (RCS)

DOC No. Description of Change ITS Requirement CTS Change Type Requirement 3.4.8 L.2 CTS 4.4.1.3.2 states that the required pumps, ifnot in operation, shall be SR 3.4.8.2 Note 4.4.1.3.2 7 determined to be OPERABLE once per 7 days by verifying correct breaker alignment and indicated power availability. ITS SR 3.4.8.2 requires verification of correct breaker alignment and indicated power availability to the required pump that is not in operation every 7 days. It is modified by a Note which states, "Not required to be performed until 24 hours1 days 0.143 weeks 0.0329 months after a required pump is not in operation."

This changes the CTS by not requiring the SR to be performed until 24 hours1 days 0.143 weeks 0.0329 months after a pump is taken out of operation.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 8 of 24 L - 3.4

Table L - Less Restrictive Changes ITS Section 3.4 - Reactor Coolant System (RCS)

DOC No. Description of Change ITS Requirement CTS Change Type Requirement 3.4.8 L.3 CTS 3.4.1.3, Note "*" states that all reactor coolant pumps and RHIR pumps may LCO 3.4.8 Note I 3.4.1.3 Note "" 4 be deenergized for up to I hour provided no operations are permitted that would and Action B and 3.4.1.3 cause dilution of the reactor coolant system boron concentration. CTS 3.4.1.3, Action b Action b , states that when no coolant loop is in operation, all operations involving a reduction in boron concentration of the RCS must be suspended and action must be initiated to return the required loop to operation. ITS LCO 3.4.8 Note I states that all reactor coolant pumps and RHR pumps may be removed from operation provided no operations are permitted that would cause introduction into the RCS, coolant with boron concentration less than required to meet the SDM of LCO 3.1. 1. ITS 3.4.8, Action B states that ifno required loops are OPERABLE or the required RHIR loop is not in operation, operations that would cause introduction into the RCS, coolant with boron concentration less than required to meet the SDM of LCO 3.1.1 must be suspended, and action must be immediately initiated to restore one loop to operable status and operation. This relaxes the CTS Required Actions by revising the action from suspending reductions in boron concentration to suspending introduction of coolant with a boron concentration less than required to meet LCO 3.1. 1.

3.4.9 L.I CTS 3.4.4, action b, requires that the plant be in HOT STANDBY with the reactor 3.4.9 Action A 3.4.4 Action b 4 trip breakers open within 6 hours0.25 days 0.0357 weeks 0.00822 months . ITS 3.4.9, Action A, also requires that the plant be in MODE 3 within 6 hours0.25 days 0.0357 weeks 0.00822 months for this Condition, but requires that the rods be fully inserted and the Rod Control System be in a condition incapable of rod withdrawal. This changes the CTS by not specifically requiring that the RTBs be open.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 9 of 24 L -3.4

Table L - Less Restrictive Changes ITS Section 3.4 - Reactor Coolant System (RCS)

DOC No. Description of Change ITS Requiremlent CTS Change Type Requirement 3.4.10 L. I CTS 3.4.2 requires a safety valve to be OPERABLE in MODE 4. ITS 3.4.10 3.4.10 3.4.2 2 requires three safety valves to be OPERABLE in MODE 4 with all RCS cold leg temperatures > 235'F (Unit 1), 270'F (Unit 2). This changes the operating regime within MODE 4 in which pressurizer safety valves are required to be OPERABLE.

The change in the number of required safety valves is discussed in DOC M.3 3.4.10 L.2 CTS 3.4.2 Action states that with no pressurizer safety valve OPERABLE in 3.4.10 3.4.2 Action 4 MODE 4, immediately suspend positive reactivity changes and place an OPERABLE RI]R loop into operation. ITS 3.4. 10 states that with one pressurizer safety valve inoperable in MODE 4 with all RCS cold leg temperature > 235 'F (Unit 1), 270'F (Unit 2), restore the valve to OPERABLE status within 15 minutes.

If in MODE 4 the valve is not restored within that time, or if two or more pressurizer safety valves are inoperable, be in MODE 4 with any RCS cold leg temperature < 235'F (Unit 1), 270'F (Unit 2) within 12 hours0.5 days 0.0714 weeks 0.0164 months . This changes the CTS actions to be taken in MODE 4 when one or more pressurizer safety valves are inoperable.

3.4.10 L.3 CTS LCOs 3.4.3.1 and 3.4.2 provide requirements on the pressurizer code safety LCO 3.4.10 3.4.2 and 3.4.3.1 2 valves in MODES 1, 2, 3, and 4. The ITS LCO 3.4.10 Applicability is modified by Applicability Note a Note which allows the lift settings-to not be within the LCO limits during MODES 3 and 4 for the purpose of setting the pressurizer safety valves under ambient (hot) conditions. The exception is allowed for 54 hours2.25 days 0.321 weeks 0.074 months following entry into MODE 3 provided a preliminary cold setting was made prior to heatup. This changes the CTS by allowing entry into MODES 3 and 4 without verifying that the pressurizer code safety valve lift settings are within the LCO limits.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 10 of 24 L -3.4

Table L - Less Restrictive Changes ITS Section 3.4 - Reactor Coolant System (RCS)

DOC No. Description of Change ITS Requirement CTS Change Type Requirement 3.4.10 L.4 CTS 3.4.3.1 states that with one pressurizer code safety valve inoperable, be in 3.4.10 3.4.3.1 3 HOT SHUTDOWN within 12 hours0.5 days 0.0714 weeks 0.0164 months . ITS 3.4.10 states that with one pressurizer safety valve inoperable, be in MODE 4 with any RCS cold leg temperature _<235

'F (Unit 1), 270 'F (Unit 2) within 24 hours1 days 0.143 weeks 0.0329 months . The change in the end condition is discussed in DOC M.2. This changes the CTS by allowing 24 hours1 days 0.143 weeks 0.0329 months vice 12 hours0.5 days 0.0714 weeks 0.0164 months to reach the end condition.

3.4.11 L.I CTS 4.4.3.2.2 requires testing of each block valve every 92 days CTS SR 3.4.11.2 and 4.4.3.2.2 and 7 4.4.3.2.l.b. 1 requires operating a PORV through one complete cycle of full travel 3.4.11.3 Notes 4.4.3.2. 1.b. I at least once per 18 months. ITS SR 3.4.11.2 and 3.4.11.3 modify these CTS Surveillances with a Note which states, "Only required to be performed in MODES I and 2." This changes the CTS by allowing entry into MODE 3 prior to performing the Surveillance.

3.4.11 L,2 CTS 3.4.3.2, Action B, applies when one or both block valves are inoperable. ITS None 3.4.3.2 Action B 4 3.4.11, Action D and G, apply when one or both block valves, respectively, are inoperable. ITS 3.4.11, Actions D and G, are modified by a Note which states that the Required Actions are not applicable when the block valve is inoperable solely as a result of complying with Required Actions C.2 and F.2. ITS Required Actions C.2 and F.2 require power to be removed from the block valve and apply when'the associated PORV is inoperable. This changes the CTS by eliminating the requirement to declare the block valve inoperable when power is removed because the associated PORV is inoperable.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page I11 of 24 L - 3.4

Table L - Less Restrictive Changes ITS Section 3.4 - Reactor Coolant System (RCS)

DOC No. Description of Change ITS Requirement CTS Change Type Requirement 3.4.11 L.3 CTS 3.4.3.2, Action A.3, states, "With one or both PORV(s) inoperable due to a None 3.4.3.2 Action I malfunction in the PORV automatic control system, within I hour restore the A.3 affected automatic control system(s) to OPERABLE status or place and maintain the affected PORV(s) in manual control." CT'S 4.4.3.2.1 .a required performance 4.4.3.2.1 .b.3 of a Channel Functional Test every 31 days and CTS 4.4.3.2. .b.3 requires a Channel Calibration of the actuation instrumentation every 18 months. ITS 3.4.11 does not require the PORV automatic control system for OPERABILITY. This changes the CTS by eliminating the LCO requirement and SRs for the PORV automatic control system.

3.4.11 L.4 CTS 4.4.3.2.2 states that each block valve shall be cycled unless the block valve is SR 3.4.11.2 4.4.3.2.2 7 closed in order to meet the requirements of ACTION A.4 or A.5. ACTIONS A.4 and A.5 require the block valve to be closed for reasons other than excessive PORV seat leakage. ITS SR 3.4.11.2 states that each block valve shall be cycled, but it is modified by a Note stating that the SR is not required to be performed with the block valve closed in accordance with the Required Actions. This changes the CTS by not requiring a cycle of the block valve when the block valve is closed due to excessive PORV seat leakage.

3.4.12 L.1 CTS 3.4.9.3, Action c, allows 8 hours0.333 days 0.0476 weeks 0.011 months to depressurize the RCS and establish an 3.4.12 Action G 3.4.9.3 Action c 3 RCS vent when both PORVs are inoperable. ITS 3.4.12, Action G, allows to depressurize the RCS and establish an RCS vent when both PORVs are inoperable.

This changes the CTS by allowing 12 hours0.5 days 0.0714 weeks 0.0164 months vice 8 hours0.333 days 0.0476 weeks 0.011 months to depressurize and vent the RCS when both PORVs are inoperable.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 12 of 24 L -3.4

Table L - Less Restrictive Changes ITS Section 3.4 - Reactor Coolant System (RCS)

DOC No. Description of Change ITS Requirement CTS Change Type Requirement 3.4.12 L.2 CTS 3.4.9.3.e states that in the event either the PORVs or the RCS vent(s) are used None 3.4.9.3.e 8 to mitigate an RCS pressure transient, a Special Report shall be prepared and submitted to the Commission pursuant to Specification 5.9.2 within 30 days. The report shall describe the circumstances initiating the transient, the effect of the PORVs or RCS vent(s) on the transient, and any corrective action necessary to prevent recurrence. The ITS does not have a similar requirement. This changes the CTS by eliminating a Special Report.

3.4.13 L.lI CTS Surveillance 4.4.6.2.1.d requires the performance ofa Reactor Coolant SR 3.4.13.1 Note 4.4.6.2.l.d 7 System water inventory balance at least once per 72 hours3 days 0.429 weeks 0.0986 months during steady state operation. ITS SR 3.4.13.1 also requires that RCS operational leakage be verified to be within its limits by performance of an RCS water inventory balance every 72 hours3 days 0.429 weeks 0.0986 months during steady state operation. In addition, ITS SR 3.4.13.1 contains a Note which states that the Surveillance is not required to be performed until 12 hours0.5 days 0.0714 weeks 0.0164 months after establishment of steady state operation. This changes the CTS by providing an exception to the Surveillance Frequency.

3.4.13 L.2 CTS Surveillances 4.4.6.2. l.a, 4.4.6.2. .b, and 4.4.6.2. I.e require monitoring of None 4.4.6.2.1 .a, 5 the containment atmosphere particulate radioactivity monitor and the containment 4.4.6.2.1.b, and sump inventory and discharge every 12 hours0.5 days 0.0714 weeks 0.0164 months , and the reactor head flange leakoff 4.4.6.2. I.e temperature every 24 hours1 days 0.143 weeks 0.0329 months . The ITS does not contain these Surveillance Requirements. This changes the CTS by eliminating these Surveillance Requirements.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 13 of 24 L-3.4

Table L - Less Restrictive Changes ITS Section 3.4 - Reactor Coolant System (RCS)

ITS Requirement CTS Change Type Description of Change Requirement 3.4.14: 3.4.6.2 2 CTS 3.4.6.2 is applicable in MODES 1, 2, 3, and 4. ITS 3.4.14 is applicable in MODES 1, 2, and 3, and MODE 4, except valves in the residual heat removal Applicability and (RHIR) flow path when in, or during the transition to or from, the RI-IR mode of SR 3.4.14. INote 2 operation. SR 3.4.14.1, Note 2, exempts RHIR PIVs from the leakage surveillance when in the shutdown cooling mode of operation. This changes CTS by exempting the RIHR isolation PIVs from the leakage requirements when those valves are open.

3.4.14 Action 3.4.6.2 4 3.4.14 L.2 CTS 3.4.6.2 does not contain an ACTION for more than one flow path with RCS PIVs inoperable. In this condition, entry into LCO 3.0.3 is required. ITS 3.4.14 Note I contains ACTION Note I which allows separate condition entry for each flow path. This changes the CTS by allowing the Completion Times to apply to each flow path and prevents an LCO 3.0.3 entry should more than one RCS PIV flow path be inoperable.

3.4.14 Action A 3.4.6.2 Action c 4 3.4.14 L.3 CTS 3.4.6.2, Actions b and c, requires a shutdown to MODE 3 in 6 hours0.25 days 0.0357 weeks 0.00822 months and MODE 5 in the following 30 hours1.25 days 0.179 weeks 0.0411 months when leakage from required RCS PIVs is greater than the limit. ITS 3.4.14, ACTION A allows 4 hours0.167 days 0.0238 weeks 0.00548 months to restore RCS PIV leakage to within limit. Ifthe RCS PIV leakage can not be restored within limit within 4 hours0.167 days 0.0238 weeks 0.00548 months , the ITS requires a shutdown to MODE 3 in 6 hours0.25 days 0.0357 weeks 0.00822 months and MODE 5 in the following 30 hours1.25 days 0.179 weeks 0.0411 months . This changes the CTS by allowing up to 4 hours0.167 days 0.0238 weeks 0.00548 months to restore RCS PIV leakage to within limit instead of requiring an immediate shutdown.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements Page 14 of 24 L -3.4 North Anna Power Station

Table L - Less Restrictive Changes ITS Section 3.4 - Reactor Coolant System (RCS)

DOC No. Description of Change ITS Requirement CTS Change Type Requirement 3.4.14 L.4 CTS Surveillance 4.4.6.2.2.b requires testing of RCS PIVs prior to entering MODE SR 3.4.14.1 4.4.6.2.2.b 7 2 whenever the plant has been in Cold Shutdown for 72 hours3 days 0.429 weeks 0.0986 months or more and if leakage testing has not been performed in the previous 9 months. ITS SR 3.4.14.1 requires testing of RCS PIVs prior to entering MODE 2 whenever the unit has been in MODE 5 for 7 days or more, if leakage testing has not been performed in the previous 9 months. This changes the CTS by allowing shutdowns to MODE 5 from 3 to 7 days in length without requiring RCS PIV testing.

3.4.14 L.5 CTS Surveillance 4.4.6.2.2.c requires testing of RCS PIVs following maintenance, None 4.4.6.2.2.c 5 repair, or replacement work on the valve. ITS 3.4.14 does not include this requirement. This changes the CTS by eliminating a post-maintenance Surveillance Requirement.

3.4.14 L.6 Unit 2 CTS Surveillance 4.4.6.2.2.d requires testing of RCS PIVs within 24 hours1 days 0.143 weeks 0.0329 months SR 3.4.14.1 Note 3 4.4.6.2.2.d 7 following a valve actuation. ITS SR 3.4.14.1 contains a Frequency which requires RCS PIVs to be tested within 24 hours1 days 0.143 weeks 0.0329 months following valve actuation due to automatic or manual action or flow through the valve. SR 3.4.14.1, Note 3, states that such testing does not have to be performed more than once on valves ifra repetitive testing loop cannot be avoided. This changes the CTS by allowing valve testing to not be performed if it would result in a repetitive testing loop.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 15 of 24 L - 3.4

Table L - Less Restrictive Changes ITS Section 3.4 - Reactor Coolant System (RCS)

DOC No. Description of Change ITS Requirement CTS Change Type Requirement 3.4.14 L.7 Unit I CTS Surveillance 4.4.6.2.2 requires each RCS PIV specified in CTS Table 3.4.14.1 Footnote to LCO 6 3.4-1 be demonstrated OPERABLE by verifying leakage to be within its lim it. 3.4.6.2.f and "Tile Unit I leakage limit is I gpm to 5 gpm, depending of the results of past tests. 4.4.6.2.2 In addition, the minimum differential test pressure must be 150 psid or greater.

The Unit 2 CTS Surveillance 4.4.6.2.2 requires each RCS PIV specified in CTS Table 3.4-1 be tested in accordance with Specification 4.0.5 (the Inservice Test Program). This requirement is modified by a footnote to LCO 3.4.6.2.f which states that the leakage limit for any RHR system isolation valve shall be 5 gpm.

ITS SR 3.4.14.1 requires verification of leakage foiom each RCS PIV required to be tested equivalent to 0.5 gpm per nominal inch of valve size up to a maximum of 5 gpm at an RCS pressure >_ 2215 psig and < 2255 psig. This changes the Unit I and Unit 2 Surveillance acceptance criteria.

3.4.15 L.I Not Used N/A N/A N/A 3.4.15 L.2 CTS 3.4.6.1 ACTION does not include an exclusion allowing a delay in 3.4.15 Required 3.4.6.1 4 performing an RCS water inventory balance. ITS 3.4.15 REQUIRED ACTIONS Actions A. I and A. I and B. 1.2 include NOTES that state, "Not required until 12 hours0.5 days 0.0714 weeks 0.0164 months after B. 1.2 Notes establishment of steady state operation." This changes the CTS by allowing 12 hours0.5 days 0.0714 weeks 0.0164 months after establishment of steady state operation AND after entering tile respective Conditions before an RCS water inventory balance must be performed.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 16 of 24 L - 3.4

Table L - Less Restrictive Changes ITS Section 3.4 - Reactor Coolant System (RCS)

DOC No. Description of Change ITS Requirement CTS Change Type Requirement 3.4.15 L.3 CTS 3.4.6.1.a states, "The following Reactor Coolant System leakage detection 3.4.15.b 3.4.6.1.a I systems shall be OPERABLE: a. The containment atmosphere particulate and gaseous radioactivity monitoring system, and..." ITS 3.4.15.b states, "The following RCS leakage detection instrumentation shall be OPERABLE: ... One containment atmosphere radioactivity monitor (gaseous or particulate)." This changes the CTS by requiring only one containment atmosphere radioactivity monitor, gaseous or particulate, instead of two.

3.4.15 L.4 CTS 3.3.3.1 Table 4.3-3 requires a monthly Channel Functional Test for the SR 3.4.15.2 Table 4.3-3 7 containment RCS leakage detection radiation monitors. ITS SR 3.4.15.2 requires a Channel Operational Test be performed every 92 days. This changes the CTS by increasing the Frequency for the test friom monthly to 92 days.

3.4.16 L. I CTS 3.4.8 is applicable in MODES 1,2, 3, 4, and 5. ITS 3.4.16 is applicable in 3.4.16 3.4.8 2 MODES I and 2, and MODE 3 with RCS T,,,ý> 500 [F. This changes the CTS by reducing the MODES in which the LCO is applicable.

3.4.16 L.2 Not Used N/A N/A N/A 3.4.16 L.3 CTS '[able 4.4-4, Item I, requires gross activity determination at least once per 72 SR 3.4.16.1 Table 4.4-4 7 hours0.292 days 0.0417 weeks 0.00959 months . ITS SR 3.4.16.1 requires verification that the reactor coolant gross specific Item I activity < 100 / E pCi/gm every 7 days. This changes the CTS by reducing the Frequency from 72 hours3 days 0.429 weeks 0.0986 months to 7 days.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6- Relaxation Of Surveillance Requirement Acceptance Criteria 7- Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 17 of 24 L- 3.4

Table L - Less Restrictive Changes ITS Section 3.4 - Reactor Coolant System (RCS)

DOC No. Description of Change ITS Requirement CTS Change Type Requirement L.4 CTS Table 4.4-4, Item 4, requires isotopic analysis for iodine once per 4 hours0.167 days 0.0238 weeks 0.00548 months None 3.4.8 Action a 4 3.4.16 when the specific activity exceeds 100 / F iCi/gm. The ITS does not contain this and Table 4.4-4 Action. This changes the ITS by eliminating a conditionally performed Item 4 Surveillance when gross activity exceeds 100 / k Ci/gm.

L.5 CTS Table 4.4-4, Item 3, requires radiochemical determination of E- once per 6 SR 3.4.16.3 Note Table 4.4-4 7 3.4.16 of 2 Item 3 and months. Footnote

states that the sample is to be taken after a minimum Footnote the reactor was EFPD and 20 days of POWER OPERATION have elapsed since last subcritical for 48 hours2 days 0.286 weeks 0.0658 months or longer. ITS SR 3.4.16.3 requires E to be determined from a sample taken in MODE I after a minimum of 2 effective full power days and 20 days of MODE I operation have elapsed since the reactor was last subcritical for Ž48 hours2 days 0.286 weeks 0.0658 months . ITS SR 3.4.16.3 is modified by a Note which states, "Not required to be performed until 31 days after a minimum of 2 effective full power days and 20 days of MODE I operation have elapsed since the reactor was last subcritical for Ž>48 hours2 days 0.286 weeks 0.0658 months . This changes the CTS by putting a limit, 31 days, on when the Surveillance must be performed after the requisite conditions are met.

Change Category:

I - Relaxation of LCO Requirements 2- Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 18 of*24 L- 3.4

Table L - Less Restrictive Changes ITS Section 3.4 - Reactor Coolant System (RCS)

DOC No. Description of Change ITS Requirement CTS Change Type Requirement 3.4.17 L. I CTS 3.4.1.1 requires that all reactor coolant loops be in operation with power 3.4.17 Actions 3.4.1.1 4 removed from the loop stop valve operators. CTS 3.4.1.1 does not contain an Note Action for power available to one or more of the loop stop valve operators and, in this condition, LCO 3.0.3 would be entered. ITS 3.4.17 requires that when power is available to one or more loop isolation valve operators that the power must be removed within 30 minutes. The Actions are modified by a Note that states that separate condition entry is allowed for each RCS loop isolation valve. If power is not removed within 30 minutes, LCO 3.0.3 would be entered. This changes the CTS by allowing 30 minutes per isolation valve to remove power from the isolation valve operator before entering LCO 3.0.3.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 19 of 24 L -3.4

Table L - Less Restrictive Changes ITS Section 3.4 - Reactor Coolant System (RCS)

DOC No. Description of Change ITS Requirement CTS Change Type Requirement 3.4.18 L. I CTS 3.4.1.4 states that the boron concentration ofan isolated loop is to be None 3.4.1.4 and I and 6 maintained greater than equal to the boron concentration corresponding to the 4.4.1.4 SHUTDOWN MARGIN requirements of Specification 3.1. 1.1 or 3.1.1.2 as applicable for the active volume of the Reactor Coolant System unless the loop has been drained for maintenance. CTS 3.4.1.4 Action contains the actions to be taken when the loop isolation valves are closed but the boron concentration of the isolated loop is less than required. CTS Surveillance 4.4.1.4 requires that the boron concentration of the isolated loop must be verified to be within limits at least once per 24 hours1 days 0.143 weeks 0.0329 months . ITS 3.4.18 states that the hot and cold leg isolation valves of a filled, isolated loop must remain closed if the boron concentration of the isolated loop is less than the boron concentration required to meet the SDM of LCO 3. 1.1 or the boron concentration of LCO 3.9.1. If the loop isolation valves are opened without the isolated loop boron concentration requirement being met, the loop isolation valves must be closed. This changes the CTS LCO requirement (and the corresponding Action and Surveillance) by eliminating the ongoing requirement that the boron concentration of an isolated loop be equal to or greater than the concentration of the operating loops unless the loop has been drained for maintenance and applying requirements on boron concentration only when a loop isolation valve is to be opened. The addition to reference to LCO 3.9.1 is addressed in DOC A.2.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 20 of 24 L -3.4

Table L - Less Restrictive Changes ITS Section 3.4 - Reactor Coolant System (RCS)

.. I I- e qurm I lI. ClllýT%

DOC No. Description of Change IT1R5Icqulrenment Requirement cliange i yle I

________________________________________________ I None I 4.4.1.6.3 5 L.2 CTS Surveillance 4.4.1.6.3 requires that the source range neutron flux monitor be None 4.4.1.6.3 3.4.18 demonstrated OPERABLE by a CHANNEL FUNCTIONAL TEST within 8 hours0.333 days 0.0476 weeks 0.011 months prior to commencing isolated loop backfill and a CHANNEL CHECK at least once per 15 minutes during backfilling of an isolated loop. ITS 3.4.18 does not contain these requirements. This changes the CTS by eliminating a CHANNEL FUNCTIONAL TEST and periodic CHANNEL CHECKS firom the process of backfilling a drained loop from the active RCS volume.

I -+

I None t

I

- t.-

I Iý 3.4.1.5 ,3.4.1.6, 3.4.18 L.3 CTS LCO 3.4.1.5 and CTS LCO 3.4.1.6 require that the stop valves remain closed and Note to with A.C. power removed and its breaker locked open unless certain conditions are 3.4.1.5 satisfied. The CTS LCO 3.4.1.5 Note *, CTS 3.4.1.5 Action, and CTS 3.4.1.6 and the Actions b and d also specify that A.C. power be removed from the valve(s) 3.4.18 Action F state that an RCS loop breaker locked open. ITS 3.4.18 and ITS shall remain isolated with power removed from tile valve unless certain conditions are satisfied. This changes the CTS by removing the LCO requirement (and be corresponding Action and Notes requirements) that the isolation valve breaker locked open.

1 ______________________________ ___________________________

I Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements Page 21 of24 L - 3.4 North Anna Power Station

Table L - Less Restrictive Changes ITS Section 3.4 - Reactor Coolant System (RCS)

DOC No. Description of Change ITS Requirement CTS Change Type Requirement 3.4.18 L.4 CTS 3.4.1.6.c.2 states that the source range neutron flux count rate shall be no None 3.4.1.6.c.2 and 1 more that a factor of2 above the initial count rate during the filling of a drained 3.4.1.6 Action d RCS loop from the active volume of the RCS. CTS 3.4.1.6 Action d, states that if the source range count rate increase by a factor to two over the initial count rate, then the loop stop valves must be closed, power removed, and the breakers locked open. Furthermore, it states that no attempt shall be made to reopen the loop stop valves until the reason for the count rate increase has been determined. The ITS does not contain these requirements. This changes the CTS by eliminating the requirement to maintain count rate a less than twice the initial count rate and the corresponding Action.

