ML20216J517
| ML20216J517 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  |
| Issue date: | 09/10/1997 |
| From: | Kelly G NRC (Affiliation Not Assigned) |
| To: | Leslie Liu IES UTILITIES INC., (FORMERLY IOWA ELECTRIC LIGHT |
| References | |
| NUDOCS 9709170343 | |
| Download: ML20216J517 (287) | |
Text
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, g j NUCLEAR REGULATORY COMMISSION WASHINGTON. O.C. haseHe01 4.....
Septenber 10, 1997
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Mr. Lee Liu Chairman of the Board and Chief Executive Officer IES Utilities Inc. 200 Firs.t Street, SE l P.O. Box 351 Cedar Rapids, IA 52406-0351 l
SUBJECT:
NRC REVIEW OF THE DUANE ARNOLD ENERGY CENTER CONVERSION FROM CURRENT TECHNICAL SPECIFICATIONS TO IMPROVED TECHNICAL SPECIFICATIONS
Dear Mr. Liu:
On August 25,1997, NRR staff spoke to Ken Paveler and Tony Browning, IES Utilities inc, licensing, regarding the status of the Duane Arnold Energy Center (DAEC) current iachnical Specifications conversion to the Improved Technical , Specifications (ITS). The purpose of the phone call was to reaffirm NRC's 1 commitment to successfully complete the Duane Arnold conversion with DAEC assistance. Once we have received DAEC responses to all NRC comments, we will be able to give you a firm date for the draft Duane Arnold Safety Evaluation (SE). Enclosed is a copy of the draft H.B. Robinson SE to give you a heads-up on a proposed new format for future SEs. The draft SE departs from previously issued SEs through the use of tables to provide a more concise document. The licensee assisted NRC in preparing the tables. The draft SE is still undergoing internal NRC review, but the format has been discussed with NRR senior management and NRC's Office of the General Council. Copies have been simultaneously mailed to the licensee and placed in NRC's Public Documeni. Room. EC RLE CEHa epy pm88=:;8:rg El!IIMMEllli
4 L6e Liu - Duane Arnold Energy Center IES Utilities Inc. cc: Jack Newman, Esquire Kathleen H. Shea, Esquire , Morgan, Lewis, & Bockius - 1800 M Street, NW, Washington. DC 20036-586g Chairman, Linn County ' Baard of Supervisors Cedar Rapids,IA 52406 IES Utilities Inc. ATTN: Gary Van Middlesworth Plant Superintendent, Nuclear 3277 DAEC Road Palo,IA 52324 John F. Franz, Jr, Vice President, Noclear Duane Arnold Energy Center 3277 DAEC Road Palo, IA 52324 Ken Peveler Manager of Regulatory Performance Duane Arnold Energy Center 3277 DAEC Road Palo,IA 52324 U.S. Nuclear Regulatory Commission Resident inspector's Office Rural Route #1 Palo,IA 52324 Regional Administrator, Rlil U.S. Nuclear Regulatory Commission 801 Warrenville Road Lisle, IL 60532 4531 Parween Baig Utilities Division Iowa Department of Commerce Lucan Office Building, 5th floor Dus Moines, IA 50319 4 +. --e, +,%s. w e er w e + e - ++ + e e w - m -w
L. . '. L.Liu We appreciate the discussion candor of August 25, and look forward to working with IES Utilities Inc. to complete the DAEC conversion and issuance of the SE. , Sincerely, Original signed by: Glenn B. Kelly, Senior Project Manager Project Directorate lll 3 Division of Reantor Projects Ill/IV Office of Nuclear Reactor Regulation Docket No. 50-331
Enclosure:
Draft H. B. Robinson SE cc: . See next page J k ~ DISTRIBUTION w/ enc / Docket File PUBLIC w/o encl: PD3-3 R/F EAdensam (EGA1) OGC ACRS GMarcus WBeckner, TSB CLipa, SRI GGrant, Rlli DOCUMENT NAME: G:\DUANEARN\97197LTT.WPD OFFICE PD3 3:PM ,E PD3-3:LA, , E NAME GKelly M CBoyle (Qb DATE 09//cy97 09/p/97 b OFFICIAL RECORD COPY
. ~ . - . . - - . _ . _ _ .
L. Liu . -We appreciate the discussion candor of August 25, and look forward to workin0-with IES Utilities Inc. to complete the DAEC conversion and issuance of the SE. Sincerely, Original signed by: Glenn B. Kelly, Senior Project Manager Project Directorate lll-3 Division of Reactor Projects lil/IV Office of Nuclear Reactor Regulation Docket No. 50 331
Enclosure:
Draft H. B, Robinson SE
- cc
- See next page 1
I QlSTBJRUTION w/ enc /t Docket File PUBLIC w/o enc /: PD3 3 R/F EAdensam (EGA1)- OGC-ACRS GMarcus WBecknei, TSB CLipa, SRI GGrant, Rlli
- DOCUMENT NAME: G:\DUANEARN\97197LTT.WPD OFFICE PD3 3:PM .
E PD3 3:LA, ) F. NAME GKelly /Jid ' CBoyle (f[ , DATE 09/hy97 09/p/97 6 OFFICIAL RECORD COPY
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION HELATED TO AMENDMENT NO. ## TO FACILITY OPERATING LICENSE DPR 23 H. B. ROBINSON STEAM ELECTRIC PLANT UNIT NO. 2 CAROLINA POWER & LIGHT COMPANY DOCKET NO. 50-261
- l. INTRODUCTION H. B. Robinson Steam Electric Plant 'Jnit No. 2 (HBR) has been operating with technical specifications (TS) issued with the original operating license on July 31,1970, as amended from time to time. By letter dated August 27,1996, as supplemented by letters dated January 17, February 18, March 27, April 4, April 25, April 29, May 30, June 2, June 13, June 18, August 4, and August 8,1997, Carolina Power & Light (the licensee) proposed to amend Appendix A of Operating License No. DPR 23 to completely revise the HBR TS. The proposed amendment was based upon NUREG 1431," Standard Technical Specifications Westinghouse Plants,"
Revision 1, dated April 1995, and upon guidance in the "NRC Final Policy Gtatement on Technical Specification Improvements for Nuclear Power Reactors"(Final Policy Statement), published on July 22,1993 (58 FR 39132). The overall objective of the proposed amendment, consistent with the Final Policy Statement, was to rewrite, reformat, and streamline completely the existing TS for HBR. Hereinafter, the proposed TS are referred to as the improved TS (ITS), the existing HBR TS are referred to as the current TS (CTS), and the TS in NUREG 1431 are referred to as the standard TS (STS). The corresponding TS Bases are ITS Bases, CTS Bases, and STS Bases, . respectively. In addition to basing its ITS on STS and the Final Policy Statement, the licensee retained portions of the CTS as a basis for the ITS. Plant-specific issues, including design features, requirements, and operating practices, were discussed with the licensee during a series of conference calls and meetings that concluded on July 30,1996. Based on these discussions, the licensee revised its proposed changes by submittals dated August 8,1997, and [") 1997. In addition, the licensee proposed matters of a generic nature that were not in STS. The NRC staff requested that the bcensee submit such generic issues as a proposed change to STS through the Nuclear Energy Institute's Technical Specifications Task Force (TSTF). These generic issues were considered for specific applications in the HBR ITS. Consistent with the Final Policy Statement, the licensee proposed transferring some CTS requirements to iicensee-controlled documents, in addition, human factors principles were emphasized to add clarity and understanding to the CTS requirements being retained in the (Plant hemel cat...\draftse.a20 1- revised: noon; August 20, 1997
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< ITS and to define more clearty the appropriate scope of the ITS Further, significant changes were proposed to the CTS Bases to make each ITS requirement clearer and easier to '
- understand.
The Commission's proposed action on the HBR application for an amendment dated
- August 27, igg 6, was published in the FEDERAL REGISTER on October 2g,1996 (61 FR 55830). Supplements to the licensee's ITS proposal, submitted by letters dated January
< 17, February 18, March 27, April 4, April 25,- April 2g, May 30, June 2, June 13, June 18, August
. 4, and August 8,1997, that resulted from discussions with the licensee during the stafheview,-
are incorporated in this Safety Evaluation (SE). These plant specific changes serve to clarify the , . ITS with respect to the guidance in the Final Policy Statement and _STS. Therefore, the changes l are within the scope of the action described in the initial FEDERAL REGISTER notice. . During its review, the NRC staff relied on the Final Policy Statement and on STS as guidance for acceptance of CTS changes. This SE provides a summary basis for the staff conclusion that HBR can develop ITS based on STS, as modified by plant specific changes, and that the use of the ITS is acceptable for continued operation. The staff also acknowledges that, by the Final Policy Statement, the conversion to STS is a voluntary process. Therefore, ITS differs from STS, l.. reflecting the current licenslog basis. The staff accepts the licensee changes to the CTS with modifications documented in the revised submittals. Fee the reasons stated infra in this SE, the staff finds that the TS lasued with this license amenoment comply with Section 182a of the Atomic Energy Act,10 CFR 50.36, and the guidance in the Final Policy Statement, and that they are in accord with the common defense and security and provide adequate protection to the public health and safety. f II. BACKGROUND l
- l. Section 182a of the Atomic Energy Act requires that applicants for nuclear power plant operating
, licenses will state: [S]uch technical specifications, including information of the amount, kind, and ! source of special nuclear material required, the place of the use, the specific ! characteristics of the facility, and such other information as the Commission may, ' by rule or regulation, deem necessary in order to enable it to find that the * , utilization . . of special nuclear material will be in accord with the common defense and security and will provide adequate protection to the health and safety of the public. ' Such technical specifications shall be a part of any license issued. In 10 CFR 50.36, the Commission established its regulatory requirements related to the content of TS. . In doing so, the Commission placed emphasis on those matters related to the prevention of accidents and the mitigation of accident consequences: the Commission noted that applicants ' were expected to incorporate into their TS "those items that are directly related to maintaining the integrity of the physical barriers designed to contain radioactivity." Statement of Consideration,
" Technical Specifications for Facility Licenses; Safety Analysis Reports," 33 FR 18610 (December 17, ig68). Pursuant to 10 CFR 50.36, TS are required to include items in the
- following five specific categories: (1) safety limits, limiting safety system settings and limiting control settings; (2) limiting conditions for operation (LCOs); (3) surveillance requirements (SR);
(4) design features; and (5) administrative controls. However, the rule does not specify the particular requirements to be included in a plant's TS.
, (Plant bene) c \...\draf tee.e20 2* revised: 12 noon, August 20,.1997 +
I I For several years, NRC and industry representatives have sought to develop guidelines for improving the content and quality of nuclear power plant TS. On February 6,1987, the i I Commission issued an interim policy statement on TS improvements, " Interim Policy Statement on Technical Specification improvements for Nuclear Power Reactors"(52 FR 3788). During the i period from 1989 to 1992, the utility Owners Groups and the NRC staff developed improved standard technical specifications that would establish models of the Commission's policy for each ! primary reactor type. In addition, the staff, licensees, and Owners Groups developed generic , administrative and editorial guidelines in the form of a " Writers Guide" for preparing technical l specifications, which gives greater consideration to human factors principles and was used throughout the development of licensee-specific ITS. In September 1992, the Commission issued NUREG-1431, which was developed using the guidance and criteria contained in the Commission's interim policy statement. STS were established as a model for developing improved TS for Westinghouse plants in general. STS reflect the results of a detailed review of the application of the interim policy statement criteria to generic system functions, which were published in a " Split Report" issued to the Nuclear Steam System Supplier (NSSS) Owners Groups in May 1938. STS also reflect the results of extensive discussions conceming various drafts of STS, so that the application of the TS criteria and the Writer's Guide would consistently reflect detailed system configurations ar'd operating characteristics for all NSSS designs. As such, the generic Bases presented in NUREG-1431 provide an abundance of information regarding the extent to which the STS present requirements that are necessary to protect the public health and safety. On July 22,1993, the Commission issued its Final Policy Statement, exprt@ the view that satisfying the guidance in the policy statement also satisfies Section 182a ofi..e Act and 10 CFR 50.36. The Final Policy Statement described the safety benefits of the improved STS, and encouraged licensees to use the improved STS as the basis for plant specific TS amendments, and for complete conversions to improved STS. Further, the Final Policy Statement gave guidance for evaluating the required scope of the TS and defined the guidance criteria to be used in determining which of the LCOs and associated surveillances should remain in the TS. The Commission noted (58 FR 39132) that, in allowing certain items to be relocated to licensee-controlled documents while requiring that other items be retained in the TS, it was adopting the qualitative standard enunciated by the Atomic Safety and Licensing Appeal Board in Portland Genera / Electric Co. (Trojan Nuclear Plant), ALAB-531,9 NRC 263,273 (1979). There, the Appeal Board observed: [T]here is neither a statutory nor a regulatory requirement that every operational detail set fnrth in an applicant's safety analysis report (or equivalent) be subject to a technical specification, to be included in the license as an absolute condition of operation which is legally binding upon the licensee unless and until changed with specific Commission approval. Rather, as best we can discem it, the contemplation of both the Act and the regulations is that technical specifications are to be reserved for those matters as to which the imposition of rigid cond,tions or limitations upon reactor operation is deemed necessary to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety. By this approach, existing LCO requirements that fall within or satisfy any of the criteria in the Final Policy Statement should be retained in the TS; those LCO requiremants that do not fall within or satisfy these criteria may be relocated to licensee-controlled documents. The (Plant Namel ct\...\draf tse.o20 3- revisec': 12 noon, August 20, 1997
L - l Commission codified the four criteria in 10 CFR 50.36 (60 FR 36593, July 19,1995)c The Final Policy Statement criteria are as follows: - CrHenon'1.
' installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary. :
l CrNenon 2 i i A process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier, - Crifenon 3 - l A structure, system, or component that is part of the primary success path and which functic ns or actuates to mitigate a design basis accident or transient that either assumes ; i the failure of or presents a challenge to the integrity of a fission product barrier, l Cntenon 4 A structure, system, or component which operating experience or probabilistic safety assessment has shown to be significant to public health and safety. 4 Part 111 of this SE explains the staff conclusion that the conve:sion of the HBR CTS to those [ based on STS, as modified by plant. specific changes, is consistent with the HBR current L licensing basis and the requirements and guidance of the Final Policy Statement and 10 CFR 1- 50.36. < 111. EVALUATION The staff ITS review evaluates changes to CTS that fall into four categories defined by the , ~ licensee and includes reviewing whether existing regulatory requirements are adequate for controlling future changes to requirements removed from the CTS and placed in licensee. controlled documents. This evaluation also discusses the staff plans for monitoring the j licensee's implementation plans of these controls at HBR. 1 The staff review identified the need for clarifications and additions to the submittal in order to
- establish an appropriate regulatory basis for translation of current TS requirements into ITS.
Each change proposed in the amendment request is identified as either a discussion of change to CTS or a justification for deviation from STS. The staff comments were documented as requests for additional information (RAls) and forwarded to the licensee for response by letters dated January 10, February 24, March 6, March 28, April 9, and May 22,1997. -The licensee provided written responses to the staff requests in letters dated February 18, March 27, April 4, April 25, April 29, May 30, June 13, June 18, and August 8,1997. The docketed letters clarified
- and revised the licensee basis for translating CTS requirements into ITS. The staff finds that the docketed material related to the review of ITS provides sufficient detail to reach conclusion regarding the adequacy of the licensee proposed changes.
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The license amendment application was organized such that changes were included in each of the following CTS change categones, as appropriate: administrative changes, less restrictive requirements (LR), more restrictive requirements (MR), STS differences, and relocated specifications. (1) Administrative, i.e., non technical changes in the presentation of existing requirements; (2) Less Restrictive, i.e., deletion of existing TS requirements, by movement of information and requirements from existing specifications (that are otherwise being retained) to licensee-controlled documents, including TS Bases; (3) More Restrictive, require, i.e., new or additional CTS requirements; (4) STS differences, i.e., retention of existing requirements based on plant-specific dssign or current licensing basis; and (5) Relocated specifications (from CTS Chapter 3/4.0 only), i.e., relaxations in which whole speci5 cations (the LCO and associated action and SR) are removed from the existing TS t .n NRC-controlled document) and placed in licensee-controlled documents. These general categories of changes to the licensee's current TS requirements and STS differences may be better understood as follows: Administrative Changes Administrative (non-technical) changes are intended to incorporate human factors principles into the form and structure of the ITS so that plant operations personnel can use them more easily, These changes are editorial in nature or involve the reorganization or reformatting of CTS requirements without affecting technical content or operational restrictions. Every section of the ITS reflects this type of change. In order to ensure consistency, the NRC staff and the licensee have used STS as guidance to reformat and make other administrative changes. Among the changes proposed by the licensee and found acceptable by the staff are: (1) providing the appropriate numbors, etc., for STS bracketed information (information that must be supplied on a plant specific basis and that may change from plant to plant) (2) identifying plant specific wording for system names, etc. (3) changing the wording of soecification titles in STS to conform to existing plant practices (4) splitting up requirements currently grouped under a single current specification to more appropriate locations in two or more specifications of ITS (5) comiaining related requirements currently presented in separate specifications of the CTS into a single specification oi ITS, Conclusion (Plant Name) c \ ..\draftse.s20 5- revised: noon; August 20, 1997
-._ _ . . . _ _ _ ~ __ . _ _ _ _ . _ _ _ . _ _ _ _ _ _ . _ _ _ . _ . _ _ . _ _ . _ _ . _ . _ . . _ _ _
The staff reviewed all of the administrative and editorial changes proposed by the licensee and finds them acceptable, because they are compatible with the Writers Guide and STS and are __ . consistent with the Commission's regulations.- t i- - More Restrictive Requirements ' i The licensee, in electing to implement the specifications of STS' proposed a number of-requirements more restrictive than those in the CTS. ITS requirements in this category include , requirements that are either new, more conservative than corresponding requirements in the . , CTS, or that have additional restrictions that are not in the CTS but are in STS.- Examples of more restrictive requirements are placing an LCO on plant equipment which is not required by the CTS to be operable, more restrictive requirements to restore inoperable equipment, and . more restrictive SRs. 4 Table MR lists the more restrictive changes proposed in ITS. Table MR is organized by the corresponding ITS section discussion of change and provides a summary description of the more restrictive change that was adopted, and CTS and ITS LCO references, e Conclusion These changes are additional restrictions on plant operation and are appropriate and acceptable. Less Restrictive Requirements 4 ! Less restrictive requirements include changes, deletions and relaxations to portions of current TS l' requirements that are not being retained in ITS, or the ITS Bases.- When requirements have been shown to give little or no safety benefit, their removal from the TS may be appropriate in most cases, relaxations previously granted to individual plants on a plant-specific basis were the result of (1) generic NRC actions, (2) new staff positions that have evolved from technological advancements and operating experience, or (3) resolution of the Owners Groups comments on STS. The NRC staff reviewed generic relaxations contained in STS and found them acceptable because they are consistent with current licensing practices and the Commission's regulations. l The HBR design was also reviewed to determine if the specific design basis and licensing basis i are consistent with the technical basis for the model requirements in STS, and thus provide a j basis for ITS , A significant number of changes to the CTS involved the removal of specific requirements and ,~ detailed information from individual specifications. Such changes have been made to
- requirements and detailed information of the following general Catego ies
Category 1 CTS LCO Applicability changes ( Categori l} , - Category 2 CTS Surveillance Frequency changes (Category 11) . Category 3 CTS LCO revised to address train configuration (Category 111) t Category 4 CTS Allowed outage time extensions (Categories IV & Vil)- Category 5 CTS Action requirements for exiting LCOs are changed (Category V) $ plant memet en...\draf te.. 20 6- revised: noon: August 20, 1997 1: y a
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- Category 6 . CTS surveillance acceptance criteria are changed (Category VI) -
l' L ' Category 7 Elimination of CTS reporting requirements . (Category Vill)
-- Category 8 -- Relaxation of LCO requirement ' (Category IX) j l- The staff has reviewed changes to the CTS in the above categories and concluded that these . I L types of detailed information and specifh requirements are not necessary to ensure the _.
effectiveness of ITS to adequately protect the health and safety of the public bc Muse they do , not affect safe operation of the plant. The TS requirements that remain are consistent with current licensing practices, operating experience, and plant accident and transient analyses, and -i provide reasonable assurance that the public health and safety will be protected. [ F The following discussions address why each of the eight categones of information or specific j' requirements do not need to be included in ITS . i CTS LCO Applicability channes (Category 1) , Reactor c,perating conditions are used in CTS to define when the LCO features are ! required to be operable. CTS applicabilities can be specific defined terms of reactor conditions: hot shutdown, cold shutdown, reactor critical or power operating condition. ~
- Applicabilities can also be more general. Depending on the circumstances, CTS may L require that the LCO be maintained within limits in "all modes" or "any operating mode."
L-Generalized applicability conditions are not contained in STS, therefore iTS eliminate CTS requirements such as 'all mode" or "any operating mode." , - ITS use defined modes or applicable conditions that are consistent with the application of the plant safety analysis assumptions for operability of the required features. _In another
- application of this type of change, CTS requirements may be eliminated during conditions for which the safety function of the specified safety system is met because the feature is F - performing its intended safety function. Deleting applicability requirements that are -
indeterminant or which are inconsistent with application of accident analyses assumptions is acceptable because when LCOs cannot be met, the TS can be satisfied by exiting the applicabilty thus taking the plant out of the conditions that require the safety system to be operable. These changes are consistent with STS. Therefore, deletion of Category 1 requirements _is acceptable. p [ CTS Surveillance Freauency channes _ (Category ll) l CTS and ITS surveillance frequencies specify time interval requirements for performing i surveillance requirement testing. Increasing the time interval between surveillance tests in the ITS results in decreased equipment unavailability due to test which increases . __ equipment availability. In general, the STS contain test frequencies that are consistent with industry practice or industry standards for scheiving acceptable levels of equipment
- reliability. Adopting testing practices specified in the STS is acceptable based on similar-design, like-component testing for the system application and the availability of other TS requirements which provide regular checks to ensure limits are met, c Reduced testing can result in a safety enhancement because the unavailability due to test is reduced; however, reliability of the affected structure, system or component should
- remain constant or increase. Reduced testing is acceptable if operating experience,
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L L L L: industry practice or the industry standards such as manufacturers' recon,mendations P have shown that these components usually pass the Surveillance when performed at the , specifed interval, thus the fregency is acceptable from a reliability standpoint. Altomate train testing is acceptable if there are other qualitative or quantitative test requirements : .
'which are established predictors of system performance, e.g., air flow is an indicator that -
positive pressure in a controlled space will be maintained since a more frequent (31 day)
- air flow test would use the same fans as the less frequent (36 month) pressurization test -
E and experience shows that components usually pass the pressurization test.- i Surveillance frequency extension can be based on' staff approved topical reports._ The l staff can accept topical report changes if the topical report bounds the plant specife i: design and component reliabiltiy assumptions are met. These changes are consistent with STS. Therefore, deletion of Category 2 requirements is acceptable. CTS LCO revised to address train confiouration (Category til) - i Due to the redundancy of trains and the diversity of subsystems, the inoperability of one > component in a train does not render a safety system incapable of performing its intended > !- _ design function. Neither does the inoperability of two different components, each in a different train, necessarily result in a loss of functional capability for a safety system. The intent of STS Conoitions is to control the inventory of the equipment taken credit for in the safety analysis such that a sufficient complement of safety systems is available to perform their intended safety function for analyzed accidents. This allows increased i flexibility in plant operations under circumstances when components in different trains are inoperable; however, fundamental requirements for train separation are required to be met, i Specified STS Actions and Completion Times for trains are based on availability of redundant operable features, reasonable time for repairs, and low probability of a dnign
- basis accident (DBA) occurring during the period features retcain inoperable. In general the STS use industry practice or industry standards for restoring trains to operable status.
l These changes are consistent with STS. Therefore, deletion of Category 3 requirements is acceptable. { CTS Allowed outace time extensiong (Category IV & Vil) Upon discovery of a failure to meet an LCO, STS specify times for completing required actions of the associated TS conditions. Required actions of the associated conditions
- are used to establish remedial measures that must be taken within specified completion 4
times (allowed outage times). These changes are consistent with STS. These times define I: nits during which operation in a degraded condition is permitted.
-Adopting completion times from the STS is acceptable because completion times take
, into account the operability status of the redundant systems of TS required features, the
. capacity and capability of remaining features, a reasonable time for repairs or replacement of required features, and the low probability of a DBA occurring during the
' repair period. These changes are consistent with STS. Therefore, extension of Category 4 allowed outage times is acceptable. j . CTS Action reouirements for exitina LCOs are chanced (Category V)
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, CTS require that, in the event that any of the specifed LCOs are not met, specifed reactor operations shall cease, wotk shall be initiated to correct the conditions so that the ;
specifed limits are met, and no operations which may affect reactivity of the core shall be - ; . . made.1The STS actions are constructed to specify only conditions of required features - . made inoperable. Change to CTS action requirements for exiting LCO applicabilities is -j acceptable because CTS conditions include actions which also apply when some or all -
; required features are inoperable. This change is also acceptable because the Required
- Actions assure that operations that could challenge other TS systems are ceased within
. an appropriate Completion Time. Additionally, making these types of changes is -
acceptable because they place the reactor in a Mode where the specification no longer * , < applies; and these actions provids the same degree of protection required by the 1 applicable safety analyses. These changes are consistent with STS. Therefore, deletion of Category 5 rsquirements is acceptable. CTS surveillance reouirement acceptance critena are chanced (Category VI) CTS require safety systems to be tested and verified operable prior to entering applicable
, conditions. - ITS provide the additonal requirement to verify operablility by actual or test conditions.- Adopting the STS allowance is acceptable because TS required features i i car'not distinguish between an " actual" signal or a " test" signal. Category 6 also includes 4 changes to CTS requirements that are replaced in the ITS with separate and distinct testing requirements which when combined include operatHlity verification of all TS required components for the features specified in the CTS. Adopting this format preference in it.e STS is ecceptable because TS SRs that remain include testing of all previous features required to be verified operable. These changes are consistent with STS. Therefore, deletion of Category 6 requirements is acceptable.
Elimination of CTS reportino reauirements (Category Vill) CTS include requirements to submit Special Reports when specifed limits are not met. , !- Typically, the time period for the report to be issued is within 30 . lays. However, the STS eliminates the TS administrative control requirements for Special Reports and instead r - relies on the reporting requirements govemed by the requirements of 10 CFR 50.73. ITS L changes to reporting requirements are acceptable because special reporting i- requirements do not assure that the plant will operate in a safe manner and there is no _ regulatory basis for the staff to accept or deny the reports it receives. Therefore, this change has no impact on the safe operation of the plant. Additionally, deletion of TS , reporting requirements reduces the administrative burden on the plant and allows efforts l to be concentrated on restoring TS required limits. These changes are consistent with i STS. Therefore, deletion of Category 7 requirements is acceptable. ! Relax 9 tion of LCO reouirement (Category IX) CTS list acceptable devices that may be used to satisfy the LCO requirements. The ITS - reflect the STS approach to provide requirements that specify the protective limit that is required to meet the safety analysis assumptions for operable features in place of
- acceptable mechanisms that are acceptable for meeting the TS limit for the specifed E
- feature. The ITS changes provide the same degree of protection required by the safety L analysis and provide flexibility for meeting limits without adversely affecting operations L since equivalent _ features are required to be operable. These changes are consistent with -
STS. Therefore, deletion of Category 8 requirements is acceptable.
- j. (Ptent Isame) c \...\draf tse.a20 9- revised: 12 noon, August 20, 1997 l
l 1
L
-Table L lists specific CTS requirements that have been deleted and which pertain to the above ,
general types of changes. Table L is organized by ITS section discussion of change and provides -
~
- a summary description of the change, CTS and ITS LCO references, a reference to the specific -
change category as discussed above, and a characterization of the discussion of change. - These eight general categories of CTS requirements that have been deleted from CTS are not required by 10 CFR 50.36 to be in the TS.
-- The licensee, in electir.g to implement the specifications of STS, also proposed a number of requirements less restrictive than those in the CTS and which are not included in the general discussion of change-types.- The most significant of these changes are discussed below, t
Section 1.0
- L.1 The CTS 1.6.2 defines channel calibration to encompass the entire channel and does not exclude resistance temperature devices (RTDs) and thermoccupies. For channels with RTDs and/or thermocouples, the ITS definition of channel calibration allows performing
" an in place qualitative assessment of sensor behavior..." for these devices. This change is a less restrictive requirement for unit operations and is consistent with the STS.
A qualitative assessment of sensor behavior is acceptable for RTDs and thermocouples since the operation of these devices is govemed by well understood and predictable physical reWlonships between the temperature of the sensed medium and the output of the RTD or thermocouple. Additionally, the output of RTDs and thermocouples is the a same manner as other sensors. As a result a qualitative assessment of sensor behavior is sufficient to determine its OPERABILITY and acceptability for continued use. Section 2.0 E none + Section 3.0 L1 CTS 3.0 does not include a provision equivalent to ITS 3.0.5 which allows retuming equipment to service under administrative control, solely to perform testing to demonstrate its OPERABILITY or the OPER ABILITY of other equipment. This is an exception to ITS 3.0.2. It allows certain equipment to be restored to OPERABLE status while continuing to comply with ACTIONS associated with the LCOs, thus avoiding a plant shutdown. This allowance represents a stable, safe attemative to requiring a plant shutdown to complete restoration and confirmatory testing of equipment removed from service or declared inoperable. Because this provision is restricted to activities deemed necessary to restore equipment Operability, it is accepiable. [ L2 CTS 4.0 does not include a provision equivalent to ITS SR 3.0.2, which states, "If a Completion Time requires periodic performance on a "once per..." basis, the above Frequency extension applies to each performance after the initial performance." The purpose of ITS SR 3.0.2 is to allow the "1.25 times the interval specified in the
- Frequency" concept to apply to periodic Completion Times associated with Actions. -This provides consistency in scheduling flexibility for all performances of periodic requirements, whether they are Surveillances or Required Actions. The activity is still
- IPlant bene) c \...\draftse.e20 -
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- - -- . - . . . -.--_.~ _ -..- - - - . - -- - . - - . -
i
- performed, on the average, once during each specified interval. _Therefore, this is an
- l. scoeptable less restrictive change.
Section 3.1 L2 - CTS 3.1.3.3 requires that the reactor be made suberitical by an amount greater than or , equal to the potential reactivity insertion due to depressurization if the Moderator -
- - Temperature Coefficient (MTC) is outside the limits provided in the Core Operating Limit-
- Repof1(COLR). No completion time is stated. CTS 3.0 requires hot shutdown be l'
achieved within 8 hcurs. ITS 3.1.3 Action A.1 requires establishment of administrative withdrawal limits for control banks to mobtain MTC within the upper limit with a completion time of 24 hours if MTC is not within the upper limit. If ITS 3.1.3 Action A.1 is , satisfied, no further action is required. The CTS does not preclude establishment of i administrative withdrawal limits for control banks to maintain MTC within the upper limit. ! However, the completion time of 24 hours allowed by the ITG is less restrictive than the 8 ~ l hours permitted by the CTS. i- If ITS 3.1.3 Action A.1 is not met, ITS 3.1.3 Action B.1 requires being in MODE 2 with K,,
< 1.0 within 6 hours. This completion time is in addition to the 24 hours permitted by ITS 3.1.3 Action A.1 and is less restrictive than the 8 hours permitted by CTS. )
1 (A specific Completion Time for CTS 3.1.3.3 to restore MTC to within the upper limit.)- In , order to place the plant in a non applicable MODE, evaluating the MTC measurement and l obtaining the necessary input to compute the bank withdrawal limits for MTC limit compliance may require a time period longer than 8 hours. The ITS 3.1.3 Action A.1 l completion time of 24 hours provides s:.:fficient time for evaluating the MTC measurement and coroputing the required bank withdrawal limits. Additionally, the 24-hour Completion Time is based on the low probab.lity of an accident occurring during this period and takes into consideration the fact that as cycle bumup is increased, reactor coolant system . (RCS) boron concentration is reduced which causes MTC to become more negative. . This reduces plant *hutdown transients while in a condition where unit response during i postulated events may not be as predicted. The change provides a specific action and completion time for failing to satisfy the LCO. This is an acceptable less restrictive change. L5 CTS 3.1.3.3 requires that the renetor be made subcritical by an amount greater than or l equal to the potential reactivity insertion due to depressurization if the MTC is outside the limits provided in the COLR. No completion time is explicitly stated. CTS 3.0 requires hot shutdown be achieved within 8 hours. ITS 3.1.3 Action C.1 requires being in MODE 4 with a completion time of 12 hours if MTC is not within the lower limit. The completion time allowed by the iTS is greater than the 8 hours permitted by CTS 3.1.3.3. This change allows for a more contrclied shutdown which reduces thermal stress on components and also reduces the chaness for a plant transient which could challenge safety systems. This is an acceptable less restrictive change.- L6 - CTS 3,10.1.5 actions associated with a misaligned rod are required to be taken within 2 hours if the rod position indication requirements of CTS Table 4.1-1 items 9 and 10 are - , not satisfied. The rod position indication instruments do not necessarily relate directly to rod OPERABILITY (e.g., rods aligned within hmits) or the ability to maintain rods within , alignment limits.- Because of th!s, ITS 3.1.7 is added to require the Analog Rod Position 4 : Indication (ARPI) System and the Demand Position Indication System to be OPERABLE (Plant name) c:\..,\draftse.a20 revised: 12 noon, August 20, 1997 pTv ' y +mw y wew,,,=='- ---
.r in MODES 1 and'2 and provide altomate Actions to determine rod position or reduce power to s 50% RTP in the event of inoperable rod position indication. Reducing power to s 50% RTP puts the core into a condition where rod position is not signifcantly
~
affecting core peaking factors. The ITS 3,1.7 Actions are modified by a Note which allows separate Condition entry for each inoperable rod position indicator per group and - ' each demand position indicator per bank. The ITS 3.1.7 Actions and the Completion r Times contained in ITS 1.3 provide copropriate compensatory actions for each inoperable ; oosition indicator. There is a low prodility of having a rod significantly out of position : I and an ovent sensitive to that rod position during the time period allowed to either - implement an altomate method of determinir6g rod position or reducing power to a level
- where rod position does not significantly affect core peaking factors. Any reduction in a margin of safety resulting from the proposed change will be offset by the potential benefit gained by avoiding an unnecessary plant power reduction or shu*down transient when altemate means exist to determine rod position. Tne change eliminates the requirement '
4 to consider rods to be misaligned when rod position indication is inoperable by providing
- an LCO and associated ACTIONS for rod position indication. This is an acceptable less l restrictive change.
l . Section 3.2
' L7 CTS 3.10.2.g allows calibration of the excore detectors if the axial flux difference (AFD) is . :
within the target band for > 90% rated power, and if the AFD does not exceed the lim 5 specified in the COLR for reactor power between 50% and 90% rated power. ITS 3.2.s Applicability Note allows up to 16 hours of operation to be accumulated with AFD outside the target band without penalty deviation time while the excore detectors era being
- calibrated, Soma deviation from the target band is necessary to perform the calibration of
. the excore detectors, m duration that the AFD will be outside the target band for the l. purposes of excore detector calibration is sufficiently low to provide rossonable assurance that the overall effect on the axial peaking factor and axial xenon distribution will not impact the consequences of analyzed accidents. The process of the incore . excore calibratian involves inducing short-term axial power deviations in altemating directions in order to develop a plot of excore detector response. Since the axial power deviations are altemated, the overall effect on axial xenon distribution is small. As such, any reduction in the margin of safety will be insignificant and offset by the benefit of l avoiding an unnecessary change in Thermal Power during the calibration process. Some deviation from the target band is necessary to perform the calibration, and the axial offsets that are used to calibrate the excore detecto s altemate between a plus and , minus axial offset, such that the overall effect is small. This is an acceptable less restrictive change. Section 3.3 l L1 The CTS is revised to adopt the " ALLOWABLE VALUE" column from ISTS Table 3.3.1 1 and Table 3.3.2-1. This limit includes allowances for calibration tolerances, instrument uncertainties, instrument drift, and errors due to severe environmental conditions for RPS and ESFAS channels that must function in a harsh environment. The Allowable Values specified in Table 3.3.1-1 and Table 3.3.21 are conservatively set with respect to the analytical limits, in establishing these allowable values, some have been determined to , be less conservative than the CTS trip setpoint limits. The ITS limits for power range - L neutron flux (high and low), OTAT, OPAT, low pressurizer pressure, and RCS loop low flow result in a less conservative requirement for declaring channels inoperable.
- (Plant name) c \.. A draftse.e20 - 12 - revised
- 12 noon, August 20, 1997 L
,. _ - ~
, , . , _ _ . . . . ,_n-._s. ,,, . ._.. .... ,
L (L I I However, because the actual nominal trip setpoint (operational limit as opposed to the TS limh) is stili more conservative than that specified by the Allowable Value to account for _ , E
- changes in random measurement errors, such as drift during a survelliance interval 1
;these changes are acceptable. Setpoints set in accordance with the Allowable Value ensure that safety limits are not violated during abnormal operational occurrences (AOOs), and that the consequences of design bas 4 accidents (DBAs) will be acceptable,-
providing the unit is operated from within the LCOs at the onset of the ADO or DBA and _ ,
- the equipment functions as designed. The Allowable Values listed in Table 3.3.1 1 is the ;
Limiting Safety System Setting as defined by 10 CFR 50.36. The Allowable Values listed in Table 3.3.1 1 and Table 3.3.21 are conservatively set with respect to the analytical limits, and are based on the methodology described in the company setpoint methodology - , procedure. The magnitudes of uncertainties are factored into the determination of each trip setpoint. All field sensors and signal processing equipment for these channels are assumed to operate within the allowances of these uncertainty magnitudes. This change - . is consistent with STS.