3.4.19 L.lI CTS 4.10.4.2 requires that tests be performed on each Intermediate and Power SR 3.4.19.2 4.10.4.27 Range channel and P-7 Interlock within 12 hours0.5 days 0.0714 weeks 0.0164 months prior to initiating startup or PHYSICS TESTS. ITS SR 3.4.19.2 requires that the testing be performed prior to initiation of startup and PHYSICS TESTS. This changes the CTS by eliminating the time period prior to initiation of startup and PHYSICS TrESTS within which tile testing must be performed.

CTS 3.7.9.2 CTS Surveillance 4.7.9.2.c.2 requires each RHR pump in the subsystem flowpath None 4.7.9.2.c.2 5 L.I to be verified OPERABLE per Specification 4.0.5. The ITS does not contain this Surveillance.

Change Category:

I - Relaxation of LCO Requirements 2- Relaxation of Applicability 3 - Relaxation of Completion Time 4- Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7- Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 22 of 24 L - 3.4

Table L - Less Restrictive Changes ITS Section 3.4 - Reactor Coolant System (RCS)

Description of Change ITS Requirement CTS Change Type DOC No. Requirement None 4.7.9.2.b. 1, 5 CTS 3.7.9.2 CTS Surveillance 4.7.9.2.b. I requires, every 31 days, the cycling of each testable, L.2 remote or automatically operated valve in the RHR subsystem flowpath through at 4.7.9.2.b.2 and least one complete cycle. CTS Surveillance 4.7.9.2.b.2 states that the correct 4.7.9.2.b.3 position of each manual valve in tile RIAR subsystem flowpath that is not locked, sealed, or otherwise secured in position must be verified at least once per 3 1 days.

CTS Surveillance 4.7.9.2.b.3 requires that the correct position of each remote or automatically operated valve in the RHIR subsystems flowpath must be verified to be in the correct position at least once per 3 1 days. The ITS does not contain these requirements.

None 4.7.9.2.a 5 CTS 3.7.9.2 CTS Surveillance 4.7.9.2.a requires that the RHR subsystem be demonstrated L.3 OPERABLE by verifying isolation of the RIJR system prior to the Reactor Coolant System pressure exceeding 500 psig by closing and de-energizing both remote operated RHR suction isolation valves and locking the associated breakers.

The ITS does not contain this requirement.

None 3.7.9.2 CTS 3.7.9.2 CTS 3.7.9.2 states that one RHIR subsystem shall be OPERABLE in MODES 4 L.4 and 5. CTS 3.4.1.3 states that at least two coolant loops shall be OPERABLE and at least one must be in operation in MODES 4 and 5. The two coolant loops may consist of any combination of RCS and RHIR loops. ITS 3.4.6 states that two loops consisting of any combination of RCS loops and RIIR loops shall be OPERABLE and one loop shall be in operation. ITS 3.4.7 and 3.4.8 require on RI-IR subsystem to be OPERABLE in MODE 5. This changes the CTS by eliminating the requirement that one RHR subsystem be OPERABLE in MODE 4.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7- Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements Page 23 of 24 L-3.4 North Anna Power Station

Table L - Less Restrictive Changes ITS Section 3.4 - Reactor Coolant System (RCS)

DOC No. Description of Change ITS Requirement CTS Change Type Requirement CTS 3.7.9.2 CTS 3.7.9.2 Action states that when no RHR subsystem is OPERABLE, None 3.7.9.2 4 L.5 immediate action must be taken to restore an RHR subsystem to OPERABLE status or maintain RCS temperature less than 350'F by use of alternate heat removal methods. ITS 3.4.6 states that when one required cooling loop is inoperable, immediate action must be taken to restore a second loop to OPERABLE status. That second loop may be an RIJR loop or an RCS loop. ITS 3.4.7 and 3.4.8 states that if no REAR loop is OPERABLE in MODE 5, immediate action must be taken to restore the inoperable loop. This changes the CTS by eliminating the requirement to immediately restore an RHIR loop to OPERABLE status in MODE 4. The requirement to maintain RCS temperature less than 350'F by alternate heat removal methods is unchanged as, in this context, the OPERABLE RCS loop is an alternate heat removal method and heatup above 3507F (i.e., to MODE 3) is prohibited by ITS LCO 3.0.4.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6- Relaxation Of Surveillance Requirement Acceptance Criteria 7- Relaxation Of Surveillance Frequency 8- Deletion of Reporting Requirements North Anna Power Station Page 24 of 24 L - 3.4

Table L - Less Restrictive Changes ITS Section 3.5 - Emergency Core Cooling Systems (ECCS) f IS Requirement t I 5 Keqllirement L flange I

DOC No. Description of Change iTrS lequirenicnt CT R,51equilremlent Typange

. i 3.5.1 Applicability -1 3.5.1 Applicability I. f 12 I

3 applicability is 3.5.1 L.I The CTS 3.5.1 Applicability is MODES I, 2, and 3. The MODE 3.5.1 Applicability 3.5.1 Applicability Pressure above 1000 psig. Power modified by a footnote that states, "Pressurizer 3 when below 1000 psig." The ITS lock out of valves is not permitted in MODE 2, and MODE 3 with RCS pressure > 1000 3.5.1 Applicability is MODES I and by eliminating the CTS Applicability statement, psig. This changes the CTS 10(10 p;ig."

"Power lock out or valves is not permitted in MODE 3 when below i +

3.5.1 L.2 3.5.1 Action A. I 3.5.1 IAction ia CTS 3.5.1 Action a states that an inoperable accumulator must he restored to valve.

OPERABLE status within one hour, except as a result of a closed isolation due to boron ITS 3.5. I ACTION A. I states that if one accumulator is inoperable within 72 concentration not within limits, it must be restored to OPERABLE status may be hours. This changes CTS by increasing the time one accumulator to 72 hours3 days 0.429 weeks 0.0986 months .

inoperable due to boron concentration not within limits from 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months i1 t i 3.5.1 L.3 3.5.1 Action 1)

CTS 3.5.1, Action b, requires that a unit be in HOT STANDBY within I hour and 3.5.1 HOT SHUTDOWN within the next 12 hours0.5 days 0.0714 weeks 0.0164 months when an accumulator is inoperabhle.

if an due to a closed accumulator isolation valve. ITS LCO 3.5.1 states thai limit bo0on accumulator is inoperable for any reason other than an out of within one concentration, the accumulator must be restored to OPERABLE status status within one hour, the hour. If the accumulator is not restored to OPERABLE pressure< 1000 Osig in unit must be in MODE 3 in 6 hours0.25 days 0.0357 weeks 0.00822 months and MODE 3 with RCS the time to enter MODIE ,3 with a 12 hours0.5 days 0.0714 weeks 0.0164 months . This changes the CTS by extending I hour to 7 hours. The time to exit the closed accumulator isolation MOV firom and is addressed Applicability remains 13 hours0.542 days 0.0774 weeks 0.0178 months from the time of the inoperability, by Discussion of Change A.6.

Change Category:

I - Relaxation o" LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement Criteria 6 - Relaxation Of Surveillance Requiremcnt Acceptance 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements Page I ol(6 L-3.5 North Anna Power Station

Table L - Less Restrictive Changes ITS Section 3.5 - Emergency Core Cooling Systems (ECCS)

DOC No. Description of Change ITS Requirement CTS Requirement Change Type 3.5.1 L.4 CTS Surveillance 4.5. .b requires that tile accumnulator boron concentration be SR 3.5.1.4 4.5.1 .b 7 verificd at least once per 31 days and within 6 hours0.25 days 0.0357 weeks 0.00822 months after each solution volume increase of > 5% of tank volume. ITS SR 3.5.1.4 conlains the same requiremeets, but it will not require the boron concentration to be measured if the solution volume increase was made from the Refueling Water Storage Tank (RWST).

3.5.1 L.5 CTS Surveillance 4.5. 1lA requires verification every 18 months that each None 4.5. I.d 5 accumulator isolation MOV opens automatically'when RCS pressure exceeds 2010 psig and on receipt of a safety injection test signal. The ITS does not contain that requirement.

3.5.1 L.6 CTS Surveillance 4.5. I.c requires verification that the breaker supplying powe)v to SR 3.5.1.5 4.5. I.c 6 the accumulator isolation MOV is locked in the off position at least every 31 days when the RCS pressure is above 2000 psig. ITS SR 3.5.1.5 requires verification that power is removed from each accumulator isolation MOV at leasi every 3 1 days when the RCS pressure is above 2000 psig. This changes the CTS by not specifying in what manner electrical power is removed from the valve.

3.5.2 L. I CTS 4.5.2.e. 1 and 4.5.2.e.2 require verification ol the automatic actuation of ECCS SR 3.5.2.5 and 4.5.2.c. I and 6 components on a safety injection test signal. ITS SR 3.5.2.5 and SR 3.5.2.6 state 3.5.2.6 4.5.2.c.2 that automatic actuation of ECCS components may be performed with an actual or simulated actuation signal. This changes the CTS by explicitly allowing tie use of either an actual or simulated signal for the test. The change from "safert injce;ion" to "actuation" is discussed in LA.6.

Change Category:

I - Relaxation of LCO Requirements 2- Relaxation of Applicability 3- Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8- Deletion of Reporting Rcquirements North Anna Power Station Page 2 o16(- L -3.5

Table L - Less Restrictive Changes ITS Section 3.5 - Emergency Core Cooling Systems (ECCS)

I ITS Requirement I (21'S Requirement

..--.. . 1 Change DOC No. Description of Change [TS Reqluiremecnt CTIS Requirement Clhnge Type

__ __ __ __ ___ ___ __ __ _ __ __ _ I I T be 3.5.2 Actions A 3.5.2 Action a 4 3.5.2 L.2 CTS 3.5.2 Action a states that when one ECCS train is inopcrable, it must and C 72 hours. ITS 3.5.2 Action A slates that returned to OPERABLE status within are inoperable, restore the trains to OPERABLE status when one or more trains the ECCS within 72 hours3 days 0.429 weeks 0.0986 months . ITS 3.5.2, Action C states that with less than 100% of OPERABLE ECCS train available, entcr LCO 3.0.3 flow equivalent to a single the CTS by allowing combinations of equipment from immediately. This changes as meeting the ECCS sal'ety function provided 100% of the each train to be credited to a single OPERABLE ECCS train is available. For ECCS flow equivalent example, under the CTS an inoperable HHSI pump in one train and an inoperable a 3.0.3 low head safety injection (LHSI) pump in the other train would require ITS, the same condition would allow 72 hours bhlorc requiring a entry. Under the are shutdown because the remaining OPERABLE HIHSI pump and LHSI pump capable of producing the flow equivalent to a single OPERABLE train. 8 I i None 3.5.2 Action b A L.3 CTS 3.5.2 Action b requires that a Special Report be prepared and sub None 3.5.2 Action 1) 9 3.5.2 NRC within 90 days following an ECCS actuation that results in water injected into the Reactor Coolant System. The report is to include the accumulated actuation cycles to date. ITS 3.5.2 does not include this r . _- ____ i 4.5.2.g. 1Iand 3.5.2 I.4 CTS 4.5.2.g. 1 and 4.5.2.h describe tests that must be performed follow None 4.5.2.h1 repositioning of valves, maintenance, or modification to the ECCS. TI not include these testing requirements. - -- - I -______________I___________ ,______

I_

I Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requiremcnt Acceptance Criteria 7 - Relaxation Of Surveillance Frcquency 8 - Deletion of Reporting Requirements Page 3 of 6 L-3.5 North Anna Power Station

Table L - Less Restrictive Changes (ECCS)

ITS Section 3.5 - Emergency Core Cooling Systems I. ti S KequireOleOl I . I . KCLfLIIICILICII Change Description of Change ITS Requirement CTS RýC(]Lllicnient Type DOC No.

SR 3.5.2.8 4.5.2.d. I ol the containment sump 3.5.2 L.5 CTS Surveillance 4.5.2.d. I requires a visual inspection not restricted by debris and and verification that the subsystemns suction inlets are that the sump components (trash racks, screens, etc.) show no evidence of structural distress or corrosion. ITS SR 3.5.2.8 contains the same rcquirements, hut it is only of abn.rmal necessary to verify that the sump components show no evidence of no abnormal corrosion. This changes CTS by only requiring verification .. _

corrosion versus corrosion. SR 3.5.2.5 4.5.2.c. 1 valves actuate to their 3.5.2 L.6 CTS 4.5.2.e. I requires ve-ification that ECCS auttolatic ECCS automatic valves correct position. ITS SR 3.5.2.5 requires vcril'ication that secured in position, actuate in the flow path that are not locked, sealed or otherwise signal. This changes the to the correct position on an actual or simulated actuation secured in or otherwise CTS by excluding those valves that are locked, sealed, position friom the verification. SR 3.5.2.7 4.5.2.g 6 manual valves arc 3.5.2 L.7 CTS Surveillance 4.5.2.g requires verification that specificd injection. ITS SR 3.5.2.7 requires locked and tagged in the proper position for throttle valves are secured in the correct verification that the specified ECCS not specifying that the valves be verified locked position. This changes the CTS by and tagged. LCO 3.5.2 Note None (SI) flow patlhs may 3.5.2 L.8 ITS 3.5.2 LCO Note states, "In MODE 3, both safety injection it) perform rrcssum e be isolated by closing the isolation valves for up to 2 hours0.0833 days 0.0119 weeks 0.00274 months a Note.

not include such isolation valve testing per SR 3.4.14." CTS 3.5.2 does to be inoperable in MODE This changes the CTS by allowing both trains of ECCS testing per 3.4.14. 1.

3 for up to 2 hours0.0833 days 0.0119 weeks 0.00274 months f~or required pressure isolation valve I Change Categor*y:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement Criteria 6 - Relaxation Of Surveillance Requirement Acceptance 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements L-3.5 North Anna Power Station Page 4 of 6

Table L - Less Restrictive Changes ITS Section 3.5 - Emergency Core Cooling Systems (ECCS)

ITS Requirement ClS Requirement T Change Description of Change ITS Requirement CTIS Rc(Iuir-cilent Change I DOC No. ,TIpe

________________________________________________________________- I None 1 3.5.3 Action c 8 3.5.3 Action c 8 3.5.3 L.lI CTS 3.5.3, Action c requires that a Special Report be prepared and submitted to the None NRC within 90 days following an ECCS actuation that results in water being injected into the Reactor Coolant System. The report is to include the total accumulated actuation cycles to date. ITS 3.5.3 does not inchlde this requiremcnt.

-i t i its 3.5.3 L.2 CTS 3.5.3 Action a allows 20 hours0.833 days 0.119 weeks 0.0274 months to reach MODE 5 when a HHSI pump or 3.5.3 Action B 3.5.3 Action it B

[low path From the refueling water storage tank is inoperable. ITS 3.5.3 Action allows 24 hours1 days 0.143 weeks 0.0329 months to reach MODE 5. This change the CTS by extending the Completion Time from 20 to 24 hours1 days 0.143 weeks 0.0329 months .

+ i t 3.5.4 L.1 The CTS 3.5.5 Action allows I hour to restore an inoperable RWST. ITS LCO 3.5.4 Action A 3.5.5 Applicability 3.5.5 Action 13 3.5.4, Action A allows 8 hous to restore the RWST to OPERABI.E status if the inoperability is due to the RWST boron concentration or temperature not within limits. This changes CTS by increasing the Completion Time for the specified Conditions from I1hour to 8 hours0.333 days 0.0476 weeks 0.011 months .

I --.-----.--.------ t- 3.5.5 1 3.4.6.2.e 12 3.5.5 3.4.6.2.e 3.5.5 L. I CTS 3.4.6.2.e is applicable in MODES I, 2, 3 and 4. IFthe requirenments of the LCO are not met, Action b requires entering MODE 5 (Cold ShUtdown) within 30 hours1.25 days 0.179 weeks 0.0411 months . ITS 3.5.5 is applicable in MODES I, 2, and 3. If the requirements of I0.O are not met, Action B requires entering MODE 4 in 12 hours0.5 days 0.0714 weeks 0.0164 months . This cha'nges the CTS by deleting MODE 4 from the MODES of Applicability and making corresponding changes to the ACTIONS and Completion Times.

I 4.4.6.2.1 .c 7 SSR 3.5.5 1I R 3.5.5. 4.4.6.2. I.c 1 3.5.5 L.2 CTS Surveillance 4.4.6.2. I.c requires measurement ofthe RCP scal in.jcction Ilow when RCS pressure is 2235 +/- 20 psig. ITS SR 3.5.5.1 will allow 4 hours0.167 days 0.0238 weeks 0.00548 months tc perform the Surveillance after RCS prcssurc stabilizes ->2215 psig and < 2255 psig. This changes the CTS by allowing 4 hours0.167 days 0.0238 weeks 0.00548 months after RCS pressure is stabilized at normal operating pressure to perform the Surveillance.

I Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillancc Frequency 8 - Deletion of Reporting Requirements Page 5 of 6 L -3.5 North Anna Power Station

"Fable L - Less Restrictive Changes (ECCS)

ITS Section 3.5 - Emergency Core Cooling Systems Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement Criteria 6 - Relaxation O1" Surveillance Requirement Acceptance 7 - Relaxation O Surveillance Frequency 8 - Deletion of Reporting Requirements Page 6 oif6 L- 3.5 North Anna Power Station

Table L - Less Restrictive Changes ITS Section 3.6 - Containment Systems DOC No. Description of Change ITS CTS Change Requirement Requirement Type 3.6.1 L.I CTS 1.6 states, "CONTAINMENT INTEGRITY shall exist when:... 1.6.2 All equipment 3.6.3 1.6 hatches are closed and sealed." 3.6.3 states, "Each containment isolation valve shall be OPERABLE." This changes the CTS by not including an explicit reference to sealing the equipment hatches. The change associated with moving the reference to the equipment hatch to the Bases is addressed by DOC LA. I.

3.6.2 L. I CTS 3.6.1.3 footnote "+" allows entry to the air lock to repair the inner air lock door, if 3.6.2 Action 3.6.1.3, footnote 4 inoperable. ITS 3.6.2 contains an Action NOTE that allows entry and exit to perform Note +

repairs on the affected air lock components. This changes CTS 3.6.1.3 by stating that exiting is allowed in addition to entry, and the entry can be for repairs on any affected air lock components, not just the inner air lock door.

3.6.2 L.2 CTS 3.6.1.3 Action b states, "With a containment air lock inoperable, except as the result 3.6.2, Action 3.6.1.3, 4 of an inoperable air lock door, maintain at least one air lock door closed, restore the B Notes Action b inoperable air lock to OPERABLE status within 24 hours1 days 0.143 weeks 0.0329 months , or be in HOT STANDBY within the next 6 hours0.25 days 0.0357 weeks 0.00822 months and in COLD SHUTDOWN within the following 30 hours1.25 days 0.179 weeks 0.0411 months ." This is the action that would be taken in the event of an inoperable air lock interlock mechanism. ITS 3.6.2 Condition B requires that with a containment air lock interlock mechanism inoperable, an OPERABLE door is verified closed in the affected air lock within I hour, an OPERABLE door is closed in the affected air lock, and an OPERABLE door is verified locked closed in the affected air lock once per 31 days. Required Action NOTES indicate that these Required Actions are not applicable if both doors in the same air lock are inoperable and Condition C is entered, and entry and exit of containment is permissible under the control of a dedicated individual. This changes the CTS by allowing indefinite operation with an inoperable air lock interlock mechanism, and allows entry and exit of containment under the control of a dedicated individual.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page I of 13 L- 3.6

Table L - Less Restrictive Changes ITS Section 3.6 - Containment Systems DOC No. Description of Change ITS CTS Change Requirement Requirement Type 3.6.2 L.3 CTS 3.6.1.3 does not provide an allowance for entry or exit through an air lock except for 3.6.2, Action 3.6.1.3 4 repair to the inner air lock door, if inoperable. ITS 3.6.2 Required Action A NOTE 2 A, Note 2 states, "Entry and exit is permissible for 7 days under administrative controls if both air locks are inoperable." This changes CTS by allowing entry and exit of containment under specified criteria for any reason.

3.6.2 L.4 CTS 3.6.1.3 does not address how to verify locked closed air lock doors in high radiation 3.6.2, Action 3.6.1.3 4 areas. ITS 3.6.2 Required Action A.3 contains a NOTE that provides an allowance for air A.3 Note lock doors in high radiation areas to be verified locked closed by administrative means when a containment air lock door or containment air lock interlock mechanism is inoperable. This changes CTS by allowing an air lock door in a high radiation area to be verified closed by administrative means.

3.6.2 L.5 Not used. N/A N/A N/A 3.6.2 L.6 CTS 4.6.1.3.b, which requires testing of the containment airlock interlock once per SR 3.6.2.2 4.6.1.3.b 7 refueling outage. For North Anna, a refueling outage testing frequency is equivalent to 18 months. ITS SR 3.6.2.2 requires testing of the containment airlock interlock every 24 months. This changes the CTS by decreasing the Frequency for the containment airlock interlock test from every 18 months to every 24 months.

3.6.3 L. I CTS 4.6.3.1.1 .b describes tests that must be performed prior to returning a valve to service None 4.6.3. 1.1 .b5 after maintenance, repair or replacement work is performed on the valve or its associated actuator, control or power circuit. The ITS does not include these testing requirements.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 2 of 13 L - 3.6

Table L - Less Restrictive Changes ITS Section 3.6 - Containment Systems DOC No. Description of Change i 3.6.3, Action 3.6.5.1 Action 3.6.3 L.2 CTS 3.6.5.1 Action states, "With the inside or outside isolation valve in the steam jet air A.I ejector suction line not closed, restore the valve to the closed position within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months ..."

ITS 3.6.3 Action A. I requires that with one or more penetration flow paths with one containment isolation valve inoperable, the affected isolation flow path be isolated by one of the specified methods within 4 hours0.167 days 0.0238 weeks 0.00548 months . This changes CTS by increasing the time within which to take the Required Action from I hour to 4 hours0.167 days 0.0238 weeks 0.00548 months .

3.6.3 L.3 CTS 3.6.3.1 states, "With one or more of the (containment) isolation valves inoperable, 3.6.3, 3.6.3.1 maintain at least one isolation valve OPERABLE in each affected penetration that is open Condition C and: isolate each affected penetration within 4 hours0.167 days 0.0238 weeks 0.00548 months " by one of the means specified. ITS 3.6.3 Condition C includes a Note stating that Condition C only applies to penetration flow paths with only one containment isolation valve and a closed system. Action C.1 requires that with one or more penetration flow paths with one containment isolation valve inoperable, the penetration flow path be isolated by one of the means specified within 72 hours3 days 0.429 weeks 0.0986 months . This changes the CTS by extending the Completion Time from 4 hours0.167 days 0.0238 weeks 0.00548 months to 72 hours3 days 0.429 weeks 0.0986 months when the inoperable valve is used in conjunction with a closed system.

3.6.3 L.4 CTS 3.6.5.1 Action states, "With the inside or outside isolation valve in the steam jet air 3.6.3, Action 3.6.5.1, Action ejector suction line not closed, restore the valve to the closed position..." ITS 3.6.3 Action A.I A. I requires that with one or more penetration flow paths with one containment isolation valve inoperable, the affected isolation flow path be isolated by use of at least one closed and de-activated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured. This changes CTS by only requiring the flow path be isolated by one of the specified methods, rather than requiring both valves be closed.

Change Category:

I - Relaxation of LCO Requirements 2- Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements Page 3 of 13 L- 3.6 North Anna Power Station

Table L - Less Restrictive Changes ITS Section 3.6 - Containment Systems DOC No. Description of Change ITS CTS Change Requirement Requirement Type 3.6.3 L.5 CTS 4.6.I1.l.a, 4.6.5. 1.1, and 4.6.5.1.2 require verification that specified containment SR 3.6.3.1 4.6.l1.l.a, 6 penetrations are closed. ITS SR 3.6.3.1 and ITS SR 3.6.3.2 include similar requirements, Note, SR 4.6.5.1.1, but contain a Note that allows valves and blind flanges in high radiation areas to be 3.6.3.2 Note 4.6.5.1.2 verified administratively. This changes the CTS by allowing certain valves and blind flanges to not require physical verification.