- - L2 CTS 2.3.1.2.d and 2.3.1.2.e set the values of certain OTaT and OPaT parameters as being *=" to specific values. ITS Table 3.3.1 1, Notes 1 and 2, set these same ,
parameters as being either "r.' or "s' specific values. This is a relaxation of current TS requirements, and is less restrictive in that the ITS specifies a range of values, not
- previously permitted, as meeting TS requirements. This change is acceptable, however, because these parameter settings only permit the use of a more conservative setpoint in the plant hardware. Although these parameters normally do not change, they are cycle-
! specific and may change from time to time as a result of evaluations performed in the review of refueling safety analyses. This change is consistent with STS. ! L7 The CTS is revised to odopt STS Specification 3.3.1, Required Action D.2.2 " Note." CTS Table 3.5 2, Action 2, requires that the Quadrant Power Tilt Ratio (QPTR) b3 monitored
- every 12 hoursc This is required when Nuclear Flux Power Range channels are inoperable but only if thermal power is not restricted to less than 75% RTP and the Power Range Neutron Flux channel setpoints are not reduced to less than or equal to 85% of RTP within 4 hours. The ITS Required Action D.2.2 Note requires only that the QPTR surveillance be performed when the Power Range Neutron Flux QPTR input is inoperable. This is a relaxation of CTS remedial actions for TS requirements, and is less l' restrictive. This change is acceptable because failure of a component in the Power 4 Range Neutron Flux channel which does not render the High Flux Trip Function inoperable does not affect QPTR monitoring capability.- As such, performing the CTS surveillance using the movable incore detectors, when the Power Range Neutron Flux 4 - input is operable, is unnecessary. Therefore, the SR can be eliminated. This change is
!= consistent with STS. Lg The CTS is revised to adopt STS Specification 3.3.1 Required Action G in the ITS. The CTS has no specific action requirements in the event two intermediate
- 1. Range Neutron Flux channels become inoperable when the unit is operating at a Thermal power >P-6 and <P-10. CTS Section 3.0 would therefore be entered, j requiring the unit to be in hot shutdown in 8 hours and in cold shutdown within the next 30 hours or the reactor placed in a non-applicable Mode or conden.
STS Required Action G requires, under these conditions, that operations ' involving positive reactivity additions be suspended immediately, and Thermal [ Plant Name) c \ ..\draf tee.a20 -- 13 - revised: 12 noon, August 20, 1997 4 8 . 7
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power be reduced to <P4 in 2 hours (i.e., placing the plant in a non-applicable . condition). P910w P4, STS Required Action H.1 requires restoration of two inoperable Intermediate Range Neutron Flux channels prior to increasing power t
- above the P4 interlock. This change is acceptable, however, because with no -
intermediate range channels Operable, Required Action G.1 is added to ' . immediately suspend operations involving positive reactivity additions. This will preclude any power level increase when the ability to monitor neutron flux is not available (above the P4 setpoint and below the P-10 setpoint, the intermediate - range performs the routron flux monitoring function). Power must also be reduced below the P4 setpoint within 2 hours (Required Action G.2). Below P-6, the Source Range Neutron Flux channels (STS Table 3.3.1-1 Function 4) are . ! required to be Operable and will be able to monitor neutron flux. Therefore, since adequate neutron flux monitoring capability and trip capability is provided ._ i by the Source Range Neutron Flux channels and positive reactivity additions are l required to be suspended, it is not necessary to require a plant shutdown in i j accordance with CTS 3.0. This change is consistent with STS. L27 CTS Table 4.1 1 requires that the power operated relief valve (PORV) Position Indication, ! PORV Bloci Valve Position Indicator, and Safety Relici Valve Position inoicator, Containment Level, Pressure, Hydrogen and Radiation Monitors be tested at an "R" frequency. ITS Specification 3.3.3 has no such requirement. This is a relaxation of requirements and is less restrictive. This change is acceptable, however, because a ! channel calibration is p arformed on these channels at an 18-month frequency. The channel calibration encompasses all the testing requirements for these Functions, from sensor to indicator, and provides reasonable assurane that the entire channel is
- operable. This change is consistent with STS. j l
- L30 CTS 3.5.1 is revised to adopt the STC Specification 3.3.5 " Note
- to Required Action B.1 in l l
the ITS. The Note permits an inoperable Degraded Voltage Function channel to be ! bypassed for up to 4 hours for surveillance testing of other channels. Adoption of this ) l Note is a relaxation of requirements, and is therefore less restrictive. This change is l acceptable, however, because there are three Degraded Voltage channels per bus, and - l L this allowance is given where bypassing the channel does not cause an actuation, and i where at least two other channels per bus are monitoring the parameter. The Degraded
. Voltage Function is arranged in a two-out-of three configuration. Bypassing one channel l would still p ovide a two-out-of-two logic. The time allowed is reasonable, considering the
+
- Function remains fully operable on each bus and the low probability of an event occurring l during the interval. This change is consistent with STS.
! L32 CTS Table 3.4-1, Function 1, requires under certain channel inoperability conditions that 2 the unit be maintained in hot shutdown. ITS 3.3.8, Required Action B, requires under-similar conditions, that the inoperable channel be placed in tr!p la 6 hours, or be in Mode 3 in 12 hours, and MODE 4 in 18 hours. This is a relaxation of requirements, and is less i restrictive. This change is acceptable, however, because placing the inoperable channel
-in trip maintains the AFW pump autostart Function Operable, but in a one-out-of-two 4
- - configuration,'instead of two-out-of-three. The allowance of 6 hours to retum the channel i
to operable status or place it in trip is consistent with WCAP-10271 P-A, Supplement 2, Rev.1, June 1990. This change is consistent with STS. L L (Plant name) c \...\draf tse.a20 - 14 - revised: 12 noon, tuss t A , 1997 i-i
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ll
; As required by the staff Safety Evaluation (dated April 30,1990) accepting the generic; '
reliability analysis in WCAP 10271 P A, Supplement 2, Rev.1, CP&L has confirmed that - L ' the HBR logic design of the affected instrumentation is bounded by that analyzed in the - re: lability analysis and the conclusions are applicable to the HBR design. In addition, CP&L has confirmed that the instrument drift due to extended Surveillance Frequencies, 1
- associated with appi: cation of the generic reliability analysis to the HBR instrumentation,- .
is already property accounted for in the setpoint calculation methodology. . l L36 CTS Table 3.5 2 Action 3 requires for an inoperable intermediate range neutron flux : channel with thermal power above the P 6 setpoint, but below 10% RTP, that the inoperable channel be restored to operable status prior to increasing thermal power E above 10% RTP. ITS 3.3.1 Required Action F requires for an inoperable intermediate . range neutron flux c.hannel with thermal power above the P 6 setpoint, but below the P 10 ;
- setpoint, that thermal power either be reduced to below P4 cr necreased above P-10 in 2 i hours.- The intermediate range neutron flux channels must be operable when the power ,
levelis above the capability of the source range and be!ow the capability of the power , range, The CTS does not permit an increase in power level to exit the Applicability of the intermediate range detectors. The required action to increase thermal power to exit the ; Applicability for the intermediate range detectors is less restrictive. The change is . - acceptable since the intermediate range detectors are not required to be operable above P 10 setpoint, and power range instrumentation provides the necessary protection above
- P 10 and this allowance represents exiting the LCO Applicability. This change is consistent with STS.
L41 This change adds a Note to the calibraoon requirement in CTS Table 4.1 1 for items 1,2, l l and 3 (Nuclear Power Range, Nuclear intermediate Range, and Nuclec 3ource Range) , excluding the neutron detectors from this Surveillance (ITS SR 3.3.1.11). The channel calibration is a complete check of the instrument loop and the sensor. The test verifies that the channel responds to the measured parameter within the necessary range and c': curacy. The neutron detectors are excluded from the channel calibration because they ) are passive devices, with minimal drift, and because of the difficulty of simulating a j meaningful signal. This change is consistent with industry practice and with STS.
. L50 GTS Table 3 5-3 does not address the condition of all channels of an ESFAS Instrumentation Function inoperable or a train of ESFAS instrumentation inoperable. Due to the plant design, maintenance or surveillance testing of a single channel can r.ot be '
- performed without causing all channels of the associated Function to be inoperable. In many cases, maintenance or surveillance testing will also cause the associated train to be inoperable. Therefore, ITS 3.3.2 Required Actions Note 2 is adopted to permit a
- single ESFAS instrumentation train to be inoperable fer the purpose of maintenance or surveillance testing for up to 12 hours provided the other train is Operable. The Note also specifies that the provision does not apply to manual actuation Functions, h turrently, all Functions of an associated ESFAS train are tested at one time, The .
precedure for performing testing does not result in the entire train being made inoperable.
' However, each of the Functions within an ESFAS train are made inoperable for short
- -- periods of time until testing of all channels of the associated ESFAS train is completed.
- Repetit:ye action entry and exit during testing of ti,e associated ESFAS train, on a rst Function basis; represents an unnecessary administrative burden on the plant operations staff and would result in extending the time period required to complete the testing.
revised: 12 noon, August 20, 1997 (Ptent asene) c:\...\draf tee.e20 - _ 7
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.Therefore, s' single time period is provided to cover all testing of the associated ESFAS !
train._ ; he repair or reflecement of Engineered Safeguard System relays and/or test switches, ! 12 hours nm. in in determined to be a reasonable Completion Time for restoration of the ;
; two most frequently occuning types of failures that occur in the HBR Engineered Safeguards System. These two failures are 1) failure of a logic or actuation relay, and 2)~
a- failure of the test switches used for the perforraance of the survei0ance testiv A failure
- of enhor of these items only r,auses one portion of the Engineered Safeguards System to -
$ . be Inoperable, but due to the wiring configuration of the system (the common side of the ' ,
relay power source is " daisy chained" together) the entire train must be considered inoperable once maintenance on the failed item has commenced .- In addition with the , test switches in " test" during surveillance testing, all channels in an ESFAS - t' Instrumentation FuocGon are rendered inoperable. L _ _ - -
; - The change to provide 12 hours for the performance maintenance or surveillance testing :
' on an ESFAS instrumentation train is acceptable based on the other ESFAS
! instrumentation train that is available to perform the actuation function and the low .
- probability of an event requiring an ESFAS actuation. In addition, the change provides
- the potential benefit of the avoidance of a plant shutdown tran= lent by providing a time period to perform required surveillance testing or necessary malatenance prior to ;
c requiring a plant shutdown. Section 3.4 L1 ITS 3.4.5
- Note," ITS 3.4.6 " Note 1," and ITS 3.4.7 " Note 1' permit all reactor coolant pumps (RCPs) or residual heat removal (RHR) pumps to be de-energized for up to i tout in any 8-hour period to permit tests designed to validate various accident analyses values. This exception is not addressed in the CTS. This change is acceptable, .
however, because such an operation would be performed as part of a special test, and be contsolled under close scrutiny by shift operating personnel, in addition, the allowances ' i of the Notes may only he used if no operations which could cause a reduction of RCS i boron concentration are being performed, core outlet temperature is maintained at least l 10 degrees F below saturation temperature, and for ITS 3 4.5 and 3.4.6 measures are - taken to preclude a power excursion resulting from an inadvertent control rod withdrawal event (the Rod Control System is incapable of rod withdrawal). Industry operating ' ! experience has shown boron stratification is not a problem during a 1-hour period with no i' forced flow and netwal circulation in conjunction with the core outlet temperature restriction discussed above ensure the core remains adequately cooled. - For the above reasons this change is acceptable. L4 CTS 3.3.1,4.b requires thtt, if both _RHR loops become inoperable, all containment f- penetrations providing direct access from the containment atmosphere to the outside o atmosphere be closed prior to the RCS average temperature exceeding 200*F. Thib l requicament is not retained in ITS 3.4.7 and 3.4.8. This is a relaxation of requirements, -
- and is less restrictive, This change is acceptable because ITS 3.4,7 and 3.4.8, unlike the L CTS, rsquire action be initiated immediately to restore one RHR train to OPERABLE status and operation. Further, to proc!ude any change in the shutdown margin and in tum any increased possibility of a radioactive release, the ITS suspends all operations invosving the reduction in RCS boron concentration.
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1
-L5 LThe CTS is revised to adopt ITS 3.4.7 ' Note 2,* and ITS 3.4.8 " Notes 1 and 2." ITS 3.4.8 .
Note 1 permits all RHR puraps to be de-energized for up to 15 minutes when switching ~- i from one train to another or to perform testing of the RHR loop supply valves. Note 2 _ allows one RHR train to be inoperable and doenergized (for ITS 3.4.7 Note 2) for a per6od - of up to 2 hours. These are relaxations of requirements because CTS does not contain l these exceptions, and they are therei.we less restrictive. The changes are acceptable, however, because the circumstances for stopping both RHR pumps are limited to situations when the outage time is short and core outlet temperature is maintained > 10*F L - r below saturation temperature. Boron dilution and draining operations are prohibited when - RHR forced flow is stopped thus reducing risk of boron stratification. An RNR train is only permitted to be inoperable for a period of 2 hours provided the other train is OPERABLE. k- Additionally, these exceptions provide the added safety benefit of permitting periodic
- surveillance tests to be performed on the inoperable train during the only time when these tests are safe and possible,
. -L6 CTS 3.3.1.4 requires that both RHR loops be OPERABLE in the cold shutdown condition. [
- ITS 3.4.7 requires, when in MODE 5 with the RCS loops filled, that either both RHR trains be OPERABLE and one in operation, or one RHR train OPERABLE and in operation and ;
one SG be OPERABLE. This change is less restrictive because both trains of RHR are >
- not required to be OPERABLE at all times during MODE 5. This change is acceptable,
- however, because in either ITS configuration (as in the CTS), redundant decay heat -
- removal systems are required to be OPERABLE and available for use.
L7 CTS 3.1.1.3.c.1 requires that pressurizer code safety valve lift settings be between 2485
- psig and 2560 psig. ITS 3,4.10 requires that safety valve lift settings be between 2410 psig and 2560 psig. This is a relaxation of requirements and is less restrictive. This .
change is acceptable, however, since the same level of overpressure protection is i provided, The wider OPERABILITY range of 2485 psig i 3% allows for drift during valve i setpoint test intervals, as permitted by Section 111 of the ASME Code. During setpoint l testing, the valves are reset to 2485 psig i 1%, as required by Section XI of the ASME F Code. L8 CTS 3.3.1,3 requires that the safety injection (SI) pump breakers be racked out whe,1 RCS temperature is below 350'F and the system is not vented to containment
- - atmosphere. ITS 3.4.12.a.2 requires all but one Si pump be made incapable of injecting i into the RCS when the RCS temperature is a 175'F. This is a relaxation of requirements, and is less restrictive. This change is acceptable based on a new overpressure ?
protection analysis performed to allow OPERABILITY of one train of Si in MODE 4. The analysis assumes one SI pump capable of injection into the RCS with RCS temperature a 175'F and < 350'F, _ L9 Not Used. [L DOC Matrix includes L.9 as in the "none" category. O L12- CTS 3.1.5.4.b requires that, with leakage from any pressure isolation valve (PlV) not -
- within limits, operation may continue provided at least two. valves are confirmed to be in, j and romain in, the position corresponding to the isolated condition. ITS 3.4.14 requires isolation of the high pressure line by a single valve within 4 hours, followed with isolation of the line by a second valve within 72 hours._ This is a relaxation of requirements and is =
less restrictive.- This change is acceptable, nowever, because although the CTS requires L both valves to be closed essentially simultaneously, it does not specify a completion time '
- limit for the required actions; The extended interval is also acceptable because it is
- (Hent name cis...\drette.. 20 ' -
tr . revised: 12 noon, Aueust 20, 1997 j
&x
L I based on the time usually required to perform this action and considers the low probability; - I- of another valve failing during this period.
. L13: CTS Table 4.13, item 17.1, requires PlV leakage be verified prior to entering reactor-
!- operation whenever the unit has been in cold shutdown for 72 hours. ITS 3.4,14 requires
' PlV leakage be verified w.,enever the unit has been in MODE 5 for 7 days or more.- Since '
j the result of this change is a not reduction in the number of times PlV leakage verifcation J will be required over the remaining life of the plant, it is a relaxation of requirements and is less restrictive. This change is acceptable, however, since PlV leakage verification is
- performed routinely at an 18-month frequency, and historical leakage verification experience has shown the PlVs usucIly pass the surveillances when performed at that
. frequency; Further, any maintenance performed on a PlV while the plant is in cold
- shutdown for any length of time is required to be followed up with the appropriate post :
maintenance testing Consequently, extending the shutdown period for which the testing exception will apply should have little impact on safety . . L17- CTS 3.3.1.4.a requires, in the event of an inoperable RHR loop, the existence of a method to add make up water to the RCS be vertfied within 24 hours, and the inoperable 1 RHR loop be restored to operable status within 14 days. ITS 3.4.7 and 3.4.8 each require r
- action be initiated immediately to restore a second RHR train to operable status. This 4- change imposes lose restrictive requirements because in the ITS there are no time
! requirements within which the inoperable RHR train is to be restored nor are there any requirements to verify a method to add make-up water. These changes are acceptable because while the specific action times are removed, an immediate completion time is added. As discussed in ITO 1.3, when an "Immediately" is used as a Completion Time, i the Required Action should be pursued without delay and in a controlled manner. The
, substitution of a requirement that results in immediate action in place of two requirements ,
which would allow action to be delayed for hours and days, respectively, has been determined to provide an acceptable level of safety. ! L20 The CTS is modified by the addition of ITS 3.4.17, Required Actions D.1, D.2, and D.3 to require that in the event that seal injection to any RCP is not within limits and both required charging pumps are inoperable, then the plant must be cooled down and depressurized to an RCS pressure < 1400 psig. No comparable action is contained in the CTS. In such a condition, the CTS would require entry into CTS 3.0 which requires that
- the plant be placed in hot shutdown within 8 hours and in cold shutdown within an F auditional 30 hours. Therefore, the ITS requirement to reduce reactor pressure to below 1400 psig is a less restrictive requirement. The changes, however, are acceptable.
j Depressurizing the reactor to < 1400 psig would allow the Si pumps to perform the RCS
- makeup function during the repair period to restore charging pumps to operable status.
With RCS inventory controlled in such a manner, there would not be a rK:ed to proceed to a shutdown mode. If at anytime, seal failure (s) increased plant leakage above the limit of ITS 3.4.13 "RCS operational LEAKAGE," then the failure to comply with these limits would require the plant to be placed in cold shutdown in a time period consistant with
, CTS requirements, thereby assuring adequate protection of public health and safety.
L21 CTS 3.2,2.d requires system piping, instrumentation, controls, and valves be operable to i the extent of establishing one flow path from the BASTS and one flow path from the RWST to the RCS. That is modified in ITS 3.4.17 to require two operable Makeup Water 4 Pathways from the RWST. This change is acceptable because it assures that there are -
- two pathways available from the RWST to the charging pump suction header, each of IPtent namel c \...\draf tse a20 revised: 12 noon, August 20, 1997
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'which provides an adequate source of makeup for RCP sealinjection. Further, removal
. of the requirements for one flow path from the BASTS is acceptable because, boration - ,
flow paths are not required to prevent or mitigate the consequences of my accident - analyzed as part of the plant design basis, i i: L24 - CTS Table 4.13 item 17.2 requires, whenever the integrity of a RCS pressure isolation ! valve cannot be demonstrated, the integrity of the remaining valve to be determined and recorded daily, in this condition, CTS Table 4.1.3 item 17.2 also requires that the position - ! Of the other closed valve located in the high pressure piping to be recorded daily. Under .i e~ this same condition, ITS 3.4.14, RCS Pressure Isolation Valves (PlVs), Required Actica - ' A.1 and A.2 require isolation of the high pressure portion of the piping from the low pressure portion of the piping by the use of two valves.- In addition, ITS 3.4.14 Required Actions A.1 and A.2 are modified by a Note that requires the valves used to meet the requirements of Required Actions A.1 and A.2 to satisfy the leakage criteria of SR 3.4.14.1 (i.e., integrity determined to be acceptable) and that the valves be in the reactor . coolant pressure boundary or high pressure portion of the piping. This is less restrictive ! because the ITS does not require daily determinations and recordings of valve integrity. !- However, this change is acceptable because with two valves providing the isolation the 1 ncrmal periodic surveillance frequency (ITS SR 3.4.14.1) for RCS PlV leakage testing i 3
, provides adequate assurance of PlV OPERABILITY, While during the surveillance _
Interval it would be possible that both valves could lose the!r integrity, that is very unlikely, i if the Surveillance is not performed within the normal surveillance interval, compliance - with the requirements of the Note to Required Actions A.1 and A.2 would not be satisfied for these valves and a shutdown per Required Actions C.1 and C.2 would be required (i.e., action taken to exit the Applicability of the LCO). If at any time it is discovered that , the valves used to comply with Required Actions A.1 and A.2 did not satisfy the ! requirements of SR 3.4.14.1, Condition C must be immediately entered and Required
~ Actions C.1 and C.2 taken. .
Section 3.5 L3- CTS 4.5.1.1 requires the Si System tests be performed in such a manner to prevent i injection into the reactor coolant system. This requirement is not retained in the ITS. It is expected future testing will be consistent with current methodology which does not result
. In actual injection. Testing which results in actual injection is acceptable since the test 4
would still demonstrate acceptaolo system operation. This change is consistent with the , STS, != L4 CTS 4.5.1.2 specifies certain details regarding test method (e.g., control board indications and visual observation, proper sequence and timing, etc.) regarding acceptable SI System test results. These test method details are not retained in ITS. The ITS-specified . verification of pump starts and valve actuations is sufficient to demonstrate , j OPERABILITY, This change allows increased flexibility in testing methodology while still
- requiring verification of OPERABILITY, This change is consistent with STS.
.. L5 CTS 4.5.2.1 mandates a test method for the verification of the specified valve positions.
Specifically, this specification requires verification ". . . from the RTGB indicators / controls
. . . that the specified valves are in the proper position with control power removed. This - .
test method detailis not retained in ITS. The ITS SR 3.5.2.1 specified verification that the valves are in their proper position with control power removed is sufficient to demonstrate OPERABILITY. This change allows increased flexibility in testing l~ (N ant Name) c \...\ draftee.e20' i 19 - revised: 12 noon, August 20, 1997 1 V { ~
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p - 1 [ , i methodology while still requiring verification of OPERABILITY. This change is consistent i with the STS. L6 In Hot Shutdown, CTS 3.3.1.3 imp. ' s requirements for ECCS in accordance with CTS I
- 3.3.1.1 and 3.3.1.2. CTS 3.3.1.1 requires two ECCS trains to t;e operable. CTS 3.3,1.2 permits one ECCS component (81 pump, RHR pump, RHR heat exchanger) to be :
inoperable for up to 24 hours. With less than or,e ECCS train OPERABLE, no specific ,
- ; action is provided in this condition, entry into CTS 3.0 is required, CTS 3.0 requires the unit be placed in Cold Shutdown within 30 hours. - ITS 3.5.3 requires only one ECCS train - ;
to be OPERABLE in MODE 4. With the required ECCS RHR subsystem inoperable, ITS - 3.5.3 Required Action A.1 requires action be initiated immediately to restore one required L ECCS RHR subsystem to OPERABLE status; This change is c:,nsistent with the STS.' Due to the stable conditions associated with operation in MODE 4 and the reduced , probability of occurrence of a DBA, the ECCS operational requirements are reduced. With both RHR pumps and heat exchangers inoperable, it would be unwise to require the
= plant to go to MODE 5, where the only available heat removal system is the RHR.
i . Therefore, the appropriate action is to initiate measures to restore one ECCS RHR subsystem and to continue the actions until the subsystem is restored to OPERABLE-status. L7 ' With the RWST boron concentration not within limits, CTS-required action is specified in
- 3.0. CTS 3.0 requires achieving hot shutdown within 8 hours, followed by cold shutdown within an additional 30 hours. ITS 3.5.4 Required Action A.1 permits 8 hours to restore the RWST to OPERABLE status. With Required Action A.1 and its associated
- completion time not met, ITS Required Actions C.1 and C.2 require achieving MODE 3 within 6 hours, and MODE 5 within 36 hours.
The 8 hours to restore the boron concentration to within limits is acceptable based upon consideration Of the time required to change the boron concentration and the fact that the , contents of the tank are still available for injection. Permitting prompt corrective action to i restore the boron concentration to within limits is preferable to requiring immediate plant shutdown, with the increased risk for a plant transient. This change is consistent with the STSi l L8 - A CTS provision comparable to the Note to the Applicability of ITS Specification 3.5.2 does not exist. This ITS Note permits one ECCS train to be inoperable for up to four hours after entry into MODE 3 or until the RCS cold leg temperatures exceed 375'F, - . whichever comes first. Operation in MODE 3 with one ECCS train declared inoperable pursuant to LCO 3.4.12, " Low Temperature Overpressure Protection (LTOP) System,'is r necessary for plants with an LTOP arming temperature at or near the MODE 3 boundary
- temperature of 350'F, LCO 3.4,12 requires that certain pumps be rendered inoperable at
. and below the LTOP arming temperature. When this temperature is at or near the MODE 3 boundary temperature, time is needed to restore the inoperable pumps to i
OPERABLE statusi This Note permits entry into MODE 3 without first meeting the LCO requirements. The limitations imposed on duration and cold leg temperatures are i
- bounded by the 72 hours permitted by ITS 3.5.2 Required Action A.1 for or e ECCS train
, being inoperable when in MODES 1,2 and 3. This change is consistent with the STS. Section 3.6: p
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.t L1: CTS 3.6.1.c and d contain unique requirements.
CTS 3.6.1.c limits positive reactivity changes by rod drive motion when containment
; integrity is not intact except during specified evolutions. During the specified evolutions _ i SDM is limited to a 1% 6Wk. CTS 3.6.1.d limits positive reactive changes made by boron
- dilution when conisinment integrity is not intact. The limitations are not retained in ITS.
= ITS 3.1.1 directly limits SDM and ITS 3.9.1 directly limits SDM by imposing a limit on ~ >
boron concentration independent of containment status. Limiting positive reactivity ' changes which do not challenge the required SDM is unnecessary, since the specified SDMs are the minimum values assumed in the applicable safety analysis. This less
. restrictive change eliminates unnecessary restrictions on plant operation and is acceptable.
1 L2 CTS requirements comparable to ITS 3.6.3 ACTION Note 1 do not exist. ITS 3.6.3 ACTION Note 1 permits an INOPERABLE penetration flow path to be unisolated
- intermittently under administrative control. This is a less restrictive requirement upon n plant operation. Permitting intermittent unisolation of an inoperable penetration under
= administrative control may be required in order to meet other Surveillance Requirements, !
and the Note is not intended to allow circunivention of the Completion Times. An-- *
, example of when the capabilities afforded by this Note may be utilized is temporarily unisolating a sample flow path to acquire a required sample. -
i L6 CTS 3.3.2.2.a permits a containment cooler or flow path to be inoperable provided both containment spray pumps are OPERABLE. This restriction regarding OPERAEH.lTY of the two containment spray pumps is not retained provided the four containment coolers
- are OPERABLE. This restriction regarding OPERABILITY of the four containment coolers is not retained in iTS.- ITS 3.6.6 R.A A.1 and R.A C.1 permit a containment cooling unit associated with the same train to be inoperable simultaneously without F regard to other systems OPERABILITY, These are less restrictive requirements upon
- plant operation.
The combination of ITS Condition A and Condition C is bounded by failure of a single 2 emergency diesel generator (EDG). A failure of a single EDG results in loss of one containment spray train and one containment cooling train. ITS Condition A and Condition C are both predicted upon a short term relaxation of the single failure criteria (i.e., for the duration of the Completion Time of the applicable ACTION, no additional' single failure is assumed). One containment spray train in combination with one train of containment cooling provides sufficient heat removal capacity to maintain containment l peak pressure and temperature below the design limits. Additionally, the iodine removal f capability remains consistent with the assumptions of the accident analysis. The
- individual Completion Times were developert taking into account the redundant heat removal capabilities afforded by combinations of the Containment Spray System and Containment Cooling System and the low probability of DBA occurring during this period.
- '- Section 3.7-
- L1- CTS 3A.1.a requires 12 main steam safety valves (MSSVs) OPERABLE. ITS 3.7.1 i requires MSSVs OPERABLE as specified in ITS Tables 3.7.1 1 and 3.7.12. -Table 3.7.1-1 permits fewer MSSVs to be OPERABLE at reduced power levels. This is a relaxation
- of CTS requirements which is less restrictive. This change is acceptable, however, because Section 111 of the American Society of Mechanical Enginects (ASME) Boiler and (Plant Namel c \...\draf tee.a20 -
21 - revised: 12 noon, Auevet 20, 1997 l 4 W - - ow.w,, -- - -
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' Pressure Vessel Code permits operation with fewer than 12 MSSVs OPERABLE as long as THERMAL POWER is limited to the relief capacity of the MSSVs remaining .-
OPERABLE. This is accomplished by restricting THERMAL POWER so the_ energy . 1 transfer to the most limiting steam generator is not greater than the available relief
" capacity in that steam generator. Such limitations are specified in ITS Table 3.7.1 1.
U2 I CTS 3.4.1 requires the plant to be shut down if the requirements for OPERABILITY of the - MSSVs are not met within 24 hours. A Note to ITS Action 3.7.1 is added that allows-l- separate condition entry for each MSSV.- Since the CTS has no provision to increase the " l allowed outage time when one MSSV becomes inoperable after another, this change is less restrictive. This change is acceptable because ITS 3.7.1 Required Action A.1 allows l only 4 hours for THERMAL POWER reductions to maintain the steam generator stored energy below the available relief capacity. Separate condition entry for each inoperable MSSV is necessary to allow the use -)f ITS Table 3 7.12 and allows the orderly adjustment of THERMAL POWER infesponse to the Required Actions. LS . ITS 3.7.4 Required Action E.1 and Note include requirements for three inoperable AFW
- pumps or four inoperable AFW flow paths. CTS 3.4.5 has no specific required action to address the inoperability of all three AFW pumps and essential features._ Hence, those conditions would result in entry into CTS 3.0 and the required action is to place the plant in hot shutdown in 8 hours and cold shutdown within an additional 30 hours. Because the .
- addition of ITS 3.7.4 Required Action E.1 allows continued operation until at least one pump and flow path of AFW is restored to OPERABLE status, this change is less restrictive. This change is acceptable, however, because it is appropriate to restore at least one pump and flow path of AFW to OPERABLE before placing the unit in conditions
- where AFW is required to provide inventory to the steam generators.
. L12- The CTS 3.15.2.b requirement suspending any operation which would reduce shutdown margin to less than required for cold shutdown or refueling is not retained in the ITS. This
- is a relaxation of requirements, which is less restrictive. This change is acceptable, however, because ITS 3.7.10 is applicable specifically during the times during cold shutdown or refueling (CORE ALTERATIONS and movement of fuel assemblies) where radioactive releases could potentially occur. Those activities are suspended if both trains of control room emergency air temperature control are inoperable, thereby this eliminates l any activities that could result in a release of radioactivity that might enter the control room.
Section 3.8 3.8,6 L7 CTS Surveillance Requirement 4.6.3.3 requires an annual equalization charge of each battery. This requirement is not retained in the ITS. An equalization charge is a special-g charge given a battery when non-uniformity in voltage or specific cravity has developed between cells. It is given to restore all cells to a fully charged condition using a charging voltage higher than the normal float voltage. Therefore, it is inappropriate to mandate an equalization charge at a set frequency.. The ITS SRs provide appropriate verification of
- battery parameters. When the need for an equalization charge is indicated by battery parameters, an equalization charge is utilized to restore all cells to a fully charged condition. This is controlled by plant procedures, but required to keep the cells above the
- (Plant Name} c \...\draf tse.a20 - 22
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Category A limits. Deleting the required annual equalizing charge on each battery is a less restrictive requirement upon plant operation, consistent with the STS. L8 CTS Surveillance Requirement 4.6.1.5 requires testing the DG with a load between 2650 kW and 2750 kW (110% of continuous load rating) for two hours of the 24-hour loaded run test. ITS SR 3.8.11 requires this load be maintained for 21.75 hours of the 24 hour loaded run test. The 2 hour duration specified in CTS Surveillance Requirement 4.6.1.5 cannot be exceeded in any 24-hour period. The ITS test duration of a 1.75 hours confirms the DG OPERABILITY without exceeding the DG rating. The actual DG load during an accident will exceed the continuous load rating of 2500 kW for a period less than the specified test interval of 1.75 hours. This less restrictive change upon plant operation is consistent with the DG design requirements and increases safety. Table 3.8.9-4 L9 CTS Table 4.13, item 18, requires testing the magnetic and thermal trip elements for the molded case circuit breakers supplying the automatic bus transfer (ABT) device associated with Auxiliary Feedwater header discharge valve to steam generator A, V2-16A, and Turbine Building Cooling Water isolation valve, V6-16C. ITS SR 3.8.9.2 requires verifying the trip capability (magnetic only) for both of these breakers. Circuit breakers with a higher current interrupt capability and no thermal trip have replaced the original circuit breakers. A circuit thermal protection device is provided at the motor contetor. Elimination of the testing of these thermal trip elements reflects the current plant configuration and is a less restrictive requirement upon plant operation. Sectio , :.9 none Section 4.0 L.1 CTS Specification 5.3.1.1 is revised by adopting the STS Specification 4.2,1 allowances for limited substitutions of filler rods end limited use of lead test assemblies in the ITS. This is relaxation of requirements and is less restrictive. This change is acceptable, however, because it provides specific recognition that reconstitution of a fuel assembly to replace damaged and leaking fuel rods is not considered to be an unreviewed safety question if the repaired fuel assembly constitutes a previously approved design. This change will not result in modifications to fuel assemblies that would have a significant effect on safety because of the necessity to justify such changes using an NRC-approved methodology. This requirement will confirm (a) conformance to existing design limits, and (b) that safety analyses criteria are met before operation dunng the next fuel r ycle. This change provides flexibility for improved fuel performance and is consistent #A1 Supplement i to Generic Letter 90-02, and STS. CTS Section 5.0 5.2.2 L1 CTS 6.2.3f, which requires that an inoividual qualified in radiation protection procedures be on site when there is fuel in the reactor, is revised in ITS 5.2.2d to add a sentence which permits this position to be vacant for up to 2 hours to provide for unexpected (Plant Namel c \...\draf tse.a20 23 - revised: 12 noon, August 20, 1997
1: - absences.- This is a less restrictive requirement that is realistic since unexpected- . b absences can, and do, occur. This change considers the unlikelihood of a radiological'. ? L occurrence during the perled of absence, and the added provision of ITS 5.2.2d requiring ,
. immediate action to fill the vacant position. This change is consistent with_the STS.
L2 CTS 6.2.3h, which allows the operating shift complement to be one less than minimum - ~;
-requirement for up to 2 hours, is revised in ITS 5.2.2c to delete the word 'one.' This allowance for the absence of more than 'one' shift crew member is a less restrictive l requirements tha' is realistic since unexpected absences can, and do, occur. -The impact i
of the change is t ist it raises the threshold for reporting a less than-full-complement c condition as a violation of the ITS requirements. This change requires immediate action to fill the vacant position, and does not negate the requirement that such a condition shall-not exceed 2 hours.. Additionally, Footnote 1 to the Minimum Staffing Table in 10 CFR 50.54(m) permits temporary deviations from the required staffing numbers as established l in the unit's Technical Specifications. This change is consistent with the STS.
- L3 CTS 6.3.2 requires the " Manager Operations"_ to hold, or have held, an SRO license, -
and, the " Manager- Shift Operations" to hold an SRO license. ITS 5.2.2f requires either , the " Operations Manager" or the " Superintendent in charge of the operations shift crews" hold an SRO license. The Superintendent in charge of the shift crews is an off shift manager reporting to the Operations Manager who can be delegated the Operations
- Manager duties. This is a less restrictive requirement.10 CFR 55 requires that an 4_ individua! directing the licensed activities of licensed operators hold an SRO license. The
- on shift Superintendent Shift Operations (SSO), who is in command of the control room, meets this requirement. This change does not impact safety and is consistent with the 1
STS.- Section 5.3 L4 CTS 6.3.3 requires the manager of the radiation protection function meet or exceed the qualifications of Regulatory Guide 1.8, September 1975. ITS 5.3.1 requires that the manager of the radiation protection function meet or exceed the minimum qualifications of ANSI /ANS 3.1 1981. In addition to other requirements, Regulatory Guide 1.8 specifies
- - that this individual have at least 5 years experience in applied radiation protection, while
- ANSI /ANS 3.1 1981 requires only 4 years of such experience. This is a less restrictive requirement. An industry standard, ANSI /ANS 3.1-1981, reflects current qualification requirements for nuclear power plant personnel and is updated as necessery, based on operating raperience and lessons leamed throughout the commercial nuclear industry.
Section 5.6
- L5 CTS 6.g.1.2.1 requires submitting the annual Occupational Radiation Expcsure Report by March 1 of each year; ITS 5.6.1 requires submitting this report by April 30 of each year.
CTS 6.g.1.2.3 requires submitting the annual Radiological Environmental Operating Report by May 1 of each year; iTS 5.6.2 requires submitting this report by May 15 of each year. These are less restrictive requirements. The reports cover the previous calendar year, and there is no requirerront for the NRC to approve either report. Completion and - submittal of the reports are not _necessary to ensure safe operation of the unit during the additional time intervals provided by these changes.- These changes are consistent with
- the STS.
; . (Plant name) c:\.~..\draf tse.a20
- 24 - revised: 12 noon, August 20, 1997 l
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L6 CTS 6.9.1.2.1 contains reporting requirements associated with the reactor coolant exceeding specific activity limits. These reporting requirements are not retained in ITS 5.6. This is a relaxation of requirements, which is less restrictive. These reporting requirements are specified in 10 CFR 50.73, and failure to retum specific activity to within specification limits in the allotted time results in a unit shutdown and those related reporting requirements. This change is consistent with the STS. L7 CTS 6.9.1.3, which requires subinitting the Radioactive Effluent Release Report on a somlannual basis, is revised in ITS 5.6.3 to require submitting this report on an annual Msis in accordance with 10 CFR 50.36s. This is a less restrictive requirement. This report covers the previous calendar year, and there is not a requirement for the NRC to approve the report. Completion and suorWttol of the report is not necessary to ensure safe operation of the unit during the additional 6 months. This change is consistent with the STS, L8 CTS 6.9.1.4 requires suomittal of the Monthly Operating Report to the NRC no later than the 10th of the month following the calendar month covered by the report. ITS 5.6.4 requires submitting this report by the 15th of each month. This is a less restrictive requirement. This report covers the previous month, and there is not a requirement for the NRC to approve the report. Completion and submittal of the report is not necessary to ensure safe operation of the unit during the additional 5 days. This change is consistont with the STS. L9 CTS 4.2.1.3.2 requires including the complete results of the Steam Generator (SG) tube inservice inspection in the Operating Report for the period in which tne inspection was completed. ITS 5.6.8b requires incluJing the complate results of the steam generator tube inspection in the Monthly Operating Rt port for the period beginning after the inspection was comptr*.. This is a less restrictive requirement. The current requirement can impv r unnecessary berden if the inspections are completed late in the reporting period, % s would be little time to include inspection results in the report and obtain approprae review and approval by the required completion date. Submitting the inspection results in the subsequent Monthly Operating Report is acceptable. This report is an after tne fact report covering planned inspection activities, and there is no requirement for the NRC to approve these reports. Completion and submittal of the report is not necessary to ens, re safe operation of the unit during the additional time interval provided by this change. L10 CTS 6.9.3.1.a, which requires the submittal of a Containment Leak Rate Test Report to the NRC upon completion of each containment leak rate test, is not retained in ITS 5.5.16. Thr. removat of a reporting requirement is a relaxation of requirements and is less restrictive. The removal of this reporting requirement is not necessary to ensure safe operation of the unit. This change is consistent with 10 CFR 50, Appendix J, Option D. Qonclusion For the reasons presented above, these lass restrictive requirements are acceptable because they will not affect the safe operation of the plant. The TS requirements that remain are consistent with current licensing practices, operating experience, and plant accident and transient analyses, and provide reasonable assurance that the public health and safety will be protected. Such information and requirements are not required to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and cafety. (Plant teme) c:\.. % W se a20 25
- revised: 12 reon, August 20, 1997
Further, where such information and requirements are contained in LCOs and associated requtements in the CTS, the staff has concluded that they do not fall within any of the four criteria in the Fi ett Policy Statement (discusted in Part ll of this safety evaluation). Accordingly, eusting detailed information and specific requirements, such as generally described above, may be deleted from CTS. Relocated Less Restrictive Requirements When requirements have been shown to give little or no safety benefit, their removal from the TS may be appropriate, in most cases, relaxations previously granted to individual plants on a plant specific basis were the result of (1) Generic NRC actions, (2) new staff positions that have evolved from technological advancements and operating experience, or (3) resolution of the Owners Groups comments on STS. The NRC staff reviewed generic relaxations contained in STS and found them acceptable because they are consistent with current licensing practices and the Commission's regulations. The HBR design was also reviewed to determine if the specific design bsJis and licensing basis are consistent with the technical basis for the model requirements in STS, and thus provide a basis for ITS. A significant number of chanDes to the CTS involved the removal of specific requirements and detailed information from individual specifications that can be adequately maintained in licensee-controlled documents, by applicable regulatory requirements. Such changes have been made to retained specifications that contained specific requirements and detailed information of the fo:lowin9 General types: Typei Details of system design and system description including design limits Type 2 Descriptions of systems operation Type 3 Procedural details for TS requirements and related reporting problems Type 4 Performance requirements for indication-only instrumentation and alarms The following discussions address why each of the four types of information or specific requirements do not need to be included in ITS . Details of System Deslan and System Description includina Deslan Limitt (Type 1) The design of the facility is required to be described in the UFSAR by 10 CFR 50.34. In addition, the quality assurance (QA) requiremente of Appendix B to 10 CFR Part 50 require that plant design be documented in controlled procedures and drawings, and maintained in accordance with an NRC-approved QA plan (UFSAR Chapter 17). In 10 CFR 50.59 controls are specified for changing the facility as described in the UFSAR, and in 10 CFR 50.54(a) criteria are specified for changing the QA plan. In ITS, the Bases also contain descriptions of system design. ITS 5.5.10 specifies controls for changing the Bases. Removing details of system design from the CTS is acceptable because this infom1ation will be adequately controlled in the UFSAR, controlled design documents and drawings, or the TS Bases, as appropriate. Cycle-specific design limits are moved from the CTS to the Core Operating Limits Report (COLR) in (Plant name) c \...\dren.e.a20 -26* revhed: 12 noon, August 20, 1997
accordance with Generic Letter 8816. ITS Administrative Controls are revised to include the programmatic requirements for the COLR. Descriptions of Systems Operation (Type 2) The plans for the normal and emergency operation of ths facility are required to be described in the UFSAR by 10 CFR 50.34. ITS 5.4.1.a requires written procedures to be established, implemented, and maintained for plant operating procedures including procedures recommended in Regulatory Guide 1.33 Revision 2, Appendix A, Fet.ruary 1978. Controls specified in 10 CFR 50.5g apply to changes in procedures as described in the UFSAR. In ITS, the Bases also contain descriptions of system operation. It is acceptable to remove details of system operation from the TS because inis type of information will be adequately controlled in the UFSAR, plant operating procedures, and the TS Bases, as appropriate. Procedural Details for Meetina TS Reaulromonts & Related Reportina Problems (Type 3) Details for performing action and surveillances requirements are more appropriately specified in the plant procedures required by ITS 5.4.1, the UFSAR, and ITS Bases. For example, control of the plant conditions appropriate to perform a surveillance test is an issue for procedures and scheduling and has previously been determined to be ' unnecessary as a TS restriction. As indicated in Generic Letter 9104, allowing this controlls consistent with the vast majority of other SRs that do not dictate plant conditions for surveillances. Prescriptive proceduralinformation in an action requirement is unliitely to contain all procedural considerations necessary for the plant operators to complete the actions required. Such information in the TS could distract the plant operators from focusing on applying the appropriate plant operational or emergency procedure to accomplish the action requirement. Thus, removal of such information from the TS la potintially beneficial to safe operation of the plant during compilance with a TS ' action statement. In addition to the potential safety benefit, the removal of these kinds of procedural details from the CTS s acceptable because they will be adequately controlled in the UFSAR, plant procedures and the Bases, as appropriate, in addition, removal of reporting requirements from LCOs is appropriate because ITS 5.6,10 CFR 50.36 and 10 CFR 50.73 adequately cover the reports the staff deems necessary. Performance Reauirements for indication-Only Instrumentation and Alarms (Type 4) Indication only instrumentation, test equipment, and alarms are usually not required to be operable to support TS operability of a system or component. Thus, wah the exception of the Accident Monitoring instrumentation, STS generally contain no operability requirements for Indication-only equipment. The availability of such indication instruments, monitoring instruments, and alarms, and necessary compensatory activities if they are not available, are more appropriately specified in plant operationni, maintenance, and annunciator response procedures required by ITS 5.4.1. Removal of requirements for indication only instrumentation and alarms from the CTS is acceptable because they will be adequately controlled in plant procedures. Table RL I;sts specific CTS details that are relocated to licensee-controlled documents in ITS. Table RL 18 organized by ITS section discussion of change and provides a CTS reference, a summary description of the item, the name of the dvcument that retains the CTS requirements, (Plant llame) ct\...\draf tse.620 revised: U noon, August 20, W i
the method for controlling future changes to relocated requirements, a characterization Of the change including a type of change reference. Conclusion The staff has concluded that these types of detailed information and specific requirements are not necessary to ensure the effectiveness of ITS to adequately protect the health and safety of the public. Accordingly, these requirements may be moved to one of the following licensee-controlled documents for which changes are adequately govemed by a regulatory or TS requirement: (1) TS Bases controlled by ITS 5.5.14 ' Technical Specifications Bases Control Program;" (2) UFSAR (includes the Technical Requirements Manual (TRM) by reference) controlled by 10 CFR 50.59; (3) the Offsite Dose Calculation Manual (ODCM) controlled by 10 CFR 50.59; (4) the Inservice Testing Program controlled by 10 CFR 50.59; and (5) the QA plans as approved by the NRC and contained in UFSAR Chapter 17. For each of these changes, Table 1 of the letter also lists the licensee controlled documents and the TS or regulatory requirements goveming changes to those documents. Relocated Specifications The Final Policy Statement states that CTS Section 3/4.0 specifications (LCOs and associated requirements) that do not satisfy or fall within any of the four specified criteria may be relocated from existing TS (an NRC-controlled document) to appropriate licensee-controlled documents. These requirements include the LCOs, (system description, design limits, functional capabilities, and performance levels), Action Statements (ACTIONS), and associated SRs. In its application, the licensee proposed relocating such specifications to the Updated Final Safety Analysis Report (UFSAR) (includes the Technical Requirements Manual (TRM) by reference), and the ODCM, as appropriate. Accordingly, these specifications may be relocated to one of the following licensee-controlled documents for which changes are adequately govemed by a regulatory or TS requirement: UFSAR (includes the TRM by reference) controlled by 10 CFR 50.59; and the Offsite Dose Calculation Manual controlled by 10 CFR 50.50. These provisions will continue to be implemented by appropriate plant procedures: 1.e., operating procedures, maintenance procedures, surveillance and desting procedures, and work control procedures. The licensee, in electing to implement the specifications of STS, also proposed, in accordance with the criteria in the Final Policy Statement, to entirely remove the following specifications from the CTS and place them in licensee-controlled documents noted in Table R. TaNe R lists specifications and specific CTS details that are relocated, based on the Final Policy Stateinent, to licensee-controlled documents in ITS. Table R is organized by ITS section discussion of change and provides a CTS reference, a summary description of the item, the name of the document that retains the CTS requirements, the method for controlling future changes to relocated requirements and a characterization of the discussion of change. CTS 31.1.4 REACTOR COOLANT SYSTEM VENT PATH When the RCS temperature is greater that 200'F, the RCS vent paths, consisting of at least two valves in series powered from emergency buses, are required to be operable (except that valves RC 567,568,569 and 570 shall be closed with power removed from the valve actuators) from the reactor vessel head and pressurizer steam space. , (Plant hase) c \,..\draftse.a20 -20' revised: 12 noon, August 20, 1997 i i l i
l The RCS vent paths are provided to exhaust non condensible gases and/or steam from the RCS which could inhibit natural circulation core coeling following any event involvin0 a loss of offsite power and requiring long term cooling, sue as a Loss-of Coolant Accident (LOCA). Their function, capabilities, and testing requirements are consistent with the requirements of item II.B.1 of NUREG-0737,"Clanfication of TMt Action Plan Requirements" However, the operation of reactor vessel head vents is not assumed in the safety analysis. This is became the operation of the vents is not part of the primary success path in the Updated Final Safety Analysis Re? ort (UFSAR). The operation of these vents is an operator action after the event has occurred. und is only required when there is indication that natural circulation is not occurring. CTS 31.2 2 STEAM GENERATOR PRESSURE / TEMPERATURE (P/T) LIMITQ The secondary side of the steam generator must not be pressurized above 200 psig if the temperature of the primary and vesselis below 70'F. The steam generator pressure and temperature (P/T) limits ensure that pressure induced stresses on the steam generators do not exceed the maximum allowable fracture toughness limits. Tnese P/T limits are based on maintaining steam generator rte sufficient to prevent bnttle fracture. As such, the TS places limits on variables consistent with structural analysis results. However, these limits are not initial condition assumptions of a UFSAR accident analysis. These limits represent operating restrictions and Criterion 2 includes operating restrictions. However, the Final Policy Staternent Cnterion 2 discussion specified only those operating restrictions required to preclude unanalyzed accidents and transients be included in TS. CTS 31.2.3 PRESSURIZER TEMPERATURE LIMITS The pressurizer shall neither exceed a maximum heatup rate of 100'F/hr nor a cool-down ate of 200'F/hr. The spray shall not be used if the temperature difference between the pressurizer end the spray fluid is greater than 320'F. Limits are placed on pressurizer operation to prevent a non ductile failure. These limitations are consistent with structural analysis results. However, these limits are not an initial condition assumption of a DBA or transient. These limits represent operating restrictions and Criterion 2 includes operating restrictions. The Final Policy Statement discussion for Criterion 2 specified only those operating restrictions required to preclude unanalyzed accidents and transients be included in TS.
' 3.1.6. (TABLE 4.1.2. Item 1) MAXIMUM REACTOR COOLANT OXYGEN AND CHLORIDE CONCENTRATION 3.1.6.1 The concentration of oxygen in the reactor coolant shall not exceed 0.1 ppm when the reactor coolant temperature exceeds 250*F.
3.1.6.2 The concentration of chloride in the reactor coolant shall not exceed 0.15 ppm when the reactor coolant temperature exceeds 250'F. 3.1.6.3 If the oxygen concentration or the chloride concentration of the reactor coolant exceed the limits given in 3.1.6.1 or 3.1.6.2, respectively, corrective action is to be taken immediately to retum the system to within normal operation specifications, if the (Plant Namel c:\...\draftse.oro revised: 12 reon, August 20, 1997
dormal operational limits are not achieved within 24 hours, the reactor is to be placed in the cold shutdown condition utilizing normal operating procedures. For coolant wh ' chemistry contributes to the long term degradation of system materials of WWgtico Sno F o is not of immediate importance w the plant operator Reactor coolant we %.g 4 i sn,nitoreo for a variety of reasons. One reason is to reduce the possibility of
% ,? m h4 03 prossure boundary caused by corrosion. However, the chemistry monitoring / 9 : of a long term preventative purpose rather than mitigative. 'O $ POST ACCIDENT CONTAINMENT VENTING SYSTEM The reactor shall not be made critical unless the valves of the post accident containment venting system are operable.
The containment venting system ensures that hydrogen concentration within containment will be maintained below its flammability limit during post LOCA conditions. The containment venting system is capable of controlling expected hydrogen generation associated with: (1) zirconium-water reaction, (2) radiolytic decomposition of water, and (3) corrosion of metals within containment. The buildup of hydrogen is expected Ia be quite smallinitially, such that the use of the Containment Venting System is not anticipated before 24 hours after the initiation of an accident and containment Isolation valves will be maintained operable for closure and purging as provided for by ITS 3.6.3 and 3.3.6. 3.5.1 Table 3.5 5 Operational Safety Instrumentation 3.5.1.2 For on line testing or in the event of a subsyAem instrumentation channel failure, plant operation at rated power shall be permitted to continue in accordance with Tables 3.5 2 through 3.5 5. 3.5.1.3 in the event the number t,f channels in a particular subsystem in service falls below the limits given in the column entitled Minimum Operable Channels, or Minimum Degree of Redundancy cannot be achieved, operation shall be limited according to the requirements shown in Column 3 of tables 3.5 2 through 3.5-4 and column 2 of Table 3.5 5 Note: HBR current TS do notinclude a unique LCO that requires the operability of the instrumentation identified Table 3.5 5. Each individual accident monitoring parameter has a specific purpose; however, the general purpose for accident monitoring instrumentation is to provide sufficient information to confirm an accident is proceeding as predicted (i.e., automatic safety systems are performing properly, and deviations from expected accident course are minimal). The application of deterministic selection criteria to post accident monitoring instrumentation is documented in NRC letter dated May 9,1988 from T. E. Murley (NRC) to R. A. Newton (Westinghouse Owners Group). The position was that the post accident monitoring instrumentation table list should contain, on a plant specific basis, Regulatory Guide 1.97 Type A instruments specified in the SER on Regulatory Guide 1.97, and Regulatory Guide 1.97 Category 1 instruments dated March 5,1997. Accordingly, this position has been applied to the HBR Regulatory Guide 1.97 instruments. Those instruments meeting this criteria have remained in
.-- - - - _ _ . - . - _ . ~ _ - . __ . . - . -
TS. The instruments not meeting this enteria may be relocated from the TS to plant controlled documents. The following summarizes the HBR position for those instruments currently in TS: From NRC SE dated March 5,1987
Subject:
Regulatory Guide 1.97 Emergency Response Capability. Type A Variables
- 1. Pressurtzer Level
- 2. Containment Vessel Level (Wide Range)
- 3. Containment Vessel Pressure (Wide range)
- 4. Containment Vessel Hydrogen Concentration i
- 5. Incore Thermocouple Other Type, Category i Variables
- 1. Containment Area Radiation (High Range)
Additionalinstrumentation, Associated With Risk Significant Scenarios or Mitigation Systems (These indications are not specifically modeled in the HBR Probabilistic Safety Assessment (PSA); however they provide information to the operators regarding risk significant systems modeled in the PSA.)
- 1. Auxiliary Feedwater Flow (SD AFW Pump)
- 2. Auxiliary Feedwater Flow (MD AFW Pump)
- 3. PORV Position Indicator (Primary)
- 4. PORV Blocking Valve Position Indicator (Prirnary)
- 6. Safety Valve Position Indicator For other post accident monitoring instrumentation currently in TS, their loss is not considered risk significant since the variable they monitor does not qualify as a Type A or Category i variable (one that is important to safety, er needed by the operator so that the operator can perform necessary manual actions).
Because the selection criteria have not been satisfied for other non Regulatory Guide 1.97 Type A or Category 1 variable instruments, their associated LCO and Surveillances may be relocated to other plant-controlled documents outside the TS. The instruments to be relocated are es follows:
- 1. Reactor Coolant System Subcooling Monitor
- 2. Noble Gas Effluent Monitor Main Steam Lines
- 3. Noble Gas Effluent Monitor Main Vent Stack High Range
- 4. Noble Gas Effluent Monitor Main Vent Stack Mid Range
- 5. Noble Gas Effluent Monitor Spent Fuel Pit Lower Level High Range
- 6. Reactor Vessel Level Instrumentation System (RVLIS) 3,5 2. (Table 3.5 6)/ RADIOACTIVE LIQUID EFFLUENT INSTRUMENTATION 4.19.1 SYSTEM 31 -
i
?
i The radioactive liquid effluent monitoring instrumentation channels shown in Table 3.5.2.1 ! 4 3.54 shall be operable with their alarm / trip setpoints set to ensure that the limits of i Specif6 cation 3.g.1.1 are not exceeded. The alarmttrip setpoints shall be determined l
- in accordance with the ODCM. !
, 3.5.2.2 With a radioactive liquid monitoring instrumentation channel alarm / trip setpoint less conservative than required by the above spoolfloation, without delay suspend the i release of radioactive 16 quid effluent monitored by the affected channel, change the i setpoint so it is acceptably conservative, or declare the channel not operable.
- 3.5.2.3 With less than the minimum number of radioactive liquid offluent monitoring instrumentation operable, take the action shown in Table 3.54, fj
- 3.5.2.4 The provisions of Specification 3.0 are not applicable.
l i The purpose of the Radioactive Liquid Effluent instrumentation is to monitor routine radioactive releases. This instrumentation provides a surveillance of release peints and initiates automatic ! i slarm and trip functions to terminate the release prior to exceeding the limits of 10 CFR 20; The ; alarm and trip functions are set in accordance with the ODCM Radioactive liquid effluent ! l Instrumentation and associated requirements for effluent releases are used to assure l conformance to the discharge limits of 10 CFR Part 20. The radioactive liquid effluent monitors i are used routinely to provide a continuous check on the release of radioactive liquid effluent from-J the normal plant effluent flow pathsc These requirements ensure the various liquid effluent 1 monitors are maintained operable with setpoints established in accordance with the ODCM. Plant DBA and transient analyses do not assume any action, either automatic or manual, . resulting from radioactive liquid effluent monitors.
' 3.5 3. (Table 3.53/ RADIOACTIVE GASEOUS EFFLUENT '
j 4.192 lNSTRUMENTATION SYSTEM 3.5.3.1 The radioactive gaseous effluent monitoring instrumentation channels shown in Table 3.5 7 shall be operable with their alarm / trip setpoints set to ensure that the limits of Specification 3.g.3.1 are not exceeded. The alarm / trip setpoints of these chann91s t shall be determined in accordance with the ODCM. 3.5.3.2 With a radioactive effluent monitoring instrumentation channel clarm/ trip setpoint less conservative than required by the above specification, without delay suspend the ; i release of radioactive gaseous effluents, chango the setpoint so it is acceptably ) conservative, or declare the channel not operable. 3.6.3,3 With less than the minimum number of radioactive liquid effluent monitoring 4 instrumentation channels operable, take the action shown in Table 3.5 7. 3.5.3.4 The provisions of Specification 3.0 are not app!icable. 4- The purpose of the Radioactive Gaseous Effluent instrumentation is to monitor routine and control, as applicable, radioactive releases. This instrumentation provides a surveillance of
- release points and initiates automatic alarm / trip functions to terminate the release prior to exceeding the limits of 10 CFR 20. The alarm / trip functions are set in accordance with the .
ODCM. Radioactive gases effluent monitoring instrumentation and associated requirements for +
.n. l I
I gaseous effluent releases are used to assure conformance to the discharge limits of 10 CFR Part
- 20. The radioactive gaseous effluent monhors are used routinely to provide a continaous check on the release of radioactive gaseous effluents from the normal plant gaseous effluent flow paths These requirements ensure the various effluent monitors are maintained operable with setpoints established in accordance with the ODCM. Plant DBA and transient analyses do not assume any action, either automatic or manual, resulting from radioactive gaseous effluent monitors.
3 0.1.c SPENT FUEL STORAGE AREA RADIATION MONITORING DURING REFUELING Radiation levels in the containment and spent fuel storage areas shall be monitored continuously. This relocated item addresses only the portion of the specification associated with spent fuel storage area radiation monitoring. The portion associated with containment radiation monitoring is retained in the HDR ITS. Radiation monitoring in the spent fuel storage area during refueling operations provides waming of abnormal or unusually high radiation levels in the spent fuel storage area. However, these monitors do not automatically initiate the Spent Fuel Building Ventilation System. The Spent Fuel Building Ventilation System is required to be in operation with the exhaust discharging through high efficiency participate operator air (HEPA) and charcoal filters during movement of irradiated fuelin the Spent Fuel Building. 3 0.1.a COMMUNICATIONS DURING REFUELING Direct communication between the control room and the refueling cavity manipulator crane shall be available whenever changes in core geometry are taking place. Communication between the control room personnel and personnel performing core alterations is maintained to ensure that personnel can be promptly Informed of significant changes in the plant status or core reactivity condition during refueling. The communications allow for coordination of activities that require interaction between the control room and containment personnel. However, the refueling system design accident or transient response does not take credit for communications in analyzing accident consequences. LQJ SPENT FUEL PQOL WATER TEMPERATURE During the discharge of a full core into the spent fuel pit, the temperature of the spent fuel pool water shall be maintained at or below 150'F. The spent fuel pool water temperature shall be monitored once each shift when the temperature is at of below 125'F. If the temperature exceeds 125'F, it shall be monitored houriy. If the pool temperature reaches 150'F, fuel assemblies will be transfaned back to the containment to reduce the pool temperature below 150'F. The spent fuel cooling system is desl0ned to maintain the pool temperature less than or equal to 166'F. The restriction of 150'F provides a margin to prevent the fuel pool temperature from reaching the design value. Plant operating procedures provide adequate controls for this plant parameter. These limits are not related to protection of the public from the consequences of any DBA or transient. l 214 SPENT FUEL CASK HANDLING CRANE 1 3.8.4 The following restrictions and requirements shall be applied to the Spent Fuel Cask Handling Crane:
- a. Use of the Spent Fuel Cask Handling Crane for lifting operations shall be permitted only when the ambient outside air temperature is greater than 33'F. If the temperature falls below this limit, lifting operations shall be suspended, with the load placed in c safe configuration, until the temperature increases above the limit. l
- 0. Limit switches provided to limit travel of the bridge, trolley, and hoist shall be tested every 6 months when the crane is not in service, and shall be tested prior to each period of service and on a monthly basis while the crane is in service,
- c. Crane ropes shall be inspected in accordance with ANSI B30.2.0 1967 overy 6 months when the crane is not in service, and shall be inspected prior to each period of servica and on a monthly basis while the crane is in service. A crane rope shall be replaced if any of the replacement criteria given in ANSI B30.2.01967 are met.
The requirements of Specification 3.8.4 ers based on limiting the potential for a cask drop accident. Provisions have been made to redace the potential for a spent fuel cask drop as a credible accident. Redundancy has been incorporated in the design of the spent fuel cask lifting yoke and the 125-ton spent fuel cask handling crane to reduce the risk to public health and safety. A discussion of the safety features of the cask and handling components is contained in Letter NG 741246, dated October 17,1974, CP&L to U.S. Atomic Energy Commission, Spent Fuel Cask Handling. Other actions implemented associated with the control of heavy loads include training of personnel; use of appropriate load handling procedures; identification and utilization of safe load paths; inspection, testing and maintenance of cranes; appropriate design j of crane and lifting devices, etc. These actions and the redundancy associated with the design of the spent fuel cask liftliig yoke and crane provide reasonable assurance regarding the limited potential for a cask drop accident. 3 9.1/4.10.1 COMPLlANCE WITH 10 CFR 20. RADIOACTIVE MATERIALS IN LIQUID EFFLUENTS 3.9.1.1 The concentration of radioactive materialin liquid effluents released at any time from the site to unrestricted areas (see Figure 1,1 1) shall be limited to the concentrations specified in 10 CFR 20, Appendix B, Table 11, Column 2 for radionuclides other than dissolved or entrained noble gases. For dissolved or entrained noble gases, the concentration shall be limited to 2 x 10-4 pCl/ml total activity. 3.9.1.2 With the concentration of radioactive material in liquid effluents released from the site to unrestricted areas exceeding the above limits, without delay restore the concentration to within the above limits. In addition, notification must be made to the Commission in accordance with Specification 6.6. 3.9.1.3 In the event that the immediate action required by 3.9,1.2 above cannot be satisfied, the facility shall be placed in hot shutdown within 12 hours and in cold shutdown within the next 30 hours, and entry into the power operating condition shall not be made unless Specification 3.9.1.1 is met. 34
y r 3.9.1.4 - The provisions of Specification 3.0 are not applicable. The Liquid Effluent Concentration Limit ensures that the concentration of radioactt e materials released in liquid waste effluent to unrestricted areas will be less than the concentration levels i specified in 10 CFR 20, Appendix B.10 CFR Part 20, Bil(2) refers to liquid release to an unrestricted area of radioactive materialin concentrations that exceed the specified limits. No screenir g criteria apply because the process variable of the LCO (concentration of radioactive materialin liquid effluents) is not an initial condition of a DBA or transient analysis. Effluent control is for protection against radiation hazards from licensed activities, not accidents.
;L92 COMPLIANCE WITH 10 CFR 50 RADIOACTIVE MATERIALS IN LIQUID EFFLUENTS 3.9.2.1 The dose commitment at all times to a member of the public from radioactive materials in liquid effluents released to unrestricted areas (See Figure 1.1 1) shall be limited:
I
- a. During any calendar quarter to s 1.5 mrom to the total body and to s 5 mrom to any organ, and
- b. During any calendar year to s 3 mrom to the total body and to s 10 mrom to any organ.
3.9.2.2 With the cahulated dose commitment from the release of radioactive materials in liquid effluents exceeding any of the limits prescribed by Specification 3.9.2.1 above, prepare and submit a report to the Commission in accordance with Specification 6.9.3.2. This specification is provided to implement the requirements of Sections ll.A, Ill.A, and IV.A of Appendix 1,10 CFR Part 50. The LCO Implements the guides set forth in Section ll.A of Appendix 1. The action statement provides the required operating flexibility and at the same time implements the guides set forth in Section IV.A of Appendix l of 10 CFR Part 50 to assure that the release of rsdioactive material in liquid effluents will be kept "as low as is reasonably achievable." Limitation of the quarterly and annual projected doses to MEMBERS OF THE PUBLIC as a result of cumulative liquid effluent discharge during normal operation over extended periods is intended to assure compliance with the dose objectives of 10 CFR Part 50, Appendix l. These limits are not related to protection of the public from the consequences of any DBA or transient. 3.9.3/4.10.2 COMPLIANCE WITH 10 CFR 20 - RADIOACTIVE MATERIAL IN GASEOUS EFFLUENTS 3.9.3.1 The dose rate due to radioactive materials in gaseous effluents released from the site boundary (see Figure 1.1 1) shall be limited to the following:
- a. For radionoble gases: s 500 mrom/yr to the total body, s 3000 mromlyr to the skin, and 35-
- b. For 1 131,1 133, and tritium, and for all radioactive materials in particulate form, inhalation pathway only, with half lives greater than 8 days: s 1500 mremlyr to any organ.
3.9.3.2 With the dose rate (s) exceeding the above limits, without delay decrease the release rate to within the above limits. In addition, a notification must be made to the Commission in accordance with Specification 6.0. 3.9.3.3 in the event that the immediate action required by 3.9.3.2 above cannot be satisfied, the facility shall be placed in hot shutdown within 12 hours and in cold shutdown within the next 30 hours, and entry into the power operating condition shall not be made until Specification 3.9.3.1 is met. This specification is provided to ensure the dose rate at any time at the site boundary from gaseous effluents is within the annual dose limits of 10 CFR 20 for unrestricted areas. The annual dose limits are the doses associated with the concentrations of 10 CFR 20 Appendix B. Table ll, Column 1. These are limits which apply to normal operation of the plant. They are not assumed as an initial condition of any DBA or transient analysis and are not relied upon to limit the consequences of such events. 3 9.4/4.10.3 COMPLIANCE WITH 10 CFR 50 RADIONOBLE GASES 3.9.4.1 The air dose commitment due to radionoble gases released in gaseous effluents to areas at and beyond the site boundary (See F10 ure 1.1 1) shall be limited, at all times, to the following:
- a. During any calendar quarter, to s 5 mrad for gamma radiation and s 10 mrad for beta radiation;
- b. During any calendar year, to s 10 mrad for gamma radiation and s 20 mrad for beta radiation.
3.9.4.2 With the calculated air dose commitment from radioactive noble gases in gaseous effluents exceeding any of the limits prescribed by Specification 3.9.4.1 above, prepare and submit a report to the Commission in accordance with Specification 6.9.3.2. The specification ensures that the concentration of radioactive materials released in gaseous effluent to unrestricted areas are kept as low as reasonably achievable. This specification is provided to implement the requirements of Sections ll. B, Ill.A and IV.A of Appendix 1,10 CFR Part 50. The LCO implementing the guides provides the required operating flexibility and at the same time implements the guides set forth in Section IV.A of Appendix l to assure that the releases of radioactive maicrial in gaseous effluents will be kept "as low as is reasonably achievable." These limits are not related to protection of the public from the consequences of any DBA or transient. 315/4.104 COMPLIANOE WITH 10 CFR 50 - RADIOIODINES. RADLQACTIVE MATERIALS IN PARTICULATE FORM AND RADIONUCLIDES OTHER THAN RADIONO%E GASES 38
^
1 l, 3.9.5.1 The dose to a member of the public from I 131,1 133, tritium and radioactive materials : in particulate form, with half lives greater than 8 days in gaseous effluents released to !
+
unrestricted areas (See Figure 1.1 1), shall be limited, at all times, to the following:
- a. During any calender quarter, s 7.5 mrom to any organ, and
- b. During any calendar year, s 15 mrom to any organ. l 3.9.5.2 Wsth the calculated dose commitment from the release of I 131.1 133, tritium and !
radioactive materials in particulate form, with half lives greater than 8 days, in gaseous l
- effluents exceeding any of the limits prescribed by Specification 3.9.5.1 above, r prepare and submit a report to the Commission in accordance with Specification 6.9.3.2. ,
This specification is provided to implement the requirements of Sections ll. C, Ill.A, and IV.A of
- a Appendix 1,10 CFR Par 150. The LCO implements the guides set forth in Section ll.C of
, Appendix 1. The action statement provides the required operating flexibility and at the same time implements the guides set forth in Section IV.A of Appendix I to assure that the releases of
- radioactive materials as gaseous effluents will be kept *as low as reasonably achievable." These -
limits are not related to protection of the public from the consequences of any DBA or transient. , 3 9 6/410J COMPLIANCE WITH 10 CFR 190 - RADlQACILVEIEELUENLEBOM. URANIUM FUEL CYCLE 80URCES , 3.9.6.1 The dose commitment to any member of the public, due to releases of licensed materials and radiation from uranium fuel cycle sources shall be limited to s 25 mrom to the total body or any organ except the thyroid, which shall be limited to s 75 mrom ,
- over 12 consecutive months. This specification is applicable to HBR only for the area within a 5 mile radius ground the HBR. >
t 3.9.6.2 With the calculated doses from the release of the radioactive materials in liquid or gaseous effluents exceeding twice the limits of TS 3.9.2.1.a. 3.9.2.1.b,3.9.4.1.a. 3.9.4.1.b 3.9.5.1.a. or 3 9.5.1.b, calculations shnuld be made including direct radiation contributions from the reactor unit and from outside storage tanks to determine whether the above limits of Specification 3.9.6.1 have been exceeded, if such is the , case, prepare and submit to the Commission within 30 days, pursuant to Specification 6.9.3.2.d, a Special Report that defines the corrective action to be taken to reduce subsequent releases to prevent recurrence of exceeding the above limits and includes the schedule for achieving conformance with the above limits. This Special Report, as defined in 10 CFR Par 120.405c, shall include an analysis that estimates the radiation exposure (dose) tu a member of the public from uranium fuel cycle sources, including all effluent pathways and direct radiation, for the calendar year that includes the release (s) covered by this report. it shall also describe levels of radiation and c concentrations of radioactive materialinvolvod, and the cause of the exposure levels or concentrations, if the estimated dose (s) exceeds the above limits, and if the release condition resulting in violation of 40 CFR Part 190 has not already been corrected, the Special Report shall include a request for a variance in accordance with the provisions of 40 CFR Part 190 Submittal of the report is considered a timely request, and a variance is granted until staff action on the same request is complete.
+
i
, _ . . . . . , _ . . _ _.--,-._,,_-.m.__,_,- , _ , - _ - _ _ . , _ , . _ , _ . - , _ . _ _ _ ~ . ._.~.____-~___-.-_.-- _-,_ _
3.9.8.3 The provisions of Specification 3.0 are not applicable. This specification ensures the dose limitations of 10 CFR 40 Part 190 which were incorporated into 10 CFR 20 are not exceeded. This is intended to assure that normal operation of the plant is in compliance with the provisions of 40 CFR Part 190. These limits are not related to protection of the public from any DBA or transient. 3,101 POWER RAMP RATE LIMITS 3.10.7.1 During the retum to power following a shutdown where fuel assemblies have been handled (e.g., refueling, inspection), ' lie rate of reactor power increase shall be limited to 3 percent of rated power in an hour between 20 percent and 100 percent of rateo power. This ramp rate requirement applies during the initial startup anti may apply during subsequent power increases, depending on the maximum power level achieved and length of operation at that power level. Specifically, this requirement can be moved for reactor power levels below a power level P (20 percent < P s 100 percont), provided that the plant has operated at or above power level P for at least 72 cumulative hours in any 7 day operating period following the shutdown. The rate of reactor power increases above the hlghest power level sustained for at least 72 cumulative hours durihg the preceding 30 cumulative days of reactor power operation shall bo limited to 3 percent of rated power in an hour. Attematively, reactor power increase can be secomplished by a single step increase less than or equal to 10 percent of rated power followed by a maximum ramp rate of 3 percent of rated power in an hour beginning 3 hours after the step increase. Calculations show that high cladding stresses can occur if the reactor power increase is rapid after startup from a refueling. The 72 hour period allows for thermal stress relaxation of the clad before the ramp rate requirement is removed, therefore reducing the potential harmful effects of possible pellet or fragment relocation. The 3 percent limit is imposed to minimize the effects of adverse cladding stresses resulting from reduced power operation for extended periods of time. The time period of 30 days is based upon the successful power ramp demonstrations performed on Zircaloy clad in operating reactors, resulting in no cladding failures. The limits essociated with this specification are related to minimizing fuel clad damage normal operation. ITS LCO 3.4.16, RCS Specific Activity provides controls to limit allowable radionuclides ln the RCS. The limits associated with CTS 3.10.7 are not directly related to a DBA or transient. 2.11 MOVABLE IN-CORE INSTRUMENTATION 3.11.1 A minimum of 15 total accessible thimbles and at least 2 per quadrant sufficient movable in-core detectors shall be operable during recalibration of the excore symmetrical offset detection system. 3,11.2 Power shall be limited to 90% of rated power if recalibration requirements for the excore symmetrical offset detection system defined in Table 4.1 1 are not met. The movable in-core instrumentation is used to determme the gross power distribution in the core as indicated by the power balance between the top and bottom halves of the core. The full l
% l 4 !