3.6.3 L.6 CTS 4.6.l.1 states, "Primary CONTAINMENT INTEGRITY shall be demonstrated: a. At SR 3.6.3.1, SR 4.6.1.1, footnote 6 least once per 31 days by verifying that all penetrations* not capable of being closed by 3.6.3.2 *, 4.6.5.1.2 OPERABLE containment automatic isolation valves and required to be closed during accident conditions are closed by valves, blind flanges, or deactivated automatic valves, secured in their positions except for valves that are open under administrative control as permitted by Specification 3.6.3.1." The "*" footnote states, "Except valves, blind flanges, and deactivated automatic valves which are located inside the containment and are locked sealed or otherwise sealed in the closed position. These penetrations shall be verified closed during each COLD SHUTDOWN except that such surveillance need not be performed more often than once per 92 days." CTS 4.6.5.1.2 states, "The steam jet air ejector suction line inside isolation valve shall be determined to be in the closed position prior to increasing the Reactor Coolant System temperature above 200'F." ITS SR 3.6.3.1 states, "Verify each containment isolation manual valve and blind flange that is located outside containment and not locked, sealed, or otherwise secured and required to be closed during accident conditions is closed, except for containment isolation valves that are open under administrative controls," every 31 days. SR 3.6.3.2 has similar controls for valves inside containment, but a different Frequency. This changes the CTS by not requiring valves locked, sealed or otherwise secured be verified closed as part of the Technical Specification Surveillance Requirements.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6- Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 4 of 13 L -3.6

"Fable L - Less Restrictive Changes ITS Section 3.6 - Containment Systems DOC No. Description of Change ITS CTS Change Requirement Requirement Type 3.6.3 L.7 CTS 4.6.1.1 states, "Primary CONTAINMENT INTEGRITY shall be demonstrated: a. At SR 3.6.3.2 4.6.1.1 footnote 7 least once per 31 days by verifying that all penetrations* not capable of being closed by

OPERABLE containment automatic isolation valves and required to be closed during accident conditions are closed by valves, blind flanges, or deactivated automatic valves, secured in their positions except for valves that are open under administrative control as permitted by Specification 3.6.3.1." The "*" footnote states, "Except valves, blind flanges, and deactivate automatic valves which are located inside the containment and are locked sealed or otherwise sealed in the closed position. These penetrations shall be verified closed during each COLD SHUTDOWN except that such surveillance need not be performed more often than once per 92 days." ITS SR 3.6.3.2.states, "Verify each containment isolation manual valve and blind flange that is located inside containment and not locked, sealed, or otherwise secured and required to be closed during accident conditions is closed, except for containment isolation valves that are open under administrative controls." The Frequency is prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days. This changes the CTS for the valves inside containment by only requiring valves not locked, sealed or otherwise secured to be verified closed prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days, instead of every 31 days. Changes associated with not requiring verification of closure of valves which are locked, sealed, or otherwise secured, are addressed in DOC L.6.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 5 of 13 L -3.6

Table L - Less Restrictive Changes ITS Section 3.6 - Containment Systems DOC No. Description of Change ITS CTS Change Requirement Requirement Type 3.6.3 L.8 CTS 4.6.5.1.2 states, "The steam jet air ejector suction line inside isolation valve shall be SR 3.6.3.2 4.6.5.1.2 7 determined to be in the closed position prior to increasing the Reactor Coolant System temperature above 2000 F." ITS SR 3.6.3.2 states, "Verify each containment isolation manual valve and blind flange that is located inside containment and not locked, sealed, or otherwise secured and required to be closed during accident conditions is closed, except for containment isolation valves that are open under administrative controls." The Frequency is prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days.

This changes the CTS by adding the criteria to the Frequency that the verification may be performed up to 92 days prior to entering MODE 4 from MODE 5. Changes associated with valves which are locked, sealed, or otherwise secured are addressed by DOC L.6.

3.6.3 L.9 CTS 3.6.3.1 footnote "'" states, "Locked or sealed closed valves may be opened on an 3.6.3, Action 3.6.3.1I intermittent basis under administrative control." ITS 3.6.3 Action Note I states, " Note I Penetration flow paths, except for 36 inch purge and exhaust valve, 18 inch containment vacuum breaking valve, 8 inch purge bypass valve, and steam jet air ejector suction flow paths, may be unisolated on an intermittent basis under administrative control." This changes the CTS by allowing any penetration, except for (he exceptions noted, to be unisolated on an intermittent basis under administrative control, and not just locked or sealed closed valves. Changes associated with the exceptions to this allowance listed are addressed by DOC M.2.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7- Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 6 of 13 L -3.6

Table L - Less Restrictive Changes ITS Section 3.6 - Containment Systems DOC No. Description of Change ITS CTS Change Requirement Requirement Type 3.6.3 L.10 CTS 3.6.3.1 Action states, "With one or more of the isolation valves inoperable...b. Isolate 3.6.3, Action 3.6.3.1 4 each affected penetration within 4 hours0.167 days 0.0238 weeks 0.00548 months by use of at least one deactivated automatic valve A. I Action secured in the isolation position, or c. Isolate each affected penetration within 4 hours0.167 days 0.0238 weeks 0.00548 months by use of at least one closed manual valve or blind flange..." ITS 3.6.3 Action A. I requires that with one or more penetration flow paths with one containment isolation valve inoperable, the affected isolation flow path be isolated by use of at least one closed and de activated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured. This changes CTS by allowing penetration flow paths with two containment isolation valves that have one containment isolation valve inoperable, to use a check valve with flow through the valve secured as the means of isolating the penetration flow path.

3.6.3 L.1 I CTS 4.6.3.1.2 states, "Each containment isolation valve shall be demonstrated SR 3.6.3.4 4.6.3.1.2 6 OPERABLE...by: a. Verifying that on a Phase A containment isolation test signal, each Phase A isolation valve actuates to its isolation position. b. Verifying that on a Phase B 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 secured in position, actuates to the isolation position on an actual or simulated actuation signal." This changes the CTS by not requiring valves locked, sealed or otherwise secured in position be tested to automatically actuate to their isolation position. Changes associated with moving details to the Bases are addressed by DOC LA.3. Changes associated with allowing the use of an actual signal for conducting the Surveillance Requirement are addressed by DOC L.12.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 7 of 13 L-3.6

Table L - Less Restrictive Changes ITS Section 3.6 - Containment Systems DOC No. Description of Change ITS CTS Change Requirement Requirement Type 3.6.3 L. 12 CTS 4.6.3.1.2 states, "Each containment isolation valve shall be demonstrated SR 3.6.3.4 4.6.3.1.2 6 OPERABLE...by: a. Verifying that on a Phase A containment isolation test signal, each Phase A isolation valve actuates to its isolation position. b. Verifying that on a Phase B 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 secured in position, actuates to the isolation position on an actual or simulated actuation signal." This changes tile CTS by not requiring valves locked, sealed or otherwise secured in position be tested to automatically actuate to their isolation position. Changes associated with moving details to the Bases are addressed by DOC LA.3. Changes associated with not requiring the Surveillance Requirement be conducted on valves locked, sealed, or otherwise secured in position are addressed by DOC L. I I.

3.6.3 L.13 CTS 4.6.3.1.3 states, "The isolation time of each power operated or automatic containment SR 3.6.3.3 4.6.3.1.3 6 isolation valve shall be determined to be within its limit when tested..." ITS SR 3.6.3.3 states, "Verify the isolation time of each automatic power operated containment isolation valve is within limits." This changes the CTS by deleting the reference to power operated containment isolation valves that may not be automatic.

3.6.3 L. 14 Not used. N/A N/A N/A 3.6.3 L. 15 CTS 3.6.3.1 states that with one or more isolation valves inoperable, maintain at least one 3.6.3 Action D 3.6.3.1 3 isolation valve OPERABLE in each affected penetration and restore the inoperable valve to OPERABLE status within 4 hours0.167 days 0.0238 weeks 0.00548 months . ITS 3.6.3, ACTION D, states that with purge valve leakage not within limit, restore leakage within limit within 24 hours1 days 0.143 weeks 0.0329 months . This changes the CTS by relaxing the Completion Time for one or more inoperable purge valves from 4 hours0.167 days 0.0238 weeks 0.00548 months to 24 hours1 days 0.143 weeks 0.0329 months .

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 8 of 13 L-3.6

Table L - Less Restrictive Changes ITS Section 3.6 - Containment Systems DOC No. Description of Change that 3.6.3 L. 16 CTS 4.6. 1. l.a requires verification that all non-automatic containment isolation valves are required to be closed are closed every 31 days. If a non-automatic valve that is supposed to be closed is found open, CTS 3.6.1.1 Action applies. That Action states, "Without primary CONTAINMENT INTEGRITY, restore CONTAINMENT INTEGRITY within one hour or be in at least Hot Standby within the next 6 hours0.25 days 0.0357 weeks 0.00822 months and in Cold Shutdown within the following 30 hours1.25 days 0.179 weeks 0.0411 months ." ITS 3.6.3 ACTIONS do not differentiate between automatic and non-automatic valves and allow I hour, 4 hours0.167 days 0.0238 weeks 0.00548 months , or 72 hours3 days 0.429 weeks 0.0986 months to isolate the affected flow path. ITS 3.6.3 allows continued operation with the inoperable containment isolation valve, but if the Required Actions and associated Completion Times are not met, a shutdown to MODE 3 in 6 hours0.25 days 0.0357 weeks 0.00822 months and MODE 5 in 36 hours1.5 days 0.214 weeks 0.0493 months is required. In addition, ITS 3.6.3 ACTIONS Notes 2, 3 and 4 allow separate condition entry for each penetration flow path, require entry into the applicable Conditions and Required Actions for systems made inoperable by containment isolation valves, and require entry into the applicable Conditions and Required Actions for LCO 3.6.1, "Containment," when leakage for a penetration flow path results in exceeding the overall containment leakage rate acceptance criteria. This changes the CTS by providing I hour, 4 hours0.167 days 0.0238 weeks 0.00548 months or 72 hours3 days 0.429 weeks 0.0986 months to isolate a penetration flow path affected by an inoperable non-automatic containment isolation valve, and allowing continued operation with an inoperable non-automatic containment isolation valve. This also changes the CTS by allowing separate condition entry for each penetration flow path with an inoperable non-automatic containment isolation valve, requiring entry into the applicable Conditions and Required Actions for systems made inoperable by inoperable non-automatic containment isolation valves, and requiring entry into tile applicable Conditions and Required Actions for LCO 3.6.1, "Containment," when leakage through a penetration flow path due to an inoperable non-automatic containment isolation valve results in exceeding the overall containment leakage rate acceptance criteria.

I _ _ _ 1_ __I_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ J _ _ _ _ _ _I _ _

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements Page 9 of 13 L-3.6 North Anna Power Station

Table L - Less Restrictive Changes ITS Section 3.6 - Containment Systems DOC No. Description of Change ITS CTS Change Requirement Requirement Type 3.6.4 None N/A N/A N/A N/A 3.6.5 None N/A N/A N/A N/A 3.6.6 L. I CTS Surveillance 4.6.2. I.c. I requires verification that each automatic valve in the flow SR 3.6.6.3 4.6.2. I.c. 1 6 path actuates to its correct position on a containment - high-high pressure signal. ITS SR 3.6.6.3 requires verification that each automatic valve in the flow path that is not locked, sealed, or otherwise secured in position actuates to its correct position on an actual or simulated actuation signal. This changes the CTS by excluding those valves that are locked, sealed, or otherwise secured in position from this test. Removal of the containment - high-high pressure signal reference and addition of the actual or simulated actuation signal reference are addressed by Removed Detail and Less Restrictive changes respectively.

L.2 CTS Surveillances 4.6.2. I.c. I and 4.6.2.1 .c.2 require verification of the automatic SR 3.6.6.3, SR 4.6.2. I.c. I, 6 3.6.6 actuation of QS components on a containment high-high pressure signal. ITS SR 3.6.6.3 3.6.6.4 4.6.2.1 .c.2 and SR 3.6.6.4 specify that the testing may be performed with an actual or simulated actuation signal. This changes the CTS by explicitly allowing the use of either an actual or simulated signal for the test. The change from "containment high-high signal" to "actuation signal" is discussed in LA.3.

3.6.7, 3.6.2.2 Action b 4 3.6.7 L.I CTS 3.6.2.2 ACTION b states that with two containment RS subsystems inoperable in one RS train, restore one inoperable subsystem to OPERABLE status within 72 hours3 days 0.429 weeks 0.0986 months . ITS Condition C 3.6.7 Condition C addresses two inside RS subsystems inoperable, allowing a COMPLETION TIME of 72 hours3 days 0.429 weeks 0.0986 months . This changes the CTS by allowing 72 to hours to restore one RS subsystem to OPERABLE status when two inside RS subsystems are inoperable instead of entering LCO 3.0.3.

Change Category:

i - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements Page 10 of 13 L-3.6 North Anna Power Station

Table L - Less Restrictive Changes ITS Section 3.6 - Containment Systems DOC No. Description of Change ITS CTS Change Requirement Requirement Type 3.6.7 L.2 CTS 3.6.2.2, ACTION b states that with two RS subsystems inoperable in one RS train, 3.6.7, Action 3.6.2.2, Action 3 one inoperable subsystem must be restored to OPERABLE status within 72 hours3 days 0.429 weeks 0.0986 months , or the E.2 b, Action c unit be placed in HOT STANDBY within the next 6 hours0.25 days 0.0357 weeks 0.00822 months , and COLD SHUTDOWN within the next 30 hours1.25 days 0.179 weeks 0.0411 months . CTS 3.6.2.2, ACTION c states that with the casing cooling tank inoperable, the tank must be restored to OPERABLE status within 72 hours3 days 0.429 weeks 0.0986 months , or tile unit be placed in HOT STANDBY within the next 6 hours0.25 days 0.0357 weeks 0.00822 months , and COLD SHUTDOWN within the next 30 hours1.25 days 0.179 weeks 0.0411 months . ITS 3.6.7 REQUIRED ACTION E.2 states that 84 hours3.5 days 0.5 weeks 0.115 months is allowed to place the unit in MODE 5. This changes CTS by allowing 48 more hours to place the unit in MODE 5 when the Required Actions and associated Completion Times are not met.

3.6.7 L.3 CTS 4.6.2.2.1 .c. I and 4.6.2.2. I.c.2 require verification of the automatic actuation of RS SR 3.6.7.6 4.6.2.2. .c. I, 6 components on a containment high-high pressure signal. ITS SR 3.6.7.6 states that 4.6.2.2.1 .c.2 automatic actuation of RS components may be performed with an actual or simulated actuation signal. This changes the CTS by explicitly allowing the use of either an actual or simulated signal for the test. The change from "containment high-high signal" to "actuation signal" is discussed in LA.4.

3.6.7 L.4 CTS 4.6.2.2.1.c.2 requires verification that each automatic valve in the RS flow path SR 3.6.7.6 4.6.2.2.1I.c.2 6 actuates to its correct position on an actuation signal. ITS SR 3.6.7.6.a requires verification that each RS automatic valve in the flow path that is not locked, sealed, or otherwise secured in position, actuates to its correct position on an actuation signal. This changes the CTS by specifying that the verification applies only to automatic RS valves that are not locked, sealed, or otherwise secured in position.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page I11 of 13 L -3.6

Table L - Less Restrictive Changes ITS Section 3.6 - Containment Systems DOC No. Description of Change ITS CTS Change Requirement Requirement Type 3.6.8 L.I CTS Surveillance 4.6.2.3.c requires verification of the automatic actuation of Chemical SR 3.6.8.4 4.6.2.3.c 6 Addition System automatic valves on a containment high-high test signal. ITS SR 3.6.8.4 specifies that the testing may be performed with an actual or simulated (i.e., test) actuation signal, This changes the CTS by explicitly allowing the use of either an actual or simulated signal for the test. The change from "containment high-high signal" to "actuation signal" is discussed in LA.3.

3.6.8 L.2 CTS Surveillance 4.6.2.3.c requires verification that each automatic valve in the flow path SR 3.6.8.4 4.6.2.3.c 6 actuates to its correct position on a containment high-high test signal. ITS SR 3.6.8.4 requires verification that each automatic valve in the flow path that is not locked, sealed, or otherwise secured in position actuates to its correct position on an actual or simulated actuation signal. This changes the CTS by excluding those valves that are locked, sealed, or otherwise secured in position from this test. Removal of the containment - high-high pressure signal reference and addition of the actual or simulated actuation signal reference are addressed by Removed Detail and Less Restrictive changes respectively.

3.6.9 L.l CTS 4.6.4.2.E requires performing a CHANNEL CALIBRATION of all instrumentation None 4.6.4.2.E and control circuits on each hydrogen recombiner once per 18 months. ITS does not include this requirement. This changes the CTS by deleting a Surveillance Requirement.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 12 of 13 L-3.6

Table L - Less Restrictive Changes ITS Section 3.6 - Containment Systems DOC No. Description of Change ITS CTS Change Requirement Requirement Type 3.6.9 L.2 CTS 3.6.4.2 states, "With one hydrogen recombiner system inoperable, restore the 3.6.9, 3.6.4.2 3 inoperable system to OPERABLE status within 30 days or be in at least HOT STANDBY Conditions A within the next 6 hours0.25 days 0.0357 weeks 0.00822 months ." ITS 3.6.9 Condition A requires one inoperable hydrogen and B recombiner be restored to OPERABLE status within 30 days. ITS 3.6.9 Condition B requires that-with two hydrogen recombiners inoperable, "Verify by administrative means that the hydrogen control function is maintained," within one hour and once per 12 hours0.5 days 0.0714 weeks 0.0164 months thereafter, and, "Restore one hydrogen recombiner to OPERABLE status," within 7 days.

This changes the CTS by allowing both hydrogen recombiners to be inoperable for 7 days if the Required Actions are met, instead of entering CTS LCO 3.0.3.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 13 of 13 L -3.6

Table L - Less Restrictive Changes ITS Section 3.7 - Plant Systems DOC No. Description of Change ITS Requirement CTS Requirement Change Type 3.7.1 L. I CTS 3.7.1. 1, Action a, provides for one or more main steam safety valves 3.7.1 Actions Note 3.7.11.1 Action a Note I (MSSVs) to be inoperable with the unit operating in MODES 1,2, and 3. The ACTION requires that within 4 hours0.167 days 0.0238 weeks 0.00548 months the MSSV(s) be restored to OPERABLE status, or the Power Range Neutron Flux High Setpoint Trip(s) to be reduced in accordance with the requirements of Table 3.7-1. ITS 3.7.1, ACTIONS Note, states "Separate Condition entry is allowed for each MSSV," This changes the CTS by allowing separate condition entry for each inoperable MSSV.

3.7.1 L.2 CTS 3.7.1.1 states that with one or more MSSVs inoperable, reduce the Power None 3.7.1.1 4 Range Neutron Flux - High trip setpoint within 4 hours0.167 days 0.0238 weeks 0.00548 months . ITS 3.7. 1, Action A, states that with one or more steam generators with one MSSV inoperable and the Moderator Temperature Coefficient (MTC) zero or negative at all power levels, reduce THERMAL POWER to _<52% RTP within 4 hours0.167 days 0.0238 weeks 0.00548 months . ITS 3.7.1, Action B, states that with one or more steam generators with one MSSV inoperable and the MTC positive at any power levels or one or more steam generators with two or more MSSVs inoperable, reduce THERMAL POWER to _<the % RTP listed in Table 3.7. 1-1 and reduce the Power Range Neutron Flux - High reactor trip setpoint to less than the limit in Table 3.7.1-1. This changes the CTS by not requiring the Power Range Neutron Flux - High trip setpoint be reduced when only one MSSV per steam generators is inoperable and the MTC is zero or negative at all power levels.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements Note I - Certain Less Restrictive changes for Section 3.7 did not fall into the categories used for the other Section. A specific Determination ofNo Significant Hazards Consideration was written for each non-categorized Less Restrictive Change in Section 3.7.

North Anna Power Station Page I of 19 L -3.7

Table L - Less Restrictive Changes ITS Section 3.7 - Plant Systems DOC No. Description of Change ITS Requirement CTS Requirement Change 3.7.1 L.3 CTS 3.7. 1.1 states that with one or more MSSVs inoperable, reduce the Power 3.7.1 Action B Range Neutron Flux - High trip 3.7.1.14 setpoint within 4 hours0.167 days 0.0238 weeks 0.00548 months . ITS 3.7.

requires the Power Range Neutron 1, Action B, also Flux - High trip setpoint to be reduced, modified by at Note stating that but is this action is only required in MODE 3.7.I L.4 changes the CTS by only requiring the Power 1. This No~~tauSn d Range Neutron Flux - High trip setpoint be reduced when in MODE 3 .

.IA Ntthe 1.

d us ed.7

. o sn tc n eamte /

ant i n o m t on h s c a /

ofheM g st e C S b /

lmn t N / ANAg/

S sfo L.5aCTS ivated.. Th 1 s hable37 2ls tsthe Cth ory aific siz Teh tee ciforth cationanos ftyap liablve s.iN ona l .

theMOdiS2ameero te3S ia wfrmthe lMTsaechncaloSedapeactifiation.

Sp ifc io Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements for the other Section. A specific Determination ofNo Significant Note 1 - Certain Less Restrictive changes for Section 3.7 did not fall into the categories used 3.7.

Hazards Consideration was written for each non-categorized Less Restrictive Change in Section Page 2 of 19 L -3.7 North Anna Power Station

Table L - Less Restrictive Changes ITS Section 3.7 - Plant Systems DOC No. Description of Change ITS Requirement CTS Requirement Change Type 3.7.2 L.2 CTS 3.7.1.5 Actions requires that when one main steam trip valve is inoperable in 3.7.2 Action A 3.7.1.5 Actions 3 MODE 1, the valve is to be restored to Operable status within 4 hours0.167 days 0.0238 weeks 0.00548 months or the unit is to be in H-lot Shutdown (MODE 3) within the next 12 hours0.5 days 0.0714 weeks 0.0164 months . ITS Action A allows 8 hours0.333 days 0.0476 weeks 0.011 months to restore an inoperable MSTV to OPERABLE status when in MODE I, and an additional 6 hours0.25 days 0.0357 weeks 0.00822 months to be in MODE 2. This changes the CTS Completion Time to restore an inoperable MSTV from 4 hours0.167 days 0.0238 weeks 0.00548 months to 8 hours0.333 days 0.0476 weeks 0.011 months , and the required MODE from MODE 3 to MODE 2. The change in the time to enter MODE 3 from 16 hours0.667 days 0.0952 weeks 0.0219 months to 14 hours0.583 days 0.0833 weeks 0.0192 months is discussed in DOC M.5.

3.7.2 L.3 CTS 3.7.1.5 Actions allow only one MSTV to be inoperable ill MODES 2 and 3. 3.7.2 Action C 3.7.1.5 Actions 4 If more than one MSTV is inoperable; LCO 3.0.3 entry is required. ITS 3.7.2 Note Action C allows one or more main steam trip valves to be inoperable in MODES 2 and 3, and contains a Note which states, "Separate Condition entry is allowed for each MSTV." This changes the CTS by allowing more than one MSTV to be inoperable in MODES 2 and 3.

3.7.2 L.4 LCO 3.7.1.5 requires that the valves to be OPERABLE in MODES I, 2, and 3. SR 3.7.2.1 Note 3.7.1.5 7 CTS 4.0.4 requires MSTVs to be tested prior to entry into the MODES of Applicability. ITS SR 3.7.2.1 contains a NOTE which allows entry into MODE 3 for the purpose of performing the required testing. This changes the CTS by allowing the plant to enter MODE 3 prior to the performance of the required testing.

3.7.3 None N/A N/A N/A N/A Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements Note I - Certain Less Restrictive changes for Section 3.7 did not fall into the categories used for the other Section. A specific Determination of No Significant Hazards Consideration was written for each non-categorized Less Restrictive Change in Section 3.7.

North Anna Power Station Page 3 of 19 L -3.7

Table L - Less Restrictive Changes ITS Section 3.7 - Plant Systems IfS Requirement ti I Kequirement .m1ange DOC No. Description of Change ITS Requirement CTS1R5 <equiremenlt Tyange Type I t i -. . , "

None N/A N/A N/A N/A 3.7.4 I SRs 3.7.5.3 and I 4.7.1 .2.c. I and 1 4 SRs 3.7.5.3 and 4.7.1.2.c.2I and 4 3.7.5 L.1 CTS 4.7.1.2.c. I and 4.7.1.2.c.2 require verification that each automatic valve 3.7.5.4 4.7.1.2.c.2 actuates to its correct position and each AFW pump starts automatically upon receipt of an AFW actuation test signal. ITS SRs 3.7.5.3 and 3.7.5.4 will contain the same requirements, except the ITS requirements will permit the use of an actual or simulated test signal to initiate the component actuation. I II It SRs 3.7.5.3 and TI 4.7.l.2.b.l T 6 3.7.5 L.2 CTS SR 4.7.1.2.b. I provides for the surveillance testing of the AFW pumps. The SRs 3.7.5.3 and 4.7.1.2. b. I 3.7.5.4 Notes requirement provides an exception to Specification 4.0.4 for the testing of the AFW steam turbine driven pump. Surveillance requirement 4.7.1.2.c.2 states at least once per 18 months verify each AFW pump will start automatically upon receipt of an auxiliary feedwater actuation test signal. A Note is added to ITS SRs 3.7.5.2 and 3.7.5.4 that allows a delay in the performance of required testing for the turbine driven AFW pump until the required steam pressure of 1005 psig is reached. This changes the CTS by providing an allowance for delaying the performance of required testing without requiring the turbine driven AFW pump to be declared inoperable, Ij Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements other Section. A specific Determination of No Significant Note I - Certain Less Restrictive changes for Section 3.7 did not fall into the categories used for the 3.7.

Hazards Consideration was written for each non-categorized Less Restrictive Change in Section

,4o .p

-__" P....,_ a ,fl19 L - 3.7 North Anna P'ower Station rugu -t vt 17

Table L - Less Restrictive Changes ITS Section 3.7 - Plant Systems Description of Change ITS Requirement CTS Requirement Change DOC No. Type 3.7.5 Action A 3.7.1.2 Action a 4 3.7.5 L.3 CTS 3.7.1.2 Action a. requires all AFW pumps to be restored to an OPERABLE status within 72 hours3 days 0.429 weeks 0.0986 months for any condition of inoperability. ITS 3.7.5 ACTION A permits 7 days to restore the steam supply valve to an OPERABLE status when the steam turbine driven AFW pump is inoperable due to an inoperable steam supply valve or if one turbine driven AFW pump is inoperable following refuteling when MODE 2 has not been entered.. This changes the CTS by extending the ACTION time from 72 hours3 days 0.429 weeks 0.0986 months to 7 days for the steam-driven pump in these conditions.

SR 3.7.5.2 4.7.1.2.b 7 3.7.5 L.4 CTS SR 4.7.1.2.b requires the testing of the AFW pumps on a 92 day staggered test basis (STB). ITS SR 3.7.5.2 requires the AFW pumps tested in accordance with the Inservice Testing (IST) program. This changes the CTS requirements by allowing the testing of the AFW pumps on a three month basis and not specifically on a 92 day STB.