- system has more capability than is needed for the calibration of th' encore detectors. If the calibration is not performed, the mandated power reduction assur i safe operation since it will compensate for an error of 10% in the excore detection system.
3.16 1/4.20.1 LIQUID RADWASTE TREATMENT SYSTEM
- 3.16.1.1 The appropnate portions of the Liquid Radweste Treatment System shall be maintained and used to reduce the concentrations of radioactive materials in liq Jid wastes prior to their discharge when the projected dose cornmitments, due to the release of radioactive liquid offluents to unrestricted areas (Gee Figure 1.1 1) when averaged over a calendar quarter, would exceed 0.2 mrom to the tctal body or 0.6 mrom to any organ.
I
- 3.16.1.2 With radioactive liquid wastes being discharged without treatment while in excess of l
~ the limits of Specification 3.16.1.1 above, prepare and submit a report to the Commission in accordance with Specification 6.g.3.2.b. The Liquid Redweste Treatment System ensures that effluents will be treated prior to release to the environment. Appropriate portions of the system are required to be operable to maintain doses as low as reasonably achlorable. The requirement for a liquid waste treatment system 4 pertains to controlling the release of site liquid effluents during normal operational occurrences.
- No loss of primary coolant is involved; neither is an accident condition assumed or implied. The
, limits for release in 10 CFR Part 50, Appendix l for liquids are design objectives for operation. In addition, M Pquid redweste subsystems are not credited in the safety sequence analysis and are i not part 6, w primary coolant pressure boundary. ,
3.16.3/4.20.3 GASEOUS RADWASTE AND VENTILATION EXHAUST TREATMENT l SYSTEMS i l 3.16.3.1 The appropriate portions of the Gaseous Radweste Treatment System and the -l Ventilation EFhaust Treatment System shall be maintained and used to reduce the ; concentrations of radioactive materials in gaseous wastes prior to their discharge j , when the projected dose commitments due to the release of gaseous effluents to . ! unrestricted areas (See Figure 1.1 1) when averaged over a calendar quarter would l l exceed: I
- a. 0.6 mrom for gamma radiation and 1.3 mrom for beta radiation due to radionoble [
- _ gases or,
- b. 1.0 mrom to any organ due to radioiodines, radioactive materials in particulate form, and radionuclides other than radionoble gases.
- 3.16.3.2 With the Gaseous Radweste Treatment System and/or the Ventilation Exhaust Treatment System not operable and with radioactiva gaseous wastes being discharged without treatment while in excess of the limits of Specification 3.16.3.1 ,
above, prepare and submit a report to the Commission in accordance with Specification 6 g.3.2.b. T l - - The specifWation ensures that appropriate portions of these systems are maintained and used . when specified to ensure that the releases of radioactive material in gaseous effluent is kept as , 3g-I
low as reasonably achievable. In addition, the operability of the gaseous radwaste treatment system is not assumed in the analysis or any DBA or translent. 116 6/4,20 6 SOLIDIFICATION OF WET RADIOACTIVE WAS7E 3.16.6.1 The Solid Radwaste System shall be used in accordance with a Process Control Program (PCP) to process wet radioactive waste to meet shipping and burial ground requirements. 3.16.6.2 With the provisions of the PCP not satisfied, suspend shipments cf defectively processed or defectively packaged solid radioactive waste from the site. 3.10.6.3 if any test specimen, as required by the PCP, falls to verify solidification, the solidification of the batch under test shall be suspended until such time as additional test specimens can be obtained, attemative solidification parameters can be determined in accordance with the PCP, and a subsequent test verifies solidification. The PCP shall be modified as required in accordance with Section 6.15, and solidification of the batch may then be resumed using attemative solidification parameters as determined by the PCP. This specification ensures that the packaging of wel radioactive waste meets the requirements of 10 CFR 20 and 10 CFR 71 prior to their shipment from the site for disposal. The solid radioactive waste system is a logical continuation of the liquid radwaste system. It operates on the same requirement for effluent control, identified cs controlling the release and handling of radioactive solid wastes. The system serves to control operational release of solid waste, not accidental retease. 3.17.1/4,21.1 MONITORING PROGRAM 3.17.1.1 The Radiological Environmental Monitoring Program shall be conducted as specified in Table 3.171. 3.17.1.2 With the radiological environmental monitoring program not being conducted as specified in Table 3.171, prepare and submit to the Commission, in the Annual Radiological Environmental Operating Report required by Specification 6.9.1.e, a description of the reasons for not conducting the program as required and the plans for preventing a recurrence. 3.17.1.3 With the level of radioactivity as the result of plant effluents in an environmental sampling medium at a specified location exceeding the reporting levels of Table 3.17 2 when averaged over any calendar quarter, prepare and submit to the Commission within 30 days, pursuant to Specification 6.9.3.2, a Special Report that identifies the cause(s) for exceeding the limit (s) and defines the corrective actions to be taken to reduce radioactive effluents so that the potential annual dose to a member of the public is less than the calendar year limits of Specifications 3.9.2.1,3.9.4.1, and 3.9.5.1. When more than one of the radionuclides in Table 3.17-2 are detected in the sampling medium, this report shall be submitted if: GQnctntrAll0DJil concentration f2) + . . . ;r 10 reporting level (1) reporting level (2)
When radionuclides other than those in Table 3.17 2 are detected ar.d are the result of plant effluents, this report shall be submitted if the potential annual dose' to a member of the public is equal to or greater than the calendar year limits of Specifications 3.9.2.1,3.9.4.1, and 3.9.5.1. This report is not required if the measured level of radioactivity was not the result of plant effluents; however, in such an event, the condition shall be reported and described in the Annual Radiological Environmental Operating Report. i 3.17.1.4 With milk or fresh leafy vegetable samples unavailable from one or more of the - sample locations required by Table 3.171, ideritify locations for obtaining ! replacement samples and add them to the radiological environmental monitoring program within 30 days. The specific locaticas from which samples were unavailable may then be deleted from the monitof.ng program. Pursuant to Specification 6.9.1.d Identify the cause of the unavailability of samples and identify the new location (s) for obtaining replacement sEmples in the next Semiannual Radioactive Effluent Release Report and also include in the repor1 a revised figure (s) and table for the ODCM reflecting the new location (s). 3.17.1.5 The provisions of Specification 3.0 are not applicable. 3.17.1.6 Deviations are permitted from the required santpling schedule if specimens are unobtainable due to hazardous conditions, seasonal unavailability, or to malfunction of automatic sampling equipment. If the latter, every effort shall be made to complete corrective action prior to the end of the next sampling period. The Environmental Monitoring Program provides data on radiation levels and radioactive materials in exposure pathways for those radionuclides that lead to the highest potential radiation exposure to members of the public resulting from plant operation. This is accomplished by effluent measurement and modeling the envirenmental exposure pathways. This program is not related to protection of the public from any DBA or transient. 3.17.2/4.21,2 LAND USE CENSy2 3.17.2.1 A land use census shall be conducted and shallidentify the location of the nearest milk animal, the nearest residence and the nearest garden of greater than 500 square feet prcducing fresh leafy vegetables in each of the 16 meteorological sectors within a distance of 5 miles. 3.17.2.2 With a land use census identifying a location (s) that yields a calculated dose or dose commitment greater that the values currently being calculated in Specification 4.10.4.1, Identify the new location (s) in the next Semlannual Radioactive Effluent report, pursuant to Specification 6.9.1.d. 3.17.2.3 With the land use census identifying a location which yields an annual calculated dose or dose commitment of a specific pathway which is 20% greater than that at a current sampling location: (a) add the new location (s) to the radiological environmental monitoring program within 30 days and,
-41
7 i 4 ! (b) if desired, delete the sampling location having the lowest calculated j dose or dose commitments via the same exposure pathway, excluding ; the control station location, from the monitoring program after Oolober ! 31 of the year in which the land use census was conducted, and : (c) identify the new location (s) in the next Semlannual Radioactive Effluent i Release Report, Specmcation 6.g.l.d, Including a revised figure (s) and table : for the CDCM reflecting the new location (s). The Land Use Census ensures that changes in the use of land are identified and accounted for t in the Radiological Environmental Monitoring Program given in the ODCM. This program is not . related to protection of the public from any DBA or transient. j l 3.17.3/4.21.3 WIE8]AR.QB61Q, BySQM268[gQHfBQQ86M 3.17.3.1 Analyses shall be performed on radioactive materials supplied by EPA as , a part of an Intertaboratory comparison Program of like media within the environmental program as per Table 3.171, ! t 3.17.3.2 With analyses not being performed as required above, report the corrective actions taken to prevent a recurrence to the Commission in the Annual Radiological Environmentel Operating Report pursuant to Specification 6.g.1.e.
- 3.17.3.3 The provisions of Specification 3.0 are not epplicable.
3.17.3.4 The interisboratory comparison Program shall be desenbod in the ODCM. A summary of the results obtained as part of the above required interiaboratory Comparison Program shall be included in the Annual c Radiological Environmental Operating Report pursuant to Specification 6.g.1.e. The intertsboratory comparison program ensures that independent checks on the precision and accuracy of the measurements of radioactive materials in the environmental samples are ; performed as part of the QA program for the environmental monitoring program. This program is ; not rolsted to protection of the public from any (DBA) or transient. 1.19 RADIOACTIVE SOURCE LEAKAGE TESTING The following surveillance requirements imply LCOs exist; however, unique LCOs are not specifically identified in Section 3 of the CTS. These surveillance requirements are comparable ,
- to surveillance requirements contained in 3/4.7.10, Sealed Source Contamination of NUREG-0452, Rev. 4, " Standard Technical Specifications For Westinghouse Pressurized Water Reactors."
4,16.1 The leakage test shall be capable of detecting the presence of .005 microcurie of radioactive material on the test sample. If the test reveals the presence of . 005 4 microcurie or more of removable contamination, it shall immediately be withdrawn from use, decontaminated, and repaired, or be disposed of in accordance with 4 e.- 4-%wyw "*+-re-*wwc=...au.4wy-+w.-.-m--e al + lar*,,=-m.a.ev-m--es.e es, 71di-'4 44q wim. yye-,p my vm - % g, y e- w i y wrv -eeww 3www-119w 9 yvr*-- er t-9.--' , gs dmq gqr *-y M e y y p y t-w$y '-'W=9
Commission reguistions. Sealed sources are exempt from such leak tests when the source contains 100 microcuries or 6ess of beta and/or gamma emitting material or 10 microruries or less of alpha emitting material. 4.16.2 Tests for leakage and/or contamination shall be performed by the licensee or bv other persons specifically authorized by the Commission or an Agreement State as follows: A. Each sealed source, except startup sources 2bject to core flux, containing radioactive mater'al, other than Hydrogen 3, with a half life greater than 30 days and in any form other than gas shall b3 tested for leakage and/or contamination at Intervals not to exceed 6 months. B. The periodic leak test required does not apply to sealed sources that are stored and not being used. The sources excepted from this test shall be testad for leakage prior to any use or transfer to another user unless they have been leak tested within 6 months prior to the date of use or transfer. In the absence of a certificate from a transferor indicating that a test has been made within six months prior to the transfer, seeled sources shall not be put into use untN tested. C. Stariup sources shall be leak tested prior to and following any repair or maintenance and before being subjected to core flux. This specification ensures that leakage from Byproduct, Source and Special Nuclear Material sources will not exceed allowable intake values. The limitation on removable contamination for sources requiring leak testing, including alpha emitters, is based on 10 CFR Part 70.39(a)(3) limits for plutonium. This program is not related to protection of the public ' rom any DBA or transient. APPENDIX B (TECHNICAL SPECIFICAYlON) A. Radioactive Effluent Releases A statement of the quantities of radioactive offluents released from the plant with data summarized or, a monthly basis following the format of USNRC Regulatory Guide 1.21.
- 1. Gaseous Effluents (a) Gross Rarfioactivity Releases (1) Total gross radioactivity (in curies), primarily noble and activation gases.
(2) Maximum gross radioactivity release rate during any 1 hour period. (3) Total gross radioactivity (in curies) by nuclide released based on representative isotopic analyses performed. (4) Percent of technical specification limit. (b) lodine Releases (1) Total lodine radioactivity (in curies) by nuclide released based on representative isotopic analyses performed. (2) Percent of technical specification limit for 1-131 released. (c) Particulate Releases 43-
(1) Total groms radioactivity (py) released (in curies) excluding background radioactivity. (2) Gross alpha radioactivity released (in curies) excluding background radioactivity. (D) Total gross radioactivity (in curies) of nuclides with half lives greater than eight days. (4) Percent of technical specification limit for particulate radioactivity with hatf lives greater than eight days.
- 2. Liquid Effluents (a) Tota! gross radioactivity (py) released (in curies) excluding tritium and average concentration released to the unrestdcted area.
(b) The maximum concentration of gross radioactivity (py) released to the unrestricted area (averaged over the period of release). (c) Tctal tritium and total alpha radioactivity (in curies) re! eased and average concentration released to the unrestricted c.rea. (d) Total disto!ved gas radioactivity (in curies) and average concentration released & the unrestricted area. (e) Total volume (in liters) of liquid waste released. (f) Total volume Qiiders) of dilui;on water used prior to release from the
,attrW4 mm. .
(g) Tc4: gus radioactivity (in curies) by nuclide released based on reprewmat!ve isotopic analyses performed. (h) Percent of technical specification limit for total rauioactivity. B. Solid Waste 1, The total amount of solid waste shipped (in cubic feet).
- 2. The total astimated radioactivity (in curies) involved.
- 3. Disposition including date anti destinction.
C. Environmental Monitorint
- 1. For each mecNm sampled during the reporting period, e.g., nir, baybottom, ,
surface water, soll, fish, include: (a) Number of sampling locations, (b) Total number of samples, (c) Number of locations at which levels are found to be significantly above local backgrounds, and (d) Highest, lowest, and the average concentrations or levels or radiation for the sampling point with the highest average and description of the location of that point with respect to the site. The Appendix B Technical Specifications contain environmental reporting requirements which were relocated to Appendix B as an interim action in 1976 pending completion of issuance of comprehensive Appendix B Environmental Technical Specifications. These requirements are comparable tc portions of other Radiological Environmental Monitoring Technical Specifications which are also being separately relocated. Conclusion 4
-n
- ,~ -
, s - - - - - . _ , ., -y n~w- 7 w, ,, -rn.-, , ,. . - - . ~ - - -..
y
These current specifications are not required to be in the TS under 10 CFR 50.36 and do not meet any of the four criteria in the Final Policy Statement. They are not needed to obviate the possibility that an abnormal situation or event will give rise to an immediate threat to the public health and safety, in addition, the staff finds that sufficient regulatory controls exist under the regulations cited above to maintain the ofioct of the provisions in these specifications. The staff has concluded that appropriate controls have been established for all of the current specifications, information, and requirements that are being moved to licensee controlled documents. Untilincorporated in the UFSAR and procedures, changes to these specifications, information, and requirements will be controlled in accordance with the applicable current procedures that control these documents. Following implementation, the NRC will audit the removed provisions to ensure that an appropriate level of control has been achieved. The staff ha,s concluded that, in accorclance with the Final Policy Statement, sufficient regulatory controls exist under the regulations, particularly in 10 CFR 50.59. Accordingly, these specifications, information, and requirements, as described in detail in this Safety Evaluation, may be relocated from CTS and placed in the UFSAR or other licensee-controlled documents as specified letter dated, i., XX 1997. Control of specifications, Requirements, and Information Removed from the CTS The facility and procedures described in the UFSAR and TRM, incorporated into the UFSAR by reference, ran only be revised in accordance with the provisions of 10 CFR 50.59, which ensures an auditable record and ectablishes appropriate control over requirements removed from CTS and over future changes to the requirements. Other licensee controlled documents contain provisions for making changes consistent with other applicable regulatory requirements: for example, the Offsite Dose Calculation Manual (ODCM) can be changed in accordance with 10 CFR Part 20; the emergency plan implementing procedures (EPIPs) can be changed in accordance with 10 CFR 50.54(q); and the adm5nistrative instructions that implement the Quality Assurance Manual (QAM) can be changed in accordance with 10 CFR 50.54(a) and 10 CFR Part 50, Appendix B. Temporary procedure cht.nges are also controlled by 10 CFR 50.54(a). The documentation of these changes will be maintained by the licensee in accordance with the record retention requirements specified in the licensee's QA plan for HBR and such applicable regulations as 10 CFR 50.59. The licensee committed by a' letter (s) dated ^ ' ~ ~xx,Lig96, to confirm that CTS requirements < designated for placement in the UFSAR or the TRM are appropriately reflected in these documents, or that they will be included in the next required update of these documents. The licensee has also ccmmitted to maintain an auditable record of, and an implementation schedule for, the procedure changes associated with the development of ITS . The licensee will also maintain the documentation of these changes in accordance with the record retention requirements in the QA plan and the LC3.f Tabte in the letter lists the changes involving specific requirements that have been removed from the CTSc For each of these changes, Table 1 also lists tne licensee-controlled documents and fho TG or regulatory requireinents goveming changes to those documentsJ IV. STATE CONSULTATION in accordance with the Commission's regulatioru, the South Carolina State official was notified of the proposed issuance of the amendment. [The State official had no comments.)[The state othoial provided comments ,,, .) [This' action will be performed when the staff issues the final TS.] 45
4 V. ENVIRONMENTAL CONSIDERATION Pursuant to 10 CFR 51.21,51.32, and 51.35, an environmental assessment and finding of no I significant impact was publiuad in the Federal Eng!gjgf on 6 FR ). Accordingly, based upon the environmental assessment, the Commission has determined that issuance of this amendment will not have a significant effect on the quality of the human environment. VI. CONCLUSION The improved HBR TS provide clearer, more readily understandable requirements to ensure safe operation of the plant. The staff concludes that they satisfy the guidance in the Commission's policy statement with regard to the content of technical specifications, and conform to the model provided in NUREG 1434 with appropriate modifications for plant specific considerations. The staff further concludes that the improved HBR TS satisfy Section 132a of the Atomic Energy Act, 10 CFR 50.36 and other app!icable standards. On this basis, the staff concludes that the proposed improved HBR TS are acceptable. The staff has also reviewed the plant specific changes to CTS as described in this evaluation, On the basis of the evaluations described herein for each of the changes, the staff concludes that these changes are acceptable. The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations; and, (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public, Principal Contributors: Date:
APPENDlX ITS 3 31- lNSTRUMENT SETPOINT METHODOLOGY USED TO ESTABLISH THE
' ALLOWABLE VALUE' column in ITS Tables 3.31 1. 3.3 21. and 3.3 81.
This ' ALLOWABLE VALUE' column is added to provide an allowance for calibration to!erances, instrumentation uncertainties, instrument drift, and severe environment errors for those Reactor Protection System (RPS), Engineered Safety Features Actuation System (ESFAS), and AFW actuation channels that must function in harsh environments. The licensee submitted Rev. 3 of Design Guide No. DG Vill.50," Instrument Setpoints"which was used to calculate instrument setpoints and to determine the allowable values and trip setpoints indicated in the ITS. These instrument setpoint calculations resulted in some allowable values and trip setpoints which were less restrictive and some which were more restrictive than the values provided in the current TS. The methodology used by the licensee is based on the guidelines provided in ANSI /ISA S67.04-1988, "Setpoints for Nuclear Safety Related Instrumentation," dated February 4,1988, ISA - dRP07.04, Part II, Draft Recommended Prst'. ice,
- Methodology for the Determination of Setpoints for Nuclear Safety Related Instrumentation," Draft 10, dated August 1992, and NRC Regulatory Guide,1.105, " Instrument Satpoints for Safety Related Systems," which endorses ISA S07.04 1988. Design Guide No. DG Vill.50 was used by the licensee to calculate instrument setpoints for all three of the licensee's nuclear plant sites. The NRC staff has previously reviewed and approved this setpoint methodology for use at Brunswick Steam Electric Plant, Units 1 and 2, during the review of the power uprate license amendments. During a meeting on July 16 and 17,1997, the licensee also provided two sample calculations for Robinson which the staff determined were consistent with the setpoint methodology discussed in the DG Vill.50.
Based on its review, the staff finds the setpoint methodology to be acceptable. The NRC staff confirmed that the proposed ITS trip setpoints and allowable values are intended to maintain acceptable margins between operating conditions an f trip setpoints, and do not significantly increase the likelihood of a false trip nor failure to trip upon demand. Therefore, the existing licensing basis is not affected. Based on the above, the staff concludes that the licensee's selpoint methodology and the resulting trip setpoints and allawable values incorporated in the ITS conversion package are consistent with the HBR licensing basis, and are, therefore, acceptable. 3.4.1 ECCS OPERABILITY WITHIN LTOP OPERATION RANGE The LTOP system controls RCS pressure at low temperatures no that the integrity of the RCS pressure boundary is not compromised by violating 10 CFR Pei 50, Appendix G. H.B. HBR's LTOP system utilizes the pressurizer PORVs to accomplish this function. The system is manually enabled by the operators. When enabled, the system signals the PORVs to open if the RCS pressure reaches the LTOP actuation pressure setpoint. The design basis of HBR's LTOP system considers both mass addition and heat addition transients during water solid RCS conditions. The transients considered in the design of the system were inadvertent Si and charging / letdown flow mismatch for mass addition; and inadvertent actuation of pressurizer heaters, loss of RHR cooling, and RCP startup with temperature asymmetry within the RCS or between the RCS and the steam Generators for heat-addition. 47-
The scope of the NRC staff review was primarily limited to the mass addition analysis and specifically, the case for a temperature range of 175'F s Ta s 350'F where one Si pump and all three charging pumps are capable of injecting into the RCS The application of the new LTOP actuation pressure setpoint limit of s 400 psig to the entire LTOP operation range, including Tu < 175'F, was also addressed. The licensee's LTOP analysis of record (old analysis) was performed for three charging pumps and no SI pumps operable over the entire LTOP operating range (i.e., To s 350'F). Accordingly, the current TS do not allow any SI pumps to be operable when T Is less than or equal to 350'F. The old analysis methodology remains valid for operational configurations within the assumptions used in that methodology, including int not limited to the assumption that no SI pumps be capable of injecting into the RCS. The licensee evaluated the effect of the proposed LTOP setpoint of 400 psig and instrument uncertainty value of 45.9 psi on the old analysis. In accordance with that previously approved methodology, the new peak pressures achieved remain acceptable. Therefore, the licensee proposes to continue to rely on the old analysis methodology for LTOP operation belcw T of 175'F. To support the proposed changes which would allow an SI pump to be operable in Mode 4 and 5 when Tw a 175'F, the licensee performed a new analysis for that configuration. The licensee's new anatysis was performed using a modified ANF RELAP model based on the plant's Cycle 17 non LOCA transient model. The new analysis models the injection from all three charging pumps and one Si pump into a water solid RCS with all three RCPs and both RHR pumps in operation. Assumptions related to the number of injection pumps operating (i.e., three charging and one Si in this case) affect the mass addition rate and hence the pressurization rate. Assumptions relating to the number of RCPs and RHR pumps in operation affect the dynamic head between the pressure transmitter used for actuating the PORV and the location of interest for the analysis (i.e., most limiting location from a n:sterial embrittlement perspective). The analysis conservatively assumed that only one PORV actuated and, further, did not credit dynamic compensation for this actuation. Dynamic compensation would have resulted in early actuation of the ?ORV leading to a lower analysis peak pressure, in addition, the analysis did not credit the operation of the RHR system relief valves or the coolant letdown system since these would have also assisted the PORV in lim. ting the peak pressure. A pressure of 445.9 psig was used to actuate the LTOP system in the new analysis. Thus, the proposed TS limit of 400 psig ensures that an instrument uncertainty value of 45.9 psi, as calculated by the licenseo's setpoint methodology procedure,it accounted for, in addition, the static pressure, dynamic pressure, and peak analysis pressure were calculated at the bottom of fuel elevation in the reactor vessel downcomer, which is below the lower circumferential beltline weld of the reactor vessel. The lower circumferential beltline weld of the reactor vesselis the most limiting location from a material embrittlement perspective for HBR. The difference in position (with regard to elevation and flow) between the location at which the peak pressure was calculated and the lower circumferential beltline weld of the reactor vessel results in added conservatism when static and dynamic heads are considered. To bound the operating range affected by the licensee's request, five separtte cases were analyzed. The cases analyzed considered different combinations of maximum and minimum initial RCS pressures, temperatures, and injection water temperatures. The following table summarizing these cases was submitted to the NRC by the licensee in a letter dated April 25,1997:
+48-
LTOP System Analyela Raoulta ! For The Temperature Range of 178'F s T s 380'F : i Case initial Conditions Total P/T LimM Margin ; Downoome (psig) to l r Limit ! ! Pressure Temperature 81 Temp. Pressure (psi) l (psic) ('F) ('F) inw j A 275 175 38 597.72 602.61 4.89 : B 275 175 100 599.25_,_ 602.61 3.36 C 400 175 100 -599.44 602.61 3.17 . l i D 275 350 100 575.15 813.88 238.73 E 400 350 100 574.57 813.88 239.31 !
- For the range of 160'F to 220*F, plant heatup procedures restrict plant heatup to a maximum l rate of 30*F/ hour. For this range and heatup rate, en Appendix G P/T limM of 602.61 psig is !
applied by the licensee, This limit corresponds to the lower end of the range (i.e.,160'F) and is therefore conservative for that range. For the range of 200'F to 170'F, plant oooldown l procedures restrict plant cooldown to a maximum rate of 10'F/ hour. For this range and cooldown rate, an Appendix G P/T limit of 612.54 psig is applied by the licensee. This limit corresponds to the lower end of the range (i.e.,170'F) and is therefore conservative for that 4 range. For LTOP Cases A, B and C above, the licensee applied the more conservative of the two limits (i.e., the hestup limit of 602.61 psig). This value is consistent with plant operational limitations, is more limiting than the steady state limit, and is therefore acceptable. l - . For the range of L*20'F to 350'F, plant heatup procedures restrict plant heatup to a maximum i rste of 60'F/ hour, For this range and heatup rate, an Appendix G P/T limit of 813.88 psig is i applied by the licensee. This limit corresponds to the lower end of the range (i.e.,220'F) and is therefore conservative for that range For the range of 350'F to 300'F, plant cooldown procedures restrict plant cooldown to a maximum rate of 60'F/ hour. For th's range and ,
- cooldown rate, an Appendix G P/T limit of 1450 psig is applied by the licensee. This limit corresponds to the lower end of the range (i.e.,300'F) and is therefore conservative for that i range. For LTOP Cases D and E above, the licensee applied the more conservative of the two limits (i.e., the heatup limit of 813.88 psig). - This value is consistent with plant operational limitations, is more limiting than the steady state limit, and is therefore acceptable. '
For all cases, the licensee has shown that the peak pressures achieved remained below their
- respective P/T limit. The resulting limiting case was Case C from the table, where the initial RCS inlet pressure arJ temperature were 400 psig and 175'F, respectively, and the Sl water temperature was 100'F. This case resulted in an acceptable peak pressure value of 599.44 psig (3.17 psiless than the P/T limit of 602.61 psig at 175'F).
The NRC staff has reviewed the licensee's submittels relating to the mass addition overpressurization analyses for the range of 175'F s T s 350'F. Based on our review of this material and the above discussion, the NRC staff finds the licensee's analyses of mass addition overpressurization event acceptable. The staff further concurs with the licensee's conclusions , i ee-r,.es-e,-w e ,,n,--+.- ww - rwev - y w-,- .,.----.w.c,r- - wm *w se = ,v w < --r * % rw W-er-w-- -- i-,9we%wn a w er.e rn+e-+vwrem*em-===ee-vr-- e
that the peak pressures achieved in those anstyses are below the P/T limits and, therefore, acceptable. The licensee's proposals to: a) amend the LTOP TS to allow one Si pump to be capable of injecting into the RCS when operating within the range of 175'F s T. s 350'F, and b) change the PORV lift setpoint to s 400 psig; consistent with the licensee's anaWes and, therefore, also acceptable, j in addition, for T. < 175'F the old analysis methodology and therefore limitations of that methodology (including but not limited to the assumption that no Si pumps be capable of injecting into the RCS) remain valid. Therefore, since the new lift setpoint limit of s 400 psig and new instrument uncertainty value of 45.9 psi have been verified by the licensee to give acceptable results, the staff finds the application of this limit to the entire LTOP range, including : Tw < 175 psig, acceptable. Note that for Tw < 175 psig the licensee is appropriately maintaining the restriction that none of the Si pumps be capable of injecting into the RCS. 4
- 50
1 ? TABLE M - MATRIX OF ReORE REST 7WCTNE CHANGES . SECTION 1.0 "Use and Application" page 1 of 1 i . Discussion of Summary at Change ITS Secesen CTS Secelen Change t i 1.0"Use and Applicahon* 2 , i 1.1 M1 Definton of E was expanded to include weighted average and 1.1 3.1.4 , composeon of isotopes ==r*=6ng sodene instead of average of beta ; and gamma energy dismtegrahon of the specific actmty. ! 1.1 M2 Defineon for Refueling Operabons was expended to include the 1.1 1.2.6 time from inetsal Cetenssonsng of the first reactor vessel hood closure boet une the reactor vessel head is unbaned and the time imm i bogenmg reinstallshon of the first rear 4ar vessel head ciosure bolt i until the reactor vessel head is fully tenssoned 1 1.1 M3 Defineon for Channel Funcbonal Test was expanded to include 1.1 1.6.4 ! 4 specsfying the point of test segnal insechon. The more prescnptive ! requrement provides for inpchon of the test segnal as close to the sensor as pr** ! 4 ! l- i I i l I , j F l 3 i l k-f i 1 1 i r i i
TABIE. M - MATRIX OF MORE RESTRICTIVE CHANGES SECTION 2.0 " Safety Limi ts (SL)" page 1 of 1 Discussion Summary of Change ITS Section CTS of Change Section 2.0 " Safety Limits (SL)" 2.0 M1 The requirements for Reactor Core Safety 2.1.1 2.1 Limit were expanded to apply to MODE 2 and the reactor is subcritical instead of when the reactor is critical. 2.0 M2 Requir-ments when Safety Limits are violated were expanded to include restoration of 2.2 6.7 compliance with the Safety .-imit within S minutes and specifying a timt: of one hour to place the unit in MODE 3. The requirement to restore compliance with the Safety Limit and the time to place the unit in shutdown were not previously specified.
.- . - , .. - . . - - -- . - - . . .- . . .-, . _ _ . ~ . - .
1
, TABLE M - MATRIX OF MORE RESTRICTIVE CHANGES SECTION 3.0,- " LIMITING CONDITION FDR OPERATION (LCO) APPLICABILITY" page 1 of.1 risme..maimsof' Summary of Change ITS Secuon CTS Secuen , Change 3.0 M1 If a speedcahon cannot be met a:4 there is no speede achon to be LCO 3.0.3 3.0 '
taken, the time allowed to reach MODE 3 was Imted to seven (7) i hours, the time allowed to reach MODE 4 was Imted to 13 hours, e and the time allowed to reach MODE 5 was lated to 37 hours.
- The previous bmes allowed were eight (8) hours to reach hot - r i shutdown and 38 hours to reach cold shutdown
[ 3.0 M2 A requrement was added that prohdnts entry into a MODE or other LCO 3.0.4 3.0 - t s;+;:'.;d conddson when a spec 6cahon is not met and the requwed SR 3.0.4 4.0 ~ ~ achon for that spec 6cahon does not pommt entry into the MODE. A requerement was added that prohsbded entry into a MODE or j specified condshon utsless the surveillance requwements for the spec 6 cations appiscable to the MODE or specded condshon are ! met. .! i 3.0 M3 For frequences of surveillance requirements specmad as "once," a SR 3.0.2 4.0 ' ' requerement was added to clanfy that an extensson of 25% does not apply , i t i i I I i l
. _ _ _ _ _ _ . . _- _ ~___.._~._w
1 a
. MATRIX OF MORE RESTRICTIVE CHANGES SECTION'3.1, " REACTIVITY CONTROL SYSTEMS," page 1 of 5:
i - - Discussion or 1 - rfofChange ITs secelon cts section Change LCO 3.1.1,
- SHUTDOWN MARGIN (SDM)*
3.1 M1 A surseshance requwements was added to venfy that Shutdown SR 3.1.1.1 3.10.8-Margin is within the lets of the Core Operahng Lmts Report , (COLR). LCO 3.1.2, " Core Reachysty* t j 3.1 M2 A frequency requwement of prior to entenng MODE 1 after each ' SR 3.1.2.1 '4.9 '
- refuehng and 31 Effechve Full Power Days (EFPDs) thereafter we a added to the surveellance requerement to compare actual to
! predicted bomn concentrabon values. Normahzabon of predscled l values was requwed to be performed prior to exceeding a fuel bumup of 60 EFPDs. , 3.1 M3 Requrements were added that the measured core reachvity be LCO 3.1.2 ' 4.9 withen i ak/k of predected values in MODES 1 and 2, and if not met. -l to reevaluate design and safety analyses and determine that the .i core is acceptable for conhnued operabon within 72 hours, estabbsh ' ! appropnate operahng restnctions withen 72 hours, or be in MODE 3 in six (6) hours .j
- LCO 3.1.3, *1Wloderator Temperature Coefficent (MTC)*
3.1 M4 The requwements for the Moderator Temperature Coefficient (MTC) LCO 3.1.3 Appbcabshty 3.1.3.1 lower limit were extended to apply to a:I of MODE 2 and MODE 3 rather than only to reactor entecal and power operabons as was previously requieed. 3.1 M6 Surveillance requwements were added that venfy that the MTC is ' SR 3.1.3.1 3.1.3 - j , within the upper limit'once prior to entenng MODE 1 after each SR 3.1.3.2 refueling and venfy that MTC is within the lower ;imit once each j ' cycle i
1
' MATRIX OF MORE RESTRICTIVE CHANGES L SECTION 3.1, " REACTIVITY CONTROL SYSTEMS," page 2 of 51 l l Discussion of Summary of Change ITS Section CTS Section ,
Change
.t LCO 3.1.4 " Rod Group Abgnment Limits" _ ;
3.1 M7 The allowed time to restore a rod to withm alignment Imts was LCO 3.1.4 Requwed 3.10.1.5 ' reduced to one (1) hour from two (2) hours Achon B.1 , 3.1 M9 Requwements were added for the condetson when one rod is not LCO 3.1.4 3.10.1.5' withm abgnment hmets to venfy that SDM is within the limits of the Requwed Actons COLR or irutsate borshon to restore SDM to within limit withm one B.2.1.1,B.2.1.2,B.2.3, (1) hour, venfy SDM is withen limits of the COLR once per 12 hours. B.2.6, C.1, D.1.1, ! reevaluate the safety analyses and confirm results roman valid for D.1.2, and D.2 duration of operabon within 5 days, or if the requirements for a rod j not withm abgnment Ismets cannot be met, be in MODE 3 in six (6) i hours. Requrements were added for the condsbon when more than -i i one rod that is not withen the alignment limit to venfy SOM is withm the kmets of the COLR withm one (1) hour, msbate borabon to restore ;
- . SDM to withm limit withm one (1) hour, and be in MODE 3 in six (6) - ,
i hours , i 3.1 M8 The allowed time to measure the hot channel factors when a rod is LCO 3.1.4 3.10.1.5 i not within abgnment hmets was limited to 72 hours No time limit Requwed Achons B.2.4 1 . previously existed. and B.2.5 I' ,
- 3.1 M28 The requerements for rod group alignment limits were made LCO 3.1.4 3.10.1.5 specifically appbcable to MODES 1 and 2. No specific reactor Appiscatzhty ;
condition apphed to the rod group alignment limits previously. ! i 3.1 M24 A requwement to measure the rod drop time from the point of decay SR 3.1.4.3 3.10.4.1 4 of the stahonary gnpper coil voltage rather than the beginneng of rod . mobon dunng the rod drop test. The effect of this change is to i
- - shahtly decrease the allowed rod drop time. .
t I
MATRIX OF MORE RESTRICTIVE CHANGES SECTION 3.1, " REACTIVITY CONTROL SYSTEMS," page 3lof 5: Descussion of Summary of Change ITS Section CTS Section
- Change ;
3.1 M29 A requwement was added to the rod drop time surveillance test to SR 3.1.4.3 3.10.4.1 .[ measure the time from the fully withdrawn posstion. No possbon was prewously speafied 1 3.1 M26 Requwements were added for the condition when control rod drop LCO 3.1.4 Requwed 3.10.4.1' twnes are not withm irruts to venfy SDM is withm the limits prowded Achons A.1.1, A.1.2,- in the COLR withm one (1) hour, nutsate borabon to restore SDM to and A.2 I withh the limit withen one (1) hour, and the time allowed to reach MODE 3 was limited to six (6) hours rather than eight (8) hours as , was previously required 3.1 M10 A requwement that allowed contmuous operabon with one control LCO 3.1.4 3.10.6 2 J rod inoperable was deleted. I 3.1 M25 Requwemonts were added for the condition when one or more LCO 3.1.4 3.10.6.3 l contml rods cannot be moved by its mechanism to restore SDM or i l venfy SDM is withen Irnets within one (1) hour. No completion time i i previously existed. For the same condition, the time allowed to reach MODE 3 was limited to six (6) hours rather than eight (8) l i hours as was previously required ') ! 3.1 M11 A requirements was added to the rod exercise test to move control SR 3.1.4.2 Table 4.1-3 i ! rods at least ten (10) steps dunng the test. No movement critenon item 2 i l was previously speafied t . l 3.1 M12 A survesitance requwement was added to venfy mdrwdual rod SR 3.1.4.1 Table 4.1-3
- positions are within alignment limit every 12 hours LCO 3.1.5,~ " Shutdown Bank Insertson Limits" i
3.1 M13 Requwements for the shutdown bank insertson limits were extended LCO 3.1.5 Applicabihty 3.1.5 I to apply to MODES 1 and 2 with any control bank not fully inserted, rather than to reactor cntecal and power operations. l i I
MATRIX OF MORE RESTRICTIVE CHANGES SECTION 3.1, " REACTIVITY CONTROL SYSTEMS," page 4 of 5 Discussion of Summary of Change ITS Section CTS Section Change 3.1 M14 Requirements were added for the condition where one or both LCO 3.1.5 Required 3.10.1 shutdown banks are not within limits to venfy SDM is within the Actions A.1.1, A.1.2, limits in the COLR within one (1) hour or initiate boraton to restore A.2, and 8.1 SDM to within limits within one (1) hour, and to restore shutdown banks to within limits in two (2) hours. The time allowed to reach MODE 3 with one or more shutdown banks not within limits was limited to six (6) hours rather than eight (8) hours as previously required. 3.1 MIS A surveillance requirement to verify each shutdown bank is within SR 3.1.5.1 3.10.1 limits specified in the COLR every 12 hours was added LCO 3.1.6, " Control Bank Insertion Limits" 3.1 M16 Requirements to maintain control rods within insertion, sequence LCO 3.1.6 3.10.1.3 and overlap limits speofied in the COLR were added 3.1 M17 Requirements were added for the condition when control bank LCO 3.1.6 Required 3.10.1 insertion limits are not met to verify SDM is within the limits of the Actions A.1.1, A.1.2, COLR within one (1) hour, initiate boration to restore SDM within 8.1.1, 8.1.2, B.2.2, and one (1) hour, and restore control banks within limits within two (2) 8.2.3 hours. Similarly, requirements were added for the condition when control bank sequence or overlap limits are not met to verify SDM is within the limits of the COLR within one (1) hour, initiate boraten to restoro SDM within one (1) hour, and restore control banks within limits within two (2) hours. 3.1 M18 Surveillance requirements were added to verify that estimated SR 3.1.6.1 3.10.1 critical control bank position is within limits specified in the COLR SR 3.1.6.2 within four (4) hours prior to achieving criticality, each control bank SR 3.1.6.3 insertion is within the limits specified in the COLR every 12 hours, and sequence and overlap limits speofiec .. .he COLR are met for control banks not fully inserted in the core every 12 hours.
- - ,ai m. ., .m .
. . ._ .m.._.m.. .s m6 +% ,i 1 .
-l
~
t t i MATRIX OF.MORE RESTRICTIVE CHANGES , .: I SECTION 3.1, " REACTIVITY CONTROL SYSTEMS "' , page'5 of 5 rhe.a=W of Surnmery of Change ITS Section CTS Section i Change ; LCO 3.1.7, " Rod Posdson inde=hari" , i
- 3.1 M27 A requwement was added to perform the surveillance requwement to SR 3.1.7.1 Table 4.1-1 . ,
items 9 and 10 compare anasog rod posebon indicahon and bank demand posebon indicahon once within four (4) hours following rod mobon in eacess
- of six (6) inches when the rod posdson deviahon monitor is inoperable ,
I LCO 3.1.8. "Physses Test Excepisons-MODE 2"
- 3.1 M20 Requerements were added for the condshon that the SDM is not LCO 3.1.8 Requwed 3.10.1 l withwi limits dunng physses tests to inetsste borahon to restore SOM Achons A.1 A.2, B.1, to withwi limit within 15 minutes, and to suspend physses tests withen C.1, and D.1 one (1) hours. A requerement was added for the condshon that the thermal power is not less than or equal to 5% rated thermal power s to w
' w ="?
'; open the reactor trip breakers. A req 0'W was added for the condshon that the lowest Reactor Coolant System ;
(RCS) loop average temperature is not wethen limit to restore the RCS lowest average loop temperature to withen limit within 15 rrunutes or be in MODE 3 withen 15 manutes
- i
! 3.1 M21 Survesitance requwements were added dunng physses tests to SR 3.1.8.1 3.10.1 ! perform a channel caisbrabon on power range and intermediate SR 3.1.8.2 - 'l 4 range channels withwi 7 days prior to instsabon of physses tests, to SR 3.1.8.3 venfy the RCS lowest loop average temperature is > 530*F every SR 3.1.8.4 30 rrunutes, venfy thermal power is s 530*F 5% rated thermal i power every 30 rmnutes, and to venfy that SDM is withen the Iwnats of the COLR every 24 hours i 3.1 M23 An allowance for the SOM not to meet the lwmts in the COLR dunng LCO 3.1.8 3.10.1.6 physses tests whole measunng control rod worth and SOM was deleted i i t
I' i TABLE M - MATRIX OF MORE RESTRICTIVE CHANGES SECTION 3.2, " REACTIVITY CONTROL SYSTEMS" page 1-of 5 l l Discussion of Summary of Change ' ITS Section CTS Section Change LCO 3.2.1, " Heat Flux Hot Channel Factor" 3.2 M1 An exception from ira g heat flux hot channel factor limits dunng LCO 3.2.1 3.10.3.1 physcs tests was deleted 3.2 M2 Requirements were added for the cordtion when the heat flux hot - LCO 3.2.1 Requwed 3.10.2.1 channel factor is not withm limits to reduce the power range high Achons A.2.2, A.2.4, , neutron flux setpoent by 21% for each 1% that the factor exceeds B.1 . the limit within 72 hours, and to verify that heat flux hot channel factor is withe limits prior to increasing thermal power above the required action value. The allowed time to reach MODE 2 if the requirements for heat flux hot channel factor outside of limsts cannot be met was limited to six (6) hours instead of eight (8) hours as previously required. ' 3.2 M3 Requirements were added to venfy that the heat flux hot channel SR 3.2.1.1 3.10.2.1.1 factor is withen limit once after each refuehng outage prior to exceeding 75% rated thermal power, and once vnthen 12 hours after achieving equilibnum conditions after exceeding by 2 10% rated thermal power the thermal power at which the heat flux hot channel was last determoed 3.2 M28 / n allowance to not reduce the overpower and overtemperature aT LCO 3.2.1 Required 3.10.2.1.1 setpowes ". . .if subsequent incore mappeg . . ." demonstrate that Action A.2.3 the hot channel factors are not met is deleted. 3.2 M4 A requirement was added to reduce the AFD target band limsts to LCO 3.2.1 Requwed 3.10.2.2.1 restore the heat flux hot channel factor to withm limits withm 15 Action A.1 , minutes was added
- - . - _ _ . -. _. . - . . _ - - - - - - - ~ - - . -. . _ . .. . . - . . - _ -
l' i 4 i
. TABLE M - MATRIX OF TORE RESTRICTIVE CHANGES .I SECTION 3.2,." REACTIVITY CONTROL SYSTEMS" page 2.of 5 ' j s
i r h
- of Summary of Change ITS Sectson CTS Secelen ll Change
, 3.2 MS A time limit of 30 rmnutes was imposed upon the requwement to. LCO 3.2.1 Requwod 3.10.2.2.1 reduce thermal power when the heat flux hot channel factor Acton A.2.1 ' i
- exceeds the limds specdied in the Core Operahng times Report
- (COLR). ;
l 32 M6 An allowance to raise thermal power above the thermal power limds LCO 3.2.1 3.10.2.2.1 ! specific d when the heat flux hot channel factor is not withm hmds by 3.10222 i !- utskration of the Amal Power Destnbubon Mondonng System 4.11 i (APDMS) was deleted Requrements for the APDMS that, when in : I opesation, permd less restnctive thermal power kmds were deleted s
- LCO 3.2.2, 'Meiaar Enthalpy Rise hot Channe8 Factor" 4 .>
3.2 M7 An excephon from meetmg nuclear enthalpy rise hot charmel factor LCO 3.2.2 3.10.2.1
- limits dunna physics tests was deleted j 3.2 M8 A requwements was added to the survedlance to venfy the nuclear SR 3.2.2.1 3.10.2.1.1 ~
j enthalpy rise hot channel factor it withen Iwruts to perform the j l survedlance once after each refteling outage prior to thermal power ; i exceedmg 75% rated thermal power. No power limit previously l 1 existed. ; j.;
- 3.2 M9 The allowed time for reducmg thermal power and the high neutron LCO 3.2.2 Requred 3.10.2.1.1 1i 4 flux setponts when the nuclear enthalpy rise hot channel factor Action A.1.1, A.1.2.1, ! .l exceeds limits was Ismded to four (4) hours and 72 hours, me_.,. No time limits existed prevously.
and A.1.2.2 f} ! 3.2 M10 The requrements for reducmg thermal power and the high neutron LCO 3.2.2 Requesd 3.10.2.1.1 !
- - flux setpoents by a fraction relatog to the degree to whech the Achon A.1.2.1 and nuclear enthalpy rise hot channel factor exceeds hmets was changed A.1.2.2 ,
to a requwement to reduce power to less than 50% rated thermal power and to reduce the high neutron flux setpoents to s 55% rated thermal power l 1 _ __________________d
TABLE M - MATRIX OF MORE RESTRICTIVE CHANGES SECTION 3.2, " REACTIVITY CONTROL SYSTEMS" page 3 of 5 Discussion of Summary of Change ITS Section CTS Section Change 3.2 M11 Requirements were added for when the nuclear enthalpy hot LCO 3.2.2 Required 3.102.1.1 channel factor exceeds limits to verify the hest flux hot channel Action A.2, A.3, and factor is within limits within 24 hours, venfy the nuclear enthalpy rise B.1 hot channel factor is within limiis prior to thermal power exceeding 50% rated thermal power and prior to thermal power exceeding 75% rated thermal power and 24 hours after thermal power reaches 2 95 '
% rated thermal power, and if the requirements to restore nuclear enthalpy rise hot channel factor cannot be met, to be in MODE 2 in six (6) hours.
3.2 M12 A requirement was added to a surveillance note to reverify that the SR 32.2.1 3.10.2.2.2 heat flux hot channel factor is within limits in the event that the , nuclear enthalpy rise hot channel factor shows and increasing trend ! LCO 3.2.3, " Axial Flux Difference (AFD) (PDC-3 Axial offset Coritrol Methodology) 3.2 M13 A time limit of once within 31 Effective Full Power Days (EFPDs) SR 32.3.3 3.10.2.3 i after each refueling was imposed on the requirement to determine the target flux difference of each operable excore channel 3.2 M14 An exception from meeting axial flux difference requirements during LCO 32.3 3.10.2.5 physics tests was deleted. 3.2 M15 A requirement maintain axial flux difference within acceptable LCO 3.2.3 3.10.2.5 operation limits specified in the COLR was added 3.2 M16 The requirements for axial flux difference were extended to apply to LCO 3.2.3 Applicret,;1dy 3.10.2 MODE 1 with thermal power greater than 15% rated thermal power, rather than to greater than 50% rated thermal power as previously required. 4 I
4 j .- I-TABLE M - MATRIX OF MORE RESTRICTIVE > CHANGES i- SECTION 3.2,'" REACTIVITY CONTROL SYSTEMS" . page' .4 of ' 5' I L
- Discussion of Summary of Change ITS Section CTS Section change !
{ 3.2 M17 The time allowed to reduce thermal power to less than 90% rated LCO 3.2.3 3.10.2.61 i thermal power or 0.9 Allowable Power Level (APL) whichever is less Required Achon B.1 , j was limsted to 15 rmnutes. No time requwement previously existed . t l 3.2 M18 A requwement to reduce thermal power to less than 15 % rated LCO 3.2.3 Requwed 3.10.2 thermal power withen nine (9) hours was .edded for the condshon Achon D.1 ' when requirements to reduce thermal power or restore cumulahve SR 3.2.3.1
- penalty deviahon time to less than one (1) are not met. A . i survedance requerement to venfy that axial flux dsfference is withwi lemets for each excore channel every seven (7) days was added ,
r 3.2 M19 The requwements for the accumulation of penalty deviaison time LCO 3.2.3 3.10.2.8 were extended to apply to greater than or equal to 50% rated -; thermal power rather than greater than 50% rated thermal power as previously requwed.
'f 3.2 M20 A requirement was added to log axial flux difference once withen 15 SR 32.32 3.10.2.10 i musules and every 15 rmnules thereafter when the axial flux -i difference alarms are out of service and the reactor is 2 90% rated j thermal power or 0.9 APL .! !
3.2 M21 The time allowed after refuehng to perform the survedance SR 3.2.3.3 3.10 2.1.1 -6
- requwemerd to determene the target flux difference of each excore channel was limited to 31 EFPDs. No time limit existed previously i t
I ! LCO 3.2.4, " Quadrant Power Tilt Ratio" y An ew1W from 6 . ..,g Quadrant PowerTilt Rabo (QPTR)
^
- 3.2 M22 LCO 3.2.4 3.10.3.1 ,
l requerements dunne physics tests was deleted. 'j l' 3.2 M23 An allowed time to restore QPTR to within Iwats without talung any LCO 3.2.4 - 3.10.3.1- , l other tchons was ehminated. f w-%- _
, _ _ _ _ ._____,,\---. _ _ _ _ _ _ _ _ _ , _ _ _ _ _ _ _ _ _ _ _ , _ _ _ _ _ . _ _ _ . , _ _ _ . _ . . _ .
-i TABLE M - MATRIX OF MORE RESTRICTIVE CHANGES j SECTION 3.2, " REACTIVITY CONTROL SYSTEMS" page 5 of15 4
- rme.% og . Susumery of Change ITS Section CTS Section Che<ee -
t 3.2 M24 The time allowed to reduce thermal power wtaen QPTR is in excess LCO 3.2.4 Requred 3.10.3.1- ' of Imts was hmded to two (2) hours. No time limit previously Achons A.1 easted .j 3.2 M25 The requred power rd% when QPTR exceeds Ints was LCO 3.2.4 Requred 3.10.3.1 j j mcreased from two (2) percent for each percent that QPTR ==emade Achon a.1 j 1.02 to three (3) percerd for each percent that QPTR exceeds 1.02. Requrements were added where none omsted pnmously as 3.10.3
- 3.2 M26 ~ LCO 3.2.4 F follows The QPTR is requred to be s; 1.02. If QPTR is not wdhm Requred Actions A.2, '
i the limit the QPTR is requred to be determined once per 12 hours A.3, A.4, A.5, and A.6 ] and then.ml power further reduced by 2 3% for each 1% that QPTR SR 3.2.4.1
- is greater than 1.00, the hot channel factors are required to be SR 3.2.4.2 l
, venfied withm limds withm 24 hours and once per seven (7) days . 2 thereanor, the safety analyses are requred to be reevaluated for i . contmuous operabon prior to increasing thermal power above the restncted levels, the excore detectors are requred to be normahzed to show zero QPTR prior to increasing power above the resencted } levels, and the hot channel factors are requred to be venlied within > l- Imts withen 24 hours of reachmg rated thermal power or withm 48 1
- hours of increa4mg thermal power above the resencted levels. ! j Survesilence requrements were added to venty that QPTR is withm l:
the limit by chatson every seven (7) days and once wdhen 12 '! hours and every 12 hours thereafter when the QPTR alarm is out of i sonnce and to venfy QPTR is withm the limit w ising the incore ! detectors once within 12 hours and every 12 hours 2 weaner when ! one or more power range neutron flux channels are ' . operable and j thermal power is > 75% rated thermal power .; 4 0
- i
TABLE M - MATRIX OF MORE RESTRICTIVE CHANGES SECTION 3.2, " REACTIVITY CONTROL SYSTEMS" page 6 of 5 Discussion of 9may of Change ITS Section CTS Section ' Change 3.2 W127 Requrements were added for the surveillance requwement in the SR 3.2.4.1 1.8 conddion when one excore detector is out of serwce, that the remawung three excore detectors may be used to calculate QPTR if reactor power is less than 75% rated thermal power. No power restriction prewously appleed 4 t i b
e 1 TABLE M - MATRIX OF MORE RESTRICTIVE CHANGES SECTION 3.3, "INSTREMEP \ TION" .page71.of 9 rme.==% of S- --- rp of Change ITS Section CTS Section l j Change LCO 3.3.1, "RPS Instrumentation" 3.3 M1 Trip setpoents have been specded in accordance with the hcensee LCO 3.3.1 2.3.1.2 setpomt methodology procedure. The setpomis are more Table 3.3.1-1 2.3.1.3 restnctive. Funcbons 2, 3,4.a. 4.b, 5, 6, 7, 8, 9,11, t 12,13,14,15 & 17 3 3 M2 The allowed time for an inoperable channel was restncied LCO 3.3.1 Requwed 3.5.1.5 immodately where no allowed time was previously specded. Achons A and I . Table 3.5-2 i Achon 4 i l 3.3 M3 When the requwed number of source range monitors cannot be met. LCO 3.3.1 Requwed Table 3.5-2 ; requwements were added to suspend actmties mvolving posstive Achon L Achon5' rsectMiy addebon wnmediately, arxi to close unborated water source isotahon valves in one (1) hour. j 3.3 M4 The allowed time before the unit must be shut down when an LCO 3.3.1 Requwod 3.0 .
- moperable channel is not placed in trip was reduced from eight (8) Achon D & E Table 3.5-2 hours to six (6) hours Achon 6 3.3 M6 A requwement was added to reach MODE 3 in 12 hours for an LCO 3.3.1 Requwed Table 3.5-2 i inoperable excore channel. Action E Table Notebon
- ACTION 2.b 3.3 M7 Requwements were added to require the unit be placed within either LCO 3.3.1 Requwed Table 3.5-2
l the range of the source range instrumentation or the power range Achon F ACTION 3.b mstrumentation withm two (2) hours i L !; i l
. . - - .. - .-. . . = . - . . . ~
t TABLE M - MATRIX OF MCSE RESTRICTIVE CHANGES
- , SECTION 3.3, " INSTRUMENTATION" page 2 of 9f rh==% of Summary of Change ITS Section CTS Section !
Change .; 3.3 M8 The allowed time to restore an inoperable channel of automahc trip LCO 3.3.1 Requwod 3.10.5.2 ,
- l. logic to OPERABLE status was restricted to six (6) hours from 12 Achon Q and R -;
i hours and if not restored, the allowed time to reach MODE 3 was ; j restncied to six (6) hours from eight (6) hours The allowed time to ! i restore an inoperable reactor trip breakers (RTBs) to OPERABLE status was reduced fmm 12 hours to ono (1) hour ar'<1 if not restored, the allowed time was reduced from eight (8) hours to six ,- (6) hours to place the unit in MODE 3. j 3.3 M9 The requ'.rements for the reactor protechon system (RPS) were LCO 3.3.1 Requwed 3.10- i encreased to include the RTBs, RTB UV & shunt trip mecharusms Achon C & V; Table and Automahc Trip funchons in MODES 3,4 and 5 including 3.3.1-1 Funcbons 18, i associated requirements when the RTBs are closed 19 8.20 , 3.3 M10 The allowed times when the RTB trip mecharusm is inoperable were LCO 3.3.1 Requwed 3.10.5.3 limited to mquwe the unit be placed in MODE 3 in 54 hours and RTS Acton U .i opened within 55 hours instead of hot shutdown vnthen 56 hours i i 3.3 M11 Requwements were added for two inoperabie source range LCO 3.3.1 Requwed 3.10: ! l instruments; one inoperable P-6 or P-10 interlock; one inoperable P- Actions J S, T and V
- 7. P-8 and turtune wnpulse pressure interlock; and two inoperable RPS trains .
i
.1~ e f
3.3 M12 Allowable Values were established that are more restnctrve than the LCO 3.3.1 3.10' current technical specifications for RPS Instrumentation, ESFAS Table 3.3.1-1 Instrumentation and AFW System instrumentation in accordance , with the Ow+aiiy setpoent methodology. 3.3 M13 Requwements added for reactor coolant pump breaker posdion Table 3.3-1 Funcbons 3.10 (single loop and two loops); safety injechon input from ESFAS; and .10,16 & 17 RPS interiocks for intermediate range neutron flux, P-7, P-8, P-10 and turtune amoulse pressure. _ i g y L., 9rm .< i,,,f4 , g 2i_
TABLE M - MATRIX OF HORE RESTRICTIVE CHANGES SECTION 3.3, " INSTRUMENTATION" page 3 of 9 Discussion of Summary of Change ITS Sechon CTS Sechon Change 3.3 M14 Survei!!ance requirements were added requiring companson of SR 3.3.1.3 Table 4.1-1 incore measurement results to NIS axial flux difference and SR 3.3.1.6 calibration of the excore nuclear instrument channels to agree with SR 3.3.1.1 OTaT and OPaT functions. Survei!!ance requirements were added SR 3.3.1.8 requiring CHANNEL CHECKS, Channel Operational Tests (COTS) SR 3,3,1,11 and CHANNEL CAllBRATION for the Power Range Neutron Flux- SR 3.3.1.13 Low function. Surveillance requirements were added requiring a SR 3.3.1.14 TADOT for the Reactor Coolant Pump (RCP) breaker position, Surveillance requirements were added requiring a COT for the RPS interlock fenction P-6 P-8 and P-10 functions. Safety injection (SI) input from ESFAS functions and the RPS P-7 interlock. 3.3 M15 Surveillance Frequency requirements were added for a COT of the SR 3.3.1.8 Table 4.1-1 Nuclear Intermediate Range and Nudear source range items 2 and 3 instrumentation to include within four (4) hours after reducing power below P-10, within four (4) hours after reducing power below P-6 if the COT has not been performed in the previous 92 days, and every 92 days thereafter. 3.3 M16 A surveillance requirement was added to perform a CHANNEL SR 3.3.1.11 Table 4.1-1 CALIBRATION for the Nudear Intermediate Range and Nuclear items 2 and 3 Source Range instruments every 18 months. 3.3 M17 Surveillance requirements were added to perform a TADOT for the SR 3.3.1.15 Table 4.1-1 Turbine Trip Logic prior to startup if not performed in the previous SR 3.3.1.10 Item 22 31 day; and a CHANNEL CALIBRATION every 18 months. 3.3 M18 Surveillance requirements were extended to apply to MODES 1,2, SR 3.3.1.5 Table 4.1-1 3,4, and 5 when the RTBs are closed for performance of an item 27 ACTUATION LOGIC TEST every 31 days on a staggered test basis. The previous requirement required a similar surveillance during hot shutdown and power operation only.
_ . _ ._ . _ _ _ _ _ _ . . . . .. . _ . , - - . . _ _ . _ _ . . _ _ .._ . . - _ . . . . .m . . _ _. . l
]
H tam.R M - MATRIX'OF MORE RESTRICTIVE CHANGES .i ! SECTION 3.3, "INSTREDENTATION" page.4 of.:9 Discussion of Summary of Change ITS Secelon CTS Secelon j Change i . ' 3.3 M19 Survedlance requerements were extended to apply to MODES 1,2 SR 3.3.1.5 Table 4.1-1 , 3,4, and 5 when the RTBs are closed for performance of an SR 3.3.2.2 Item 27 " ACTUATION LOGIC TEST every 31 days on a staggered test bases. The previous requirement requred a serrular survedlance prior to , i startup when not tested in the previous month 3.3 M20 Trip setpoint values were added for intermediate range neutron flux, _ LCO 3.3.1 2.3.1 i- source range neutron flux, steam generator water level and turbine Table 3.3.1-1 Funchon l trip (low oil pressure and turtune stop valve dosure 3,4.14 and 15. 3.3 D1 Surveillance requerements were added to perform a CHANNEL SR 3.3.1.1 TableA1-1 ' CHECK for Steam /Feedwater Flow Mismatch and Low Steam items 30 and ' Generator Level 40 i j 3.3 M49 The allowed time to place the plant in MODE 3 was reduced from LCO 3.3.1 Requesd Tabis 3.5-2 eight (8) hours tow' w =' ^ _", open the RTBs. Achon J.1 Reques l Achons 4, 5, 8 l 3.3 MSO The requirements for Reactor Coolant Flow - Low, smgle loop, trip LCO 3.3.1 Table 3.5-2 l l were extended to apply to the range of MODE 1 power operabon Table 2"L.1-1 Funcaon Funchon 10A i between the P-8 setpoint at approximately 40% rated thermal power 9. Foob.de (g) ,[ (RTP) and 45% RTP. LCO 3.3.2, "ESFAS Instrumentabon" 'f 3.3 M1 Trip setpoints have been specdied in accordance with the licensee LCO 3.3.2 Table 3.5-1 ; , setpomt methodology procedure. The setponts are more Table 3.3.2-1 leems 1,2,3,' ! restnctive Funcbons 1.c,1.d, i.e, 4, and 5 ' ; j 1.f.1.g. 2.c 3.b.3, 4.c, 3 4.d. 4.e & 6 a I i i i
"f 1 I
~. . ~ . - - ~ . , . .
TABLE M - MATRIX OF MORE RESTRICTIVE CHANGES SECTION 3.3, " INSTRUMENTATION" page 5_of 9 Discussion of Summary of Change ITE Section CTS Sectson Change 3.3 M2 The allowed time for an inoperable channel was restricted LCO 3.3.2 Requwed 3.5.1.5 immediately where no allowed time was previously specifHxt Action A Table 3.5 2 Achon 4 3.3 M12 Aliowable Values were established that are more estrictive than the LCO 3.3.2 N/A current "echnical specifications for RPS Instrumentation ESFAS Table 3.3.2-1 Instrumentation and AFW System Instrumentation in accordance with the company setpoint methodology ; 3.3 M19 Surveillance requirements were extended to apply to MODES 1,2, SR 3.3.2.2 Table 4.1-1 3, and in one case MODE 4 for performance of an ACTUATION Item 27 i LOGIC TEST every 31 days on a staggered test basis. The previous requirement required a similar surveillance prior to startup when not tested in the previous mondi. 3.3 M22 The allowed time to reach MODE 3 was limited to six (6) hours LCO 3.3.2 Requred Table 3.5-3 - rather than eight (8) hours as was previously required for an Actim B ACTION 11 I inoperable channel or train of the manual Si actuation function and the Manual Containment Phase A isolation function t 3.3 M23 The allowed time to reach MODE 3 was limited to six (6) hours LCO 3.3.2 Requwed Table 3.5.3 rather than eight (8) hours and to reach MODE 5 was limited to 36 Actions C, D, E, and G ACTION 12 hours rather than 38 hours for inoperable channels in which the time to place the channel in trip cantml be met. 3.3 M24 The allowed time to reech MODE 3 was limited to seven (7) hours LCO 3.3.2 Requwed Table 3.5-3 i rather than eight (8) hours and to reach MODE 5 was limited to 37 Action i Item 2.a hours rather than 38 hours for an inoperable marwal initiation ! channel in which the time to restore the channel to operable status cannot be met.
TABLE M - MATRIX OF MORE RESTRICTIVE CHANGES SECTION 3.3, " INSTRUMENTATION" page 6 of 9' Discussion of Summary of Cher.ge ITS Section CTS Section Change 3.3 M25 The allowed time to reach MODE 3 was limited to six (6) hours LCO 3.32 Requesd Table 3.5-4 rather than 24 hours plus the time required to bring the plant to hot Achon F ltem 2.d shutdown utdizing normal operatog procedures when a channel of main steam line isolabon is not restored to OPERABLE status in the requaed time penod The allowed time to reach MODE 4 was limited to 60 hours rather than 72 hours when a channel of main steam line isolabon is not restored to OPERABLE status in the requwed time penod 3,3 M26 The allowed time between surveillances for the containment SR 3.32.6 Table 4.1-3 isolabon trip funcbon were limited to 18 months rather than refLeling ite m 5 interval. The length of time between refueling irdervals was not speedied in the previous requirements. 1 3.3 M27 Requirements were added for one inoperable channel of Pressunzer LCO 3.32 Requred Table 3.5-4 Pressure-Low and T,-Low interlock to verify the interiocks are in Achon H requwed state. SR 3.311 Surveellance reqiarements were added to perform 4. CHANNEL SR 3.323 ' CHECK, MASTER RELAY TEST, SLAVE RELAY TEST and SR 3.3.2.4 CHANNEL CALIBRATION on ESFAS instrumentahon. SR 3.3.2.5 Requaements added for the setpoints for ESFAS m ' terlocks wtuch SR 3.3.2.7 did not exist previously. Table 3.32-1 Item 6
+
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t 4 if y TABLE M - MATRIX OF MORE RESTRICTIVE CHANGES l SECTION 3.3, "INSTRIDGENTATION" page 19 'of.i9- '
-l 1 i rm-=% of ' Sununary of Change ITS Secean CTS Section ;
- Change i j LCO 3.3.7, "CREFS Actuabon Instrumentatun" l
- j. 3.3 M43 Requwements were added for the CREFS Actuabon instrumentabon LCO 3.3.7 3.5'
' l System No requwements emsted pnmously j LCO 3 3.8, "AFW System Instrumentabon" i i 3.3 M12 Allowable Values were established that are more restnctive than the LCO 3.3.8 TatWe 3.4-2 current technscal specificahons for RPS Instrumentabon, ESFAS Table 3.3.8-1 j instrumentabon and AFW System instrumentabon in accordance with the company setpoent methodology 'l ]- 3.3 M44 A complebon time to reach MODE 3 was imposed of six (6) hours LCO 3.3.8 Requwod Table 3.4-1 ! and a requwement was added to reach MODE 4 was imposed of 12 Achon D & E Note 2 ; i hours rather than no =-+r':J ; hmes for either MODE, when AFW pump start instrumentation is not restored to OPERABLE status - . withen requwed time of 48 hours ; 3.3 M48 The complebon time to reach MODE 3.was reduced to six (6) hours LCO 3.3.8 Required TatWe 3.4-1 ; from eight (8) hours and a requwement was added to reach MODE 4 Achon B Note 1 -, in 12 hours when AFW undervoltage ch::nnel instrumentabon is not restored to OPERABLE status withen requwed time of 48 hours
- 3.3 M51 The allowance for one channel of steam generator waster low low ' LCO 3.3.8 Table 3.4-1 :l l level to be inogKrable conhnuously was elemonated and an allowed Table 3.3.8-1 Functon Funcison 1 outage time of for one inoperable channel was imposed 1 I
i.
. . . ,- ._~ .
_, . . . . - . - . = - - . - _ . - . ~ - - - . - . . - . [ < i' : i . TABLE M"- MATRIX OF MORE RESTRICTIVE CHANO S' ! ! 'SECTION 3.4, " REACTOR COOLANT STSTEM* page 1 of'11I ' g rme===iani of : Sununary of Change U
- Change .!
i LCO 3.4.1, "RCS Pressure, Temperature, and Fkwr Departure from Mw4aste Boshng (DNB) Lauts" ! 3.4 M1 A new specificehon for Reactor Coolant System (RCS) pressure, LCO 3.4.1 3.1 j temperature and flow to be within iets was mMarf No l regurements for these values prewously emsted. i LCO 3.4.2, "RCS Minimurn Temperature for Cr%r ;
- 3.4 M2 The asowed mwumum temperature for enhcably was limsted to LCO 3.4.2 - 3.1.3.2 ;
i greater than or equal to 530"F. Lower temperature values for .t minimum temperature for enhcahty were previously allowed i 3.4 M3 The time requwed to reach subenhcal condshons when the reactor is LCO 3.4.2 3.1.3.2 ! cnhcal and the mensmum temperature for cnhcahty was not met was Requwed Achon A.1 -{ !: restncted to 30 nunutes from the previous requrement of 8 hours ! A survesilence requrement to venly that the mwumum temperature ; for enhemisty is met was added ; i 3.4 M4 Requirements were added for failure to meet RCS Pressure RCS LCO 3.4.3 Requesd 3.1.2.1 ] Temperature, and RCS Heatup and raaMawn rate iwnit to restore Actons A.1, A.2, B.1, .. parameters to within hmds in 30 minutes, to detomune it the RCS is B.2 C.1, and C.2 [ acceptable for conhnued operahon, to bring the unit to MODE 3 in 6 SR 3.4.3.1 ! 7 hours and MODE 5 with RCS pressure less than 400 psig in 36 i hours if compiehon twnes are not met, and to restore parameters to withen iets 'T.T
. 'M::, and determine if the RCS is arcardshia for <
- conhnued operahon prior to entenng MODE 4 when the unit is not in
- MODES 1,2,3, or 4. A surveellance recurement was added to :
!- venfy that RCS pressure, RCS temperature, and RCS heatup and '{ i cooldown rates are wittun hmds every 30 nunutes dunng RCS l heatup, RCS cooldown and RCS inservice and hydrostahc teshng I LCO 3.4.4. "RCS Loops-MODES 1 and 2 - j
.i
.. i
-{
_ . . _ _ - _ __ _ ,_. ~ . _ .
TABLE M - MATRIX OF MORE RESTRICTIVE CHANGES SECTION 3.4, " REACTOR COOLANT SYSTEM" page 2 of 11 Discussion of Summary of Change ITS Sechon CTS Sechon Change 3.4 MS The requirements for maintaining three RCS loops operable and in LCO 3.4.4, Appbcabikty 3.1.1.1 operation were extended to apply to MODES 1 and 2, rather than 3.3.1.1 only to power operation as previously existed. 3.4 M6 The time requirement to bring the unit to MODE 3 was reduced to 6 LCO 3.4.4 Requred 3.1.1.1 hours from 8 hours and a surveillance requeement to verify that Action; A.1 each RCS loop is in operation every 12 hours was added SR 3.4.4.1 3.4 M7 The requirements for maintaining two RCS loops operable and in LCO 3.4.4 Applicabelsty 3.1.1.1 operation were extended to apply to MODE 3. rather than only to reactor power greater than or equal to 2% rated thermal power. , LCO 3.4.5, "RCS Loops-MODE 3" LCO 3.4.6, "RCS Loops-MODE 4" LCO 3.4.7, "RCS Loops-MODE 5. Loops Filled" LCO 3.4.8, "RCS Loops-MODE 5, Loops Not Filled" 3.4 M8 Reqtsrements are added to de-energize all control rod drive LCO 3.4.5 3.1.1.1 mechanisms immediately, suspend all operations involving a Requwed Action D.1, . reduction of RCS boron concentration immediately, and initiate D.2,D.3 l action to restore one RCS loop to operable status and operation SR 3.4.5.1 - immediately. Surveillance requirements are added to verify required SR 3.4.5.2 + RCS loops in operation, verify that steam generator secondary side SR 3.4.5.3 water levels are 2 16%, verify the.1he rod control system is not SR 3.4.5.4 capable of rod withdrawal when required, venfy that the reactor trip SR 3.4.5.5 breakers are open when required, and verify t!wt the lift disconnect SR 3.4.5.6 ; switches are open for all control rods not fully withdrawn when SR 3.4.5.7 required, all every 12 hours. 3.4 M38 A NOTE is added to the specifications that restricts operation with LCO 3.4.5 NOTE 3.1.1.1 less than two RCS Loops in operation under certain conditions to a LCO 3.4.6 NOTE 1 ; maximum of 1 hour. LCO 3.4.7 NOTE 1 ! r t
L 4 - L TABI2 M - MATRIX OF MORE RESTRICTIVE CHANGES SECTION 3.4, " REACTOR COOIANT SYSTEM"
'page 3 of'll rh* of ; Summary of Changs ITS Section CTSSeselon Change ,
3.4 M36 The requirement for two steam generators to be operable in MODE LCO 3.4.5 - 3.1.1.2.
- 3 is extended to apply to two RCS Loops which indudes two Reactor Coolant Pumps (RCPs).
f: 3.4 M9 The requerements for one RCS loops or RHR trains were resencted LCO 3.4.6, Applicatdity 3.1.1.1" to apply only to MODE 4 rather than for RCS temperature 2 200*F , and reactor power less than 2% rated thermal power as was previously requwed ; i 3.4 M1C The requwements for operable RCS loops and/or RHR trains in LCO 3.4.6 3.1.1.1 MODE 4 were extended to apply to two loops or trains, rather than to one RCS loop or RHR train as was previously requwed.
- . 3.4 M11 A requwement was added to inshete schon ;.. .+' "i to restore a LCO 3.4.6 Requwod 3.1.1.1 'i second RCS loop or RHR train to operable status if one requwed Actions A.1, B.1, C.1 1I loop or train is inoperable and one RCS toop is operable. A and C.2
, requirement was added to be in MODE 5 in 24 hours if one required SR 3.4.6.1, SR 3.4.6.2,
- loop or train is inoperable and one RHR train is operable. The time SR 3.4.6.3 .i allowed to restore one inoperable loop or train to operable status !