SR 3.7.5.5 4.7.1.2.d 7 3.7.5 L.5 CTS SR 4.7.1.2.d requires that the AFW system flow paths shall be demonstrated Operable prior to entry into MODE 3 following each COLD SHUTDOWN. This requires the flow testing of the AFW train from the ECST to the associated Steam Generator (SG). ITS SR 3.7.5.5 requires the flow path verification only when the unit has been in MODES 5, 6, or defueled for outages that last for a cumulative period of greater than 30 days. This change to the CTS eliminates performance of the SR for outages of less than 30 days.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements Determination ofNo Significant Note I - Certain Less Restrictive changes for Section 3.7 did not fall into the categories used for the other Section. A specific Hazards Consideration was written for each non-categorized Less Restrictive Change in Section 3.7.

Page 5 of 19 L - 3.7 North Anna Power Station

Table L - Less Restrictive Changes ITS Section 3.7 - Plant Systems DOC No. Description of Change ITS Requirement CTS Requirement Change Type 3.7.5 L.6 CTS 3.7.1.2 ACTION c. states with three AFW pumps inoperable, immediately 3.7.5 Action D 3.7.1.2 Action c 4 initiate corrective action to restore at least one AFW pump to OPERABLE status as soon as possible. This ACTION does not require the plant to be shutdown or provide an exception to Specification 3.0.3. ITS ACTION D requires with three inoperable AFW trains in MODES 1,2, or 3 initiate action to restore one AFW trains to OPERABLE status immediately. This also adds a Note which state that LCO 3.0.3 and all other LCO Required Actions requiring MODE changes are suspended until one AFW train is OPERABLE. This changes the CTS requirements for the AFW system to not require a plant shutdown when all AFW trains are inoperable.

3.7.5 L.7 CTS Surveillance Requirement 4.7.1.2.c. I requires the verification of the actuation SR 3.7.5.3 4.7.1.2.c. 1 6 for each AFW automatic valve in the flow path to its correct position. This is applicable for each valve on an AFW actuation test signal at least once per 18 months when the plant is shutdown. ITS SR 3.7.5.3 requires verifying that each AFW automatic valve not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal once every 18 months. This changes the CTS by only requiring the testing of AFW valves that are not locked, sealed or otherwise secured in position.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7- Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements Note I - Certain Less Restrictive changes for Section 3.7 did not fall into the categories used for the other Section. A specific Determination ofNo Significant Hazards Consideration was written for each non-categorized Less Restrictive Change in Section 3.7.

North Anna Power Station Page 6 of 19 L -3.7

Table L - Less Restrictive Changes ITS Section 3.7 - Plant Systems Description of Change ITS Requirement CTS Requirement Change DOC No. Type 3.7.5 Actions A 3.7.1.2 Action a 3 3.7.5 L.8 CTS 3.7.1.2 ACTION a. states, "With one AFW pump inoperable, restore the required AFW pumps to OPERABLE status within 72 hours3 days 0.429 weeks 0.0986 months ." ITS 3.7.5 and B ACTION A states, "One steam supply to turbine driven pump inoperable, or one turbine driven AFW pump inoperable following refueling, restore the affected equipment to OPERABLE status within 7 days." ACTION B requires, "One AFW train inoperable in MODE I, 2, or 3 for any reason other than Condition A, restore AFW train to OPERABLE status within 72 hours3 days 0.429 weeks 0.0986 months ." ACTIONS A and B have a modified Completion Time that states, "10 days friom the discovery of failure to meet the LCO." This changes the CTS by allowing up to 10 days to have a combination of inoperable AFW trains.

3.7.5 Action C 3.7.1.2 Action b 3 3.7.5 L.9 CTS 3.7.1.2 ACTION b. states that with two AFW pumps inoperable, be in HOT STANDBY within 6 hours0.25 days 0.0357 weeks 0.00822 months and in HOT SH1UTDOWN within the following 6 hours0.25 days 0.0357 weeks 0.00822 months . ITS Action C states, in part, that with two AFW trains inoperable, be in MODE 3 in 6 hours0.25 days 0.0357 weeks 0.00822 months and MODE 4 in 18 hours0.75 days 0.107 weeks 0.0247 months . This changes the CTS by allowing 18 hours0.75 days 0.107 weeks 0.0247 months instead of 12 hours0.5 days 0.0714 weeks 0.0164 months to be in MODE 4.

the 3.7.5 ACTION C 3.7.1.2 ACTION a 3 3.7.5 L. 10 CTS 3.7.1.2 ACTION a. states that with one AFW pump inoperable, restore pump to OPERABLE status within 72 hours3 days 0.429 weeks 0.0986 months or be in HOT SHUTDOWN (i.e.,

MODE 4) within 6 hours0.25 days 0.0357 weeks 0.00822 months . ITS ACTION C states that if an inoperable AFW train is not restored, be in MODE 3 in 6 hours0.25 days 0.0357 weeks 0.00822 months and MODE 4 in 18 hours0.75 days 0.107 weeks 0.0247 months . This changes the CTS by allowing 6 hours0.25 days 0.0357 weeks 0.00822 months to be in MODE 3 instead of MODE 4 and allowing 4.

18 hours0.75 days 0.107 weeks 0.0247 months to be in MODE Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements specific Determination ofNo Significant Note I - Certain Less Restrictive changes for Section 3.7 did not fall into the categories used for the other Section. A Hazards Consideration was written for each non-categorized Less Restrictive Change in Section 337.

Page 7 of 19 L-3.7 North Anna Power Station

Table L - Less Restrictive Changes ITS Section 3.7 - Plant Systems Description of Change ITS Requirement CTS Requirement Change DOC No. Type 3.7.6 Action B 3.7.1.2 Action b 3 3.7.6 L.I CTS 3.7.1.2, Action b. states that if an inoperable ECST is not restored to OPERABLE status within 7 days, the plant must be in HOT SHUTDOWN within 24 hours1 days 0.143 weeks 0.0329 months . ITS 3.7.6, Action B, states that if an inoperable ECST is not restored to OPERABLE status within 7 days, the plant must be in MODE 3 within 6 hours0.25 days 0.0357 weeks 0.00822 months and MODE 4 without reliance on the steam generators for heat removal within 24 hours1 days 0.143 weeks 0.0329 months . This changes the time to be in MODE 4 without reliance on the steam generators for heat removal friom 12 hours0.5 days 0.0714 weeks 0.0164 months to 24 hours1 days 0.143 weeks 0.0329 months . The addition of the MODE 3 Completion Time is discussed in DOC M.2. 'Fhe addition of the condition to be in MODE 4 without reliance on the steam generators for heat removal is discussed in DOC M.I.

None Table 4.7-1, Item 1 5 3.7.7 L.I CTS Table 4.7-1 item #1 requires that the gross activity determination be completed at least once per 72 hours3 days 0.429 weeks 0.0986 months . ITS 3.7.7 does not require any sampling to be performed to determine the gross activity of the secondary coolant. This changes the CTS by deleting the requirement for gross activity determination once per 72 hours3 days 0.429 weeks 0.0986 months .

SR 3.7.8.2 4.7.4.1 .c. I and 3.7.8 L. I CTS 4.7.4.1 .c. I and 4.7.4.1 .c.2 require verification that SW System automatic valves actuate to their correct position. ITS SR 3.7.8.2 requires verification that 4.7.4.1 .c.2 SW System automatic valves in the flow path that are not locked, sealed or otherwise secured in position, actuate to the correct position on an actual or simulated actuation signal. This changes the CTS by exempting valves that are locked, sealed, or otherwise secured in position from the verification.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements specific Determination ofNo Significant Note I - Certain Less Restrictive changes for Section 3.7 did not fall into the categories used for the other Section. A Hazards Consideration was written for each non-categorized Less Restrictive Change in Section 3.7.

Page 8 of 19 L -3.7 North Anna Power Station

Table L - Less Restrictive Changes ITS Section 3.7 - Plant Systems DOC No. Description of Change ITS Requirement CTS Requirement Change Type 3.7.8 L.2 Not used. N/A N/A N/A 3.7.9 None N/A N/A N/A N/A 3.7.10 L.I CTS 4.7.7.1 states, "Each control room emergency ventilation system shall be SR 3.7. 10.1 4.7.7.1 7 demonstrated OPERABLE: a. At least once per 31 days on a STAGGERED TEST BASIS by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that the system operates for at least 10 hours0.417 days 0.0595 weeks 0.0137 months with the heaters on." ITS SR 3.7.10.1 states, "Operate each required MCR/ESGR EVS train for > 10 continuous hours with the heaters operating." The Frequency is every 31 days. This changes the CTS by removing the STAGGERED TEST BASIS requirement from the 31 day Frequency. The change moving details of the test to the Bases is addressed in a removed detail discussion of change.

3.7.10 L.2 CTS 4.7.7.1 states, "Each control room emergency ventilation system shall be SR 3.7.10.3 4.7.7. 1.d.2 6 demonstrated OPERABLE:...d. At least once per 18 months by:...2. Verifying that the normal air supply and exhaust are automatically shutdown on a Safety Injection Actuation Test Signal." ITS SR 3.7.10.3 states, "Verify each LCO 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 allowing the automatic actuation to be verified by either an actual or simulated actuation signal. The change moving the detail of what is verified by the surveillance and how it is performed to the Bases is addressed in a removed detail discussion of change.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements Note I - Certain Less Restrictive changes for Section 3.7 did not fall into the categories used for the other Section. A specific Determination ofNo Significant Hazards Consideration was written for each non-categorized Less Restrictive Change in Section 3.7.

North Anna Power Station Page 9 of 19 L -3.7

Table L - Less Restrictive Changes ITS Section 3.7 - Plant Systems ITS Requirement CTS Requirement Change DOC No. Description of Change Type CTS 4.7.7. l.d.2 states, "Each control room emergency ventilation system shall be SR 3.7.10.4 4.7.7.1.d.2 7 3.7.10 L.3 demonstrated OPERABLE:...At least once per 18 months by:....verifying that the system maintains the control room at a positive pressure of> 0.04 inch W.G.

relative to the outside atmosphere at a system flow rate of 1000 cfin +/- 10%." ITS SR 3.7.10.4 requires the same surveillance be performed every 18 months on a STAGGERED TEST BASIS. This changes the CTS by requiring the surveillance be performed every 18 months on a STAGGERED TEST BASIS instead of every 18 months. The change in the positive pressure required is addressed by DOC M.5.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements specific Determination of No Significant Note I - Certain Less Restrictive changes for Section 3.7 did not fall into the categories used for the other Section. A Hazards Consideration was written for each non-categorized Less Restrictive Change in Section 3.7.

Page 10 of 19 L-3.7 North Anna Power Station

Table L - Less Restrictive Changes ITS Section 3.7 - Plant Systems DOC No. Description of Change I I'S Requirement CTS Requirement Change Type 3.7.10 L.4 CTS 3.7.7.1 Action a states, "With either the emergency ventilation system or the 3.7.10 Action A 3.7.7.1 Actions a 3 bottled air pressurization system inoperable, restore the inoperable system to and b OPERABLE status within 7 days..." CTS 3.7.7.1 Action b states, "With both the emergency ventilation system and the bottled air pressurization system inoperable, restore at least one of these systems to OPERABLE status within 24 hours1 days 0.143 weeks 0.0329 months or be in at least IlOT STANDBY within the next 6 hours0.25 days 0.0357 weeks 0.00822 months and in COLD SHUTDOWN within the following 30 hours1.25 days 0.179 weeks 0.0411 months ." ITS 3.7.10 Condition A states, "One required LCO 3.7.10.a or 3.7.10.b MCR/ESGR EVS train inoperable." ITS Required Action A.I states, "Restore train to OPERABLE status," within 7 days. ITS 3.7,13, "MCR/ESGR Bottled Air System," has a similar Required Action A.I1.

This changes the CTS by allowing portions of both the MCR/ESGR bottled air system and the MCR/ESGR EVS to be inoperable for 7 days rather than 24 hours1 days 0.143 weeks 0.0329 months .

Changes associated with identifying system train inoperabilities rather than whole systems are addressed by DOC M.2. Changes associated with not allowing both systems to be inoperable for 24 hours1 days 0.143 weeks 0.0329 months are addressed by DOC M.3. Changes associated with the MCR/ESGR bottled air system are addressed in ITS 3.7.13.

3.7.10 L.5 The ITS LCO 3.7.10 Note states, "The MCR/ESGR boundary may be opened 3.7. 10 LCO Note None intermittently under administrative control." This allowance is not explicitly stated in CTS 3.7.7. 1. This changes CTS by explicitly allowing the MCR/ESGR boundary to be opened intermittently under administrative control.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements Note I - Certain Less Restrictive changes for Section 3.7 did not fall into the categories used for the other Section. A specific Determination ofNo Significant Hazards Consideration was written for each non-categorized Less Restrictive Change in Section 3.7.

North Anna Power Station Page I11 of 19 L -3.7

Table L - Less Restrictive Changes ITS Section 3.7 - Plant Systems DOC No. Description of Change ITS Requirement CTS Requirement Change Type 3.7.11 L. I CTS 3.7.7.1 Action c allows 7 days to restore an inoperable air conditioning 3.7.1 I 3.7.7.1 Action c 3 subsystem to OPERABLE status. ITS 3.7.11 allows 30 days to restore an inoperable air conditioning subsystem to OPERABLE status. This changes the CTS by increasing the time allowed to restore the inoperable components from 7 days to 30 days.

3.7.12 L. I CTS 4.7.8.1 states, "Each ECCS PREACS train shall be demonstrated SR 3.7.12.1 4.7.8. 1.a. 3 OPERABLE: a. At least once per 31 days on a STAGGERED TEST BASIS by:

1. Initiating, from the control room, Safeguards Area exhaust flow and Auxiliary Building Central exhaust flow through the auxiliary building HEPA filter and charcoal adsorber assembly and verifying that the ECCS PREACS train operates for at least 10 hours0.417 days 0.0595 weeks 0.0137 months with the heater on." ITS SR 3.7.12.1 states, "Operate each ECCS PREACS train for > 10 continuous hours with the heaters operating." The Frequency is every 3 1 days. This changes the CTS by removing the STAGGERED TEST BASIS requirement friom the 31 day frequency. The change moving details of the test to the Bases is addressed in a removed detail discussion of change.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements Note I - Certain Less Restrictive changes for Section 3.7 did not fall into the categories used for the other Section. A specific Determination of No Significant Hazards Consideration was written for each non-categorized Less Restrictive Change in Section 3.7.

North Anna Power Station Page 12 of 19 L -3.7

Table L - Less Restrictive Changes ITS Section 3.7 - Plant Systems DOC No. Description of Change ITS Requirement CTS Requirement Change Type 3.7.12 L.2 CTS 4.7.8.1 .d.2 requires demonstrating the SAVS OPERABLE every 18 months SR 3.7.12.4 4.7.8.1 .d.2 6 by, "Verifying that on a Containment I-li-Hi Test Signal, the system automatically diverts Safeguards Area exhaust flow..." 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." The frequency is every 18 months. This changes the CTS by allowing the automatic actuation to be verified by either an actual or simulated actuation signal. The change moving the detail of what is verified by the surveillance and how it is performed to the Bases is addressed in DOC LA.3.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements Note I - Certain Less Restrictive changes for Section 3.7 did not fall into the categories used for the other Section. A specific Determination of No Significant Hazards Consideration was written for each non-categorized Less Restrictive Change in Section 3.7.

North Anna Power Station Page 13 of 19 L -3.7

Table L - Less Restrictive Changes ITS Section 3.7 -- Plant Systems DOC No. Description of Change ITS Requirement CTS Requirement Change Type 3.7.13 L.I CTS 3.7.7.1 Action a states, "With either the emergency ventilation system or the 3.7.13 Action A 3.7.7.1 Actions a 3 bottled air pressurization system inoperable, restore the inoperable system to and b OPERABLE status within 7 days..." CTS 3.7.7.1 Action b states, "With both the emergency ventilation system and the bottled air pressurization system inoperable, restore at least one of these systems to OPERABLE status within 24 hours1 days 0.143 weeks 0.0329 months or be in at least HOT STANDBY within the next 6 hours0.25 days 0.0357 weeks 0.00822 months and in COLD SHUTDOWN within the following 30 hours1.25 days 0.179 weeks 0.0411 months ." ITS 3.7.13 Condition A states, "One required MCR/ESGR bottled air system train inoperable." ITS Required Action A. I states, "Restore train to OPERABLE status," within 7 days. ITs 3.7.10, "MCR/ESGR EVS-MODES 1, 2, 3, and 4," has a similar Required Action A. 1. This changes the CTS by allowing portions of both the MCR/ESGR bottled air system and the MCR/ESGR EVS to be inoperable for 7 days rather than 24 hours1 days 0.143 weeks 0.0329 months . Changes associated with identifying system train inoperabilities rather than whole systems are addressed by DOC M.2. Changes associated with not allowing both systems to be inoperable for 24 hours1 days 0.143 weeks 0.0329 months are addressed by DOC M.3. Changes associated with the MCR/ESGR bottled air system are addressed in ITS 3.7.13.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements Note I - Certain Less Restrictive changes for Section 3.7 did not fall into the categories used for the other Section. A specific Determination of No Significant Hazards Consideration was written for each non-categorized Less Restrictive Change in Section 3.7.

North Anna Power Station Page 14 of 19 L -3.7

Table L - Less Restrictive Changes ITS Section 3.7 - Plant Systems Description of Change ITS Requirement CTS Requirement Change Type 3.7.13 L.2 CTS 4.7.7.1 states, "Each control room emergency ventilation system shall be SR 3.7.13.3 4.7.7.1.d.2 6 demonstrated OPERABLE:...d. At least once per 18 months by:...2. Verifying that tile normal air supply and exhaust are automatically shutdown on a Safety Injection 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 allowing tile automatic actuation to be verified by either an actual or simulated actuation signal. The change moving the detail of what is verified by the surveillance and how it is performed to the Bases is addressed in a removed detail discussion of change.

3.7.13 L.3 CTS 4.7.7.2.b states, "Each bottled air pressurization system shall be demonstrated SR 3.7.13.4 4.7.7.2.b 7 OPERABLE :...At least once per 18 months by verifying that the system will supply at least 340 cfin of air to maintain the control room at a positive pressure of

> 0.05 inch W.G. relative to the outside atmosphere for at least 60 minutes." ITS SR 3.7.13.4 requires the same surveillance be performed every 18 months on a STAGGERED TEST BASIS. This changes tile CTS by requiring the surveillance be performed every 18 months on a STAGGERED TEST BASIS instead of every 18 months.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements Note I - Certain Less Restrictive changes for Section 3.7 did not fall into the categories used for the other Section. A specific Determination of No Significant Hazards Consideration was written for each non-categorized Less Restrictive Change in Section 3.7.

North Anna Power Station Page 15 of 19 L -3.7

Table L - Less Restrictive Changes ITS Section 3.7 - Plant Systems DOC No. Description of Change ITS Requirement CTS Requirement Change Type 3.7.13 L.4 CTS 3..7.1 Action a states, "With either the emergency ventilation system or the 3.7.13 Action A 3.7.7.1 Actions a 3 bottled air pressurization system inoperable, restore the inoperable system to and b OPERABLE status within 7 days..." CTS 3.7.7.1 Action b states, "With both the emergency ventilation system and the bottled air pressurization system inoperable, restore at least one of these systems to OPERABLE status within 24 hours1 days 0.143 weeks 0.0329 months or be in at least HOT STANDBY within the next 6 hours0.25 days 0.0357 weeks 0.00822 months and in COLD SHUTDOWN within the following 30 hours1.25 days 0.179 weeks 0.0411 months ." ITS 3.7.13 Condition A states, "One required MCR/ESGR bottled air system train inoperable." ITS Required Action A. I states, "Restore train to OPERABLE status," within 7 days. ITS 3.7.10, "MCR/ESGR EVS-MODES 1, 2, 3, and 4," has a similar Required Action A.1. This changes the CTS by allowing portions of both the MCR/ESGR bottled air system and the MCR/ESGR EVS to be inoperable for 7 days rather than 24 hours1 days 0.143 weeks 0.0329 months . Changes associated with identifying system train inoperabilities rather than whole systems are addressed by DOC M.2. Changes associated with not allowing both systems to be inoperable for 24 hours1 days 0.143 weeks 0.0329 months are addressed by DOC M.3. Changes associated with the MCR/ESGR bottled air system are addressed in ITS 3.7.13.

3.7.13 L.5 The ITS LCO 3.7.13 Note states, "The MCR/ESGR boundary may be opened 3.7.13 LCO Note None intermittently under administrative control." This allowance is not explicitly stated in CTS 3.7.7.1. This changes CTS by explicitly allowing the MCR/ESGR boundary to be opened intermittently under administrative control.

3.7.14 None N/A N/A N/A N/A Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements Note I - Certain Less Restrictive changes for Section 3.7 did not fall into the categories used for the other Section. A specific Determination ofNo Significant Hazards Consideration was written for each non-categorized Less Restrictive Change in Section 3.7.

North Anna Power Station Page 16 of 19 L -3.7

Table L - Less Restrictive Changes ITS Section 3.7 - Plant Systems

. . -- I I-r eulem n I ClinnI DOC No. Description of Change IT 5 R equiremrentt CTSI Kequilelllilt Type 3.7.15 3.9.12] 2 3.7.15 L.I CTS 3.9.12 Applicability includes, "During irradiated fuel movement within the Applicability Applicability spent fuel pit." ITS 3.7.-15 Applicability is, "During movement of recently irradiated fuel assemblies in the fuel building." All references in CTS 3.9.12 to irradiated fuel are changed to "recently" irradiated fuel. This changes tile CTS by eliminating requirements for the FBVS during movement of fuel that is not recently irradiated.

None 4.9.12.a and 3.7.15 L.2 CTS 4.9.12 states, "The above required fuel building ventilation system shall be 4.9.12.c demonstrated OPERABLE and discharging through at least one auxiliary building HEPA filter and charcoal adsorber assembly: a. At least once per 31 days by initiating flow through the HIEPA filter and charcoal adsorber assembly for 15 minutes...c. By performance of the Surveillance Requirements of Specification 4.7.8.1 b, c, d, e, and f." CTS LCO 3.9.12 and CTS Action a refer to the HEPA filter and charcoal adsorber assembly of the FBVS. ITS 3.7.15 does not include these requirements. This changes CTS by deleting the testing requirements for the fuel building filtration systems.

--II- None -t I 3.9.12 None 3.9.12 113.7.15 L.3 CTS 3.9.12 Applicability includes, "b. During crane operation with.loads over Applicability b, irradiated fuel in the spent fuel pit." CTS 3.9.12 Actions "a" and "b" address 3.9.12 Actions a actions to take during "crane operation with loads over the spent fuel pit." ITS and b 3.7.15 does not include these requirements. This changes CTS by not requiring requirements be met for a portion of the current applicability. --- _______ I _________________________________

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements used for the other Section. A specific Determination of No Significant Note I - Certain Less Restrictive changes for Section 3.7 did not fall into the categories in Section 3.7.

Hazards Consideration was written for each non-categorized Less Restrictive Change Page 17 of 19 L-3.7 North Anna Power Station

Table L - Less Restrictive Changes ITS Section 3.7 - Plant Systems ITS Requirement CTS Requirement Change Description of Change Type 3.7.16 3.9.11 and 4.9.11 2 CTS 3.9.11 states that the requirements on spent fuel pit water level are applicable, "Whenever irradiated fuel assemblies are in the spent fuel pit." CTS 4.9.11 Applicability and requires the water level in the spent fuel pit to be verified every 7 days when SR 3.7.16.1 irradiated fuel assemblies are in the spent fuel pit. ITS 3.7.16 is applicable, "During movement of irradiated fuel assemblies in the fuel storage pool." ITS SR 3.7.16.1 requires verification of the spent fuel pool water level every 7 days. This changes the CTS by restricting the applicability of the spent fuel pool water level specification and performance of the Surveillance to during the movement of irradiated fuel assemblies in the fuel storage pool.

3.7...16 ActIon A 591 1 Acto CTS 3.9.11 ACTION states that when the spent fuel pool water level is not met, 3.7.16 Action A 3.9.1 IAction and Action A Note suspend all movement of fuel assemblies and crane operations with loads in the spent fuel pit areas and place the load in a safe condition, and restore the water level to within its limit within 4 hours0.167 days 0.0238 weeks 0.00548 months . The CTS also states that Specification 3.0.3 is not applicable. ITS 3.7.16 REQUIRED ACTION A.lI states that when fuel storage pool water level is not within limit, immediately suspend movement of irradiated fuel assemblies in the fuel storage pool. A NOTE to REQUIRED ACTION A.lI states that LCO 3.0.3 is not applicable. This changes the CTS requiring the suspension of movement of only irradiated fuel, by eliminating actions related to crane operation over the spent fuel pool and eliminating the I requirement to restore the water level within 4 hours0.167 days 0.0238 weeks 0.00548 months . I I I i Al

ý3.7.17 None 3.7.17NoneN/_A

/ANAIN/

_/A N/A ___ A*

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements A specific Determination of No Significant Note I - Certain Less Restrictive changes for Section 3.7 did not fall into the categories used for the other Section.

Hazards Consideration was written for each non-categorized Less Restrictive Change in Section 3.7.

Page 18 of 19 L-3.7 North Anna Power Station

Table L - Less Restrictive Changes ITS Section 3.7 - Plant Systems DOC No. Description of Change ITS Requirement CTS Requirement Change Type 3.7.18 None N/A N/A N/A N/A L.1 CTS 4.7.3.1.b requires each component cooling water pump to be tested in None 4.7.3.l1.b 5 3.7.19 accordance with Specification 4.0.5. ITS 3.7.19 does not contain this Surveillance.

This changes the CTS by deleting a Surveillance Requirement.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4- Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements ofNo Significant Note 1 - Certain Less Restrictive changes for Section 3.7 did not fall into the categories used for the other Section. A specific Determination Hazards Consideration was written for each non-categorized Less Restrictive Change in Section 3.7.

Page 19 of 19 L-3.7 North Anna Power Station

Table L - Less Restrictive Changes ITS Section 3.8 - Electrical Power Systems DOC No. Description of Change ITS Requirement CTS Requirement Change Type L. I CTS LCO 3.0.5 allows a system, subsystem, train, component, or device to be 3.8.1, Required 3.0.5 3 3.8.1 considered OPERABLE with an inoperable emergency or normal power source Action A.2 provided its normal or emergency power source is OPERABLE and its redundant system(s), subsystem(s), train(s), component(s), and device(s) are OPERABLE. If the redundant feature is not OPERABLE, a shutdown to a MODE in which the feature is not required must be started within one hour. ITS 3.8.1 Required Action A.2 requires the declaration of required feature(s), with no offsite power available, inoperable when its redundant required feature(s) is inoperable. The Completion Time allowed by the new action is 24 hours1 days 0.143 weeks 0.0329 months from discovery of no offsite power to one train concurrent with inoperability of redundant required feature(s). This changes the CTS to allow 24 hours1 days 0.143 weeks 0.0329 months before declaring a required feature inoperable, when an offsite source and a redundant required feature are inoperable.

L.2 CTS LCO 3.0.5 allows a system, subsystem, train, component, or device to be 3.8.1, Required 3.0.5 3 3.8.1 considered OPERABLE with an inoperable emergency or normal power source Action B.2 provided its normal or emergency power source is OPERABLE and its redundant system(s), subsystem(s), train(s), component(s), and device(s) are OPERABLE. If the redundant feature is not OPERABLE, a shutdown to a MODE in which the feature is not required must be started within one hour. ITS Required Action B.2 requires the declaration of required feature(s), with no EDG available, inoperable when its redundant required feature(s) is inoperable. The Completion Time allowed by the new action is 4 hours0.167 days 0.0238 weeks 0.00548 months from discovery of inoperable EDG on one train concurrent with inoperability of redundant required feature(s). This changes the CTS to allow 4 hours0.167 days 0.0238 weeks 0.00548 months before declaring a required feature inoperable, with ar.

EDG and a redundant required feature inoperable.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page I of 22 L-3.8

Table L - Less Restrictive Changes ITS Section 3.8 - Electrical Power Systems DOC No. Description of Change ITS Requirement CTS Requirement Change Type 3..1 I, Required 3.8. 1.1, Action b 4 3.8.1 L.3 CTS 3.8.1.1 Action b requires that within the next twenty-four hours of one EDG becoming inoperable, tile other train's OPERABLE EDG must be started and fully Action B.3 loaded for one hour in accordance with CTS SR 4.8.1.1.2.a.4. This is required regardless of whether or not the inoperable EDG is restored to OPERABLE status.

This is not required to be performed if the absence of any potential for common mode failure can be demonstrated for tile OPERABLE EDG. ITS Action B.3 requires a determination that the OPERABLE EDG is not inoperable due to a common cause failure. This evaluation is required to be completed within twenty four hours or the performance of ITS SR 3.8.1.2 is required. This Surveillance only requires the start of the OPERABLE EDG. This changes the CTS requirements by not requiring the OPERABLE EDG to be run at full load for one hour and eliminates the requirement that the test for the OPERABLE EDG be completed regardless of whether the inoperable EDG is restored to OPERABLE status.

3.8.1, Required 3.0.5 3 3.8.1 L.4 CTS LCO 3.0.5 allows a system, subsystem, train, component, or device to be considered OPERABLE with an inoperable emergency or normal power source Action B.I provided its normal or emergency power source is OPERABLE and its redundant system(s), subsystem(s), train(s), component(s), and device(s) are OPERABLE.

LCO 3.0.5 requires a unit shutdown to start within one hour with two offsite circuits inoperable. ITS 3.8.1 Required Action G.1 requires tile declaration of required feature(s) with no offsite power available, inoperable when its redundant required feature(s) is inoperable. The Completion Time allowed by the Required Action G. I is 12 hours0.5 days 0.0714 weeks 0.0164 months from discovery of no offsite power concurrent with inoperability of redundant required feature(s). This changes the CTS by allowing 12 hours0.5 days 0.0714 weeks 0.0164 months before declaring a required feature inoperable.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements Page 2 of 22 L -3.8 North Anna Power Station

"Table L - Less Restrictive Changes ITS Section 3.8 - Electrical Power Systems Description of Change ITS Requirement CTS Requirement Change DOC No. Type SR 3.8.1.2 4.8.1 .1.2.a, Table 7 3.8.1 L.5 CTS surveillance requirement 4.8.1.1 .2.a requires that each EDG be demonstrated OPERABLE in accordance with the frequency specified in Table 4.8-2 on a 4.8-2 STAGGERED TEST BASIS (STB). CTS Table 4.8-2 specifies the test frequency based on the number of failures that have occurred in testing each EDG during the previous 20 or 100 tests. Ifthe number of failures do not exceed the specified limit, testing is to be performed every 31 days. If failures occur above the specified limits, then testing is conducted every 7 days. ITS SR 3.8.1.2 states that each EDG be started and reach steady state voltage and frequency within a fixed Frequency of 31 days. This changes the CTS by eliminating the requirements to test on a staggered test basis and an increasing firequency of testing based on the number of test failures.

SR 3.8.1. 10, 4.8.1.1 .2.d.3, 6 3.8.1 L.6 CTS requirements 4.8.1.1 .2.d.3, 4, and 5 state that an EDG will respond to a loss ofoffsite power, an ESF actuation, and a loss of offsite power in conjunction with SR 3.8.1.11, 4.8.1.1.2.d.4, ESF actuation. These requirements do not specifically state that an actual or SR 3.8.1.12, and 4.8.1.1.2.d.5 simulated signal may be used for the requirements. ITS SRs 3.8.1.10, 3.8.1.11, SR 3.8.1.17 3.8.1 .12, and 3.8.1.17 state the EDG may be started for these requirements with an actual or simulated signal. This changes the CTS to allow either an actual or simulated signal to be credited in the performance of these requirements.

None Unit 2 4.8.1.1.l.bL5 3.8.1 L.7 Unit 2 CTS requirement 4.8.1I.1.1.b requires the demonstration of OPERABILITY for the alternate offsite circuit by the manual transferring of the onsite Class I E power source from the normal circuit to the alternate circuit every 18 months with the plant shutdown. The ITS does not include this requirement for Unit 2. This change eliminates a CTS Surveillance.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7- Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements Page 3 of 22 L -3.8 North Anna Power Station

Table L- Less Restrictive Changes ITS Section 3.8 - Electrical Power Systems DOC No. Description of Change ITS Requirement CTS Requirement Change Type 3.8.1 L.8 CTS Surveillance 4.8.1.1.2.e describes the testing that must be performed None 4.8.1.1 .2.e 5 following any modification that could affect EDG interdependence. ITS 3.8. I does not include these testing requirements.

3.8.1 L.9 CTS Surveillance Requirements 4.8.1.1.1.and 4.8.1.1.2 contain the requirements to SR 3.8.1.11 Note 4.8.1.1. 1and 6 perform various testing "during shutdown." Surveillance Requirement for 4.8.1.1.2 4.8.1.1.2.d is required to be performed during shutdown. ITS SR 3.8. 1.11 states in a Note that the required Surveillance shall not be performed in MODE I or 2. This changes the CTS requirements for testing of the AC sources by allowing the listed test to be performed in MODES 3 or 4.

3.8.1 L. 10 CTS Surveillance Requirements 4.8.1.1.1 and 4.8.1.1.2 contain requirements to Note to SR 3.8.1.8, 4.8.1.1.1 and 6 perform various testing "during shutdown." ITS SRs 3.8.1.8, 3.8.1.12, and 3.8.1.13 SR 3.8.1.12, and 4.8.1.1.2 add a Note that restricts performance of the SRs in MODES I and 2. The Note is SR 3.8.1.13 modified with an allowance that the SR may be performed for the purpose of re establishing OPERABILITY for inoperable equipment. This changes the CTS by allowing the specified surveillances to be performed in a MODE that is not currently allowed.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements Page 4 of 22 L-3.8 North Anna Power Station

Table L - Less Restrictive Changes ITS Section 3.8 - Electrical Power Systems DOC No. Description of Change ITS Requirement CTS Requirement Change Type 3.8.1 L. I CTS LCO 3.7.4.1, Service Water System - Operating, states, "Two service water LCO 3.7.10, 3.7.4.1 4 loops (shared with the other unit) shall be OPERABLE with each loop consisting LCO 3.7.12, of two OPERABLE service water pumps (excluding auxiliary service water LCO 3.7.19, pumps) with their associated normal and emergency power supplies, and all LCO 3.8.1 Actions OPERABLE flow path . . . ." Each unit's service water system requirements A, B, C, D, E, and consist of the above requirements for either unit operating in MODES I, 2, 3, or 4. F CTS LCO 3.7.3.1, Component Cooling Water System - Operating, requires three component cooling water subsystems (shared with the other unit) shall be OPERABLE. This requirement Must be met with either unit is in MODES 1, 2, 3, or 4. ITS LCO 3.7.10 specifies the requirements for the Main Control Room (MCR) / Emergency Switchgear Room (ESGR) Habitability System. This system requires the MCR and ESGR fans on both units to be OPERABLE in MODES 1, 2, 3, and 4 and during tile movement of recently irradiated fuel assemblies. ITS LCO 3.7.12 requires tile fans friom the Auxiliary Building central exhaust system to be OPERABLE to support the Emergency Core Cooling System (ECCS) Pump Room Exhaust Air Cleanup System. This could require a fan powered from tile other unit to be required for this unit. Tile SW and CC pumps and tile fans from the ventilation systems are components that may be required by either or both units. Therefore, these pumps and fans are classified as "shared components," for the electrical power requirements. ITS LCO 3.8.1 Actions A, B, and C provide for an evaluation of all safety functions powered by this unit's AC sources and provide 72 hours3 days 0.429 weeks 0.0986 months for an inoperable offsite circuit and up to 14 days for an inoperable EDG.

ITS 3.8.1 Action D for one or more offsite circuit(s), and Actions E and F for an inoperable EDG on the other unit that is needed to support a shared components.

This changes the CTS by allowing a shared components to be considered OPERABLE for up to 72 hours3 days 0.429 weeks 0.0986 months with a required offsite circuit(s) inoperable and up to 14 days for an inoperable EDG on the other unit.

Thange Mategory:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 5 of 22 L-3.8

Table L - Less Restrictive Changes ITS Section 3.8 - Electrical Power Systems ITS Requirement I? CIS Requirement I nange DOG No. Description of Change ITS Requirement CTS Requirement Tpange Type

____________________________________________ 4 LCO 3.8.l.c, LCO 3.8.1 1 4.8.l.l.2.d.2 I I 3.8.1 L.12 CTS SR 4.8.1.1.2.d.2 states, "Verifying that the load sequencing timers are .c, 4.8.1.1.2.d.2 Required Action OPERABLE with times within the tolerances shown in Table 3.8-I." If the K.2.1, Required requirement can not be met, the EDG is declared inoperable and the appropriate Action K.2.2 Action entered. ITS LCO 3.8.I.c requires the following AC electrical sources shall be OPERABLE with the sequencing timing relays for Train H and Train J. ITS Required Action K. I states with one or more sequencing timing relay(s) inoperable, immediately enter appropriate Conditions and Required Actions for system, subsystem, or component made inoperable by sequencing timing relay(s).

Required Action K.2. I states, "Place the component(s) with the inoperable sequencing timing relay in a condition where it can not automatically load to the associated emergency electrical bus." Required Action K.2.2 provides an option to declare the associated EDG inoperable. This changes the CTS requirements by allowing a system, subsystem or component served by an inoperable sequencing timing relay to be declared inoperable, instead of the electrical source(s). I I i Al I

None 4.8.1 I.1.2.d.7 5 3.8.1 L. 13 CTS Surveillance Requirement 4.8.1.1.2.d,7 states, "Verifying that the auto-connected loads to each EDG do not exceed the 2000 hour0.0231 days 0.556 hours 0.00331 weeks 7.61e-4 months rating of 3000 kw."

ITS 3.8.1 does not require the verification of loading limit to ensure OPERABILITY of the EDGs. This changes the CTS by deleting the surveillance requirement.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements Page 6 of 22 L -3.8 North Anna Power Station

Table L - Less Restrictive Changes ITS Section 3.8 - Electrical Power Systems Description of Change ITS Requirement CTS Requirement Change DOC No. Type 3.8.1 Required 3.8.1.1 Action b 4 3.8.1 L. 14 CTS 3.8.1.1 Action b states that the OPERABLE EDG must be demonstrated to be OPERABLE within 24 hours1 days 0.143 weeks 0.0329 months unless the absence of any potential common mode Action B.3 failure is demonstrated. This is required if the inoperable EDG inoperability is due to any cause "other than an inoperable support system, an independently testable component, or preplanned preventive maintenance or testing," ITS Required Action B.3 states "Determine OPERABLE LCO 3.8.I.b EDG is not inoperable due to common cause failure." This changes the CTS by allowing a determination for common cause failure, instead of requiring a demonstration for a potential common mode failure, for the OPERABLE EDG.

Note to 1 1.2I 3.8.1 L. 15 CTS Surveillance Requirement 4.8.1 . 1.2 contains the requirement to perform Note to 4.*.1.1.2 various tests for the EDGs "during shutdown." ITS SRs 3.8.1.10, 3.8.11,3.8.1.15, SR 3.8.1.10, 3.8.1.16, and 3.8.1.17 are modified in a Note that states the Surveillance shall not SR 3.8.1.11, SR 3.8.1.15, normally be performed in specific MODES. An additional statement modifies the SR 3.8.1.16, and Note. It allows a full or partial Surveillance to be performed to reestablish SR 3.8. 1.17 OPERABILITY provided an assessment determines the safety of the unit is maintained or enhanced. This changes the CTS requirements for testing of the EDGs by allowing the listed tests to be performed in MODES in which they are normally prohibited from being conducted.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements Page 7 of 22 L-3.8 North Anna Power Station

Table L - Less Restrictive Changes ITS Section 3.8 - Electrical Power Systems I I S Kequireiflent UI Iequirei'ieiit '.-.IiaiL DOC No. Description of Change ITS R equirement CTSI* Keqtulrelnielt Type I 3.8.1.6 4.8.1.1.2.a.3, 7 3.8.1 L.16 CTS 4.8.1 .1.2.a.3 states, "Verifying the fuel oil transfer pump can be started and Table 4.8-2 be transfers fuel from the storage tank to the day tank." This requirement shall performed with a frequency specified in Table 4.8-2 on a Staggered Test Basis the (STB). Table 4.8-2 states that the EDG test schedule is once per 31 days when one in the past 20 valid tests, and once per 7 number of test failures is less than days if the number of test failures is two or more in the previous 20 valid tests.

ITS SR 3.8.1.6 states, "Verify each required fuel oil transfer pump operates to transfer fuel oil from the storage tank to the day tank," and the requirement is the required to be performed every 92 days. This changes the CTS by decreasing SR Frequency from 7 or 31 days on a STB to every 92 days.

SR 3.8.1.7 4.8.1.1.1.2.c 3.8.1 L.17 CTS 4.8.1.1.1 .2.c states that every 184 days the EDG will be started within 10 a

seconds by one of the following signals on a rotating test basis. The signals are simulated loss of offsite power, simulated loss of offsite power with an ESF actuation, and an ESF actuation. The start requires specific values of voltage and frequency to be obtained within specified limits. ITS SR 3.8.1.7 states that each EDG is started within 10 seconds every 184 days. The start requires specific values the of voltage and frequency to be obtained within specified limits. This changes CTS by eliminating the specific start signals.

+ SR 3.8.1.18 t 4.8.1.1.2 - -I 6 SR 3.8.1.18 4.8.1.1.2 3.8.1 L.18 CTS Surveillance Requirement 4.8.1.1.2 contains the requirement to perform various testing "during shutdown." ITS SR 3.8. 1.18 removes the MODE restrictions for performing the required testing. This changes the CTS in requirements for testing of the AC sources by allowing this test to be performed any MODE.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements Page 8 of 22 L -3.8 North Anna Power Station

Table L - Less Restrictive Changes ITS Section 3.8 - Electrical Power Systems DOC No. Description of Change ITS Requirement CTS Requirement Change Type 3.8.1 L. 19 CTS surveillance requirements 4.8.1.1.2 a.4, c, d.3, d.4, d.5.b, d.6, d. 10, and e state Note to Footnote ** to 6 that the EDG shall be started and are modified by a note labeled **. The note SR 3.8.1.7, 4.8.1.1 .2.a.4, requires the test to be conducted in accordance with the manufacturer's SR 3.8.1.10, 4.8.1.1.2.c, recommendations, "regarding engine prelube and warmup procedure, and as SR 3.8.1.11, 4.8.1.1.2.d.3, applicable regarding loading recommendations." ITS SRs 3.8.1.7, 3.8.1. 10, SR 3.8.1.14, 4.8.1.1.2.d.4, 3.8.1.11, 3.8.1.14, 3.8.1.17, and 3.8.1.18 state this allowance as a Note to each SR. SR 3.8.1.17, 4.8.1.1.2.d.5.b, The Note states, "All EDG starts may be preceded by an engine prelube period." SR 3.8.1.18 4.8.1.1.2.d.6, No loading requirements for the SRs have been included because they were not 4.8.1.1.2.d. 10, appropriate. This changes the CTS by not requiring the manufacturer's 4.8.1.1.2.e recommendations to be followed, because the ITS states that these recommendations "may" be followed.

3.8.1 L.20 CTS Surveillance Requirement 4.8.1.1.2.d. I requires verification that an EDG SR 3.8.1.9 4.8.1.1.2.d. 16 provides power at the appropriate frequency and voltage following a load rejection. CTS 4.8.1.1.2.d states that this test is to be performed every 18 months "during shutdown." This Surveillance is performed during shutdown, but an identical test is performed at power following on-line EDG maintenance. ITS SR 3.8.1.9 does not restrict performance of the SR in any MODE. This changes the CTS by allowing the MODE I, 2, 3 or 4 performance of the load rejection test to be credited for meeting the Surveillance.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 9 of 22 L-3.8

Table L - Less Restrictive Changes ITS Section 3.8 - Electrical Power Systems Description of Change I fS Requirement CTS Requirement Change DOC No. Type I ý3.8.2I -Required I ý 0 1 n A -1:- - I 3.8.2 L.I CTS 3.8.1.2 Action a requires with less than the minimum required A.C. electrical Action A. I 3.8.1.2 Action a power sources of one train (one circuit, between the offsite transmission network and the onsite Class IE distribution system, and one diesel generator) immediately suspend all operations involving specific tasks. These activities include CORE ALTERATIONS, positive reactivity changes, and the movement, or movement of load over, irradiated fuel assemblies. ITS 3.8.2 Action A. I adds an allowance to this requirement. This allows the affected required feature(s) with no offsite power available to be declared inoperable and enter the feature(s) Conditions and Required Actions requirements for the specific finction. This would allow the utilization of the feature(s) Required Actions while continuing with activities, such as a plant cooldown. The CTS requirements do not allow this provision. I_

I I SR 3.8.2.1 Note 4.8.1.2 CTS surveillance requirement 4.8.1.2 states, "The above required A.C. electrical SR 3.8.2.1I Note 4.8.1.2 power sources shall be demonstrated OPERABLE by the performance of each of the Surveillance Requirements of 4.8.1.1.1, 4.8.1.1.2, 4.8.1.1.3, and 4.8.1.1.4."

ITS SR 3.8.2.1 states the required SRs but adds a Note which states, "The following SRs are not required to be performed: SR 3.8.1.3, SR 3.8.1.6, SR 3 . 8 .1.9, SR 3.8.1.10, SR 3.8.1.12, SR 3.8.1.13, SR 3.8.1.14, SR 3.8.1.15 and SR 3.8.1.16." This changes the CTS to allow specific surveillance requirements to not be performed on the required equipment during the time that only one offsite source and one EDG are required to be OPERABLE.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements Page 10 of 22 L -3.8 North Anna Power Station

Table L - Less Restrictive Changes ITS Section 3.8 - Electrical Power Systems DOC No. Description of Change ITS Requirement CTS Requirement Change Type 3.8.2 L.3 CTS Surveillance Requirement 4.8.1.2 states, "The above required A.C. electrical SR 3.8.2.1 4.8.1.2 6 power sources shall be demonstrated OPERABLE by the performance of each of the Surveillance Requirements of 4.8.1.1.1, 4.8.1.1.2, 4.8.1.1.3, and 4.8.1.1.4."

ITS SR 3.8.2.1 states that the listed SRs are applicable. The list is composed of SRs 3.8.1.1, 3.8.1.2, 3.8.1.3, 3.8.1.4, 3.8.1.5, 3.8.1.6, 3.8.1.7, 3.8.1.9, 3.8.1.10, 3.8.1.12, 3.8.1.13, 3.8.1.14, 3.8.1.15, and 3.8.1.16. This changes the CTS by not requiring Surveillances 4.8.1.1.1 .b, 4.8.1.1 .2.d.4, 4.8.1.1.2.d.5, and 4.8.1.1.2.eto be performed on the AC circuit and EDG that are OPERABLE.

CTS 3.8.1.2 Action a. specifies with less than the required AC electrical sources 3 8.2 Required 3.8.1.2 Action a 4 3.8.2 L.4 OPERABLE, operations involving positive reactivity changes shall be immediately Actions B.2.3 and suspended. ITS 3.8.2 Required Actions B.2.3 and C.3 modify this requirement and C.3 state, "Suspend operations involving positive reactivity additions that could result in loss of required SDM or boron concentration." This changes the CTS requirement by allowing operations that are a positive reactivity change.

L.5 CTS LCO 3.8.1.2 Applicability states, "loads over irradiated fuel assemblies when None 3.8.1.2 2 3.8.2 no fuel assemblies are in the reactor vessel." CTS 3.8.1.2 Action a. requires with Applicability less that the minimum required A.C. electrical power sources, all operations 3.8.1.2 Action a involving movement of loads over irradiated fuel assemblies shall be immediately suspended. ITS LCO and Actions of 3.8.2 do not specify these requirements. This changes the CTS by deleting the applicability during movement of loads over irradiated fuel assemblies.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7- Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page I11 of 22 L-3.8

Table L - Less Restrictive Changes ITS Section 3.8 - Electrical Power Systems DOC No. Description of Change ITS Requirement CTS Requirement Change Type 3.8.2 L.6 The Applicability for CTS 3.8.2.1, AC sources, states, "during the movement of LCO 3.8.5 3.8.2.1 2 irradiated fuel assemblies." The associated Action states with the required AC Applicability Applicability sources not fully OPERABLE immediately suspend all operations involving movement of irradiated fuel assemblies. ITS LCO 3.8.5 Applicability states, "during the movement of recently irradiated fuel assemblies." This changes tile CTS by restricting the AC sources requirements to during the movement of fuel assemblies that have been recently irradiated.

3.8.3 L.I CTS 3.8.1.1 requirements for diesel fuel oil states the fuel oil tanks will contain 3.8.3 Condition B3 3.8.1.1 4 45,000 gallons each to support the EDGs' OPERABILITY requirements. If the volume is less than this amount, the associated EDGs are to be declared inoperable.

ITS 3.8.3 Condition B allows 48 hours2 days 0.286 weeks 0.0658 months to restore a fuel oil level to 90,000 gallons, provided the level is 77,200 gallons or greater, before declaring tile EDG(s) inoperable. This changes the CTS by allowing the diesel fuel oil requirement to decrease below the current limit.

3.8.3 L.2 Not used. N/A N/A N/A 3.8.3 L.3 CTS 3.8.1.1.2.b states that every 92 days a sample from the fuel oil storage tank is 3.8.3 Action E 3.8.1.1.2.b 3 verified to be within acceptable limits. If this requirement can not be met, the associated EDGs are declared inoperable. ITS Action E states that with one or more EDGs with new fuel oil properties not within limits, 30 days is allowed to restore stored fuel oil properties within limits. This changes the CTS by allowing 30 days to restore fuel oil within required limits.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 12 of 22 L -3.8

Table L - Less Restrictive Changes ITS Section 3.8 - Electrical Power Systems ii ~ KequiremeI Chnnoc7,IIIILI DOC No. Description of Change IT1R lequiremlent ý c ., ,3 l,~.[.IIs i lllu lee t Type I

3.8.l.l.t I 4 3.8. _CnItion A . II 4- fuel oil storage tanks to be inoperable -T-3.8.3 L.4 CTS 3.8.l1.1.f allows one of the underground 13.8.1 Condition A 13.8.1 .1.tf for inspection and repair provided certain conditions are met and the tank is restored within 7 days. If those conditions are not met or the tank is not restored within 7 days, both units must be in at least Hot Standby within the next 6 hours0.25 days 0.0357 weeks 0.00822 months and Cold Shutdown within the following 30 hours1.25 days 0.179 weeks 0.0411 months . ITS 3.8.1, Condition A, allows one of the underground fuel oil storage tanks to be inoperable for inspection and repair provided certain conditions are met and the tank is restored within 7 days. If those conditions are not met or the tank is not restored within 7 days, ITS Condition F requires the associated EDGs to be declared inoperable immediately.

Once the associated EDGs are declared inoperable, the appropriate Conditions and Required Actions of Specification 3.8.1 must be followed. ITS 3.8. 1, Condition I, which applies with two EDGs inoperable, allows two hours to restore one EDG and then Condition L requires the unit to be in MODE 3 in 6 hours0.25 days 0.0357 weeks 0.00822 months and MODE 5 in 36 hours1.5 days 0.214 weeks 0.0493 months . This changes the CTS by allowing an additional 2 hours0.0833 days 0.0119 weeks 0.00274 months to restore compliance with LCO 3.8.3 or LCO 3.8.1 if the Required Actions of Condition A are not met.