'~ was restncted to immediately, rather than 14 days as was previously -l allowed. The time allowed to suspend all operations wwolving j reduchon of boron concentrabon was restncied to .. .+' _^2;. i Surveellence requwements were added to venfy one RHR train or 1 RCS loop is in operahon every 12 hours, verify that the secondary side water levels are 2 16% for requwed RCS loaps every 12 hours, and to venfy correct breaker ahgnment and indicated power are .. i avadable to the recured pigns that is not in operabon every 7 days. ' L i l I. i 1 l
~ ~ - _
TABLE M - MATRIX OF MORE RESTRICTIVE CHANGES SECTION 3.4, " REACTOR COOIANT SYSTEM" page 4 of 11 Discussion of Summary of Change ITS Section CTS Section Change , 3.4 M12 A Note was added which restricted removal of both RHR loops from LCO 3.4.7 NOTE 4 3.3.1.4 operaton in MODE 4 during heatup to only when at least one RCS SR 3.4.7.1 loop is in operation. Survetitance requirements were added to venfy SR 3.4.72 that one RHR train is in operaton every 12 hours, verify that the SR 3.4.7.3 steam generator secondary side water level is 2 16% in the requwed steam generator every 12 hours, and venfy that the correct breaker alignment and indicated power are available to the requwed RHR pump that is not in operation every 7 days. 3.4 M14 Requirements were added to suspend all operations involving a LCO 3A.7 Requwed 3.3.1.4 reduction of RCS boron concentration immediately and initiate Actions B.1 and B2 acton to restore one RHR train to operable status and in operation LCO 3.4.6 Requwed immediately when required RHR trains are inoperable or no RHR Achons B.1 and B.2 train is in operation. 3.4 M15 A requirement for one RHR train to be in operation was added for LCO 3.4.7 3.3.1.4 MODE 5 specifications. LCO 3.4.8 3A M39 The time requirement to restore an inoperable RHR train to operable LCO 3.4.7 3.3.1 A status was restricted to immediately, rather than 14 days as was Requwed Achons A.1 prevously allovad A requirement was added to restore required and A.2 steam generator secondary side water level to within limits immediately if the water level is not within limits. 3.4 M16 Surveillance requirements were added to verify that one RHR train SR 3.4.8.1 3.3.1 A is in operation every 12 hours, and to verify that the correct breaker SR 3.4.82 alignment and indicated power are available to the RHR pump that is not in operation every 7 days. LCO 3.4.9. " Pressurizer"
TABLE M - MATRIX OF MORE RESTRICTIVE CHANGES SECTION 3.4, " REACTOR COOLANT SYSTEM" page 5 of 11 Discussion of Summary of Change ITS Section CTS Section Change 3.4 M17 The requirements for the pressurizer were extended to apply to LCO 3.4.9 3.1.3.4 MODE 3, rather than only to reactor subu u iity less than 1% as Appbcatnhty was previously required 3.4 M18 The tune to reach MODE 3 was limited to 6 hours and the time to LCO 3.4.9 Requred 3.'1.1.3 reach MODE 4 was limited to 12 hours when the pressurizer Actions D.1 and D.2 heaters and emergency power supplies cannot be restored vnthen the allowed times Completion times for these actions did not previously exist. 3.4 M19 Requerements were added to be in MODE 3 with the reactor trip LCO 3.4.9 Requeed 3.1.1.3 breakers open and to be in MODE 4 in 12 hours when the Achons A.1 and A.2 pressurizer water level is not withm limits. LCO 3.4.10. " Pressurizer Safety Valves" 3.4 M20 Requirements were added to restore one inoperable pressurizer LCO 3.4.10 Requred 3.1.1.3 safety valve to operable status within 15 minutes or if not restored Achons A.1, B.1 and within 15 minutes, orif two or more safety valves are inoperable, be B.2 in MODE 3 in 6 hours and MODE 4 in 12 hours. LCO 3.4.11. " Pressurizer Power operated relief Valves (PORVs)" t
(' 4 TABLE M --MATRIX OF MORE RESTRICTIVE CHANGES , l SECTION 3.4, " REACTOR COOLANT SYSTEM" page 6 of'll - ! Discussion of. Summary of Change ITS Soc 6on CTS Secten l Change , i- 3.4 M21 The time to reach MODE 3 was isted to 6 hours and the time to LCO 3.4.11 Requwod 3.1.1.5' reach MODE 4 was Imted to 12 hours when one or both Actons D.1, D.2, E3, pressunzer PORVs are inoperable and cannct be manusuy cycled. E4, G.1, and G.4 and me assocated block valves cannot be closed and power ., removed within one hour. The time to reach MODE 3 was Imted to 6 hours and the time to reach MODE 4 was hmded to 12 hours ; when both pressunzer block valves are inoperable and cannot be j manuaDy cycled, and the associated PORVs cannot be placed in .; i manual control in one hour or one block valve cannot be restored in 1 two hours. ' Cwi@h tsmes for these achons were provsously 12 ~ hours to reach MODE 3 and 24 hours to reach MODE 4. .> . 3.4 M22 A note was deleted that allowed power opershon to contmue with a LCO 3.4.11 3.1.1.5 j pressurizer block valve closed to isohde minor leakage from the associated PORV. ; 3.4 M23 An excephon to entenng requered actions when performing LCO 3.4.11 3.1.1.5 survesilence testeg on 4:e pressurizer PORVs and associated block
- valves was deleted ,
LCO 3.4.12, " Low Ten.perature Cu.pi-ssure Protection (LTOP) System" 3.4 M35 The setpoet for the LTOP System was lowered from 420 psig to LCO 3.4.12 3.1.2.1 400 psig with an allowable value of 418 psig. t !: 3.4 M24 The time allowert to depressunze the RCS and estabbsh a vent to LCO 3.4.12 Requred 3.1.2.1 the contamment when two PORVs are inoperable, or when LTOP Achon G.1 ;I cannot be restored to operable status as requwed, was restncted to j 8 hours rather than 12 hours as was previously recured _ i- ; I i i- r L . . . _ _ _ . . . - _1
. . . . . .. . - ,. .. . . . - - . - - - . . ~ . . - -.~~. - .. _ - .
l 1- TABLE M - MATRIX OF MORE RESTRICTIVE CHANGES SECTION 3.4, " REACTOR COOIANT SYSTDr' page 7 of~11? rhen* of Summary of Change ITS Secelen CTS Secaen . Change . .i , 3.4 M25 Requwements were added to the LTOP speedicahon as follows K LCO 3.4.12 Required 3.1.2.1 y , which did not exist prewously The accumulator ==rdahart valves are Actons A.1, B.1, C.1, , requwed to be closed and deactivated in accordance with condshons D.1, and D.2 in a NOTE. K two or more Safety injechon (SI) pumps are capable SR 3.4.12.1 ] , of infechng into the RCS with RCS temperature 2 175'F and the SR 3.4.12.2 RCS is not vented, smmediate schon must be taken to render one SI SR 3.4.12.3 1 pump srir =pahaa of injechng into the RCS. N one or more Safety . mjechon (SI) pumps are cap.ha. of injechng into the RCS with RCS temperature < 175'F and the RCS is not vented, smmediate achon must be taken to render all Si pump iriempshia of injechng into the , . RCS. N an accumubtor iend=hari valve is not closed and , , doenergized when requwed the valve is requwed to be closed and j doenergized in one (1) hour. ' N the accumulatos cannot be isolated ' withm one hour, the RCS is requwed to be heated up to > 350*F ,
- withen 12 hours or the accumulator is requwed to me depressunzed withm 12 hours. Surveillarice Requwements are added to venfy a '
mmomum of one (1) Si pump capable of'mpechng into the RCS + when requwed every 12 hours, venfy no Si pumps <- paha. of injechng into the RCS when requwed every 12 hours, and venty each accumulator isolabon valve is closed and -f: ::.e..p--j every i 12 hours ! j 3.4 M37 The necessary RCS vent size to the contanment to assure LCO 3.4.12 3.1.2.1 overpressure protechon for the RCS was speedied to be at least 4.4 i square anches No speedic vent size value was specdied previously i i 3.4 M26 An allowance to not render all but one Si pump irw'=pahaa of LCO 3.4.12 3.1.2.1 mjechng into the RCS when the RCS is vented to contanment s; atmosphere is deleted i LCO 3 4.13. "RCS Ooarabonal Lealume" ? i !
- . _ . . , . ., . . . . e
I ) 1 TABIZ M - MATRIX OF MORE RESTRICTIVE CHANGES j SECTION 3.4, " REACTOR COOLANT SY3 TEM" page 8 of 11 ! Discussion of : Summary of Change ITS Section CTS Sorten ; l Change I 3.4 M27 The time allowed to reduce RCS leakage (other tinn possure LCO 3.4.13 Requwed 3.1.5.1 I boundary lad age) to restore leakage to vnthm limds wa reducqui to Achons A.1, B.1, and 3.1.5.2 4 hours from 12 hour as was prevously asowed. The tem anowed B.2 to reach MODE 3 if leakage requwements cannot be met was reduced to 6 hours from 12 hours as was prewously allowed The ! time aEowed to reach MODE 5 if leakage requwements cannot be i met was reduced to 36 hours from 42 hours as was prewously a50wed i 3.4 M28 A requwement was added whsch permds no RCS pressure boundary LCO 3.4.13 3.1.5 leakage. ! LCO 3.4.14, *RCS Pressure Isolabon Valves (PfVs)* i 3.4 M29 A requwement in a NOTE was added that restncied separate LCO 3.4.14 3.1.5.4 condsbon entry to a PfV flow path rather than to a PIV, A Requwed Achon B.1 i requwement was adoed to isolate the affected penetrabon SR 3.4.14.2 ! assocaeled with an inoperable RHR System interlock wdhm 4 hours. A Surveillance Requwement was added to venfy that the RHR 4 System interlock p...,6 the valves from opensng on a simulated [ or actual pressurc 4;nal every 18 months 3.4 M30 The surveinance tr@srement to venfy P!V leakage was requwed to SR 3.4.14.1 Table 4.1-3, , be performed wdhe 24 hot.rs followog valve actuabon or flow item 17 l 1 through the valve. No prenous requwement emsted for the !
- condebon when a P!V aduated or flow occurred through a P!V.
i j l I.CC 3.4.15. "RCS Leakaoe C.: cst;c i instrumentabon- ! 3 l t i 1
. . ~ - - - - = . . -
l- - It . f TABIE M - MATRIX OF MORE RESTRICTIVE CBAgeGES SECTICIt 3.4, ' REACTOR COOUWET SYSTEM" page 9 of 11 l-
- ' t i i j h of Sumamery of Change ITS Seseen CTS Season 3
Change -! !- 3.4 M31, and E:; _,se were added for RCS Leekage Doeschon LCO 3.4.15, Roquesd 5.4.3 ! 3.4 M32 insommentehon as foGoes Only a surveEence requeoment for - Actons A.1. A.2,8.1.1, ! l RCS Leekage rim ,*nniinstrumentehon asessed m l: C.'A- l B.1.2, Bl.1,8.22, t requsement was added tut one coneemment sump level moneer, C.1, C.2. D.1, D.2, E1,
- l. one contenment memosphere r=rEa=r*wdy morvw (geneous or E2, and F.1 j penxadese), and one contenment fan conser condensene now race SR 3.4.15.1 4 mondor be operatWe. Requsements were added so perform an RCS SR 3.4.152
- weser swensory basence every 24 hours and ressore an inoperalde SR 3.4.15.4. i
! conseinment sump levet moneer en operande = udhm 30 days if SR 3.4.15.5 4 to sump level morneor is inoperalde. Requemments were added so ': 4 analyze grab samples of Wie contomment atmosphere every 24
- hours, perform an RCS water inwonsory beience every 24 hours, I' rednse requesd contenment almosphere r==Eamr* wily mondor no
[- operatde h wdhm 30 days and wordy that the contenment fan cooler condensene aan rase monsor is operande every 30 days if the ! contenment memosphere r=rEamr*wdy mondor is inoperalde. K We contenment fan coceer condensene now raea anoneeris inoperante,
- requeements were added so perform a diennel dieck of 9se l contanment almosphere r=rEamr* wily moneer every 8 hours, and j perform an RCS wolor wwensory beience every 24 hours. N both We F contenment atmosphere r% mondor and the contenment
! fan cooler andensate now rase monnor are inoperande,
- j. recurements are added so i
j
! t e
r ' i- I' l i j I . - __ _ . ____ _ . -_ __ _ _ _ . _ . _ _ _ _. _ _ _ _I
TABLE M - MATRIX OF MORE PESTRICTIW CHANGES SECTION 3.4, " REACTOR COOLANT SYSTEM" page 10 of 11 Discussion of Summary of Change ITS Sectron CTS Section Change 3.4 M31, and restore each monitor to operable status vnthm 30 days. If these 3.4 M32 acions cannot be met, requirements are added to be in MODE 3 in (Continued) 6 hours and MODE 5 in 36 hours if au recuired monitors ars inoperable, a requirement is added to enter LCO 3.0.3. Surveihnee Regtarernents were added to perform a channel check every 12 hours on the containment atmosphere radcactmty monitor, pmicsm a dennel operational test on the contsronent e^uiesp6 e radioactmty monitor every 92 days, and perform a Geru mi calibration on the containment atmosphere radioacimty rnonitor and contei.u nent fan cooler condensate flow rate monitor every 18 L months. l LCO 3.4.15, *RCS Leakage Detection Instrumentation" 3.4 M34 The anowed frequency requirements for sampling RCS specife LCO 3.4.16 Required 3.1.4 activity when the specific actmty limits are exceeded was limited to Acton A.1 once per 4 hours, rather than the frequency specifed in the survesitance rectarernent, as was previously allowed LCO 3.4.17. " Chemical and Volume Control System (CVCS)* 3 4 M40 A survei!!ance requirement was added to venfy seat ingecten flow 2 SR 3.4.17.1 3.2.5 6 gpm every 12 hours. 3.4 M41 The time allowed to reach MODE 3 when requirements for the LCO 3.4.17 Required 3.2.3 CVCS cannot be met was limited to 6 hours No time limit was Action C.1 previously specifed. 3.4 M42 Surveillance regtareinents were added to venfy seal injeCaun flow of SR 3.4.17.2 3.2.5 2 S gpm from each makeup water pathway from the RYST every 18 SR 3.4.17.3 months and to verify 300.000 gaHons of water in the RVGT every 7 days.
i i : p
- i. :
a . TABEK M MILTRIX OF tOftE IEESTRICTIVE -* ; , SECTIcet 3.4, "ItEACTOst r'rirtraaIT SYSTEBr" page 11 of 11 [ I-i I. mt e Susumery at Change ITS Soseen CTS Seedse '[ ' p Change ! 3.4 M43 A requwement that the RCP seal invar*rwi be operaide was added. LCO 3.4.17 - 3.2.2 ' 'f 4 ; I 3.4 h Requirements were added as fotows. When seal ingschon to any LCO 3.4.17 Rogered 3.2.3 j p. y RCP is not witun limits or boti requwed diaryng pumps are inoporelde, achon is requwod unmediately to resteve seat ingschon to Actons D.1, D2, D.3, E1, E2, E3, F.1, and j the RCP and tie unit is requwod to be placed in MODE 3 in 6 hours F.2. .
- l. and to cool down and depressunes the RCS to < 1400 peig vetun i 12 hours. When seal ingschon to any RCP is not wiWiwi limits or at i
- .. I-f one diaryng pump is inoperable, admon is requwed l immediately to restore seal insechon to the RCP and the unit is ;
l' requwed to be placed in MODE 3 in 6 hours and in MODE 5 in 36 'i j hours. If boti makeup water postways from the RWST are j l wioperable,3:e unit is requwed to be pieced in MODE 3 in 6 hours - !. and in MODE 5 in 36 hours i i a i 3.4 M45 The time agowed to reach MODE 5 when the requwements for CVCS cannot be met were resended to 36 hours. No time limit LCO 3.4.17 Requwed Acton Cl - 3.2.5 li ! esosted pmviouser i , r 4 3.4 M46 An agowance to adond the agowed bmes for CVCS for extended LCO 3.4.17 3.2.4 , mentononce purposes beyond the kmes requwed in Sie speedicatens was deleted. t 1 s 3
..=_- -. ..- -- - - . -. - . - . . . . - ..- - . - - .. _ ... -. - _
TABLE M - MATRIX OF PORE RESTRICTIVE CHANGES SECTION 3.5, " EMERGENCY CORE COOLING SYSTEMS (ECCS) " page 1 of 4 Discussion of Summary of Change ITS Secbon CTS Sechon Change LCO 3.5.1, "Accurnu!ators" 3.5 M1 Requirements for the accumulator were extended to apply to LCO 3.5.1 ApprWMty 3.3.1.1 MODES 2 and 3 with pressurizer pressure greater than 1000 psig rather than to reactor entical as previously required. 3.5 M2 A requirement to verify the posrtion of the accumu!ator isolation SR 3.5.1.1 3.3.1.1 valves once prior to removing power from the valves was added to SR 3.5.1.5 the surveillance requirements for the accumulator isolatron valves. A frequency of 31 days was imposed on the surveiBance requirement to venfy power is removed from the accumulator isolation valves. No survei!!ance frequency previously existed. 3.5 M3 A frequency of 12 hours was imposed on the surveinance SR 3.5.12 3.3.1.1 requirements to venfy minimum accumulator pressure and SR 3.5.1.3 contained borated water. No su.wei!!a.w frequency previously existed. 3.5 M4 The time to reach MODE 3 was limited to 6 hours in the required LCO 3.5.1 Required 3.3.12 action for the accumulators specrfication. Completion times for Action D.1 these actions did not previously exist. 3.5 MS The time to reach MODE 4 with pressurizer pressure s 1000 psig LCO 3.5.1 Required 3.3.1.2 was limited to 12 hours in the required action for the accumulators Action D2 specification. Completion times for these actions did not previously exist. 3.5 M7 A requirement was added to enter LCO 3.0.3 immediately in the LCO 3.5.1 Required 3.3.12 event that two or more accumulators are inoperable. The allowed Action E.1 time to reach MODE 3 in this condition was therefore limited to seven (7) hours rather than eight (8) hours as was previously required.
k TABLE M - MATRIX OF MORE RESTRICTIVE CHANGES SECTION 3.5, " EMERGENCY CORE COOLING SYSTEMS (ECCS) " page 2 of 4 Dr'e===3*=t of Summary of Change ITS Section CTS Section Change 3.5 M8 A requrement was added to venfy accumulator boron concentrabon SR 3.5.1.4 Table 4.1-2 wenn Imts once within six (6) hours after each solubon volume item 6 increase of 2 70 gallons that is not the result of addsbon from the RWST. , 3.5 M9 Requrements were added to venfy that the accumulator boron SR 3.5.1.4 Table 4.1-2 concentrabon is 21950 ppm and s 2400 ppm when performeng the item 6 survesilance requirement for the accumulators. No maximum requrement existed previously. 3.5 M10 The maximum allowed time between poducinence of the SR 3.5.1.4 Table 4.1-2 ' survesitance requrement for venfyrig accumulator boron item 6 concentrabon is wenn limits was Imted to 39 days ather than 45 ! days. ! LCO 3.52, *ECCSoperating" 3.5 M11 A surveillance requrement was added to venfy by visual rispechon SR 3.52.6 3.3.1.1 the ECCS train containment sump suchon inlet is not restricted by debris and the suchon inlet trash racks and screens show no l evidence of structural distress or abnormal corrosson every 18 months. 3.5 M12 A surveillance requrement was added to venfy that manual valve SR 3.52.8 3.3.1.1 l RHR-764 is locked in the open posdson every 92 days. 3.5 M22 The requirements for removmg control power ard air from certam SR 3.5.2.1 3.3.1.1 ECCS valves were extended to apply to MODES 1,2. and 3. rather SR 3.52.7 i than to plant condsbons with RCS pressure greater than 1000 psig a as was previously recured i [ t I
_ . ,. -~ .- . -. .. . . . . . . . . .. . . - . _ . . . . . . , [t i b- TABIZ M - MATRIX OF MOEEE RESTRICTIVE CHANGES [ N SECTICBE 3.5, "EDERGDICY Cong tvirw.n0G SYSTDS (ECCS) " .page 3 of 4- i L [: . !: af' Seoussary of Change ITS SeeMon CTS Seseen i j ChanSe f SR 3.514 !? 3.5 M13 The eBowsed time behseen sunmaance requwements were limited to 4 1 1.1 ; j; 18 monts rather men refusiing interval. The longen of time SR ? 515 l [- "nehusen refueling intervals was not spoosed in wie previous i:; LTet. f 3.5 M14 A surveiBonce requwement ives changed to reques that the SR 3.515 4.5.1.2 I j: appropnote ECCS pump starts. rather Wien wie appropnete ECCS j , pump twenioresones.
- i. . .. I j, 3.5 M1d A requwement was added to venty tuvo addemonal high head SI SR 3.511 4.511 i
- valves in tie open poseen witt me control poseer to tie operate s i .- removed every 12 hoes. L i
! LCO 3.5.3, *ECCS-Shutdousi" i 1 i 3.5 M11 A surveinance regurement to meet surveinance requsements SR ' SR 3.5.3.1 ! 3.3.1.1 l 3.5.2.3 and SR 3.516 was added to tie W for ECCS SR 3.516 dunne shutdown. .{
- i j; 3.5 M17 Roquemments were added to restore requesd high hood myoction LCO 3.5.3 Reqused 3.3.1.2 subsystem to operable status wdhwi one (1) hourwhen ese regured Achons B.1 and C.1
! high heed inpocton subsystem is inoperaldo, and if not restored
- l. wilhet tie time limit, to be in MODE 5 in 24 hours. The eNoct of tiis ;
i- change is to resenct sie time to reach MODE 5 to Sve hours less 4 then ;2=_W aBoused. l' 3.5 M16 A Surveigence Requwement to venfy speedied vahes are in tie SR 3.5.3.1 4.512 l correct oosten was adonded to assiv to MODE 4. i ' l l 1 r l i, - ' I-1
-.m._... -_.. .-,-..._,...~....m.. . . - . _ . . _ ~ . . , . . , . - . . - . - . - , . . . -
_ .- ....-...._-_.r .. , . . - , . _ _ . _ . _ . _ - , _ _ _ . _ _ . . . _ . _ . . . . _ . , . _ . .
TABLE M - MATRIX OF MORE RESTRICTIVE CHANGES SECTION 3.5, " EMERGENCY CORE COOLING SYSTEMS (ECCS) " page 4 of 4 Descussion of Summary of Change ITS Sectson CTS Section Change LCO 3.5.4. "Refueing Water Storage Tarr 3.5 M18 Requrements were added to restore an inoperable RWST to LCO 3.5.4 Requred 3.3.1.1 operable status wittwn one (1) hour. The time to reach MODE 3 was Achons B.1, C 1, and fernsted to 6 hours and the time to reach MODE 5.eas Imted to 36 C.2 i hours when the RWST cannot be restored withm one (1) hour. The t effect of this change is to restnct the trne to meet appiscable l MODES to one less hour than premously allowed. l 3.5 M19 A survealiance requirement was added to venfy the RWST borated ' SR 3.5.4.1 3.3.1.1 water temperature is > 45'F and < 100*F every 24 hours ; 3.5 M20 The allowed time between survesRance requrements for the RWST SR 3.5.4.3 Table 4.1-2 ' boron concentrabon was restncted to 7 days rather than 10 days as item 3 was previously requeed. Previously there was no requrement on maxrnum boron concentrabon 3.5 M21 Requirements were added to the survedlance requrement to venfy SR 3.5.4.3 Table 4.1-2 that boron concentration is withm 2 1950 ppm and 5 2400 ppm in item 3 the RWST. 3.5 M23 An allowance to permit any S1 flow path to be isolated for Pressure LCO 3.5.2 3.3.1.1.e isolation Valve testing was restricted to apply to only to isolabon of a Appbcability cnid leg safety i' decucn flow path as opposed to any one Si or RHR " f.ow path as prevxrasly allowed. l
- i t I
TABLE M - MATRIX OF MORE RESTRICTIVE CHANGES SECTION 3.6, " CONTAINMENT SYSTEMS," page 1 of 6 Discussion of Summary of Change ITS Section CTS Sechon Change LCO 3.6.1, " Containment
- 3.6 M1 Requrements were added to restore an inoperable containment to LCO 3.6.1 Requeed 3.6.1 operable status within one (1) hour. The time to reach MODE 3 was Acbons A.1,8.1, and limited to 6 hours and the tune to reach MODE 5 was time.ed to 36 B.2 hours when the containmeni cannot be restored within one (1) hour.
The effect of this change is to restrict the time to rneet applicable MODES to one less hour than previously allowed LCO 3 6.2, "Contaatment Air Lock" 3.6 M2 Requirements were added for when one cont &rwent air lock door is LCO 3.62 Requaed 3.6.1 anoperable to venfy the operable dooris dosed wrthin one (1) hour, Actions A.1 A2, and lock the operable door dosed within 24 hours and venfy the A.3 operable door is locked dosed once per 31 days. 3.6 M3 Requirements were added for when one cent &went air lock LCO 3.62 Required 3.6.1 mechanism is inoperable to venfy an operable door is dosed within Actions B.1, B.2, and one (1) hour, lock an operable door dosed wrthen 24 hours and B.3 venfy an operable door is locked dosed once per 31 days. A survei!!ance requirement was added to venfy that only one containment air lock door can be opened at a time every 24 months. 3.6 M6 Requirements were added for when the containment air lock is LCO 3.62 Required 3.6.1 inoperable for reasons other than an inoperable door or lock Acbons C2 and C.3 mechanism to venfy a door is dosed in the air lock with:n one (1) hour and restore the air lock to operable status within 24 hours 3.6 MS When requirements for the containment air lock cannot be met, the LCO 3.62 Required 3.6.1 time to reach MODE 3 was limited to 6 hours and the time to reach Actions D.1 and D2 MODE 5 was limited to 36 hours, rather than 8 hours and 38 hours, respedively. as was previously recuired
TABLE M - MATRIX OF MORE RESTRICTIVE C5iANGES SECTION 3.6, " CONTAINMENT SYSTEMS," page 2 of 6 Descussson of Summary of Change ITS Section CTS Sectson Change LCO 3.6 3 *Contamment isolation Valves
- 3.6 MS A rec,uirement was added to place the plant in MODE 3 within 6 LCO 3.6.3 Reqtared 3.6.3 hours in ue event that the requien=nts for inoperable contamment Acbon D.1 isolation valves cannot be rnet. No previous require nent to reach MODE 3 existed.
3.6 M7 Requeements for inoperable automate e- *2 :. ment isolation valves LCO 3.6.3 Required 3.6.3 were extended to apply to manual valvu Achons A.1, B.1, and C.1 3.6 M8 An allowance to use a check va!ve to isolate an incpwir.ble LCO 3.6.3 Requred 3.6.3 penwit ison wrth only one isolation valve and a closed system was Achon C.1 deleted. 3.6 M9 The allowed outage time for two inoperable containment isolation LCO 3.6.3 Requred 3.6.3 valves was reduced to one (1) hour from four (4) hours Action B.1 3.6 M10 Requiren ents were added to venfy the affected contr.uvnent LCO 3.6.3 Requred 3.6.3 penetration flow path is isobted every 31 days when an inoperable Achons A2 and C.2 containment penetration has been isolated in accordance with requirements. 3.6 M32 The time to reach MODE 3 was limited to 6 hours and the time to LCO 3.6.3 Condsbon D 3.6.4 reach MODE 5 was limited to 36 hours when both the 6* and 42" purge valves are discovered open, rather than 8 hours and 28 hours, respectively, as was previously required. 3.6 M11 The allowed time between surveillances for the containment SR 3.6.3.5 Table 4.1-3 isolation valses were limited to 18 months rather than refueimg ite m 5 interval. The length of time between refue!ing intervals was not specified in the previous requirements.
TABLE M - MATRIX OF MORE RESTICCTIVE CHANGES SECTION 3.6, " CONTAINMENT SYST. EMS," page 3 of 6 Discussion of Summary of Change iTS Sechon CTS Sectson Change 3.6 M12 Requirements were added to the surveinance of the contarrnent SR 3.6.3.5 Table 4.1-3 isolation valves to venfy each automatic containment isolatsen valve item 5 that is not locked, sealed or otherwise secured in possbon actuates to the isolation position on an actual or simulated actuation dgnal 3.6 M13 SurvesBance requirernents were added to venfy the postben of SR 3.6.32 4.4.2 containment isolation valves located outside containment every 31 SR 3.6.3.6 days, venfy the position of corh u st isolation valves insice SR 3.6.3.6 containment prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days, and venfy each 42 irr.:h i inboard conti-wst purge valve is blocked to restoct the va;ve from opening > 70*. LCO 3.6 4, Tentainment Presm.are" 3.6 M14 The aDowed time to restore containment pressure to within the LCO 3.6.4 Required 3.62 required limits was limited to one (1) hour, rather than eight ( 3) Action A.1 hours as was previously requaed 3.6 M15 The allowed time to reach MODE 3 in the event that requu a -,m Js LCO 3.6.4 Requred 3.62 for containment pressure cannot be met was limited to six (6S hours Achons B.1 and 82 where no time requirement previously existed. A requwemert was added to reach MODE 5 in 36 hours in the event that the requirements for containment pressure cannot be met. 3.6 M16 Requirements for containment pressure were extended to apaly to LCO 3.6.4 ApfA.taldf 3.62 MODE 31,2, 3, and 4. rather than to power opm.knw, and reactor ent. cal as was previously required. 3.6 M17 A surveillance requirement was added to venfy that containrrent SR 3.6.4.1 3.62 pressure is within limits every 12 hours LCO 3 6.5. " Containment AirTw.cerature*
TABLE M - MATRIX OF MORE RESTRIt"TIVE CHANGES SECTION 3.6, " CONTAINMENT SYSTEMS," page 4 of 6 Discussion of Summary of Change ITS Sechon CTS Sectson Change 3.6 M18 Requirements were added for containment air teTipssture. No LCO 3.6.5 3.6 requerernents previously existed. LCO 3.6.6. T,ontainment Spray and CooPng Systems" 3.6 M19 A requirement was added to enter LCO 3.0.3 immediately in the LCO 3.6.6 Requred 3.6.2.2 event that two cont == u st spray trains or any combination ofithree Action F.1 or more trains are inoperable. The aucwed time to reach MODE 3 in this condition was therefore limited to seven (7) hours rather than eight (8) hours as was previously required 3.6 M20 Surveillance requirements were added to operate each conteksat SR 3.6.62 4.5.1.6 cooling fan unit for 2 15 minutes every 31 days, venfy coormg water SR 3.6.6.3 flow rate to each cooling unit is 750 gpm every 31 days, and vernfy SR 3.6.6.7 each containment cooling train starts automaticauy on an actud or simulated actuation sagnal every 18 months. 3.6 M30 Requirements were added to the surveillance requirements to % SR 3.6.6.5 4.5.1.3 each containment spray pump starts automaticauy and to venfy SR 3.6.6.6 each automatic containtnent spray valve in the flew path that is not locked, sealed, or otherwise secured in position actuates to the correct posstion on an actual or simulated signal 3.6 M31 The allowed time between surveillances for the containment sp ay SR 3.6.6.5 4.5.1.3 system was hmited to 18 months rather than refueling interval iThe SR 3.6.6.6 length of time between refueling intervals was not specified in tne previous requirements. 3.6 M34 A requirement that aDowed surveiRance tests to be satisfied on :the SR 3.6.6.5 4.5.1.5 basis of visual observation that components have operated SR 3.6.6.6 satisfacionly has been deleted.
4 TABIE M - MATRIX OF MORE RESTRICTIi/E CHANGES SECTION 3.6, "CONTADDENT SYSTEMS " page 5 of 6 rw.sans at _.. - - y of Change ITS Seceson CTS Sectee Change 3.6 M33 The surveillance requrements to venfy valves int he containmenti SR 3.6.6.1 4.5.2.2 spray system flow paths are in the correct posshon were extendecto apply to MCDES 1,2,3, and 4 rather than to power operabons ac j was previously regured. i LCO 3.6.7," Spray Ad3tive System" a' 3.6 M21 Surveillance requirements wera added to venfy that the spray SR 3.6.7.2 3.62.1 addstive tank solubon volume is 2 2505 galions every 184 days ard SR 3.6.7.3 l to venfy the spray addstive tank NaOH solubon concentrabon is 2 30% every 184 days. 3.6 M34 A requrement that allowed surveillance tests to be sabsfied on thn SR 3.6.7.4 4.5.1.3 bases of visual observation that coTipe. as have operated 4.5.1.5 sabsfactorily has been deleted. A requrement was added to the ! surveillance requrement for the spray additive system to venfy each automabc valve in the flow path '5at is not locked, sealed, or otherwise secured in possbon m to Mie correct possbon on an actual or svnulated segnal . , 3.6 M33 The survesitance requrements to venfy valves in the containment SR 3.6.7.1 4.5.2.2 l spray addstive system flow paths are in the correct posebon were extended to apply to MODES 1,2,3, and 4, rather than to power operations as was previously requred LCO 3.6.8. " Isolation Valve Seal Water System" 3.6 M24 The requwements for the Isolabon Valve Sesi Water System (IVSW) LCO 3.6.8 3.6.6.1 i were extended to apply to MODES 1,2,3, and 4, rather than to
- power operations as was previously recured 4
l
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_ _ -- _ _ _ . . . _ . _ . ~ _ ._ _ - _ . _ _ . . - f 2 a i TABLE M '- MATRIX OF MORE ItESTRICTr/g r manar_Te , l S'CTION 3.6, "CONTAIBGENT SYSTDE,'" page'6,of 6 l i,
- h et Samusary of Change ITS Seselon CTS Seselon i
! change i i !" 3.6 M25 The agowed time to reach MODE 5 if the requwements of an LCO 3.6.8 Requwed 3.6.6.2' i l inoperable IVSW System cannot be met was limeed to 36 hours. Achon B.2
- No time limit pronously W ,
3.6 M26 , A requwement was added to the surveElence reqwament for the- SR 3.6.8.4 Table 4.1-3 IVSW system to venty each automate valve = rem to the correct i Item 15 l' possbon on an actual or samulated ar*% segnal. .i 4 3.6 M29 -' The agowed time betwecen survessences for the IVSW system was SR 3.6.8.4 Table 4.1-3 !- lwruled to 18 montes ralhor than refueleng interval. The longen at SR 3.6.8.6 Item 15 t_
~
time between refueling sntervals w riot speedied in Wee pntwoous ; requwements i 3.6 M23 Requwements were added to the sur h requwement for ete SR 3.6.8 6 4.4.2 - IVSW System to venly =parde heeder flour rates whedi demonettrate
- j. the system's W for seehng containment ~% valves.
l: 3.6 M27 SurveiBance requwements were added to venty Wie IVSW tank SR 3 6.8.1 4.4.2 i' pressure is a 44 poig every 12 hcurs, venty the IVSW tank voltme SR 3.6.8.2 is 2 85 gasons every 31 days, and wenfy the IVSW nemme.a.,e SR 3.6.8.5 l
- ruirogen botges wiB pressunes Wie IVSW tank to a 44 psig eveyr 18 i- monihs
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Y: i-i w: j- TABLE M - MhTRIX OF .MDItE IEESTRICTIVE CsAIMS
, SECTION 3.7, " PLANT STsTEas,"- page 1 of 9 i E
h of J Sessenery of Cheese ITS Seselon CTSSommon l Chanse l ! ' LCO 3.7.1, "Meut Stoem Safety Vafwes," and LCO 317.2, "Mari Steam isoleton Velves" f- l !. 3.7 M1 The Requwed Achons for Main Stoem Safety Valves (M3SVs) and LCO3.7.1 Applicabigny 3.4.3 i Main Stoem W Valves (MSIVs) were made to be applicable to LCO 3.7.2 Applic biEty I l- MODES 2 and 3 for the MSSVs, and MODES 2 and 3 witi sie ! j MSIVs open for tie MSIVs, ralhar Wien only to MODE t as is - l i currently requwed. j i 3.7 M2 The time to reach MODE 3 was limded to 6 hours and 1he time to LCO 3.7.1 3.4.3 i reach MODE 4 was lwruled to 12 hours in admons for fra MSSV Requesd Achons C.1 W Completon tmes for tiese achons did 'not previously and C.2
St-i 3.7 M3 The 24 hour time atoned for more then two (2) inoperatde MSSVs LCO 3.7.1 3.4.3 - -!
i was elimmated from current requwements. Requwed Actons C.1 ! l and C.2 .I t j 3.7 M4 The time to reedi MODE 2 was limded to 6 hours in tie achon for LCO 3.7.2 Requwed 3.4.3 [ the MSIV Speedicahon. A completon time did not previously esast. Achons B.1, C.1, C.2, - A new achon to close an inoperable MSIV wsIhm 8 teurs witi the D 1 and D 2 plant in MODE 3 and venfy the MSfV closed once For 7 days was ': added where no requwements r..t;.='y enested. A new achon to ! piece the plant '.a MODE 3 withm 6 hours and MODE 4 witun 12 i
- hours if the inoperable MSIV cannot be closed was added wSere no !
i roeusements previcusly enasted l
- . i 5 I I
i 1 i . l i i 1
+ *
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- . . - . .- ~ . .... - -- . . - - - . -.. . - . . ~ . . . -
3: ; i r p TABI2 M - MkTRIX OF MMIE EIESTRICTIVE ChfAREGES
, SECTIcet 3.7, "PLAltT SYSTDS , " page 2 .of 9 ~!