I I SR 3.8.4.9 I 4.8.2.3.2.e SR 3.8.4.9 4.8.2.3.2.e 3.8.4 L.I CTS Surveillance Requirements 4.8.2.3.2 e. and 4.8.1.1.3 d. require verification at 4.8.1.1.3.d least every 60 months that the station and EDG battery capacity is at least 80% of the manufacturer's rating when subjected to a performance discharge test. ITS SR 3.8.4.9 requires verification that the station and EDG battery capacity is > 80% of the manufacturer's rating when subjected to a performance discharge test or a modified performance discharge test. This changes the CTS by allowing a modified performance discharge test to be substituted for a performance discharge test. I I I Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements Page 13 of 22 L-3.8 North Anna Power Station

Table L - Less Restrictive Changes ITS Section 3.8 - Electrical Power Systems DOC No. Description of Change ITS Requirement CTS Requirement Change Type 3.8.4 L.2 CTS Surveillance Requirements 4.8.2.3.2 b.2 and 4.8.1.1.3 b.2 require, for the SR 3.8.4.2 4.8.2.3.2.b.2 and 6 station and EDG batteries that no visible corrosion is detected at either terminals or 4.8.1.1 .3.b.2 connectors within 7 days after a battery discharge below 110 volts or overcharge above 115 volts. The connection resistance of these items is limited to less than 150 micro-ohms. ITS SR 3.8.4.2 requires, for the station and EDG batteries, no visible corrosion at the battery terminal connections and connectors be detected, or the battery connection resistance is < 1.5 E-4 ohms for the inter-cell, inter-rack, inter-tier, or terminal connections. This changes the CTS by eliminating the verification of visible corrosion or connection resistance after a battery discharge or overcharge.

3.8.4 L.3 CTS Surveillance Requirements 4.8.2.3.2 d, e, and f, and 4.8.1.1.3 d. and e. SR 3.8.4.8, 4.8.2.3.2.d, 6 contain the requirement to perform various tests for batteries "during shutdown." SR 3.8.4.9 4.8.2.3.2.e, ITS SRs 3.8.4.8 and 3.8.4.9 are modified in a Note that states the Surveillance shall 4.8.2.3.2.f, not normally be performed in specific MODES. An additional statement modifies 4.8. I. 1.3.d the Note. It allows a partial Surveillance to be performed to reestablish 4.8.1.1.3.e.

OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. This changes the CTS requirements for testing of the EDGs by allowing the listed tests to be performed in MODES in which they are normally prohibited from being conducted.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 14 of 22 L -3.8

Table L - Less Restrictive Changes ITS Section 3.8 - Electrical Power Systems LIS Requirement ti I.equIreInenL .II4Ilgc DOC No. Description of Change ITS Requirement CTS RleqUlrelnielt ypange Type L.4 ______________________________________ I SR 3.8.4.8, Note I I 4.8.2.3.2.d 4.8.2.3.2.d 1 6 SR 3.8.4.8, Note I 6 3.8.4 CTS Surveillance Requirements 4.8.2.3.2 d. requires verification of the station battery capacity when the battery is subjected to a service test. ITS SR 3.8.4.8 requires verification that the station battery capacity when subjected to a service test. The SR is modified by Note I that states, "The modified performance discharge test in SR 3.8.4.9 may be performed in lieu of tile service test in SR 3.8.4.8." This changes the CTS by allowing a modified performance discharge test to be substituted for a service test.

1-SR 3.8.4.6 1-4.8.2.3.2.c.3 F 6 3.8.4 L.5 SR 3.8.4.6 4.8.2.3.2. c. 3 CTS Surveillance Requirement 4.8.2.3.2.c.3 specifies for the battery charger to supply 200 amps at 125 volts for at least 4 hours0.167 days 0.0238 weeks 0.00548 months . ITS SR 3.8.4.6 states, "Verify each required station battery charger supplies Ž_ 270 amps at Ž_125 V for Ž_ 4 hours0.167 days 0.0238 weeks 0.00548 months .

This changes the CTS by allowing the battery charger voltage to be 125 volts or greater for the required surveillance test.

3.8.4 L.6 -1 SR 3.8.4.4 1 4.8.2.3.2.c.2, I 6 SR 3.8.4.4 4.8.2.3.2.c.2, CTS 4.8.2.3.2.c.2 and 4.8.1.1 .3.c.2 require that the cell-to-cell and terminal 4.8.1.1.3.c.2 connections for the station and EDG batteries be clean, tight and coated with anti corrosion material. ITS SR 3.8.4.4 in part states, "For each required station and EDG battery ... verify battery cell to cell and terminal connections are clean and coated with anti-corrosion material." This changes the CTS by deleting the "tight" requirement fi'om the surveillance requirement. I I ______________ ___I ____

I Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements Page 15 of 22 L-3.8 North Anna Power Station

Table L - Less Restrictive Changes ITS Section 3.8 - Electrical Power Systems II Requirement L I Z mequircment '...IIUII DOC No. Description of Change ITS Rlequirement CTS R¢equirenment Type 3.8.5 Applicability t 3.8.2.2 2 3.8.2.2 3.8.5 L.l CTS 3.8.2.2 Applicability includes, "During the movement of irradiated fuel 3.8.5 Applicability Applicability assemblies or loads over irradiated fuel assemblies when no fuel assemblies are in the reactor vessel." ITS 3.8.5 Applicability includes, "During the movement of recently irradiated fuel assemblies." This changes the CTS by deleting the applicability requirement, "loads over irradiated fuel assemblies when no fuel assemblies are in the in the reactor vessel." The addition of the word "recently" to the Applicability is discussed in DOC L.5.

3.8.5 Required 3.8.2.2 Action 4 3.8.5 L.2 CTS 3.8.2.2 Action requires that with less than the minimum DC sources Action A.1. 1 OPERABLE operations, involving CORE ALTERATIONS or positive reactivity additions, be suspended immediately, and corrective action be initiated to restore the required DC source(s) as soon as possible. ITS 3.8.5 Required Action A.1.1 provides an alternative by allowing, "Declare affected required feature(s) inoperable immediately." This changes the CTS by not requiring the immediate suspension of activities involving CORE ALTERATION or positive reactivity additions.

3.8.5 Required 3.8.2.2 Action 3.8.5 L.3 CTS 3.8.2.2 Action states with less than the minimum DC sources OPERABLE Action A.2.3 immediately suspend positive reactivity changes. ITS 3.8.5 Required Action A.2.3 states "suspend reactivity changes that are more positive than necessary to meet the required SDM or refueling boron concentration limit." This changes the CTS by allowing positive reactivity changes that are currently not allowed.

-1 SR 3.8.5.1 Note 1 Unit I 4.8.2.2.2, t 6 4.8.2.1.2 for Unit 2 state the required equipment shall SR 3.8.5.1 Note Unit 2 4.8.2.2.2, 3.8.5 L.4 CTS 4.8.2.2.2 for Unit I and Unit 2 4.8.2.1.2 be demonstrated OPERABLE per Surveillance Requirement 4.8.2.3.2. ITS SR 3.8.5.1 includes a Note stating that specified tests are not required to be performed.

These include the following SRs: 3.8.4.7, 3.8.4.8, and 3.8.4.9. This changes the CTS by specifically stating that certain SRs are not required to be performed. I I

I-.-

I Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements Page 16 of 22 L -3.8 North Anna Power Station

Table L - Less Restrictive Changes ITS Section 3.8 - Electrical Power Systems DOC No. Description of Change ITS Requirement CTS Requirement Change Type 3.8.5 L.5 CTS 3.8.2.2 Applicability for the DC source requirement states during the LCO 3.8.5 3.8.2.2 2 movement of irradiated fuel assemblies. The associated Action states with the Applicability Applicability required DC buses not fully OPERABLE immediately suspend all operations involving movement of irradiated fuel assemblies. ITS LCO 3.8.5 Applicability states during the movement of recently irradiated fuel assemblies. This changes the CTS by not applying the DC source requirements during the movement of fuel assemblies that have not been recently irradiated.

3.8.5 L.6 CTS 3.8.2.2 LCO states, "As a minimum, one of the following trains of AC and LCO 3.8.5, LCO 3.8.2.2 DC busses shall be OPERABLE and energized in the specified manner." The LCO 3.8.7, LCO lists the equipment that makes up the 1-1and J trains electrical subsystems. LCO 3.8.9, ITS LCOs 3.8.7 and 3.8.9 addresses the AC buses for shutdown conditions. ITS LCO 3.8.10 LCO 3.8.5 states, "DC electrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCO 3.8.10, "Distribution System - Shutdown." ITS LCO 3.8. 10 requires the "necessary portions" of the DC power distribution subsystems to be OPERABLE to support equipment required to be OPERABLE. This changes the CTS by requiring only the necessary portions of the DC subsystem(s) to be OPERABLE, instead of one train.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 17 of 22 L -3.8

Table L - Less Restrictive Changes ITS Section 3.8 - Electrical Power Systems Description of Change I FS Requirement CTS Requirement Change DOC No.

Type 3.8.6 L.I CTS Table 4.8-3 notes (1) and (2) specify actions for Category A and B parameters 3.8.6 Condition A Table 4.8-3 notas (1) and (2) not within limits. Note I states, "For any Category A parameter(s) outside the limit(s) shown, the battery may be considered OPERABLE provided that within 24 hours1 days 0.143 weeks 0.0329 months all the Category B measurements are taken and found to be within their allowable values, and provided all Category A and B parameter(s) are restored to within limits within the next six days." Note 2 states, "For any Category B parameter(s) outside the limit(s) shown, the battery may be considered OPERABLE provided that the Category B parameters are restored to within limits within 7 days." ITS Condition A states, "One or more station or EDG batteries with one or more battery cell parameters not within Table 3.8.6-I Category A or B limits." Ifthis condition is entered, Required Action A.2 requires the verification of battery cell parameters in Table 3.8.6-I meet Category C limits and Required Action A.3 requires the restoration of battery cell parameters to Table 3.8.6-I Category A and B limits. Category C limit verification is required within 24 hours1 days 0.143 weeks 0.0329 months and once per 7 days thereafter. The time limit for restoring the cell parameters to within the Category A and B limits is 31 days. This changes the CTS by allowing the Category A and B limits to be exceeded for a period of 31 days where the CTS only allows 7 days. I I It I

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements Page 18 of 22 L-3.8 North Anna Power Station

Table L - Less Restrictive Changes ITS Section 3.8 - Electrical Power Systems II S Requirement L lequlremeni k.narige DOC No. Description of Change IIS R¢equirement CTS R¢equiremnte Tpange Type I _______________________________ + Table 3.8.6-I, Note t Table 4.8-3 6 3.8.6 L. 2 CTS TFable 4.8-3 Battery Surveillance Requirement limits for the electrolyte level, Table 3.8.6-1, Note "Fable 4.8-3 (a) in the Category A and B columns, is greater than the minimum level indication mark, and < 'A inch mark above the maximum level indication mark. ITS Table 3.8.6-1 states for the Category A and B limits, "> Minimum level indication mark, and < 1/ inch above maximum level indication mark I')." Note I') states, "It is acceptable for the electrolyte level to temporarily increase above the specified maximum during equalizing charges provided it is not overflowing." This changes the CTS by allowing the electrolyte level to exceed the specified limit under specific conditions.

4 1 I4- .4 None I 3.8.6 L.3 CTS Table 4.8-3, Battery Cell Parameters, note (c) states, "For any cell with None Table 4.8-3 Note 0 voltage below the limit and electrolyte temperature > 3'F from the average electrolyte temperature, correct the cell voltage for the average temperature." This note applies to Category B for the battery cells' float voltage of> 2.13 volts. ITS 3.8.6 does not require this correction. This changes the CTS by deleting the requirement for cell voltage to be corrected by temperature.

N/A., ,"

None N/A N/A N/A N/A 3.8.7 II I I[ 3.8.2.2 i r 3.8.8 Applicability - I -.

3.8.2.2 2 3.8.8 L.I CTS 3.8.2.2 is applicable in MODES 5 and 6 and during movement of irradiated 3.8.8 Applicability Applicability fuel assemblies or loads over irradiated fuel assemblies when no fuel assemblies are in the reactor vessel. CTS 3.8.2.2 Action also requires suspension of movement of loads over irradiated fuel assemblies. ITS 3.8.8 is applicable in MODES 5 and 6, and during movement of irradiated fuel assemblies. This changes the CTS by deleting the applicability during movement of loads over irradiated fuel assemblies and the associated required action. I I _______

I__________

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements Page 19 of 22 L-3.8 North Anna Power Station

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

,--~ n CT'O D, ,,iir. ment I c atinpe DOC No. Description of Change 1 Kequlremlenit u i, i wl\qkUltrelltlt k,., IIld LI,r" Type 3.8.8 Action A.l1 3.8.2.2 Action 4 3.8.8 L.2 CTS 3.8.2.2 Action states that with less than the minimum required electrical busses OPERABLE, immediately suspend CORE ALTERATIONS, positive fuel reactivity changes, and the movement, or movement of load over, irradiated A.lI adds an optional Action allowing the affected assemblies. ITS 3.8.8 Action and enter required feature(s), without the required buses, to be declared inoperable the feature(s) Conditions and Required Actions requirements for the specific while function. This allows tile performance of the feature(s) Required Actions continuing with unit operations, such as a plant cooldown. The CTS requirements do not allow this option.

3.8.8 Req2i3ed 3.8.2.2 Action 3.8.8 L.3 CTS 3.8.2.2 Action requires that with less than the required electrical busses Action A.2.3 OPERABLE, operations involving positive reactivity changes shall be immediately involving suspended. ITS 3.8.8 Required Action A.2.3 states, "Suspend operations or boron positive reactivity additions that could result in loss of required SDM concentration." This changes the CTS requirement by allowing limited operations that include a positive reactivity change. 3.8.2.2 2 3.8.8 L.4 3.8.8 Applicability movement CTS 3.8.2.2 Applicability for the inverter requirement states during the Applicability of irradiated fuel assemblies. The associated Action states with the required inverter not fully OPERABLE immediately suspend all operations involving movement of irradiated fuel assemblies. ITS LCO 3.8.8 Applicability states during CTS by the movement of recently irradiated fuel assemblies. This changes the during the movement of fuel assemblies that excluding the inverter requirement have not been recently irradiated. I__________________________

IL--.- I Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7- Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements Page 20 of 22 L-3.8 North Anna Power Station

Table L - Less Restrictive Changes ITS Section 3.8 - Electrical Power Systems 1 ITS Requirement CTS Requirement 1 Change Description of Change ITS Requirement ICTFS Requirement Change I Type J I. 3.8.9 Conditions A, t 3.8.2.1 Actions a 4 CTS 3.8.2.1 Actions a and b state that one of the required buses may not be fully 3.8.9 Conditions A, 3.8.2.1 and b, Actions a B, and C energized and each Action provides appropriate time for the inoperable bus to be 3.8.2.3 Action a re-energized. CTS 3.8.2.3 Action a states that with one 125-volt DC bus inoperable, restore the inoperable bus to OPERABLE status within 2 hours0.0833 days 0.0119 weeks 0.00274 months . ITS LCO 3.8.9 Conditions A, B, and C state that with one or more of the required AC electrical power distribution subsystems inoperable, DC, or AC vital buses are inoperable. The required buses must be restore to OPERABLE status within specified times. This changes the CTS by allowing more than one required electrical power distribution subsystems or buses to be inoperable. ii I

3.8.10 3.8.10 L.I CTS 3.8.2.2 is applicable during MODES 5 and 6 and during movement of 3.8.10 Applicability 3.p.2.2 Applicability irradiated fuel assemblies or loads over irradiated fuel assemblies when no fuel assemblies are in the reactor vessel. CTS 3.8.2.2 Action also prohibits movement of loads over irradiated fuel assemblies. ITS 3.8.10 is applicable in MODES 5 and 6, and during movement of irradiated fuel assemblies. This changes the CTS by deleting from the applicability the movement of loads over irradiated fuel assemblies and the associated required action.

3.8.10 Action A. I 3.8.2.2 Action 4 3.8.10 L.2 CTS 3.8.2.2 Action states that with less than the minimum required electrical busses OPERABLE, immediately suspend CORE ALTERATIONS, positive reactivity changes, and the movement, or movement of load over, irradiated fuel assemblies. ITS 3.8. 10 Action A. I adds an optional Action allowing the affected required feature(s), without the required buses, to be declared inoperable and enter the feature(s) Conditions and Required Actions requirements for the specific function. This would allow the performan'ce of the feature(s) Required Actions while continuing with unit operations, such as a plant cooldown. The CTS requirements do not allow this option.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements Page 21 of 22 L-3.8 North Anna Power Station

Table L - Less Restrictive Changes ITS Section 3.8 - Electrical Power Systems Description of Change ITS Requirement CTS Requirement Change DOC No. Type 3.8.10 Required 3.8.2.2 Action 4 3.8.10 L.3 CTS 3.8.2.2 Action requires that with less than the required electrical busses OPERABLE, operations involving positive reactivity changes shall be immediately Action A.2.3 suspended. ITS 3.8. 10 Required Action A.2.3 states, "Suspend operations involving positive reactivity additions that could result in loss of required SDM or boron concentration." This changes the CTS requirement by allowing limited operations that includes a positive reactivity change.

3.8.10 3.8.2.2 2 3.8.10 L.4 CTS 3.8.2.2 for the AC and DC distribution systems in shutdown is applicable during the movement of irradiated fuel assemblies. The associated Action states Applicability Applicability with the required systems not fully OPERABLE, immediately suspend all operations involving movement of irradiated fuel assemblies. rIS LCO 3.8.10 is applicable during the movement of recently irradiated fuel assemblies. This changes the CTS by excluding distribution systems during the movement of fuel assemblies that have not been recently irradiated.

LCO 3.8.10 LCO 3.8.2.2 3.8.10 L.5 CTS LCO 3.8.2.2 states, "As a minimum one of the following trains of AC and DC busses shall be OPERABLE . . "This would require either the H or J train AC and DC buses to be OPERABLE. The H train specifies the two 120 VAC buses (I-I and 2 or 2-1 and 2) are energized from their associated inverter. The J train similarly states that the two 120 VAC buses (1-3 and 4 or 2-3 and 4) are energized from their associated inverter. ITS LCO 3.8.10 states, "The necessary portion of AC, DC, and AC vital bus power distribution subsystems shall be OPERABLE to support the equipment required to be OPERABLE." This changes the CTS by requiring only the necessary portions of the AC, DC, and AC vital bus distribution subsystems to be OPERABLE.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements Page 22 of 22 L - 3.8 North Anna Power Station

Table L - Less Restrictive Changes ITS Section 3.9 - Refueling Operations Change Description of Change ITS RequirCmcnt CTS Requirement Category DOC No.

3.9.1 ACTIONS 3.9. I Action 4 3.9.1 L. I CTS 3.9.1 ACTION states that when the boron concentration requirement is not met, initiate and continue boration at ->10 gpm of> 12,950 ppm boric acid solution or its equivalent until Kcn is reduced to < 0.95 or the boron concentration is restored to >

2300 ppm, whichever is more restrictive. ITS 3.9. I requires initiation ol action to restore boron concentration to within limit. This changes the CTS by eliminating the specific requirements for the boric acid solution to be used to restore compliance with the LCO.

3.9.1 L.2 CTS 4.9.1. I requires the LCO reactivity condition to be dctcrmincd prior to removing or None 4.9. I.15 unbolting the reactor vessel head, and prior to withdrawal of any full length control rod located within the reactor pressure vessel, in excess of 3 fect from its fully inserted position. ITS 3.9.1 does not contain this Surveillance Requirement.

LCO 3.9.1 Note 3.9.1 2 3.9. 1 L.3 CTS 3.9.1 provides limits on the boron concentration of all filled portions of the Reactor Coolant System and the refueling canal. ITS 3.9.1 modifies this requirement with a Note which states, "Only applicable to the relfueling canal and rel'ueling cavity when connected to the RCS." This changes the CTS by eliminating the applicability of the boron concentration limits on the refueling canal and refueling cavity when those volumes are not connected to the RCS.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements Page I of 9 L-3.9 North Anna Power Station

Table L - Less Restrictive Changes ITS Section 3.9 - Refueling Operations Change DO Description ol Change ITS Requiremcnt I CTS Requirenment Category 3.9.2 L.l 3.9.2 Actions 3.1.1.3.2 4 Unit I CTS 3. I. 1.3.2 states that when the primary grade water flow path isolation valves are not locked, sealed, or otherwise secured in the closed position in MODE 6, all operations involving positive reactivity changes or CORE ALTERATIONS must be suspended, and the valves must be locked, sealed, or secured in the closed position within 15 minutes. Unit 2 CTS 3. 1.1.3.2 states that when the primary grade water flow path isolation valves are not locked, sealed, or otherwise secured in the closed position, all operations involving positive reactivity changes or CORE ALTERATIONS must be suspended, the isolation valves must be lockcd, sealed, or otherwise secured in the closed position within 15 minutes, and SHUTDOWN MARGIN must he verified greater than or equal to 1.77% Ak/k within 60 minutes. ITS 3.9.2 Actions state than when one or more valves are not secured in the closed position, CORE ALTERATIONS must be suspended immediately, the primary grade water flow paths must be isolated within 15 minutes and the boron concentration must be verified per SR 3.9.1 .1 within 4 hours0.167 days 0.0238 weeks 0.00548 months .

This changes the Unit I and Unit 2 CTS by eliminating the requirement to suspend positive reactivity additions and changes the Unit 2 CTS by allowing 4 hours0.167 days 0.0238 weeks 0.00548 months to determine the SHUTDOWN MARGIN. The addition of the SHUTDOWN MARGIN measurement to the UnitI CTS is discussed in DOC M. 1.

-f 1 CTS 3.9.2 Action states that with less than two source range instrunmentation channels 3.9.3, Action A.2 3.9.2 Action 3.9.3 L.lI OPERABLE, immediately suspend all operations involving positive reactivity changes.

ITS 3.9.3 Action A.2 adds an allowance to this requirement, which states, "Suspend operations that would cause introduction into the RCS, coolant with boron concentration less than required to meet the boron concentration of LCO 3.9. I."This allows positive reactivity changes provided they do not reduce the boron concentration below the refueling limit. This changes the CTS requirements by allowing a limited positive reactivity additions.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Survcillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 2 of 9 L -3.9

Table L - Less Restrictive Changes ITS Section 3.9 - Refueling Operations Change Description of Change ITS Requirement CTS Rcquirement Category DOC No.

None 4.9.2 5 3.9.3 L.2 CTS surveillance requirement 4.9.2 states that a CHANNEL FUNCTION TEST is required for the source range neutron flux monitors at least once per 7 days and within 8 hours0.333 days 0.0476 weeks 0.011 months prior to the initial start of CORE ALTERATIONS. ITS SRs do not require the performance of similar tests for the source range instruments. This changes the CTS by deleting the CHANNEL FUNCTIONAL TESTS every 7 days and within 8 hours0.333 days 0.0476 weeks 0.011 months of CORE ALTERATIONS.

LCO 3.9.3 LCO 3.9.2 3.9.3 L.3 CTS LCO 3.9.2 states that two source range neutron flux monitors shall be operating, each with continuous visual indication in the control room and one with audible indication in the containment. ITS LCO 3.9.3 states that two source range neutron flux monitors shall be OPERABLE. The movement of continuous visual indication in the control room is addressed by DOC LA. I. This changes the CTS by deleting the requirement for an audible indication in the containment from the source range neutron flux monitors.

3.9.4.c. I 3.9.4.c. I 3.9.4 L. I CTS 3.9.4.c. I states that one option lor the status of a containment penetration is for it to be, "Closed by an isolation valve, blind liange, or manual valve." ITS 3.9.4.c. I states that one option for the status of a containment penetration is, "Closed by a manual or automatic isolation valve, blind flange, or equivalent." As all isolation valves are either manual or automatic, the addition of this phrase to the CTS does not result in a change.

This changes the CTS by eliminating the phrase "manual valve" and adding the option of having, "or equivalent," as the means of closing the penetration.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements Page 3 of 9 L -3.9 North Anna Power Station

Table L - Less Restrictive Changes ITS Section 3.9 - Refueling Operations Change DOC No. Description of Change ITS Requirement CTS Requirement Category SR 3.9.4. I 4.9.4 7 3.9.4 L.2 CTS 4.9.4 states that specified containment penetration surveillances shall be performed, "within 100 hours4.167 days 0.595 weeks 0.137 months prior to the start of and at least once per7 dlays during..."

the specified conditions. ITS SR 3.9.4.1 do not include the, "within 100 hours4.167 days 0.595 weeks 0.137 months prior to the start or' Frequency. ITS SR 3.0.1 states, "SRs shall be met during the MODES or other specified conditions in the Applicability for the individual LCOs, unless otherwise stated in the SR." Therefore, under the ITS, tile Surveillances must be met prior to the initiation of movement of recently irradiated fuel. This changes the CTS by eliminating the stipulation that the Surveillances be met within 100 hours4.167 days 0.595 weeks 0.137 months prior to entering the MODE of Applicability.

SR 3.9.4.2 4.9.4 7 3.9.4 L.3 CTS 4.9.4 includes a surveillance Frequency of once per 7 days during specified times in the MODE of Applicability for testing Containment Purge and Exhaust System OPERABILITY. The ITS SR 3.9.4.2 Frequency for the same requirement is 18 months.

This changes the CTS by changing thie Surveillance Frequency from 7 days to 18 months.

LCO 3.9.4 Note None 3.9.4 L.4 ITS LCO 3.9.4 Note states, "Penetration flow path(s) providing direct access from the containment atmosphere to the outside atmosphere may be unisolated under administrative controls." CTS 3.9.4 does not include such an allowance. This changes the CTS by allowing containment penetration flow paths to be unisolated under administrative controls during movement of recently irradiated fuel assemblies.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements Page 4 of 9 L-3.9 North Anna Power Station

Table L - Less Restrictive Changes ITS Section 3.9 - Refueling Operations Change DOC No. Description of Change ITS Requirement CTS Requirement Category 3.9.4 3.9.4 2 3.9.4 L.5 CTS 3.9.4 is applicable during CORE ALTERATIONS and movement of irradiated fuel assemblies within containment. ITS 3.9.4 is applicable during movement of recently irradiated fuel assemblies within containment. References to CORE ALTERATIONS in CTS 3.9.4 are eliminated in the Applicability, Action, and Surveillances. All references in CTS 3.9.4 to irradiated fuel are changed to "recently" irradiated fuel. This changes the CTS by eliminating requirements for containment closure during CORE ALTERATIONS and movement of fuel that is not recently irradiated.