[ h of Senseery of Change ITS Seedon CTS Seedon .j b
- g. LCO 3.7.31 Amin Foodsetor isoishon Velves (hEIVs), Main Feeduster Regulaton i
Valves (MFRVs), and Bypass Vatwes* !, 3.7 MS A now W for Main Foodneter teologion. Regulaton, and LCO 3.7.3 3.4 ! eypass vaiwes to em operaelia was added. No aquesments for
- 1 these waiwes pronouse r
- l LCO 3.7.4, "AsseTiery Feedwater Syssem* I j:
i [ 3.7 MS The requirements for a single Anmaliary Feedmeter(AFW) System LCO 3.7.4 Applicabitty 3.4.1 j pump and Hour palh were extended to apply to when Sie Steam j _ Generators are bows used for heat removat - 5 i j 3.7 M7 The toimi time West the requirements for the AFW System cannot be LCO 3.7.4 Requeed 3.4.5 met for any and as reasons was Irvated to 8 days before at l + I Actons A.1 and 8.1 1 requwements for ese AFW system must be met. An overa5 6 w.il:-. time for failure to most the AFW System requwements j did not pe==ously most. i
.I
!. 3.7 MS A requwement to reach MODE 4 withr 18 hours was added for sie LCO 3.7.4 3.4.4 3 ! condihon when tie plant is requwed to shut doest due to inoperable Requend Action C.2 f l AFW components No requirement to needi MCOE 4 r f: _ , } " ; 3.7 MS A requwoment to readi MODE 4 wiesn 18 hours was added for #se LCO 3.7.4 3.4.5 ! condhon when 9te plant is requwed to shut dovun due to inoporchie Required Acton C.2 ! AFW components. No requwement to reach RAODE 4 r./ z'; . i esusted I L i t 1
-_____._,__..,,,__-.m, . _ . - _ - ~ . . , _ _ , _ . _ . _ _ . - . . --,,,,.,__.__-.__m - , , _ . , . , . _ . _ . _ . _ . , _ _ _ _ . _ _ _ _ , . ,
TABLE M - MATRIX OF MORE RESTRICTIVE CHANGES SECTION 3.7, " PLANT SYSTEMS," page 3 of 9 hrebo of Summary of Change ITS Secbon CTS Section Change 3.7 M10 A condrai for three motor dnven AFW flow m'ts was added. If LCO 3.7.4 Requred 3.4.4, 3.4.5 the plant is in this condition, the p! ant must be shut down to MODE Actons D.1, D2, F 1 4 cf.id7uens. A requirement to reach MODE 3 in 6 hours and MODE 4 in 18 hours was added for the condition when a steam d-iven AFW pump or flow path is incperabie in conguncbon with a motor dnve i AFW pump or flow path. A requirement to restore a required inoperable AFW pump or row path in MODE 4 immediately was added 3.7 M11 Acceptance entena were added to the requirements for testag the SR 3.7.42 4.8.1,4.82 Auxiliary Feedwater Pumps The acceptance enteria requae that the measured pump performance be compared to and exceed the required pump perfo.mance. 3.7 M12 The testing regtdrement for AFW system pump discharge valves SR 3.7.4.3 4.8.3 was extended to include a!! valves that actuate automaticacy wtuch are not locked, sealed or ctherwise secured in the required position 3.7 M13 Surveillance requiremen'.s for the AFW system were added ver#ying SR 3.7.4.1, SR 3.7.4.4, 4.8 that AFW vahres are in the correct pos4 tion every 31 days, venfymg SR 3.7.4.5, that the AFW pumps start automatically on an actual or simu!ated SR 3.7.4.6 signal every 18 months, venfying that the AFW system is property a!igned to the Condensate Storage System after an extended plant shutdown, and venfying that the automatic bus transfer switch suppfymg power to one AFW valve operates autcarduc 2y when required LCO 3.7.5. " Condensate Storage Tank (CST)* 3.7 M14 The reqtsacrwmts for the Condensate Storage Tank requrements LCO 3.7.5 Appsc b7 ty 3.4.1 i were extended to include MODE 4 when the Steam Generators are beino used for heat removal. !
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- TAIRE2 M - MILTRIX OF MOSE RESTRICTIVE. CBABIGES i
SECTICII 3.7, "PIABET SYSTEss," 'page'4 of 9 .! Discussion of W of Change ITSSesame CTS Seagan ). 3.7 M15 The Requend Achons for the Conoonente Storage Tank (CST) were LCO 3.7.5 Appicahmey 3.4.3 [. rnede to be e to MODES 2,3, and 4 when Sie steem . y generators are used for heat removel, rapier tien ordy to MODE 1 ! asis curren8y requwed .! 3.7 M16 The time to reach MODE 3 was lisuuted to 6 hours and tie bme to LCO 3.7.5 Reqused 3.4.3 . j= for achons did not prowsously , i most. > -l t; i i: 3.7 M17 A requsement to venFy by admsustrakwe means tiet sie bodiup LCO 3.7.5 3.4 water supply to Wie AFW is operatne wieun 4 hours and once por 12 Roquead Achons A.1, hours tiereafter was added for Nie condkon when Wie CST water C.1 and C2 h level is belour Wie requwed limit. No requwement to vanfy Wie SR 3.7.5.1, !- bedsup water supply prowsously mooted. A requsement to feedi SR 3.7.5.2 ] -'- MODE 3 wieun 6 hours and MODE 4 wienout reliance on sie steem !- generators for host removal was added for Wie condton when See Sennce Water System (SWS) supply to tie AFW system is inoperalde. No requwement for Weis condton premously asseamre i i Survedence requeements for Wie CST were added venrying tiet i CST level is greater tien tie requwed limit every 12 hours and i l venfying by aderunestrahve moons tie operstmMy of sie ha. haap SWS i- suscht to tie AFW system i I l }- 3 i i j .. f
- i. t i
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" N* M - MATRIX OF } ORE RESTRICTIVE CHANGES SECTION 3.7, " PLANT SYSTEMS," page 5 of 9 Descussion of Summary of Change iTS Sechon CTS Sechen Change LCO 3.7.6
- Component Coolog Water System
- and LCO 3.7.7, Service Water System
- 3.7 M18 The time to reach MODE 3 was lim:ted to 6 hours and the trne to LCO 3.7.6 Requred 3.3.32 reach MODE 5 was limited to 36 hours foi acdons in both the Acbons B.1 and S2, 3.3.4 2 Cwnycrmni Cooling Water (CCW) System and SWS Specificabons. LCO 3.7.7 Required Comp 4 tion times for these achons d4 not previous!y exist. Achons D.1 and D2 3.7 M19 The recp.arement to enter the Residual Heat Removal (RHR) System LCO 3.7.6 Requeed 3.3.32 requhrnents, which is a system supported bv the CCW System. Acbon A note, when one requred train of CCW is inoperable was added. SR 3.7.6.1, Survedlance requisT=nts for the CCW System were added SR 3.7.62 venfying that CCW valves are in the correct postbon every 31 days and venfying that the CCW pumps start %%iWucidy on an actual or simulated sgnal every 18 months, 3.7 M20 The time to reach MODE 5 was limited to 36 hours for achons in LCO 3.7.6 Requred 3.3.3.3, both the Cui,rs=nt Cocieng Water (CCW) System and SWS Achons B.1, 3.3.4.3 Specifications. Completion times fv these actions ded not LCO 3.7.7 Regsed prevously exist. Action D 2 3.7 M21 The requirement to enter the AC electrical power sources LCO 3.7.7 Requred 3.3.42 requirements, which is a system supported by the SWS, when one Achon A Note, requeed train of SWS is inoperable was added. A requiraT.ent to Requred Achons B.1, dose and deactivate an inoperable Turtune Building loop isolabon B2, and C.1 ;
valve w: thin 72 hours and to venfy the valve is dosed every 31 days 4 was added. A requi.e to close and deachvate one cf two anoperable Turbine Buildir,g loop isolabon valves in 2 hours was added l
_ _ _ . - . -o . 4 ., f
+
L ! TABIZ M - MATRIX OF DCIIE HESTRICTIVE CEABIGES { j' SECTICIE 3.7, "P1JetT SYSTEBS," 'page 6 of 9 i !- -n - ynChan.e as seems. cvsso.mo. ! Change j
' i
. 3.7 M22 - Survoinence requesments for sie SWS were added vertyng tiet SR 313.1 3.3.4 g
- . valves in tie SWS are in sia correct ponhon every 31 d sys and SR 3JJ.2 g-ventyng tut automehc valves in Wie Aour pets actuele to tie conect poseen on an actual or amulated monal overy 18 morttis. ,
i j 3.7 M23 A surweitence requirement for Wie SWS was added wenfpng tiet SR 3JJ.4 3.3.4 i
- sie automesic bus transfer sestch suppipng poser to one Turtune
^'
BuBding loop isoishon volve operates ^ when seqused.
]
j LCO 3.7.8, h Heat Sink (UMS)" 4 j i 3.7 M24 The requwements for the UImmate Host Sink were essended to LCO 31.8 Apptcettity 3.4.1 j I' include MODE 4 condemns. 3.7 M25 The requwements for talung actons -imand witt inoperehte LCO 31.8 Apptcebtey 3.4.3 l: i, - ccenponents of tie UIhmete Host Sink were entended to incdude i + MODE 4 conditens. i 4 - i 3.7 M26 The time to react MODE 3 was limmed to 6 hours and sie time to LCO 31.8 Roqueed . 3.4.3
- j. reach MODE 5 was limeed to 36 hours in sie UIhmete Host Sink Acasons B.1 and 8.2
}: Roquesd Actons. Completon tunes for tiene admons did not i 2M; most. !
-l 3.7 M27 Surveitance Requwements for Wie UIhmete Host Sink were added SR 33.8.1, 3.4 worifyng Wiet 9:e lake water level meets toquemments every 24 SR 31.8.2 ;
,; hours and wentyng tiet sie SWS ternperature is less Sten or equei i to 95'F every 24 hours ! i 1 t
- i. i i !
I' I i l i. t
. _ . ,_ -- .-- . .. -- . - - - . - . . . . ~ . . . ._, -
' me .
- . .l vasirs M - METRIX OF BEEEE IESTRICTIVE CEMIGES l SECTIcet 3.7, "PIAleT SYSTEss," page 7 of 9-
}; .+ Dinoussion et e -- - -, et Change (TS Soemen CTSSeamen i Change .IT T. e LCO 3.7.9. " Control Room Emergency Filtrakon System (CREFS)," and ,7.. [ i LCO 3.7.10. " Control Room Emerrency Air ^_ 7 Consol (CREATCT* _ ! i 3.7 M28 The time to readi MODE 3 was changed from aght (8) hours to sist LCO 3.7.9 Reqused 3.15.1.a (6) hours for an inoperoMe Conkel Room Emergency Filtrahon Acton B1 * [ System (CREFS) or Control Room Emergency AirTemperatum LCO 3.7.10 Reqused I !- Control (CREATC) System train tiet cannot be metomd to operaMe Achon 8.1 1~
~
status witnet Wie h time. i 3.7 M29 The time to reach MODE 3 was changed from eight (8) hours to sist LCO 3.7.9 Requesd 3.15.1.b -
- - (6) hours for two inoperaMe CREFS or CREATC System trases of Actons F.1 and F.2
- which one cannot be restored to operaMe status wsBun wie abound LCO 3.7.10 Required ;
i' time.- Actons F.1 and F.2 i j 3.7 M30 A requsement to suspend movement of irradiated fuel assemWies LCO 3.7.9 Requesd 3.15.2.h l was adood when both trans of CREFS and CREATC am inoperaMe Acton C2 ! dunng movement of irradiated fuel assemMies. LCO 3.7.10 Requesd ; Actor C.2
- t l- 3.7 M31 The Surveitene Requwement for h of Control Room SR 3.7.9.4 4.15.f.4 I l posesve pressure was made more resenchve by requeng a W i l value be met for Wie air pressure reiserve to tie md==t= atmosphere. i
- , The requsemer
- t is tint Wie dSerenhof air pressure be at least one-j
[ eightis (1/6) inch water column. 1 3.7 M32 A Surveigenm Hoquwoment for h of Control Room Air SR 3.7.10.1 4.15.f2 l Temperature Control coolina conecsty was added ! t . I t 1 f .l
~
i l l t
. , _ _ . _ . , _ . , _ . _ . . . , ,- . . . . , , . _ . , . . . . . - ~ _ _ . _ - . . . _ . , , . _ . _ , _ _ _ _ _ . _ . _ _ _ , _ _ . _ _ , _ _ . _ _ _ - . - .
. .- - -- - . -~ -_ .- - -. _
l- ! 4 2 f l TABIZ M - DETRIX OF DCetE IEESTRICTIVE CHAIGGES F SECTIOtt 3.7, "PIJWIT SYSTEBEE," page 8 of 9 [ i.
' " " - l 4
h of Sunenary of Change ITS Seselon CTS Soseen l Channe i LCO 3.7.11, Tuol Buikling Air Cloenup System" 3.7 M33 Survedence Requwements were added for the Fuel Building Air SR 3.7.11.1 3.8.2 i Cloenup System (FBACS) venfying that tw FBACS be run for 10 SR 3.7.11.2 ! l conhnuous hours wilh the heelers operatmg automaticeBy every 31 SR 3.7.11.3 i days, venfying that the FBACS be tested in accontence wies tie ! j Venhisten FilterTeshng Program, and vecfying that the FBACS can i
- mentem a nogmerve pressure in the Fuel Buikkng with respect to lhe -
[' ] outsade atmosphere every 18 monIhs LCO 3.7.12 Tusi Storage Pool meter Level" ! 3.7 M34 A new specdicehon for Fuel Storage Pool Water Level was added LCO 3.7.12 3.8 : [' whitti requwes tiet a nununum of 21 feet of water be meetsened ! above tie fuel. No requwement for this value a4 esosted.
'i i
LCO 3.7.13 " Fuel Storage Pool Baron Concentrabon* '[t 3.7 M35 A requsement to suspend movement of fuel assemblies in tie fuel LCO3.7.13 Requesd 5.4.3 i
- storage pool was added when the fuel storage pool baron Acton A.1 i
- conantrabon is not wahm requwements dunne movement of fusi !
! assemtses in the fuel storage Pool. ! 3.7 M36 The fisquency for sampling boron concentration in the fuel storage SR 3.7.13.1 Tatde 4.1-2 , pool was increased from prior to refueling or fuel movement in Wie llom 7 fuel storage pool to every seven (7) days. ' i l i ! . t f n_ _ , . _ _ . _ _ . _ _ _ ___._. _ _ _. _ . . . ~ _ _ . . . _ ._ _ __ _ --.-. _ _ _ .J
' TABLE M - MATRIX OF MORE RESTRICTIVE CHANGES SECTION 3.7, "PIANT SYSTEMS," page 9 of 9 '
i Discussion of Sunumery of Change ITS Seeth CTS Section Change LCO 3.7.14 h and Spant Fuel Assemth Storage" _ 3.7 M37 A new spec 6cahon for new and spent fuel storage pool storage was LCO 3.7.4.14 5.4 added whsch requres that new and spent fuel be stored in approvec locahons. Or# a survedance requrement previously ===nad. 4 l i. i 4 . r t i l i l i l l t 9 i i I., i i d j 4
TABLE M - MATRIX OF MORE RESTRICTIVE CHANGE SECTION 3.8, " ELECTRICAL PIANT SYSTEMS," page 1 of 8 rs.e. .sa. og e- y W Change ITS Section CTS Secelen Change LCO 3.8.1, "AC S:xarces-Operahng-3.8 M1 The requrements for AC electncal power sources dunng operabon LCO 3.8.1 App 6catnidy 3.7.1 were extended to apply to MODES 3 and 4 rather than only to - 3.7.2 reactor enbcal and power operatons. 3.8 M21 A requrement was added for the qualdied crcud between the offsde LCO 3.8.1 3.7.1 transmissen network and the onsite emergency AC electncai destnbubon system to be operable
- 3.8 M2 Requrements that allowed power operabon to conhnue beyond 24 LCO 3.8.1 3.7.2 hours provided one or both the diesel generators are operable and reportrig requrements to the NRC are met were deleted 3.8 M3 The time allowed for the requrements for AC sourcer dunng LCO 3.8.1 Requred 3.72 i
- operabon to not be met regardless of actons taken was hmsted to 8 Achons A.2 and B.4 days.
3.8 M4 The time to reach MODE 3 was limded to 6 hours and the bme to LCO 3.8.1 Requred 3.7.2 ! reach MODE 5 was limited to 36 hours when requrements to Achons C.1 and C2 restore an inoperable qualsfied offsite crcud or diesel generator cannot be met. i 3.8 M25 A requrement for the diesel generators to acheeve steady state SR 3.8.1.2 4.6.1.1 i voltage 2 467 volts and s 493 volts and frequency of 2 58.8 Hz and s 61.2 Hz was added to the monthly surveillance test of the diesel oenerator. ; t
TABIZ M - MATRIX OF MORE RESTRICTIVE CHANGE SECTIG4 3.8, "EI2CTRICAL PIANT SYSTDs," page 2 of 8 I h*W sumniary or chene* ITs seceien cts seceben Change 3.8 M S Requirements to venfy that the chesel generators energue SR 3.8.1.14 4.6.1.2 perma.wdly connected loads in s 10 seconds, energues auto-ccanected emergency loads through the load sequencer, achseves steady state voltage 2 467 volts and s 493 volts and frequency of 2 58.8 Hz and s 61.2 Hz, and supplies permaneney connected and autoconnecsed emergency loads for 2 5 rmnutes, were added to the i 18 month dumd generator surveillance test. ! I l t l i l
. _. _ _ _ _ . _ . _. _ _. - - _ -, , . , , __ _ . ~ . . .
i TABLE M - MATRIX OF MORE RESTRICTIVE CHANGE SECTION 3.8, " ELECTRICAL PLANT SYSTEMS," page 3 of 8 Descussion of Summary 6T Change ITS Sechon C.'S P ct?an Change 3.8 M6 Surveillance requirernents were added as follows Venffconrect SR 3.8.1.1 4.6.1 breaker ai;gnir=61 and iruficated power avadatsty for the offsite SR 3.8.1.4 cecurt svery 7 days. venfy each day tank contains 2 140 gallons of SR 3.8.1.5 fuel od every 31 days. Check for and remove accumulated water SR 3.8.1.6 from each day tank every 31 days. Venfy the fuel oG transfer system SR 3.8.1.7 operates to automatca#y transfer from the storage tank to the day SR 3.8.1.8 tank every 31 days. Venfy each diesel generator starts from SR 3.8.1.9 standby condsten and achieves required voltage and frequency SR 3.8.1.10 every 184 days. Venfy each diesel generator rejects a load greater SR 3.8.1.13 than or ty. aal to its assocated sogle largest load without ^u ms on SR 3.8.1.14 overspeed every 18 months. Venfy that each diesel starts on a SR 3.8.1.15 simt: lated or actual loss of offsite power segnal and actueves SR 3.8.1.17 required c.,0rd'uons in the required bmes every 18 months. Venfy that each diesel generator starts and achieves reouired curd'ucrs in the required times within five minutes of the 24 hour load test every 18 months. Venfy that the interval betwa Jach sequenced load block is vnthm i 0.4 seconds of design interval every 18 months. Venfy that each diesel sta.ds on a simulated or actual Engineered Safety Features (ESF) segnal and actneves requred condibons in the required times every 18 months. Venfy the automatic transfer capability of the 4.16 kV bus 2 and the 480 voit emergency bus 1 loads from the unit auxilsary transformer to the startup transformer every 18 months. Venfy that when started ' senultaneously from standby condition each diesel actneves required conditions within 10 seconds every 10 years. 3.8 M19 A surveillance frequency requirement of 18 months was added to SR 3.8.1.11 4.6.1.3 test the emergency diesel generators tnps defeat funcbon 3.8 M24 An allowance for exceeding minimum and maximum a!iowable kW SR 3.8.1.12 4.6.1.5 values under the direct monitorino of the manufacturer was deleted.
4 l' 1 l TAmu x - mTnIx or woes RastnICTIvr Causas sacTrou ; ! 3.8, "sMCTRICAL PIANT SYSTDS," page 4 of 8-I i ! i r% or sunumery of Change ITS Socalen CTS Sommon ; ! N I LCO 3.8.2, "AC Sources-St=Mr==t* t 1 j 3.8 M7 R .- e.were added for AC elocencal power sources in LCO 3.8.2 3.7 , !' MODES 5 and 6, and dunne movement of irradiated fuel i assemtsises No requwements easted W.i=_";in these modes. : 1 ! LCO 3.8.3, " Diesel Fust Oil and Starting Aii" j 3.8 M1 The requwements for Diesel Fuel Oil and Starting Airwere extended LCO 3.8.3 AM 3.7.1 l to apply to when #w assoasted smeal generator is requwed to be
- operable, rather than only to reactor enhcal and power opershons.
- i. i 3.8 MS A requwement was added to restore the diesel generator air recewer LCO 3.8.3 Requwed 3.7.1 l pressure to a 210 psig witun 48 hours when pressure in one or Achons D.1 i
, more deemi generator air accumuistors is less tien 210 psig. j I 3.8 M28 A requwement was added to restore stored fuel oil properties to LCO 3.8.3 Requwed 3.7.1 l < within limits within 30 days of when one or rnore n= eat generators Achon C.1 [ with fuel oil proportes are not wdhen linuts. i i 3.8 M9 Survedence requwements were added to venty tiet endi diessi SR 3.8.3.3 4.6.2 ; generator air start receeww pressure is 2 210 psig and to check for SR 3.8.3.4 ! and remove accumulated water from each fuel oil storage tanit j LCO 3.8.4, "DC Sources-Operating
- l 3.8 M1 The requwements for DC elecencal power sources were extended to LCO 3.8.4 Apptcabitty 3.7.1 !
apply to MODES 1,2,3, and 4, ratier than only to reactor cribcal ! and power operabans i ! 3.8 M10 The time to reach MODE 3 was limited to 6 hou s and tie time to LCO 3.8.4 3.7.2 readi MODE 5 was limded to 38 hours when one inoperable DC Requwed Actions B.1 and B.2 l h(2)'power N source cannot be restored to -perable status in two , 4 i , i l c 1 e w ._ -,..m.. - , . _ _ . . ~ . , . , - . - .. , .
, . , , . - . _ - , .-. . . - _ . ~ _ . ~ _ . _ _ _
TARTR M - MATRIX OF MORE RESTRICTIVE CHANGE SECTION 3.8, " ELECTRICAL PIANT SYSTEMS," page 5 of 8 4 x n=e===W of Summary of Change ITS Sectron CTS Section Change 3.8 M11 Requrements to venfy that the *A" Battery capaoty is 2 80% and SR 3.8.4.6 4.6.3 the "B" Battery c.f-c,ty is 2 90% were add A to the surveiRance ; requrement to perform a perfon,.arce dPeharge test. t 3.8 M13 Surveisance requirements were added to venfy that battery ceRs, SR 3.8.42 4.6 ceR plates, and racks show no visual indca*xm of physcal damage SR 3.8.4.3 or abnormal detenonzabon that could degrade battery performance SR 3.8.4.4 every 18 months, remove visable terminal cuiras;ce, venly battery ceR to ceR and terminal connechons are clean and tight, and are , coated with ants:orrosion matenal every 18 months, and venfy each battery cis ver %s 2 300 amps at 125 2 volts for 2 4 hours 1 every 18 montr a;. s e 3.8 M12 A requrement to venfy battery tren.nal voltage is 2 125.7 volts was SR 3.8.4.1 4.6.5 , added to the surveillance W. performed on the battery chargers every 7 days. i i + t w .- . -, , , , - ,--
1 1
- 1. TABIE. ' M - MATRIX OF MORE Ra,STRICTIVE CHANGE SECTICI( - ;
j s3.8, " ELECTRICAL' PLANT SYSTEMS," page 6LofL8.. j t Discusaien of ~ Sensemary of Change iTS Section CTS Section : Change ' 1 LCO 3.8.5, E Sources-Shutdown" : _; 3.8 M14 Requrements were added for AC electncal power sources in LCO 3.8.5 3.7.1 j MODES 5 and 6, and dunng rrnvernent of irradiated fuel ' i assemblies Fe requrements a==tari previously in these modes j
)
LCO 3.8.6, " Battery Cell Parameters" 3.1 '** 5 Rer9 hetents were eu d for battery cell parameters and average LCO 3.8.6 Applicatniity 4.6.3
- elechdfr 'emperetum t's be within specsfied limds when the Sr?3.8.6.2 l asW sted DC eleumcal power subsystems are requred to be SR 3.8.6.3 !
, operetWs. Survedlance requwements were arMari to venty that , battery cell parameters be wdhm Category B imts c3er a battery ! , dscharge or a battery overcharge and to venfy average electrolyte
- . temperature of is,,.ex ' ^le; cells is > 67'F.
3.8 M26 A requremerd was added to the battery survedance requrement to . SR 3.8.6.1 4.6.3 venfy that battery coil parameters be within f'Z-xy A hmsts.. . Addshonally the survedlance requrement was made to apply to all i battery cells rather than to every fifth cell, and the allowed frequency
- ' of the surveellance was decreased from monthly to seven (7) days. j l
3.8 M29 The survedlance sequrement for measunng and recording the SR 3.8.6.3 4.6.3 j temperature of the battery electrolyte of the battery's pilot cell was .] l extended to requre measurement of the average of representatwo ; l cous. l. L a i ! I i i b
, + , ,- .' , +r ,. ,4. v .-e ..-,v ., w..
. - . . _ _ _ . - - . . ._ m . . . _ . _ _ _ ~. . . _ . _ __ . _ . _ _ . .. _ . - _ . . _ . _ . -
y :; I 4 ' TABLE M - MATRIX OF MORE RESTRICTIVE CHANGE SECTION o 3 8, " ELECTRICAL' PIANT SYSTEMS," pag'e-7.of 8 i 4
- . ru.e..a=% of Summary of Cha+;p ITS Section CTS Secelen l i Change l LCO 3.8.7, "AC instrument Bus Sources-Operahng" l !
3.8 M16 Requwaments were added for AC Instrument Bus Sources dunng LCO 3.8.7 3.7 MODES 1,2,3, and 4. No requwements easted previously in these modes LCO 3.8.8, "AC instrument Bus Sources-Shutdown" 3.7 1 3.8 M17 Requwements were added for AC Instrument Bus Sources dunng LCO 3.8.8 MODES 5 and 6, and dunng movement of irradiated fuel i assemblies No requwements existed previously in these modes I LCO 3.8.9, "Distnbuhon Systems-Operahng" l 3.8 M18 - The requirements for AC estnbubon systems dunng operabon were LCO 3.8.9 3.7.1 , extended to apply to MODES 3 and 4, rather than only to reactor Applicatulity i l cnbcal and power opershons ; t 3.8 M27 The requwament for the 480 volt emergency buses to be eneripzed LCO 3.8.9 3.7.1 - was extended to requwe also that all of Train A and Train B AC, DC, j
- and AC instrument bus electncal power distnbutoon subsystems be
- operable. .
j 3.8 M20 The total time allowed for failure to meet the distnbubon systems LCO 3.8.9 3.7.1 i specdications was hmited to 16 hours Requwements to be in Requwed Actons B.1,
- MODE 3 in 6 hours and MODE 5 in 36 hours were added in the C.1, F.1, and c.2
! event that requwements to restore inoperable AC and DC elocincal , power distnbution subsystems can not be met. _ a 3.8 M22 Survesilence requwements were added to venfy correct breaker SR 3.8.9.1 Table 4.1-3, j
- j. abgnments and voltage to AC, DC, and AC instrument bus electncel Blom 18 l power &stnbubon systems.
a - j- '
.j
. .. . . - . . . . . . , _ , .~- . _ _ _
k TABLE M - MATRIX OF MORE RESTRICTIVE CHANGE SECTION 3.8, " ELECTRICAL PLANT MSTEMS," page 8 of 8 Discussion of Summary of Change ITS Section CTS Secdon Change LCO 3.8.10, "Distnbution Systems-Shutdown" 3.8 M23 Requwements were added for distnbute systems duing MODES 5 LCO 3.8.10 3.7 ' ! and 6, and dunng movement of 'wradsated fuel assembises. No requwements existed previously in these modes. t i f i i I
l- :s j . TABLE M - MATRIX OF MORE RESTRICTIVE L1EANGES SECTION 3.9, " REACTIVITY CONTROL SYSTEMS" page 1 of 3
- i. ,
ru e. sant of Summary of Change ITS Secuen CTS SeeMon Change ! LCO 3.9.1," Boron Concentrabon" 3.9 M1 The requrements for maintaning twon concentrahon in the pnmary LCO 3.9.1 Appbcabihty 3.8.1 ' i coolant dunng refuehng operations were extended to apply to MODE , 6 rather than to reactor vessel head removal and unloading fuel i' from the reactor. LCO 3.9.2, "fev4aar instrumentatson" j 3.9 M3 The requrements for nudear instrumentahon dunng refuehng LCO 3.9.2 Applicatukty 3.8.1 - operations were extended to MODE 6 rather than to whenever core i geometry is being changed 3.9 M13 A required achon was added for the condshon of one source range LCO 3.9.2 Requered 3.8.1 l 1 neutron monstor being snopereble to suspend posstive reactivity
~
Actions A.1 and A.2 { additions. A requrement to cease refuehng of the reactorin the event that the specificahons for neutron instrumentahon cannot be met was extended to apply to core alterations. ') 3.9 M4 A requrement was added when the specificahons for neutron LCO 3.9.2 Requred 3.8.1 instrumentahon cannot be met to perform a survedance to venty Achon B.2 ; boron concentrabon is withen the Ismsts of ".ne Core Operahng Lamsts ' j- Report (COLR) once vnthen four (4) hours and every 12 hours ,[ thereafter. j ! 3.9 MS A surveillance requrement was added to perform a dumnel SR 3.9.2.2 3.8.1 '[ . cahbration every 18 months. LCO 3.9.3, " Containment Penetrabons" - 3.9 M6 A survesitance requrement was added to venfy each contanment SR 3.9.3.1 3.8.1 ! penetration is in the requered status every 7 days. I -j
-___---n-. - .... ----,u . s. y, ..,,.7.ii. , . . , . - , . . - ~m.~m .~ m..~ . .a. . . . . .mw.u
, . . .-m;., mim. .* 4 ....i& 2 m = ., ,.._ t i !
TABLE M - MATRIX OF IORE RESTRICTIVE CHANGES.
' SECTION 3.9, " REACTIVITY CONTROL SYSTEMS" page 2 of-3 7 l o
rha* of Summary of Change ITS Section CTS Secelon ; Change LCO 3.9.4, "RHR and Coolant Cucuishon-High Water Level" i i 3.9 M7 A requwement was added to the speedcolsons for the Resedual Heat LCO 3.9.4 ' 3.8.1 - [ removal (RHR) system for one RHR train to be in operabon, and a ' l note was added to allow the operahng train to be removed from ! operabon for one (1) hour in any eight (8) hour penod .; 3.9 M15 The requwements for RHR and coolant cerculebon were extended to LCO 3.9.4 Appbcatukty 3.8.1 apply to MODE 6 with water level at least 23 feet above the reactor -! vessel flange, rather than to whenever fuel assemthes are being ; ; moved withen the reactor pressure vessel l l 3.9 M8 A requirement was added for the condshon when the RHR and LCO 3.9.4 Requwed 3.8.1 l p coolant cerculebon requwements cannot be met to close aN - Achon A.4 , 'l penetrabons with detect access to outsade within four (4) hours. ; l 3.9 M9 A surveellence requwement was added to venty that one RHR train SR 3.9.4.1 - 3.8.1 is in operahon every 12 hours tt LCO 3.9.5, "RHR and Coolant Cwcuishon-Low Water Level" ". 3.9 M10 Requwements were added for RHR and coolant carn % with LCO 3.9.5 3.8.1 ; water level less than 23 feet above the top of the reactor vessel [ i flange. No requerements previously existed. ; LCO 3.9.6, " Refueling Cavity Water Level" .{ i 3.9 M11 Requwements for refuehng cawty water level were extended to apply LCO 3.9.6 Appbcatukty 3.8.1 j to dunng movement for of imediated fuel assembbes within i contaenment rather than to whenever fuel assembhes are being '! , moved within the reactor vessel : , i {: l j .. - i
4,p l i TABLE M IRTRIX-OF MORE RESTRICTIVE CHANGES SECTION 3.9,." REACTIVITY CONTROL SYSTEMS" page.'3 of-3 i nime===iani of. Summary of Change ITS Sec6on CTS Section Change ,
- 3.9 M16 Requwements for refuehng cawty water level were extended to apply LCO 3.9.6 Appbcatukty 3.8.1 ;
to core alterabons from whenever fuel assembhes are being moved vnthen the reactor vessel. j j LCO 3.9.7, "Contanment Purge Filter System" ! - i ~ 3.9 M18 Surveillance requwements were added to venfy that the contanment SR 3.9.7.2 3.6.1 j purge filter system is in operabon and maintawwng contanment SR 3.9.7.3 1 pressure negatrve reimhve to the tsJpacent amahary building every 12 -l hours and to perform requwed containment purge filter system '
- testing in accordance with the Ventilation FilterTesting Pivy ... [
i i
. 'i t
I h {
.I i
f
. . ~ . . ~ . . _ . . . . _ . - -
u , w 6 % , d_ h a _ m _ TABLE M - MATRIX OF MORE RESTR9CTNE CHANGES SECTION 4.0 "Desegn Features" Sheet 1 of 1 Discussion of Summary of Change ITS Sechon CTS Section Change 4.0
- Design Features" 4.0 M 1 Requerements regardog fuel storage were expanded to include 4.3.1.1.c 5.4 '
nommal center to center distance between fuel assembbes placed 4.3.1.1.d in the high density and low density fuel racks 4.0 M2 Requirements regarding fuel storage were expssnded to include 4.3.2 5.4 provisions hmitmg inadvertent draining the spent fuel pool below 18 feet above the top olithe fuel. , 4.0 M3 Requwements regarding desegn of spent fuel storage racks and new 4.3.1.2.b 5.4.2.1 fuel storage racks were expanded to include requong allowances 4.3.1.2.c for uncertamtes in calculation of reactivity. 4.3.1.1.b i
- . _ _ _ . _ _ _ _ _ _ _ _ _ . . _ _ _ . . _ _ _ _ _ _ _ _ _ t ___ ._ _ _ -- - m
s i i TABLE M - MATRIX OF MORE RESTRICTIVE' CHANGES
' SECT ~ON 5.0, " ADMINISTRATIVE CONTROLS" 'page.1 of?3 r h malantof Summerw of Change ITS Secdon CTS Sessen I V Change i Sechon 5.1, "Responsability" ;
r : i 5.0 M14 Requwements were added for the control room command funchon, 5.1.2 6.1.1 ., and for succession for that funchon. No requwements pnmously i . emsted i
- - i
!' Sechon 5.2, "Organnahon" *
. .t 5.0 M1 The requwements for two licensed operators to be present in the Sechon 5.2.2 6.2.3 .j
! control room under certam condebons were extended to be at an + l hmes dunng MODES 1,2,3, and 4, and the requwement was added
- that one of the two operators be a Senior Reactor Operator ;
t a j Sechon 5.4, " Procedures" , ' 5.0 M2 A requwement was added to mamtain wntten emergency operahng S echon 5.4.1 6.5.1.1.1 ! procedures '! 5.0 M3 A requirement was added for wntten procedures to cover aR Sechon 5.4.1 6.5.1.1.1 programs speedied in Specdcahon 5.5. .i Sechon 5.5, " Programs' and Controls" l l v ^ 1 5.0 M4 The level of approval for the Offsite Dose Calcuishon Manual Sechon 5.5.1 - 6.16.2 i (ODCM) was restncted from review and arragdance of the Plant Nuclear Safety Commdtee to approval by the Plant Manager. l 5.0 M12 Requirements were added for the content of the ODCM to include Sechon 5.5.1 6.16.2 the radioactive effluent controls and radiological envwonmental l: mondonng activities, and desenphons of the informahon that shnuld be included in the Radiological Envwonmental Operahng and : Radioachve Effluent Relesse Reports. o 'i I L l 4 3.