LCO 3.9.4.c.2, SR 3.9.4.c.2, 4.9.4.1, 3.9.4 L.6 CTS 3.9.4.c.2 requires open containment purge and exhaust valves to be capable of 3.9.4.2 being closed by an OPERABLE automatic Containment Purge and Exhaust isolation 4.6.3. 1.2.c valve. CTS Surveillance 4.9.4.b requires testing the Containment Purge and Exhaust isolation valves and system per the applicable portions o" Specification 4.6.3.1.2 and 4.9.9. CTS Surveillance 4.6.3.1.2.c requires verifying every 18 months that on a Containment Purge and Exhaust isolation signal, each Purge and Exhaust valve actuates to its isolation position. ITS LCO 3.9.4.c.2 states that open containment purge and exhaust valves be capable of being closed by an OPERABLE isolation valve. ITS SR 3.9.4.2 requires verification that each required containment purge and exhaust valve actuates to the isolation position on manual initiation. This changes the CTS by eliminating the requirement that open containment purge and exhaust valves close automatically on a Containment Purge and Exhaust isolation signal.

I4 I None 1 .

3.9.4 L.7 CTS 3.9.4.b, footnote *, part b.2, states that if both personnel airlock doors are open, None 3.9.4.b, Footnote part h-.2 there must be at least 23 feet of water above the top of irradiated fuel assemblies within the reactor pressure vessel during CORE ALTERATIONS excluding movement of fuel assemblies. The ITS does not have that restriction. This changes the CTS by eliminating the requirement on water level during CORE ALTERATIONS when both containment personnel airlock doors are open.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements Page 5 of 9 L-3.9 North Anna Power Station

Table L - Less Restrictive Changes ITS Section 3.9 - Refueling Operations Change DOC No. Description of Change ITS Requirement CTS Requirement Category 3.9.4 L.8 CTS 3.9.4.b is modified by a footnote

and part a of footnote

states that both doors of LCO 3.9.4 3.9.4.b, Footnote *,

the containment personnel airlock may be open provided one door is capable of being part a closed "and that an individual is designated to close the door." ITS LCO 3.9.4 allows both doors of the containment personnel airlock to be open provided one door is capable of being closed. This changes the CTS by eliminating the requirement that "an individual is designated to close the door."

3.9.5 L. I CTS 3.9.8.1 states, in part, that with less than one RHR loop in operation, close all 3.9.5 3.9.8.1 4 containment penetrations providing direct access from the containment atmosphere to the outside atmosphere within 4 hours0.167 days 0.0238 weeks 0.00548 months . ITS 3.9.5 states that with the RHR loop requirements not met, within 4 hours0.167 days 0.0238 weeks 0.00548 months secure the equipment hatch with at least four bolts, close one door in each installed air lock, and close each penetration providing direct access from the containment atmosphere to the outside atmospherc with a manual or automatic isolation valve, blind flange, or equivalent, or verify each penetration is capable of being closed by an OPERABLE Containment Purge and Exhaust Isolation System. This changes the CTS Actions by allowing penetrations capable of being closed by an OPERABLE Containment Purge and Exhaust Isolation System to remain open when the RHR requirements are not mact.

3.9.5 L.2 CTS 4.9.8.1.2 states that an RHR loop must be verified to be in operation and providing SR 3.9.5.1 4.9.8.1.2 7 the required flow at least once per 4 hours0.167 days 0.0238 weeks 0.00548 months . ITS SR 3.9.5. I requires verification that one RHR loop is operating and providing the required flow every 12 hours0.5 days 0.0714 weeks 0.0164 months . This changes the CTS by reducing the Frequency for performing this Surveillance from 4 to 12 hours0.5 days 0.0714 weeks 0.0164 months .

3.9.5 L.3 CTS Surveillance 4.9.8. 1.1 requires verification that each RHR loop is OPERABLE per None 4.9.8. I. 1 5 Specification 4.0.5. ITS 3.9.5 does not contain this Surveillance.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements North Anna Power Station Page 6 of 9 L -3.9

Table L - Less Restrictive Changes ITS Section 3.9 - Refueling Operations Change Description of Change ITS Requirement CTS Requ'ii rement Category DOC No.

3.9.5, Action A.l1 3.9.8.1 4 A

3.9.5 L.4 rS 3.9.8.1 states, in part, that with less than one RHR loop in operation, suspend all operations involving a reduction in boron concentration of the Reactor Coolant System.

ITS 3.9.5, Action A. I, states that with the RHR loop requirements not1met, suspend operations that would cause introduction into the RCS, coolant with boron concentration less than required to meet the boron concentration of LCO 3.9.1. This changes the CTS by allowing coolant with boron concentration less than the RCS boron concentration, but greater than the boron concentration limit in LCO 3.9. 1, to be added to the RCS when the RHR requirements are not met.

3.9.6 ACTIONS 3.9.8.2 4 3.9.6 L.I CTS 3.9.8.2 states, in part, that with less than one RHR loop in operation, close all containment penetrations providing direct access from the containment atmosphere to the outside atmosphere within 4 hours0.167 days 0.0238 weeks 0.00548 months . ITS 3.9.6 states that with no RHR loop in operation, within 4 hours0.167 days 0.0238 weeks 0.00548 months secure tIle equipment hatch cover with at least Four bolts, close one door in each installed air lock, and close each penetration providing direct access from the containment atmosphere to the outside atmosphere with a manual or automatic isolation valve, blind flange, or equivalent, or verify each penetration is capable of being closed by an OPERABLE Containment Purge and Exhaust Isolation System. This changes the CTS Actions by allowing penetrations capable of being closed by an OPERABLE Containment Purge and Exhaust Isolation System to remain open when no RHR loop is in operation.

SR, 3.9.6.1 4.9.8.2.2 7 3.9.6 L.2 CTS 4.9.8.2.2 states that an RHR loop must be verified to be in operation and providing the required flow at least once per 4 hours0.167 days 0.0238 weeks 0.00548 months . ITS SR 3.9.6.1 requires verification that one RHR loop is operating and providing tile required flow every 12 hours0.5 days 0.0714 weeks 0.0164 months . This changes tile CTS by reducing the Frequency for performing this Surveillance from 4 to 12 hours0.5 days 0.0714 weeks 0.0164 months .

CTS Surveillance 4.9.8.2.1 requires verification that each RHR loop is OPERABLE per None 4.9.8.2.1I5 3.9.6 L.3 Specification 4.0.5. ITS 3.9.6 does not contain this Surveillance.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements Page 7 of 9 L- 3.9 North Anna Power Station

Table L - Less Restrictive Changes ITS Section 3.9 - Refueling Operations I -I F hange cl 11 ITS Requirement CTS Requirement ca ategory DOCr Nl Description of Change u ý IN . I" -1 0- i - 4 3.9.6, Action B. I 3.9.8.2 3.9.6 L.4 CTS 3.9.8.2 states, in part, that with less than one RHR loop in operation, suspend all operations involving a reduction in boron concentration of the Reactor Coolant System.

ITS 3.9.6, Action B. I, states that with the RHR loop requirements not met, suspend operations that would cause introduction into the RCS, coolant with boron concentration less than required to meet the boron concentration of LCO 3.9. I. This changes the CTS by allowing coolant with boron concentration less than theRCS boron concentration, but greater than the boron concentration limit in LCO 3.9. 1, to be added to the RCS when the RHR requirements are not met. _ __ _ 4 i i__

i LCO 3.9.6 Notes None ITS 3.9.6 is modified by two LCO Notes. Note I allows all RHR pumps to be removed LCO 3.9.6 Notes None 3.9.6 L.5 from operation for < 15 minutes when switching from one train to another, provided several conditions are met. Note 2 allows one required RHR loop to be inoperable for up to 2 hours0.0833 days 0.0119 weeks 0.00274 months for Surveillance testing, provided that the other loop is OPERABLE and in operation. CTS 3.9.8.2 does not contain these allowances. This changes the CTS by providing allowing the LCO to not be met.

LCO 3.9.7 3.9.10.1I2 3.9.7 L. I CTS 3.9.10.1 states that at least 23 feet of water must be maintained over the reactor pressure vessel flange in MODE 6 during movement of fuel assemblies within the containment. The 3.9.10. I Action requires suspension of movement of I'ucl assemblies if the water level requirement is not met. ITS 3.9.7 states the refueling cavity water level shall be maintained > 23 feet above the top of'the reactor vessel flange during movement of irradiated fuel assemblies within containment. ITS 3.9.7, Action A.2, requires the suspension of movement o irradiated fuel assemblies within containment.

This changes the CTS restricting the applicability and Actions from movement of any fuel assemblies within containment to movement of irradiated fucl within containment.

The change eliminating MODE 6 is discussed in DOC A.3.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements Page 8 of 9 L - 3.9 North Anna Power Station

Table L - Less Restrictive Changes ITS Section 3.9 - Refueling Operations Change ITS Requi rement CTS Requiii rement Category DOC No. Description of Change SR 3.7.9.1 4.9.10.1 7 3.9.7 L.2 CTS 4.9.10.1 requires the refueling cavity water level to be determined to be within movement limit within 2 hours0.0833 days 0.0119 weeks 0.00274 months prior to the start of and at least once per 24 hours1 days 0.143 weeks 0.0329 months during cavity water of fuel assemblies. ITS SR 3.7.9.1 requires verification that the refueling changes the CTS by reducing the Frequency level is within limit every 24 hours1 days 0.143 weeks 0.0329 months . This level from 2 hours0.0833 days 0.0119 weeks 0.00274 months before fuel movement to 24 hours1 days 0.143 weeks 0.0329 months for verifying refueling cavity water before fuel movement.

Change Category:.

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of' Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements Page 9 of 9 L- 3.9 North Anna Power Station

Table L - Less Restrictive Changes ITS Section 4.0 - Design Features

-- r Change CiS Requirement Change Category D)escriptlion of Change ITS RIcquircnlcnlt CTS Req~uirenment D)OC No. - ----------------------4 4.3.2 I 5.6.2 I 4.3.2 5.6.2 Note I ained to pre'vent 4.0 L. I CTS 5.6.2 states that tile spent fuel pit is designed and shall lbe iainl Sea Le.vel, USGS inadvertent draining of the pool below elevation 288.83 foet Mean "The spent fuel storage pool is designed and shall be datum. ITS 4.3.2 states, prevent inadvertent draining of the pool below elevation 285 lFee,9 inaineiied to by reducing (he inches, Mean Sca Level, USGS datum." This changes the CTS to 285 fect, 9 minimum design water level of the spent fuel pool From 288.83

[fel inches. I Change Category:

I - Relaxation of LCO Rcquirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Fime 4 - Rhelxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Suiveillance Frequency 8 - D)eletion of Reporting Requircments used IIor the other Chapters. A specific l)etcrninatioii of No Significanlt Note 1 - The Less Restrictive changes for Chapter 4.0 did not fall inlto, the categories in ChapclAtr 0.

Hazards Consideration was written for each Less Restrictive Change Page 1of1 I. -- 4.0 North Anna Power Station

"Fable L - Less Restrictive Changes ITS Section 5.0 - Administrative Controls CI ng Change Category 1 ITS Requirenment CTS reuilenl DOG No. Description of Change I 5.2.2.b Table 6.2-1 Note I one less (hall tile llinilnilmln 5.0 LI. CTS Table 6.2-I specifies that tile shift crew may be timie not to exceed 2 hours0.0833 days 0.0119 weeks 0.00274 months .

Colliplelnenlt, except 10-r the Shirft Supervisor, fri a period of for being less than mninimum CTS Table 6.2-1 also takes an exception that the provision to be unmalln)lned upon shift crew cotmtplementet does not apply for any shift crew position late or absent. ITS 5 2.2.1b does shift change due to an toncoming shift crewman being 50.54 (m)(2)(i). This changes not make these exceptions to the rcquiremcnts of 10 CFR the manning requirements the CTS by allowing shifIt crew composition to be less than without specilying exceptions to this allowance. -L +

to be submitted to the Nuclear None 6.9.1.5.c 9 115.0 L.2 CTS 6.9. 1.5.c states the contents of an annual report in which I results o1 specific activity analyses Regulatory Commission which contains the Activity Specification. ITS the primary coolant exceeded the limits of the RCS Specific fIr such an annual report. This changes the C'l'S by 5.6 does not contain any requireftlents specific activity analv;es in which not including the requiremenlts lfor he annual report of of the RCS Specific Activity Specil'icati.n.

the priimary coolant exceeded the Iitnmls --I--I in( the UFSAR ." ITS None 6.2.2) Note I 5.0 L.3 CTS 6.2.2 states, "The Facility organization shall be as shown

" and describes the ficilily 5.2.2 states, "The Facility organization shall include.

to have the description organization. This changes the CTS by delfting the iequiremient of the facility organization in tie UFSAR.

-L Chan1geCatego:

I - Relaxation ol' LCO Requirelenlts 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Recquirement Criteria 6 - Relaxation Of Surveillance Requirement Acceptance 7 - Relaxation Of' Surveillance Frcqucn)cy 8 - Deletion of Reporting Rlequiremelits of No Significant into tltc categories tsd.(! for the other Chapters. A specific Determination Note 1 Certain Less Restrictive changes for Chapter 5.0 did not fall ge in Chapter 5.0.

strictive ('hfan Hazards Consideration was written for each non-categorized Ie ss Re l'we I of 17 L-5.()

North Anna Po Wt' 5rationl 1-ttgu I m II

Table L - Less Restrictive Changes ITS Section 5.0 - Administrative Controls Change ITS Rcquireoment CTS Requirement Category DOC No. Description of Change 5.1 .1 6 I. I Note I 5.0 L.4 CTS 6.1. I states, "The Site Vice President shall be responsible for overall f'acility operation. In his absence, the Manageir- Station Operations and Maintenance shall be Vice responsible for overall facility operation. During the absence of both, the Site shall dclegate in writing the succession to this respon hlily.'"

sib ITS 5. I.1 President operation and shall states, "The plant manager shall be responsible lbr overall utinit delegate in writing the succession to this responsibility during his absence." This changes the CTS by not specifying the title of tie person with responsibility for overall to lacility operation, and allowing the plant manager to delegate the responsibility Operations and Maintenance il that person is someone other than tie Manager - Station not absent None 6.1.2 Note 1 5.0 L.5 CTS 6.1.2 states, "A management directive to this eflect, signed by the Senior Vice Pres idcnt-NucIcar, shall be issued to all station personnel on an annual basis," regarding such d delegation of the control room command 'unction. [TS 5.1.2 does not inclUdec requirement. This changes the CTS by deleting the requirement to issue a WalngIeii'ient directive annually.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of' Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Elrequcncy 8 - Deletion of Reporting Requirements olher Chapters. A specific )etermination ol' No Significanlt Note I - Certain Less Restrictive changes for Chapter 5.0 did not 'all into the categories used for the Hazards Consideration was written for each non-categorized I.ess Restrictive Change in Chapter 5.0.

Page 2 of'17 L.-5.0 North Anna Powet' Station

Table L - Less Restrictive Changes ITS Section 5.0 - Administrative Controls T T Lilmnge I

Category Description of Change [TS RqujicnClent CTS Requiremcnt DOC No. I- t 6.2.1 .b,6.2.1 .c, t Note I

- ______ 5 2.l.b. 5.2.l.c, 11 unli safe 5.2. 1 .b, 5.2. 1.c, 6.2.1.[), 6.2. I.c, Note I 5.0 L.6 CTS 6.2.1 .b states, "The Site Vice President shall be responsible Ir overall 5.5.1 .1, 5.2.2.e and 6.1.5, 6.3.1.1 and those onsite activities necessary for safe operation and shall have contlrol over 6.2.1 operation 5.3.1 6.3.1.3 and maintenance of the plant." CTS .c states, "The Vice President -- Nuclcar Operations shall have corporate responsibility for overall plant nuclcar safety and shall olperating, take any measures needed to ensure acceptable performance o" the salf in nuclear safcty.' (CTS maintaining, and providing technical support to the plant to ensure cffcctive after...the approval of 6.15 states, "Changes to the ODCM: ... b. Shall become Superintendcnt Operations shall the Site Vice President." CTS 6.3.1.3 states, "The Radiological Protection shall hold..." CTS 6.3. I. I states, "The Superintendent-5.2. I.c meet..." ITS 5.2. I.b substitutes "plant manager" for "Site Vice President,"' IS substitutes "A specified corporate ofhcer I"The for Vice President!- Nuclear

'TS Operations," ITS 5.5. I.b substitutes "plant manager" for "Site Vice President."

for "Superintendent Operations," and ITS 5.3. I 5.2.2.e substitutes "operations manager" substitutes "radiation protection man ager"' for "Super int endent - Radiolo)gical positions Protection." This changes the CTS by using less speciflic designations for tl:c with the respective responsibilities.

-t None t 6.9.1 I 6.9. I .2 and 5.0 L.7 for None 6.9.1.1,6.9.1.2 and CTS 6.9.1.1, CTS 6.9.1.2 and CTS 6.9.1.3, "Startup Reports," contains requirements 6.9.1.3

,oetic of lllati aa submitting a report lbIllowing receipt oi an operating license; installation I aodilic;itions1, Iiha different design or has been manufactured by a different fouel supplier; may have altered the nuclear, thermal, or hydraulic perlormance of the unit; auid in power operation. The ITS does amendments to the license involving plamned increase

'This changes the CIS by deleting the not contain such reporting requirements.

requirements of CTS 6.9. 1.1, CTS 6.9.1.2 and CTS 6.9.1.3.

I Change Category:

I- Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requircment Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Dcletion of Reporting Requirements rlotrhc other Chapters. A specilic Detcrrmination of No Significant Note I - Certain Less Restrictive changcs for Chapter 5.0 did not fall into tihe catcgoriecs usced Change in Chapter 5.1.

Hazards Consideration was written for each non-categorized I.ess Restrictivc Page 3 of 17 L- 5.0 North Anna Power Station

Table L - Less Restrictive Changes ITS Section 5.0 - Administrative Controls ChnI Change ITS Rcquireinc nt Catcgory DOC No.

Description of Change CTS Rcequircmlennt.

None Notc I None 'Table 6.2-I Note 1 5.0 IA CTS TFable 6.2-I includes requircements on SS, SRO, RO, AO, and STA posiiion The manning for each unit that are beyond what is required by 10 CFR 50.54(m1.(2)(i).

deleting Ce:rtain critLria ITS does not include these conditions. This changes tile C'T'S by regarding how manning is distributed. I- 5.2.2.a I '[able 6.2- I I Note I with either or both units in MODE I, 2, 3. or 4. four 5.2.2,a "lTahlc 6.2-I1 Note I 5.0 L.9 CTS Tablc 6.2- I requires that, ned io each unit.

Auxiliary Operators (AOs) be part of the stal' Imanning, two AOs assig requires that, with both units in MODE" 5 or 6 or Dcfluclcd, two AOs CTS Table 6.2-1 "Anil auxiliary be part of staff mlanning, one AO assigned to each unit. 'I'S 5.2.2.a states, auxiiia ry operator shall be assigned to e ach reactor conlt aininIrg fucIanId 1 an additional a reactor is operating in operator shall be assigned for each control room frow which in MODES I, 2, 3, or 4. this changes MODES 1, 2, 3, or 4." When one or two units are ufutlrather the CTS by only requiring one AO be assigned for each reactor containing AO be assigned for each control room from than two, and only requiring one additional both units shutdown or defucled, this changes ihe which a reactor is operating. With rather than one CTS by only requiring one AO be assigned to each unit containing fuel, regardless of whether or not it contains fuel. Other AO be assigned for cach unit changes to the AO requirCnlltlls a1re addressed by DOC M.24.

--*None t 'l'able 6.2 I None Table 6.2-1I Note I 5).0 L.1I(0 CTS Table 6.2-I, with regard to work hour procedures, states, ".In addition, procedures from these guideltwie., and that will provide for documentation of authorized deviations such a the documentation is available for NRC review." Il'S 5.0 docs not inlcludC a requirement to have a procedure for requirenment. This changes the CTS by deleting the work hour guidelines and to have the documentation of authorized deviations from documentation available for NRC review.

I Change Category:

S- Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of' CompletionlTime 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance ReIcquirement Acceptance Critcria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements used for the other Chapters. A spoticli l)ctermiination of No Significant Note I - Certain Less Restrictive changes 'or Chapter 5.0 did not fall into the categories in Chapter 5.0.

Hazards Consideration was written for each non-categorized Less5RestrictivcC('hange 4 of 17 L- 5.0 I A.... .

North Anna Power Station

.. 1Pioe d8u -t %'I I I

Table L - Less Restrictive Changes ITS Section 5.0 - Administrative Controls

__________________________________________ i. Changc CT - eIiemn Change ITS Requirement Category CTS 1,C.equirmcntIII DOC No. Description of Change 5.2.2.d, 5.7.1 and 6.2.2.c, 6.12. I Note I technician. CTS 6.12. I, footnote "*:", and 5.0 L.II CTS 6.2.2.c references requirements for a health physics 5.7.2 CTS 6.12.2 rel'erences a 6.12.2 f'ootnote "*" describes a Health Physics technician allowance.

Plant Health Physicist. ITS responsibility of the Shift Supervisor on duty and/or the ITS 5.7. I references Radiation 5.2.2.d references a radiation protection technician, and protection shil'l supervisor, Protection personnel, and ITS 5.7.2 references the radiation responsibilities, respectively. This radiation protection manager or his or her designee in the speciflied positions to changes the CTS by changing the titles of the personnel more generic titles. Note I 5.5.2 implemented, and 6.8.4 5.0 1.12 CTS 6.8.4 states that one of tie programs to be established, those portions of systems outside maintained is, "A program to reduce leakage from fluids during a se rious traolsiunt or containment that could contain highly radioactive requires that the program minimizee ihe accident to as low as practical levels." ITS 5.5.2 the program provide controls to same leakage. This changes thie CTS by requiring minimize instead of reduce leakage.

5.() L.13 ITS 5.7.2.1' states, "Such individual areas that are within a larger area wherei no 5.7.2.1 6.12.2 I Notc I enclosure can reasonably he enclosure exists Ibr the purpose of locking and where no by a locked d'0"or or gate, constructed around the individual area need not he controlled posted, and a clearly nor continuously guarded, but shall be barricaded, conspicuously a warning device." CTS 6.12.2 visible flashing light shall be activated at the arca as CT'S by providing an addhitinal does not include such an allowance. This changes the meeting the critcria of 5.7.2.

method by which to control a high radiation area L-. I Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion"I'ime 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement Criteria 6 - Relaxation Of Surveillance Requirement Acceptance 7 - Relaxation Of Surveillahcc Frequency 8 - Deletion of Reporting Requirements Dtcerinination of No Signi licant not fall into the categories usd for the other Chapters. A specific Note I - Certain Lcss Restrictive changes for Chapter 5.0 did 5.0.

Restrictive Chane in Charter Hazards Consideration was written for each non-categorii.cd Less L - 5.0 D... S C1 17 I- jtgL; - ) U L I !

North Anna Power Station

Table L - Less Restrictive Changes ITS Section 5.0 - Administrative Controls Change Requircment CTS Requirement Category DODe.scriptionof'ChangeITS 5.0 L. 14 ITS 5.5.14 provides criteria for the Safety Function Determination Program (SEDP),

as 5.5.14 3.0.2 TIS I£CO 3.0.2 when a referenced in ITS LCO 3.0.6. This provides an exception to L(20 not being met, supported system LCO is not met solely due to a support system Actions associated with this supported system are such that the Conditions and Required sal'ety l'unction. The CTS do not required to be entered and there has been no loss ol including the not criteria exception to CTS LCO 3.0.2. This changes the CTS by suchananexception include for to CTS I£CO 3.0.2.

5.6.1 6.9.1.4 and 6.9.1.5 Note I be submitted prior to 5.0 L. 15 CTS 6.9.1.4 requircS annual reports described in CTS 6.9.1.5 Occupational Radiation Exposure Report March I of each year. ITS 5.6. I requires the changes the CTS by allowing an to be submitted by April 30 of each year. This IOS1osu rc Report eacI year.

the Occupational RadiationI additional 2 mlonths to submit 5.7. I.b and 5.7.2.h 6.12. t Note I shall be controlled by 5.0 L.1-6 CTS 6.12.1 states Ir high radiation areas, "...entrance thereto I1.b and ITS 5.7.2.b state for requiring issuance of a Radiation Work Permit."1 ITS 5.7.

in, eacih sueCh area shall be co(:ttillcd by high radiation areas, "Access to, and actlvi'ittieis ol that includes specification means of Radiation Work Permit (RWP) or equivalent and otler appropriate radiation radiation dose rates in the iinmed(liate work area(s) tile CTS by allowing an lcictivalent protection equipmenl and m111eaISurCS." This changes dle RiIM is control. The addition of (details required in document to be used1 or access addressed by DOC M.4.

Change Category:

I - Relaxation of I£CO Requirements 2 - Relaxation o1" Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement Acceptance Criteria 6 - Relaxation Of Surveillance Requirement 7 - Relaxation Of' Surveillance Frequency 8 - Deletion of Reporting Rcquircmcnls A specific Determination ol No Significant did not fall itito the categories used tor the other Chapters.

Note I - Certain Less Restrictive changes For Chapter 5.0 5.0.

Less Restrictive Change in Chapter Hazards Consideration was written for each non-categorized L - 5 .0

.. 0... , f' 1I 7 Ilit9c () M I I North Anna Power Station

Table L - Less Restrictive Changes ITS Section 5.0 - Administrative Controls Chan"c Chatgeo ITS Relqtireulent C'T'S Requircncnt Catecgory "DOC No. Description o) Change

_____________________________________- I-5.7.l.c I 6. 12 Ioottiote t Note 5.0 L. 17 5.7. I.c 6.1 2 footnote"" Note I Unit I CTS 6. 12, High Radiation Area, footnote "*," states, "'Hcalth Physics personnel shall be exempt from fhe RWP issuance rqui remenlt during thc perfon-nance or theil assigned radiation protection duties, provided they comply wilh approved radiation protection procedures for entry into high radiation areas." ITS 5.7. I.c state.;,

"Individuals qualified in radiation protection procedures and perso ) n nel c)ontin uously escorted by such individuals may bh excmpted from the requirement for an RWIP or equivailent while performing their assigned cluties provided that they are otherwisc following plant radiation protection proMcedlutires for entlry to, exit frIon , and w'ork in stch areas." This changes the Unit I CTS by allowing pcrso(n netl not qualified in radiation protection procedures, but escorted by such qualifiled individuals to use the v.xernption from the requirement forl an RW P or"eui IIi valent while pCrforming their as'si-ed Idtlies.

Changing the term "'Health Physics- to -radiation protection" is addressed by DOC L. 1. Allowing personnel( to usie the cxctmlptlion for reasons other tthan radiation is addressed by DOC L.34.

I Iprotection duties I assumes tiheeontrol ion 5.1.2 Table 6.2- I Note I 5.0) l. f18 CTS Table 6.2- 1 states the qualiications for the person that command function during the absence of the Shil't Supervisor, and excltIdes rl1,.' STA ; a person who can assume that function. ITS 5.1.2 does not include this exclusion of tle STA. This changes the CT'S by allowing an STA that holds a valid SiRO license to assiltuc tlie control roomi command function during the absence of the Shift Sttupervisot.

Change Catcgory:

I - Relaxation of LCO Requirtenntls 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillahce Requiremenl 6 - Relaxation 01 Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surtveillance Frequency 8 - Deletion of leporting Requirements l)ctlcrnination of No Significant Note I - Certain Less Restrictive changes For Chapter 5.0 did not fall into the categoll ic,ued Ior hie other Chapters. A specific Hazards Consideration was written for each non -cate goriizedcLess Restricti vc ('hinge iif Chapter 5.).

Page 7 of' 17 L -5.0 North Anna Power Station

Table L- Less Restrictive Changes ITS Section 5.0 - Administrative Controls 1 C'lS l cq U IiC liC n 1 x.I rcLtm5U Categoi 115 Requirement Description of Change ]TS Rcqulircml-Cl~ CTS RCquirl 1nt CNlegory DOC No. None 64.1 ensuring that None 6.4.1 Note I 5.t) L. 19 CTS 6.4.1 states, "The Manager - Nuclear Training is responsible wfo staff niect or exceed retraining and replacement Iraining programs For the licensed facility a retraining and replacement the requirements of' 10 CFR 55.59(c) and 55.31 (a)(4). Also, the reconimendat ions training program for non-liccnscd facility staff shall meet or exceed

"*" states, "lFxceptions to of Section 5 of ANS 3. I (12/79 Draft)*." CTS 6.4.1 footnote VEP-I1, "Quality this requirement are specified in VEPCO's QA Topical Report, inchlde these requirements.

Assurance Program, Operational Phase."" ITS 5.0 does not for ensuring tile requircments This changes tile CTS by not specifying who is rcsponsible requirements for non of 10 CFR 55.59(c) and 55.3 I(a)(4) are fiet, and not specifying licensed facility staff training. .9.5.7.c I None I 7 to insorvice te;sting 5.5.7.c None 5.0 L.20 ITS 5.5.7.c states, "The provisions of SR 3.0.3 are appllicable noticinclude an eq]uivalent staCiteinlint. This changes the CTS by activities."' CTS does is less, to llcrforni allowing 24 hours1 days 0.143 weeks 0.0329 months or up to the limit of the Firequieiicy, whichever wcr c )ot inservice testing if it is discovered that the inservice testing requirements perforined, instead o(f declaring the conmponent inoperable.

5.6.1 6.9.1.5 Note I VarliouLs duly FunctionIS to io be eslinlalCd u.lSing, 5.0 1.21 ITS 5.6. I allows close assignmentsli does not inelutide this amlong other things, an electronic dosimeter. C'T'S 6.9.1.5 CI'S by including an electronic dosilleter as one of tie allowance. This changes the may be estlilaled.

ways by which dose assignments to various duty functions I I I Changme Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion 'Time 4 - Relaxation of Required Action 5 - l)cletion of Surveillance Requirement Criteria 6 - Relaxation Of Surveillance Requirement Acceptance 7 - Relaxation Of Surveillance Frequency 9 - Deletion of Reporting Requirements of No Signilticant into tie categories used for the other ChapticS. A specific )ctcrinlination Note I - Certain Less Restrictive changes for Chapter 5.0 did not fall 9.0.

ivc Change i Clapt r Hazards Consideration was writtllen for each non-categorizedL e.ss Restrict Page 8 of 17 L - 5.0 North Anna Power Station

Table L - Less Restrictive Changes rfs Section 5.0 - Administrative Controls nange Change C'T'S Reeqtir erliCt Category Description of. Change ITS Requirement DOC No. Note I

'Fable 5.5.8-2 'Fable 4.4 I Tablc 5.5.8-2 Tahle 4.4-1 Note 1 5.0 L.22 Unit 1 CTS 4.4.5 Table 4.4-I states that if an additional steam generator is in category C-3, one Action Required is, "Report to NRC & obtain approval prior to operation.

ITS Table 5.5.8-2 for the same condition states, "Report to NRCC purstuant to 5.(,.7-.c."

the This changes the CTS by not requor i ring obtaining NRC approval prior to ope'ration in event an additional steam gcncrator is found to be in the category C-3.

t 5.7.2 T 6.12.2 F Note I than 6.12.2 Note I 5.0 L,23 CTS 6.12.2 states, regarding areas in which tlhe intensity of"radiation is greater 5.7.2 1000 mrnem/hr, but less than 5000 racs/hr at one meteoi fro a radiati,ol source oI, any radiation penetrates, "In addition, locked doors shall be provided surface through which witli to prevent unauthorized entry into such areas..." ITS 5.7.2 states, "...areas mrem/hr shall be provided with locked or conltintuois ly gtarded radiation levels > 1000 doors to prevent unauthorized entry." This changes the CT'S by allowing the doors to be guarded as an option Ito locking them.

i i 1 5.2.2.d "lTable 6.2-1I Note I 5.0 L.24 CTS Table 6.2-1 states, "Procedures will be established to insure that NRC policy state merit guidelines regarding work hours established Ifor employees are Ilowoiw.d."

imrplemerted to ITS 5.2.2.d states, "Administrative procedures shall be developed and limit working hours of personnel whi) pc rlform safety related functions..." This ch anges the CTS by not referencing the NRC policy staterilent guidelines iegarding, work hours as the souic'e Of guidance f'or limiting work hours.

-L Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Rccuired Action 5 - Deletion olf Surveillance Requirement 6 - Relalxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Prequcncy 8 - Deletion of Reporting Requirements For the other Chapters. A specific Delcrminition of' No Significant Note I - Certain Less Restrictive changes for Chapter 5.0 did not fall into the categories used 5.0.

Hazards Consideration was written Ior eachInon-categorincd L.css Restrictive Chlange inrClapter Pagc 9 of 17 L- 5.0 North Anna Power Station

Table L - Less Restrictive Changes ITS Section 5.0 - Administrative Controls Change Description or Change TS Requirement CTS Rcquiremlent Category DOC No.

5.5.4 6.8.4,0.7 5.0 L.25 CTS 6.8.4.a.5 requires, "Determination of cumulative and projected dose contributions from radioactive effluents forr (he current calendar quarter and culrrenl calendar year in accordance with the methodology and parameters in the ODCM at least every 31 days."

ITS 5.5.4 states, "The provisions of SR 3.0.2 and SR 3.0.3 are applicable to tihe Radioactive Effluent Controls Program surveiillance frequency." CTS does not include 0

this provision. This changes the CTS by piermitting a 25 1 extension of the interval specified in the Frequency.

5.6.4 6.9.1.6 8 115.0 1.26 CTS 6.9.1.6 states, "Routine reports of operating statistics and shutdown experience, including documentation or all challenges to thle Reactor Coolant System PORVs or safety valves, shall be submitted on a monthly basis..." ITS 5.6.4 states, "Routine reports of operating statistics and shutdown experiencc sshall be stbliiittcd onl a monthly basis..." This changes the CTS by deleting the requirement to include documentation of, all challenges to the Reactor Coolant Syste in PORVs or safety vwlves in lhe ntnmtnthly report.

Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation or Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements A specific Ietcrmnination of No Significant Note I - Certain Less Restrictive changes for Chapter 5.0 did not fall into the categories uscc:0o filhe other Chapters.

Chan.,e in Clhaptcr 5.0.

H-lazards Consideration was written I'or each non-c ategorized Loess Restrictive Pa c 10 oI'I 1'"L -- 5.0

, A.^.....

. ......- tation tN01111Anna iI(L owIi

Table L - Less Restrictive Changes ITS Section 5.0 - Administrative Controls Ihang

T- -

Change Category Description of Change ITS Requirrenient CTS Requirenlent DecC No. CIt

_ _ _-_'I__.......__... __._......__C'-. l . 12.1 a d 6. 12.

5.0 L.27 or group shall 5.7. I.d.3 and 6.12.1 and 6.12.2 Note I ITS 5.7. I.d.3 states that one of the options for devices an individual 5.7.2.(1.2 area with a dose rate not possess for radiation mnonitoring when entering a high radiation oritronit "uly surlace exceeding 1.0 rell/hour at 30 centimeters Irom the radiation sourcc device that Ctntin ioLiisly penetrated by tile radtalion is, "A radiatio n Monit(orinfg traqnsnmits dose ratc and eCUnIllatiye(lose information to a remote receiver ionitoied by radiation expoSurIe radiation protection personnel responsible Ior controlling personnel states that one of tile options for devices aln individual or within the area." ITS 5.7.2.d.2 a highr adiationa airca with a dose rate exceeding 1.0 group shall possess wheni en ter'ing the radliation source or from any surface plinetrated hy rein/hour at 30 Centimeters l'romi0 SOUl oCC(If the radiation, but less than 500t rads/ho or at I menter 1tr1ol1 the raditiation any by tile radiation is, "A radiation n tiitolring device that comit*IoUiisly surface penetrated nllilied by transminits dose rate and cmii id ative dose inil'Orma t ion 1( oa renmotereceivermon ne radiation

'I cx~IOSUre radiation protection personnel responsible for controlling perOsn every individual in tlhe within the area with the means to communicate with iand control an individual or grou1p.

are,.'" CTS 6.12. I and 6.12.2 do not conitain these optionsi For entering these This changes the C'T'S by providing an additional device ain individual I high radiation areas imust possess for radi ation monitoring.

-I I

Cjhange Category:

I - Relaxation of LCO Requircncnts 2 - Relaxation of Applicability 3 - Relaxation of CompletionliTine 4 - Relaxation of Required Action 5 - Deletion of Stirveillance RcquircmntCn 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillanice CFrCquency 8 - Deletion of Reporting Rcquirenments th e other Chlapteirs. A specific Deteriination ol(f No Signiiticant Note I - Certain Less Restrictive changes for Chapter 5.0 did not tall into the catcgorics u,,,d tolr Hazards Consideration was written for each non-categorimel Less Restrictive Change in C(halItei- 5.0.

Page II oI'17 L -5.0 North Anna Power Station

Table L - Less Restrictive Changes ITS Section 5.0 - Administrative Controls

- I I tJ[tange

("I'S Requiiemneflt Category Description of Change ITS RCequirencent CTIS Requirement DOC No. .1. 4 6.12.1 .h 1 5.7.1 .d.4 and 6.12.1 .b No:te I 5.0 L.28 CTS 6.12.1.b states that one ol the optional criteria that allow entry inlo a hi J! radi 5.7.2.(1.3 area is, "An individual qualified in radiation protection pr ocedutres Whoi s equipped Ior a radiation dose rate monitoring device. This individual shall be responsibhe within the area and shall perform pcrie providing positive control over the activities specified by the facility Hecalth Plhysiclist in I radiation surveillance at the frequency 5.7. I.d.4 states, "A sel freading dosinmcter (e.g., poiA Radiation Work Permit.' ITS as ionization chamber or electronic dosimeter) and, (i) be under the survcillance, qlualifCd in specified in the RWP or equivalent, while in the Mca, of an individual that radiation protection procedures, equipped with a radiation mo1nittring device',

radiation (lose aties in the area; who is responsible 0 fr n11oir continuously displays exposure within the area, or (ii) be undcr the surveillancC as speCdlied ir personnel ol pers RWP or equivalent, while in the area, by means of closed circuit television, qualified in radiation protection procedures, responsible for controlling perstmnel vWith individuala radiation exposure in the area, and With the means to communnicate reads the same as r the area who are covered by such surveillance." ITS 5.7.2.d.3 in the area who a.r 5.7.1 .d.4, except the last phrase, "communicate xWith individuals phrase, 'c'mmunicatc x,ith and covered by such surveillance," is replaced with the changes the CTS by dellting the." dis,--u:,

control every individual in the area." This and performing radiation surveillances Witli a o1 positive controls ovcr activities device to have continuous dose rate displays. and tl requirement for the monitoring dose rates in the area, and an option to pcrl'Drin the nionitt responsibility to control of personnel remotely using the speci ficd equipncent and proccsses.

I I Change Catcgory:

I - Relaxation ofL LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation ol' Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acccptance Criteria 7 - Relaxation Of Surveillance Freqctency 8 - Deletion of Reporting Requirements uscd1rtithe tother Chapters. A specific l)eteriinatio ol No Signficant Note I1- Certain Less Restrictive changes for Chapter 5.0 did not fall into thie categories Hazards Consideration was written lbFr each on{-categorized Iess R cstrictivi. Co'ar,ge in Cha',pter 5.0.

..Pas,,tgt-; i12- of!7 m 7 L - 5.0 North Anna Power NSation

Table L -- Less Restrictive Changes ITS Section 5.0 - Administrative Controls

-i -i Change Chanmgc ITS Requi, ielent CTS Rcqui rcrnent Category DOC No. Dcscliptiol lof' Change

______ I t 6.12.1 and 6.12.2 I Note I 5.7.2.d.4 6.12.1 and 6.12.2 Note I 5.0 L.29 ITS 5.7.2.d.4 states that one of the options for devices that an individual or group shall possess when entering a high radiation area with a close rate exceeding 1.0 renil/iour at 30 Centimeters from the radiation source or fromn any surlace penetrated by ;he radiation, but less than 500 rads/hour at I1me ter Irom the radiatiin soiLice 0: anyv V s lacc penetrated by the radiation is, "In those cases where options (2) and (3), above, are impractical or determined to he inconsistent with the "As Low As is Reasonably Achievable" principle, a radiation monitoring device that continuously displays radiation dose rates in the area." CTS 6.12. I and 6.12.2 do not contain these options for an individual or grou p. This changes the CTS by providling an additional option for devices an individual entering (tlese high radiation areas must possess.

I Change Category" I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Crilcria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements speciict l)etermination of No Signihcainl Note I - Certain Less Restrictive changes for Chapter 5.0 did not hall into the categories Jsed for thc other Chapters. A Hazards Cons ideratio[n was written for ecaIch nonl-c ate go r i ied ILess Restrictivc han.e in Chapter 5.0.

North Anna Power Stat ion3 Page 13 of 17 L- 5.0

Table L- Less Restrictive Changes ITS Section 5.0 - Administrative Controls cthange ITS Requirement CTS Rcquircnient Category DOC No. Description of Change

4. NO ne 4 6.8.2 and 6.8.3 1 Note I "N]one 6.8.2 and 6.8.3 Note I 5.0 L.30 CTS 6.8.2 states, "Each new piocedure of 6.8. I above, except 6.8. I.d, 6.S. i 6.8. l.1 shall he reviewed and approved by the SNSOC prior to ilnplcmcntati lorth in administrative procedures. ProcedurCs o" 6.8. L.d, 6.8. I.c, and 6.8. 1 reviewed and approved as set forth in the facility's Security Plan, Eniergenc I

section 6.5.1.6.m of the Technical Specifications, respectively.' CTS 6.8.

Program implementation. CTS 6.8. I.e is Emergency Plan implementation.

c is Fire Protection Program Implementation. CTS 6.8.3 states, "Procedure require a safety evaluation shall also be reviewed and approved by SNSOC changes shiall be independently reviewed and app,-oved as prograinmaticalli in the Updated Final Safety Analysis Report." ITS 5.0 does not inchtdc sl,31 c

those in CTS 6.8.2 and 6.8.3 regarding review and approval ol prtocedures and review and approval of changes as (described in 6.8.1 .d, 6.8. I.c, 6.8. If, This changes the CTI'S by not specifying how these procedures are reviewed approved. I I

_________ Ij - = --.- I Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Ciiteria 7 - Relaxation Of Surveillance Fecquency 8 - l)eletion of Reporting Requirements Chapters. A specific Determination ol" No Significant Note I - Certain Less Restrictive changes for Chapter 5.0 did not fall into the categories tus'.I'0l foi the o lther 5.0.

Hazurds Consideration was written for each non-c ategorized 1Less Restrictivc Change in Chapter Page 14 o I'I- L -5.0 North Anna Power Station

Table L - Less Restrictive Changes ITS Section 5.0 - Administrative Controls I I Chtt N le I 11 DOC No.

F Description of Change ITS Recluirettient CT C(I'Sl*,il-cmcint 6.8.4e.5 Category

'i.5.4.c 5.0 _31 6.8.4.c.5 Note I include 5.5.4 .c CTS 6.8.4.e.5 stales that the radioactivc eftliucnt control parogram shall anld projected close contributions From radioactive "Determination of cumulative el[Iluegnts for the current calendar quarter and ciutrre nt catlendatr year ilatacCorldance witl tile methodology and patametetrs ill the ODCM at least every 31 days." ITS 5.5.4.e states that tile radioactive c flLient control progra tn shall include "Dltermi tation(ot Iffluents for tile current caIcnad aaLIltai cumulative dose contributions from radioactive ad current calendar yeitr in accordance with the methodotlogy and paratinete rs ilatthe Imfroa ODCM at least every 31 days. Determaination (If projected dlose cnttribution,;

and parat*teters- ai tite O1)(

radioactive efltuents in accordance with tile methodology CTS by tot rcquiriatg that a1 pr1-jcctiOl) Of tlI at least every 31 clays." This changes the te ctCrenat calendar quarter anda tie current calendar year he dose contribution for thI performed every 3 Idlays. -t ft. 14 (tlatit I) aaicl N (lie I I Notate

0. 14 (Unit I ) and

-T N o tec 1I --I (Unit I ) andt CTS. ( None 5.0 L.32 CTS 1.22 describes the Process Control Programa (P(TP). CTS 6.14 6.13 (Unit 2)

I.g requiaes written pitclth (Unit 2) specifies the change control for the PCP. CTS 6.8.

nple nlttatioi. The itIS '

be established, implemented, and maintained to cover PCPI it the CTS by removing thte not specify requirements Ir tile PCP. This changes tile PC P.

requirements associated witt the contents andIcnainaite1atnaaice ot 5.5. (Ye 47.7.2 - c 6 test s:,iplcs o 5.5-10., 4.7.7.2. c 5.0 L.33 CTS 4.7.7.2.c states that the relative humidity at which tthe laboratory areltive humidi.ca at i charcoal adsorber are tested is 95%. [TS 5.5.1 0.c states that the is 7T'r Tl'liis whici the laboratory test samples oftihe charcoal adsorbcr are tested by relaxing the criteri1a for tile test Of the chatarcoalI adSortbch to ;i 701 changes the CTS humidity level instead o(f 95%.

-L Change Category:

i - Relaxation of LCO Requiremncats 2 - Relaxation of Applicability 3 - Relaxation of Completion Ti'Fme 4 - Relaxation of Required Action 5 - Dcletion of Surveillance Requirement 6- Relaxation Of Surveillance Requirement Acceptance Criteria 7- Relaxation Of Surveillance Frequency 8- Deletion of Reporting Requirements catcgori ' usLi ed f1r)'the othetr Chaptcrs. A spcilc Dctcr ttmin iDte of No Significant Note I - Certain Less Restrictive changes for Chapter 5.0 did not fI'iall into the

,1!g in Chapltear 5.0.

Hazards Considcration was writlcli for each non -catcgotizcd I.css Rcstricllv'c

.It

19. of,IJ 1-d1-I S.0 North Anna Power Station l +..t*L I +J t..,t i t

Table L - Less Restrictive Changes ITS Section 5.0 - Administrative Controls Change te men I (TI'S Req ti Change Category ITS Rcquiriciielit CTS Requirement DOC No. Description of Change 1-5.7. I .c 6.12 Footnote 4 t 5.7. l.c 6.12 f'ootnote "*" Note I Physic 5.0 L.34 Unit I CTS 6.12, High Radiation Area, Footnote "*," states, "Health shall be exempt Fromn the RWP issuance requirement during the performanc assigned radiation protection dutics, provided t hy comply with approved 2 CTS 6.1i protection procedures f[r entry into high r adiation areas." Unit Radiation Area, footnote "*," states, "Health Physics pCIesoinnel or lpersonnii from the RWP issuance rCquirCn Health Physics personncl shallhbe exempt protection duties, provided they tie performance of' their assigned radiation for entry intoI high radiation area approved radiation protection procedures and 5.7.1.c states, "Individuals qua fliied in radiation protectitn procedurcs may be exempted [roni the requi continuously escorted by such individuals Ihat th RWP or equivalent while perlorming their assigned duties prti\vidcd protect ion lrtced urc s for entry to, exit otherwise fo1llowing plant radiatioIi work in such areas." This changes the CTS by allowingtg personn elIto be ex for any duties, nt!itj ust ft rtadiatioIn p rtItect the RWP issuance requircment Changing tlie term "I lealth Physics"t ot 'radiation protection" is addressed L.I 1. For Unit I, allowing perstouiinel not (Lialified in radiation protection but escorted by such qualilicd individuals, to use theCeCxnptiotn trihn teI is addrey for an RWiP or equivalent while performing thcir assigned duties L.17. I Chanqe Category:

I - Relaxation of LCO Requirements 2 - Relaxation o(" Applicability 3 - Relaxation fCoimpleti f OtaTi'lme 4 - Relaxation of Required Action 5 - l)elctiotn of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteiia 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements secd for the toltlr 'Chapters. A specific l)ctermination of' No Sienificanlt Note I - Certain Less Restrictive changcs for Chapter 5.0 did notF all into the categories I.ess Restricti. t ,i t, in Chapter 5.0.

HIazards Con siderati on was writtllen fo0reach non-calegolized Page 160of' 17 L- 5.0 North Anna Power Station

Table L - Less Restrictive Changes ITS Section 5.0- Adminislrative Controls Change lTS RequiremCenl CTI'S Rcquireincnlt Category DOC No. Description ol Change 5.5.2 6.8.4.a17 5.0 L.35 CTrS 6.8.4.a states that the program addressing leakage from portiis ol'systems outside containmcnt shall include, "(ii) Intcgratcd leak test requirements for each system at refueling cycle intervals or less." ITS 5.5.2, l-rimary Coolant Sources Outside Containment, states that the program shall inclIde, "b. Integrated leak tes't requiiremenClts for each system at least once pcr 18 months. The provisions of SR 3.0.2 ar' the applicable." This changes tile CTS by changing the descriiptioln of tlec reitccncy for integrated leak test requirements to 18 months, and allowing the test to he performed tlhan within 1.25 tinies the 18m onth interval. This interval could be longer or shoiter the "refueling interval" frequency.

N/A 4.4. 10. 1.2 5 5.0 L.36 CTS 4.4. 10. 1.2 states, "In addition to the requircments o" Specification 4.0-5, at least one st xt n third 0' Ithe main i enmbchr to inain memtiber welds, joining A572 matcrial, in the generator supports, sithall be visually CXamlllinCd dourinig cithac40 imtonthi inspection inte rval."

C'lTS by climinating the The ITS does not containithis reqil ient. 'Thischanges tile Technit cal S peci hcatlions requliremtent Itor visual inspection of'h stean Ite 'tterorsth)plrl.

Change Cate!ory:

I - Relaxation of [LCO Requirenments 2 - Relaxation of Applicability 3 - Relaxation o' Completion Time 4 - Rclaxation of'Required Action 5 - Deletion ol Surveillancc Requirement 6 -Relaxation O' Surveillance Requirement Acceptance Criteria 7 - Relaxation 0l' Surveillance FreCqulency 8 - Delction of Reporting Requirerentens the otlher Chapters. A sl)eciflie l)cternmination of No Si'itigifcant Note I - Certain Less Restrictive changes For Chapter 5.0 did nott all into Ihe c'ategtorics used for ate*gorlid I .css Restrictivc (.'Itallgc in ChIaptecr 5.0).

HIIzar'ud.s Consideration was writlten for cach noln-c 1, .. r...A,..Pan t 17 of 17 L- 5.0 Noth' t1-11l-nal t. ,tttli

v t e Letter Sequence Acceptance Review
TAC:MB0799, Nis Power Range Channel Daily SR TS Change to Address LOW Power Decalibration, Revise Containment Requirements During Handling Irradiated Fuel and Core Alterations (Approved, Closed) TAC:MB0800, Nis Power Range Channel Daily SR TS Change to Address LOW Power Decalibration, Revise Containment Requirements During Handling Irradiated Fuel and Core Alterations (Approved, Closed)
Initiation Request, Request, Request Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance Administration Questions Answers Results Approval Other: ML020650715, ML020840253, ML021220061, ML021220088, ML021550518
MONTHYEAR2002-02-20 [Table View]

ML021220067

Text

Navigation menu

Search