.. .. . ~ - .. - - . - . ~ . - . . , . -
1 TABLE M - MATRIX OF MORE RESTRICTIVE CHANGES SECTION 5.0, " ADMINISTRATIVE CONTROIS" page 2 of 3 i Discussion of Summary of Change ITS Section CTS Section Change 5.0 MS A program for component cyclic or transient limits was added to Sechon 5.5.5 1.0 track Updated Final Safety Analysis Report (UFSAR) transeent occurrences. 5.0 M11 A program was added that provides controls for the relocated Sechon 5.5.4 1.0 requirements for control of radeoactive effluents contamed in the Current Technical Specifications Radeological Environmental Technical Specifications. 5.0 M13 A program was added for pnmary coolant sources outside of Sechon 5.5.2 1.0 containment that duplicates Facility Operatmg txense DPR-23, ' paragi.ph 3.G(2). 5.0 M9 Requirements for the Prestressed Concrete Contamment Tendon Sechon 5.5.6 4.4.4.1 i Surveillance Program were added for controls for monitormg any tendon degradatson and effectiveness in corrosson protechon j medium, frequences, and acceptance criteria. 5.0 M6 Requirements were added for the Technical Spix.dk bori Bases Sechon 5.5.14 4.20 Control Program. 5.0 M7 Requirements were added for the Safety Function Determmahon Sechon 5.5.15 4.20 ' Program (SFDP). 5.0 M15 Requirements were added to perform surveillance tests in the Sechon 5.5.13 Table 4.1-2, 1 Diesel Fuel Oil testing Program to sample for cloud point, sample items 11 and ! every 31 days rather than prior to transfer to the Unit No. 2 storage 12 , tank, restrict the allowed extension of the surveellance interval to l 38.75 days from 45 days, and determining that the fuel oil is acceptable for use prior to adding the oil to the storage tanit Section 5.6. Reportino Requirements"
TABLE M - MATRIX OF MORE RESTRICTIVE CHANGES SECTION 5.0, " ADMINISTRATIVE CONTROLS" page 3 of 3 Discussion of Summary of Change ITS Section CTS Sec6on Change 5.0 M10 A reqtarement was added that pnmary safety and relief valve Secte 5.6.4 6.9.1.2.4 challenges shall be induded in the monthly Operatog Report, rather than in an annual report as previously required 5.0 M8 A requirement was added to indude the Emergency Core Coohng Section 5.6.5 6.9.3.3 , System (ECCS) limits in the Core Operating Limits Report (COLR). 4 kL i b
.i
- t j t t:
}!
i i
TABLE L- MAT 4X OF LESS RESTRICTNE CHANGES SECTION 3.6," CONTAINMENT SYSTEMS," page 1 of 6 Discussion of Description ITS Section CTS Section Category Characterization Chance 4.. LCO 3.6.1, " Containment" none LCO 3.6.2, Th Air Lock" _ ~ none J Categortes
- 1. Re of Agr,M R. ' Reemahan of Surmeence Frequency ,
Ill. LCO elated in terms of Treins rather then componerts ! IV. Agowed OLAege Time Ejdensien from 24 hours to 72 hours : V. Relemtion of Pequired Actons to out Af9arshuey , VL Rhm of Sunemence Requrement W creede VL Reimaton of Allowed Outay Tkne Vits. Delehmi of Requirement for 30 day Special Report to NRC i
1.. _ 4 i
,j j
- TAEN.E L- MATI4X OF LESS RESTIUCTIVE CHAffGES SECTION 3.6,"CONTABfRIENT SYSTEMS," page 2 of 6 . e v
rum, -% or . Deecrtyson ITS Seceon CTS Seceon Category , Charactertmmaton f. y
.+
LCO 3.6.3, - .I 4 1 0 1 3.6 L5 The a50wed outage time LCO 3.6.6 . 3.6.2.2- Vil Unuque wtlh reaped to , for a sangle inoperable Requwed Achons 3.6 2 3 agowed outage bmes
- j. contenmord spray train A.1, B.1, and B.2 only i
!- was extended to 72 hours 1 frorn 24 hours as was pnmously requwed. If the ,
- train is not restored to '
! operable status as required, the allowed time .; to bnng the plant to cold i shutdown was extended to , 156 hours fnxn 72 hours ~!
, plus the time required to !
shutdown the reactor [
- uhlizing normal operahng j
!- procedures -;
.j l
t l I ! categerms !
- L MarW ..I
! II. Malmason er Survomence Fsequency
- 15. LCO eased in tonns er Trains remer man compenords
-{ +
IV. h Omange Tine Edension term 24 hein;*: 72 hours
- v. Resammen at Rapsed Accenstose am j VL Reimaten or Sunemence Regimernert W creerie i
- vit Reamusen er asened omoge rene ;
vs. Dessman or RapAwnere sur 30 der Spead Rupert to NRC j i ( $ ~~ i .}
-[
. . ~ , _. . . . _ . . _ _ - . . . . . . . . _ _ . _ _ . _ . .
i TABLE L - MATRIX OF LESS RESTRICTNE CHANGES .
' SECTION 3.6, " CONTAINMENT SYSTEMS " page 3 of 6 Discussion of Description ITS Section CTS Section c:^ a --y _ Charactertration Change 3.6 L6 Restnchons that required LCO 3.6.6 3.6.2.2 None Uneque no inoperabihty of the ,
diverse cooling subsystem when a containment fan cooler or containment spray pump is inoperable , were deleted. 3.6 L7 An allowance for two (2) LCO 3.6.6 3.6.2.2 Vil Uneque with respect to contaenment coohng trains Required Action allowed outage time : to be inoperable for up to D.1 details ; 72 hours was added 3.6 L8 A requirement to test ths LCO 3.6.6 4.5.1.6 None Unique < containment coohng units i monthlV Was deleted. ! l Categones
- 1. Reinelienof Appecebiey ,
fl. R% of Surveennee Frequency til. LCo sta ed in terms of Trains rather than components a IV. Amowed outage Time Extensen from 24 hours to 72 hours V. Reimedian of Requeed Aceans to og agyernhany , VI. Reteaten of Survemance Requirement acceptance creerte Vll. R% of A5 owed Outage Tene , Vllt Delenan of Requirement for 30 day W Report to NRC
i l l l' TABLE L- MATRIX OF LESS RESTRICTIVE CHANGES I SECTION 3.6, " CONTAINMENT SYSTEMS," page 4 of 6 Discussion of Description ITS Section CTS Section C_m Characterization Change LCO 3.6.7," Spray Additive System" 3.6 L9 The allowed outage time LCO 3.6.7 3.6.2.2 III, Vil Untque with respect to for one (1) inoperable Required Act,on train and allowed spray system flow path for A.1 outage time details i 24 hours was extended to apply to the spray additive system with at least 100% of the spray additive system train flow available, and the allowed outage time was extended to 72 hours frorn 24 hours. 3.6 L10 The allowed outage time LCO 3.6.7 3 6.2.3 Vil Uneque with respect to for an inoperable spray Required Actions allowed outage time additive system in MODE 3 B.1 and B.2 details only was extended to 48 hours
' rom no time allowed categones
- 1. Reismattortof Appecately
- 11. Reismation of Survemence Frequency Ift. LCO stated in terms of Trains rather then componerWs IV. AJewed outage Time Extension from 24 hours to 72 hours V. Raimum5an of Required Actions toeuR Apphcot2ty VI. Relemahon of Surveennce Requirement acceptance criterin vil. Relenstlon of ARowed otdage Time Vl!I. De.shon of fiequiremord for 30 day Fpecial Report to NRC
TABLE L- MATRIX OF LESS RESTRICTNE CHANGh5 SECTION 3.6," CONTAINMENT SYSTEMS," page 5 of 6 Discussion of Description ITS Sectior. CTS SecNon CM Characterization Chance 3.6 L11 The required surveillance SR 3.6.7.3 Table 4.1-2 11 Urnque with respect to frequency for venfying ite m 5 frequency details only NaOH concentration in the spray additive tank was extended from monthly with a maximum time between surveillances of 45 days to 184 days. l l 4 l
- 1. Reteettonof Ar;.drehmty. !
II. Reimation of Sunegance Frequency fit. LCO stated h terms of Trains rather ther; components IV. A8oured Outs 0e Time Edension Rom 24 hours to 72 hours V. Relmation of Required Actone to endt Apptesbety VI. R=8===han of Survomance R4. _._. acceNarre creene Vii. Reinsten of Asoustd Outage Time VIII. Deleton of Requiremerd for 30 day Special RW to NRC t
. . . ~ . . -
I TABLE L- MATRIX OF LESS RESTRICTNE CHANGES SECTION 3.8," CONTAINMENT SYSTEMS," page 6 of 6 Discussion of Descrip6on ITS Section CTS Section C_t:;;.-y Characterization Change i-LCO 3.6.8, *lsolation Valve Seal Water System"
- i
- , 3.6 L12 The alkmed outage time LCO 3.6.8 3.6.6.1 III, VII Ureque with respect to i! for a segle inoperable Requred Action train and aNowed Isolshon Valve Seal Water A.1, 3.1 outage time details ;
(IV3W) system was ordy -t extended to apply to the ! entre system. The.. ! allowed outage time for the IVSW system was extended from 24 hours to 72 hours. The time allowed to reach MODE 3 when the IVSW cannot be - restored as required was ; extended to 80 hours from j 32 hours. l j. i i I. Reinemanof AM II. Reimehan of Stsvesence Frequency
- i 111. LCO elated in terms of Trans relhor then carryonents IV. Ascused Oulege Tkne Essenelon Ihwn 24 heure to 72 hours ;
V. Retammon of Requeed Actens to endt Apper=hely [ VI. Reinston of Survesence Requirernent acceprance creerte i VII. Reemahan of Agoured Dimage Tirpe + Vill. Detetion of Requwement for 30 day W Report to NRC , i i
.,- . _ . . - _ . _ .m.. . ._ .. .. ___ _ _ _ _ _ . ._._._ _. _ .
1 j 1
+
i TABLE L - MATRIX OF LESS IESTRICTNE CHANGES -J SECTION 3.7," PLANT SYSTEMS," ' ped 1'of 8 ' Diocesosion of.: Doocription ITS W CTS Section Category Charactertsselon ' Change -l LCO 3.7.1,"Mam Steam Safety Valves 3.7 L1 An allowaxe was added LCO 3.7.1. Table 3.4.1.a None Unuque for one or more Main 3.7.1-1 Steam Safety Valves j (MSSV)to be inoperable j 3.7 L2 A Note was added to ITS LCO 3.7.1 Note to 3.4.1.s None Uneque -{
- i. actions for separate Achons condihon entry for each ,
inoperable MSSv. t LCO 3.7.2, '1 Ween Stoem leainhari Valves" i 3.7 L3 The requwements for the LCO 17.2 3.4.1.a i Unique'wilh respect to -- Mairl Steerriisolation W% deters of AppEcdW2y. l! valves (MSivs)were i relaxed to appy to only j when the MSIVs are open
~
'I f'
- l. Reimmeoriet Appscelmy .
- n. Rasmuson of Sesseemnoe Frequerey Nt. LCO sameed in terms or Tseins repier tien compensres :
N. AAomed Oulage Ttvie Edension tem 24 he.as to 72 hours : ; V. Raimagen of Requbed Aceans to eig am ! Vi. Reimellan et Surweannoe Requirement P creerte ! vu. Reemenon er Aw omageTune ; t
.-- -, .-.e-.- +- e . < + , , * - - - , . . - .e
TABLE L - MATRIX OF LESS RESTR9CTIVE CHANGES SECTION 3.7," PLANT SYSTEMS," paget 2 of 8 Discussion of Description ITS Sechon CTS Sechon Category Characterization Change 3.7 L4 The frequency for - SR 3.7.2.1 4.7.1 II Uneque with respect to performing a Surveillance frequency details only,- on the MSIVs was extended from every 15 months to as specified by IST. LCO 3.7.4, " Auxiliary Feedwater System" 3.7 L5 An action and Note were LCO 3.7.4 RA E.1 3.4.4 None Urnque added for the condrtion of a complete loss of the Auxiliary Feedwater (AFW) Function. 3.7 LS The frequency for SR 3.7.4.2 4.8.1, 4.8.2 11 Uruque with respect to
- performing testing of the frequency details only, AFW pumps was extended from monthly to Staggered j Test Basis (i.e.,31 days to 93 days for any one pump.
Categones
- 1. Relenshonof AM,
- 11. Retassike of Survemance Frequency fil. LCO sisted in terms of Trains rather then cargonents IV. ARowed Ottage Time Extension f'om 24 hours to 72 hatra V. Retenstio7 of Requesd Actions to euft App 8cability VI. Reinxshon of Surveelance Requirement acceptance creerie Vit. Retanalton of Anowed Outoge Tkne
TABLE L - MATRIX OF LESS RESTIUCTNE CHANGES l SECTION 3.7," PLANT SYSTEMS," paget 3 of 8 D6scussion of Desenption ITS Sechon CTS Section C:t;-:-y Charactertantion Change 3.7 L20 A Surveillance SR 3.7.42 4.8.1, 4.8.2 VI Urwque with respect to Requet was relaxed detads of acceptance to require that the AFW edwf,06. Pumps be no longer ru.1 for 15 rnenutes. 3.7 L7 The frequency for SR 3.7.4.3 4.8.3 11 Urnque with respect to performing a Surveillance frequency details only, on AFW valves was extended from 31 days to 18 months. I i calogories
- 1. Rad ===han of AM II. Relausbon of Sunreserre Frequency ill. LCO stated in terms or Trains rather than componeres IV. Agowed Outage Tame Extensen from 24 teurs to 72 hours V. Redemmonof Required Actions toedt Applicebety VI. Reinetton of Survesence rem accepttree creeris Vll. Redemstion of ABowed Outage Time
TABLE L - MATRIX OF LESS RESTRICTNE CHANGES SECTION 3.7, " PLANT SYSTEMS," paget 4 of 8 Discussion of Description ITS Section CTS Section ci;-:- y Characterization Change LCO 3.7.6, " Component Cooling Water System," and LCO 3.7.7, Serwce Water System" 3.7 L8 Actions requwed when the LCO 3.7.6 3.3.3.2, 3.3.3.3, Ill LCO stated in terms of speerfication is not met LCO 3.7.7 3.3.42,3.3.4.3 Trains rather than were changed from a components ; smgle component bases to a train basis for the Component Cooling Water (CCW) System and the Servtce Water System (SWS). 3.7 L9 The allowed time for one LCO 3.7.6 3.3.32,3.3.4.2 IV Allowed Outage Twne , inoperable CCW System LCO 3.7.7 Extension from 24 4 or SWS train was hours to 72 hours extended from 24 to 72 hours t
- l. Releasonof App 8 cat $ly IL Reimehon of SunMeance Frequency l
111. LCO stated h terms of Trains rudher then conponeris IV. Asamed ouange Time esension Anm 24 hours to 72 hours l V. Reinamon of Required Actone to suit Appecately l VL R% of Sunreitena Requeemert are=f =nce d creerte vfl Relemtion of Amowed Oulage Time l
4 s L
..t TABLE L - MATRIX OF LESS RESTRICTNE CHANGES -
SECTION 3.7 "Pt. ANT SYSTEtes," paget 5 of 8 t Discussion of - Description ITS Section CTS Secuen Category Charactortsation j Chenne LCO 3.7.9, T,ontrol Room Emergency Filtrahon System (CREFS)," and a LCO 3.7.10, " Control Room Emergency Air temperature Control (CREATC)" 3.7 L10 The requwements forthe LCO 3.7.9 3.15.1 I Urnque with respect to CREFS and CREATC LCO 3.7.10 details of Applicabihty. ,; were reduced to apply only i I to MODES 1 through 4, movement ofimedeled ;
- fuel, and CORE l ALTERATIONS !
3.7 L11 An achon was added to LCO 3.7.9 3.15.2.a ' V Uneque with respect to -! suspend CORE LCO 3.7.10 detads of Required l ALTERATIONS or Achon. movement of irradiated
- j. fuel (i.e., exit Apphcotwhty) '
rather than place CREFS into emeenency mode l ! c I i s t Reimmeon of M IL Reinsson of Survesence Frequency j 111. LCO eteled in tonne of Traine roeier then componarde ; IV. Asowed Outage Time Edension from 24 hours to 72 hours - 1 V. Reimmeon of Required Actone to se W , i VI. Reimaton of Survesence Respairement are=pam, ice creerte : Vtt. R% of AAowed Outage Time j I i
TABLE L - MATRIX OF LESS RESTRICTIVE CHANGES SECTION 3.7, " PLANT SYSTEMS," paget 6 of 8 - Discussion of Description ITS Section CTS Section C:^. ;:--y Characterizat'on Change 3.7 L12 A requirement was deleted LCO 3.7.9 3.15.2.b None Umque to suspend reduct on of LCO 3.7.10 Shutdown Margin if both trains of CREFS or CREATC are inoperable 3.7 L13 A Sur.Cace SR 3.7.9.1 4.15.b VI Unique with respect to Requirement was relaxed details of acceptance to require that the CREFS critenon. , be operated for 15 minutes rather than 1 hour. 3.7 L14 A Survestlance SR 3.7.9.1 4.15.c VI Umque with respect to Requirement was relaxed details of acceptance to no longer venfy positsve entenon. pressure dunng operational testing of the i CREFS. e l t Categories
- l. Redemmon of Ar5*=May
- 11. Reimatkm of Sunemence Fesquency til. LCO stated in terms of Trains rather than components N. Agowed Outage Time Estension from 24 hours to 72 hwrs V. Relonnon of Required Ac9ans to out AppEcebety VI. Reimmhon of Survemence Requirement acceptance creerte VII. Reimmhan of Anowed OLAage Time
TABLE L - MATRIX OF LESS RESTRICTIVE CHANGES SECTION 3.7," PLANT SYSTEMS," paget 7 of 8 i f*Ascussion of Description ITS Section CTS Section Category Characterization Change 3.7 L15 The frequency for SR 3.7.9.4 4.15.f.4 11 Umque with respect to performing a Surveillance frequency details only, was extended from 18 months to 18 months on a Staggered Test Basis 3.7 L16 The allowed time that one LCO 3.7.10 3.15.1.a. Vil Urwque with respect to train of CREATC can be 3.15.2.a Allowed Outage Time inoperable was extended details only, from 7 days to 30 days. LCO 3.7.11, " Fuel Buildmg Air Cleanup System" , 3.7 L19 An action was added to LCO 3.7.11 3.8.2 V Urnque with 6espect to suspend movement of Required Action detads of Required
- irradiated fuel assemblies A.1 Achon. ,
(i.e., exit Applicability) ; rather than temwnate fuel handling operations. LCO 3.7.15. " Secondary Specific Activity" categorms
- f. Relemtionof Aryarshmey
- 11. Relemtion of Sunedlance Frequency ill. LCO stated in terms of Trains rather than componeres IV. Agossed Outage Torne Extension from 24 hours to 72 hours V. Reimetion of Required Achone to eult Applicately VI. Relemtion of Survesence Requirement acceptance creeria Vll. Reimation of ANowed Outage Time r
. .. m . _ _. ._ -- -
TABLE L - MATRIX OF LESS RESTRK:TIVE CHANGES ' SECTION 3.7,"Pl. ANT SYSTEMS," paget 8 of 8 t Discussion of - Description ITS Section CTS Section Category Cim . :::ensation ! Change f 3.7 L17 The requrements for LCO 3.7.15 3.4.2 I Urnque with respect to i secondary W'c achwity details of Appk.abiiny. ' { were reduced to apply only l to MODES 1 through 4- + from "all modes of - operation from cold shutdown - 3.7 L18 The frequency for SR 3.7.15.1 Table 4.1-2, . 11 Urnque with respect to performeng a Survesilance item 8 frequency details only, , forsecondary specific achvity was extended from i 72 hours to 31 days i I i i ( L R%of afv*=Nuy N. Reimaban of Furvemmnm Freepsency ' 1 Bl. LCO stated in larme d Trains reiher vien cor.1ponerstr N. AAowed Oulage Time Emansion frorn 24 hours to 72 hours l V. Reimenon of Required Actons to edt AppEcabety ! VI. RW of Servemence Requirement acceptance creerta i VII. Reimation of Asowed Outage Time j e c
- . -_ - ,, s
TABLE L - MATRIX OF LESS RESTRICTNE CHANGES SECTION 3.8, " ELECTRICAL POWER SYSTEMS," page 1 of 7 Discussion of Description ITS Section CTS Sectira C ^-- a :-ry Characterization Change
- 1 LCO 3.8.1, "AC Sources-Operstmg*
3.8 L1 The allowed time to LCO 3.8.1 1.3 VII Urwque with respect to declare required features Requirad Action allowed outage time with no offsite power A 1 and B.2 extensson only. avasiable inoperable when its redundant required feature is inoperable was < extended from no allowed time to 12 hours. The allowed time to declare ' required features supported by the snoperable diesel l generator when its redundant requwed feature is inoperable was extended from no allowed , time to 4 hours I. Relaxaton of Applicabisty
- 11. Relaxaeon of Survemance Frequency
- Ill. LCO stated in terms of Trains rather than Rscwe.6 IV. A50wed Outage Tune Extemson from 24 hours to 72 hours V. Relaxabon of Required Acbor's to exit Applicabety VI. Relaxation of Survemance Requirement acceptance enterie Vll. Relaxabon of A50wed Outage Trne ,
Viit. Deleton of Requirement for 30 day Speaal Report to NRC ' 1 4
TABLE L- MATRIX OF LESS RESTRICTNE CHANGES SECTION 3.8, TLECTRICAL POWER SYSTEMS," page 2 of 7 Discussion of Description ITS Section CTS Section C_%+ y Charactertzstion Change 3.8 L8 The required time that the SR 3.8.1.11 4.6.1.5 None Umque diesel generatoris tested between 2650 kW and 2750 kWis reduced from two (2) hours to 21.75 hours. LCO 3.8.3, " Diesel Fuel Oil and Starting Air" 3.8 L2 The time allowed for LCO 3.8.5 3.7.1 VII Umque with respect to restoraten of fuel oil to Req' sired Action allowed outage time within limits is extended A.1 and B.1 details only, from no allowed time to 48 hours i categories
- 1. R%etation of Applicabiky II. Relaxabon of Surveitenes Frequency Ill. 1.CO stated in terms of */ rains rather than components IV. ABowed Outage Tune Extension from 24 hours to 72 hours V. Relaxabon of Required Actons to exit ApplicabiMy VI. Relaxabon of Surveigence Requirement scca ce entena Vll. Relaxabon of ABowed Ot.4sge Trne Viti. Delebon of Requirement for 30 day Spedal Report to NRO
TABLE L- MATRIX OF LESS RESTRICTNE CHANGES SECTION 3.8, " ELECTRICAL POWER SYSTEMS," page 3 of 7 Discussion of Description ITS Section CTS Section C"_ -pf Charactertantion Change LCO 3.8.4, "DC Sources-Operating" s 3.8 L4 The Surveillance SR 3.B.4.1 4.6.5 11 L p with respect to Frequency forvenfying frequency details only battery voltage is 2125.7 volts was extended from daily five days perweek to once every 7 days. cuesa.
- 1. Releason of Applicabitty
- 11. Relaxagon of Surveitance Frequency ill. LCO stated in terms of Trains rather than wT, pow a.
IV. AHowed Outage Time Extenson from 24 hours to 72 hours V. Relaxabon of Required Actons to exit Applicately VI. Relaxabon of Surveitance Requirement acceptance enteria Vll. Relaxabon of ANowed Outage Time Vill. Deleton of Requiremerit for 30 day Speoal Report to NRC
1 l . TABLE L- MATRfX OF LESS RESTRICTIVE CHANGES SECTION 3.8, " ELECTRICAL POWER SYSTEMS," page 4 of 7 ~ Discussion of Description ITS Sechon CTS Section Cr& geery Characterization Change j LCO 3.8.6, " Battery CeX Paramete s" '
, 3.8 L3 The time allowed for LCO 3.8 6 4.6.3 VII Unsque witi respect to
- i battery ceH parameters to' Requweo Actions a50wed outage time not be within Category A A.1, A.2, and A.3 details only and B limits was extended from no time to 31 days when pilot ceH hayte level and float voltage are venfied to meet Category C limits within 1 hour and that battery ceH parameters are venfied to meet Category C limits wrthen 24 hours and every 7 days ttweafter.
i canegories
- l. Relaxaton of Appicabibty
- 11. Relaxaton of Survemance Frequency ~
lif. LCO stated in tmns c6 Trains rather than components IV. AHowed Outage %e Extenom from 24 hours to 72 hours V. Relaxagon of Required Actons to exit Apptcabilty VI. Relaxabon of Surveilance Requwement acceptance entene VII. Reiershon of Allowed Outage Twne Vill. Deleton of Requirement for 30 day Special Report to NRC i
, e 3 p 3
+
I TABLE L - REATsuK OF LESS IESTfWCTTWE cHftf0GES ! j' SECTION 3.S, N POUWEP SYSTE:SBS," page 5 of 7 L osecuarien er osoevipsen rTS seemen CTS seemen ceaseery commenersammen
- Cheas' 3.8 L6 The Survomence 'R 3.8.6.1 4.6.3 N Unsque wiWi respect to i
,[. Frequency forvenfpng toquency detets only - !- prot cet voltage and j tornparature was extended , lr from doBy M days W [ ji week to once every7 ' 4* days. i 1 :) [ h 3.8 L7 A surveiBance requwement LCO 3.8.6 4.6.3 None Unsque , ll ' to subject the beIIenes to l
- an equesiang dierge
a 1; 3.8 L10 The Surveigence SR 3.8.6.3 4.6.3 N Unique wist respect to Frequency forverirpng " : , - y details only ; average W
- . temperature was extende6
j^ from 5 days perweek to ! once every 92 ders. t i i ,_ _L Reissagen dApescotsby l R. Reisseman of Swwesence Frequency i
- E. 8.CO seated in tenne et Trains rasher then components
! W. A3 awed Outage Tme Embenoor from 24 hows to 72 hows l V. Reisunton of Requesd Actons to es W vt Reimonnon er sunseenee Regemment acceptance creens i VIL Reimmeon etAAswed C Jtege Ten VR Delston et Regusement for 30 day W Report to NRC i f 5 i
. . . . _ _ . _ , , . . , . . - _ ., _ .._ . ,_..____. .._ u __ _
i 4 i
- TABLE L- RAATRIK OF LESS FESTf5CTWE CHANGES l SECDON 3.8, N POWER SYSTERBS," page 6 of 7 hW of n==ertption ITS Section CTS Secelon Category Chorectorisation !
Change ! 3.8 L11 - The SurveiBance SR 3.8 62 4.6.3 !! Unque witirespect to Frequency for venfying frequency details only ! bettery ces parameters i i was extended from 31 I days to 92 days. I 4 LCO 3.8.9, Tiectncal Distributon Systems-Operatrig" l ]' 3.8 L5 The time allowed for LCO 3.8.9 3.7.1 Vil Unique witt respect to , restorabon of an Requred Achon aBowed outage time
- inoperable AC electncal A.1 detais only '
i Power h. system is extended from no l ! allowed time to 8 hours and 16 houry
- rom :
G5CC.ef of failure to meet : LCO. t 4 T I i ! L Redoston of Apptcetmy ! 4 E. Reimaton of Surwesence Frequer$cy l R. LCO stesed a terms of Trans rseher then components l IV. AAowcd Outoge Tee Eulenson from 24 hours to 72 hours ! V. Reinston of Regured Acsons e est Apptcabety [ VL Relemmon of Survesence Regurement acceptance entene V5. Keimmeon of Asowed Outage Tee VM. Deleton of Reguremert for 30 der Specel Peport b NRC } . t
4 TABLE L- MATRIX OF LESS RESTRBCTIVE CHANGES SECTION 3.5, " ELECTRICAL POWER SYSTEMS." page 7 of 7 hamei-i of Descriptum ITU Section CTS Section Category CharactortasNon Change 3.8 L9 A requwement to test SR 3.8.92 Table 4.1-3, None Ursque themel trip elements of SR 3.8.9.3 flem 18 molded case creud breakers is removed from a surmillance requrement. i i t I t f cassonnes L Redesem of Apcicebety R. Reismaton of Survemence Frequency ; lit LCO stated in terms of Trans rather eten IV. Asowed Outage Tme Entensen from 24 hours to 72 hours V. Referation of Requred Achons to edt Apprrnhasy VL Rdexaton of Survegence Requrerwmt acceptance creene VII. Redexaeon of Afowe,d Outage Tsvie VNI. Deleton of Requwement for 30 day Specul Report to NRC 4
4->=+-am44 4 6 4&= 44--M A4 >4+4 wwL_.) 4 E.446 4 4 4JCW .p e.e. m .44 - 3m,, &+M-. y Aphm ----_ -4Ah i M g.Ch AJJ M h k h4m M
- Mi us+hW hMX,4 4I aP'A A-i e
4 3 e l ' fit 111 .
\
\ g _
\
=
1 i 4\ b I g is y i s. s h kn\ 1
\
4 g 1 i _ . .. -_- _ _ _ _====.- .- --- _-- . .. :
i TABLE L - MATRIX OF LESS RESTRICTNE CHANGES SECTION 3.9, N OPERATM)ag- page 2 of to ru.e.* of C;; L^_'s. ITS Section CTS Section Category Characterisation Change LCO 3.92," Nuclear Instrumentabon" 3.9 L5 The requred schons for LCO 3.9.2 3.8.1 V Unque vnth respect to the con & bon when any of Requred Achons requwed acton details the refueling specL "uc65 A 2 , B.1 and applicability were not met were relaxed to apply only to the consbon where both source ranges are i inoperable t-i t l C _^ , - L Reinemenof M
- n. Res amonaf survesence Frequency i BL LCO assame h terms er Trains reiher tupi componeres i N. Asuused Outage Trne Essension kom 24 hours to 72 heure V. Res neen of Required Actons t VL Reteuean er Stavedmence Requiremerit W creerte Vu. Reemenon er Asawed Oisage Tene VU' Ovesem of Regnernert for 30 day Sperssi Report to NRC tt Reesuman of LCO Reguremert a
N
'I i
TABLE L- MATRDC OF LESS RESTRICTNE CHANGES 4 SECTION 3.9,"REFUEUNG OPERATIONS" page 3 of 10 th* of C.w '@ ITS Section CTS Section Category Charactertmellon Change LCO 3.9.3 "Corf.asnment Penetrabons" 3.9 L2 The requrements for LCO 3.9.3 3.8.1 IX Unique with resoed to closure of the contenment Speedcohon ew doorwere requrements only : 4 relaxed to requee or$ four (4) bolts in place rather than au boats in place as prewoushr requered < t i 4 i t i l i , r L Reinamen er e N. Reimuson of Survemence Frequency ! til. LCO stated ki terms et Trains reew Wien coregseneres t IV. Assumed Outage Time Edensen kom 24 tiours to 72 tiours V. RW et Roepared Actons &
- vi. Reemumen et Survomence Requeemort W creerte !
- VM. Reemuton of Assued Odoge The vs. Deeseen at Reguremere for 30 der Special Report to NRC i IX. Reemamanof LCO C4_t.. ; !
l i l I
t
- .i I
i i TABLE L- MATRIX OF LESS RESTRICTNE CHANGES SECTION 3.9," REFUELING OPERATIONS- page 4 of 10 : I rheaa==W of Cm'fl - . ITS Section CTS Section Category Charactortantion , Change t 3.9 L9 The requwements for LCO 3.9.3 3.8.1 IX Urwque with respect to i closure of contawiment Spec 6calmn penetrabons were reioxed requwements only from requong aR i automebc valves to be , operable or have atleast i one valve in a penetrabon be dosed to at least one manual or automabc valve, i blind flange or equrvaient beme closed 3.9 L7 The requwed frequency for LCO 3.9.3 3.8.1 11 Urwque with respect to performmg the surveillance surveigence frequency , requwement to venfy the details only , contamment purge system was relaxed from prior to refueling operabons to 18 months. t i r [ .i I M L Roemenonor M j a. sreamanenerSuneemmeFreesency f ) lit. LCO stoned in terms or Traine easier then congeneres ! ] IV. Atomed Ouence Tsme Emmeon from 24 hours to 72 hours i v. ReemenonatRooered Acmons , j VL Reemsehen or Sunemence Regubemert W creerte VN. Reiseason er Aponed outspe Time vm oenemen or Regunement sur 30 day Spaced Report to NRC
^
3 IX. Retammen or LCO F , _ . . _ . j i
- . . = - , , . . -. -
TABLE L- MATRIX OF LESS RESTRICTWE CHANGES SECTION 3.9," REFUELING OPERATION!r* page 5 of 10 rwa ==3a i of Description ITS Section CTS Sechen C J__.- f Charactortsseion 1 Change 3.9 L8 The requirements for LCO 3.9.3 3.8_1 VI Urnque w% respect to i ,. pwifciirsg a surveillance surveiBance to venfy that each valve in requwement the Containment vent and acceptarice Cntene purge Sfstem actuales to the correct pos4tson were relaxed to perrrut the survesilence to be met utilcong an actual segnalin addition to the currently reound simulated segnal i ! t 1 I t i i e^ __ _ j L Reimagon of. , , ,
- n. Rei- msn of sun.amaceFrequency
- ' W. LCO stated ki terms at Trains rather than eingenenes ,
l IV, Abowed Odage Time Emlensson from 24 hours ts 72 hours i V. R% of Regwed Actons VL Reimahan of Sungeance Ragdromert @ creerte
- . VIL Reineman of AEowed Odese Tkne Vm. Deeston of Requiremert for 30 day Special Report to NRC j IX. RWeeken of LCO C
- ;- - 1...~
l i r
TABLE L- MATRIX OF LESS RESTNICTWE CHANGES SEvM 3.9, WVELING OPERATIONS" page 6 of 10 TMaesa==aast of L ~ l's. ITS Section CTS Section Category Characterization Change l 3.9 L3 The requwements for LCO 3.9.3 3.8.1 IX Urwque with respect to mainterung contariment spe m , purge penetrabon system requwements only , operable when the system is not in opershon were relaxed from requaing one valve to be securely closed i to requenng both containment isolabon valves in the penetrabon j operable i f i i P Categones L ReemanonotW , !L Reimsten of Serweamce Frequency IIL LCO stated in tenns of Troms roter fim components IV. AAoued OWege Tene Essension inwn 24 hours to 72 hours
- v. Reemasonof Requbed AcSons !
vi. Reinamen et swveerte Repegnant P creerte VM. Releeson of Amound Outage Tkne vnt Deseson of Resuremert for 30 day Spedef Report to NRC ! DL R% of LCO Regusemert i i I
- _ _ . . _ . . _ _ _ , , ~ _ _ _ _
b P TABLE L - MATRDC OF LESS RESTRICTIVE CHANGES 4 SECTION 3.9,"REFUEUNG OPERATIONS page 7 of 10 i M Of CL Li'a ITS Section CTS Sectient % m Change i 3.9 L4 The requred achons for LCO 3.9.3 3.8.1 V Umque wilh respect to the condebon when any of Requred Achons requred schon details the refue$ng spec 6cahons A.1, A2 ,. were not met were relaxed to requre that core i: alterabons and rnovement ofirradiated fuel be suspended, rather than to ' suspend as refueling ! cperabons as was ) crevioush recured I ! l l 1 I i { T f l i censoons. . I L Reheuman er W i
- n. Retaimean er survenance Frequency l M. LCO sisted in terms er Tream reener peri caregionants IV. W Odess Tone Edensen torn 24 hows to 72 hows V. Ruinesten er Regured Actons VI. Reimsten er Sungeance Requiremert =r-yemnce creerte vu. Reimaton er Agound Onaspe Twne vm. Detmean of Regutemert ser 30 der W Report to 98RC DL Rehemmen erLCO Respiremert t
i I
.,.I
TAsu F L- MATRIK OF LESS IEST14CTIVE CHANGES SECTION 3.S,"REFUELMG OPERATIONS" page 8 of10 rme..m.iani of .. Descripuon ITS Sec6on CTS Seceson Category Charactorkmeon Chenee LCO 3.9.4, *RHR and Coolant CirculaborHiigh Water Lever 3.9 L6 The requwed schons for LCO 3.9.4 3.8.1 V Uruque with respect to the condibon when any of Requred Achons requwed schon details the refueling specficahons A.1 and Al were not met were relaxed to requre that core aNer-h and rnovement i ofimediated fuel be ! suspended, rather than to suspend all refueling opershons as was I Drgnnously recured a
- i. !
a i i L Reemusener M ;
- 5. Reimaglen er Survemmnoe Fesquency
- m. LCO stated h terms er Trums remer men congenents IV. W Outage Tune Emansen from 24 hours to 72 hows V. Rahmeson er Requesd Adlons VL Reimmeon er Swweemnee Rewipemert P cmerte i vu. Reimmhan er Amused Outage Time
, vs. o weenerr , _-._:ssr1oderspaces wto seRC Ix- Reemumen er Lco Rochemure a !
--i -=m" - m -ge-,yy .- - - - -- - - >---+r -*-e y---= --
r TABLE L- MATRIX OF LESS REST 7WCTIVE CHANGES SECTION 3.9, *TIEFUEUNG OPERATIONS" page 9 of 10 . hW W ITS Secuen CTS SecNen % N
- chang, 1 LCO 3.9.7, Tontainment Purge Filter System
- j- 3.9 LS Requwements forisoishon LCO 3.9.7 3.8.1, 3.8.2 V Unque wish respect to !
j of a contawiment purge Requred Achon requwed adion details j
- system penetrabon when A.1 i i the system is inoperable j were relaxed to include addshonal means of isolshon previously not considered. The additionsi means ofisolabon are a 4 closed manuel or automsheisoishon vaht, blind flange, or an !
equnraient method that can ! provute a temporary ! atmosphene pressure and , ventilation bemer I j L Reimaton et M M. Reimmeon or Swwesence Fmponey
- M. LCO sisted in terms of Trasis roeier vuei cartponeres 1
IV. W OiAuge Tene Deensen hem 24 hours to 72 hours V. Retsuden er Requesd Actens VL Raamaton of Swwesence Regubemert W creerts VN. Reimaton of W Outspe Time Vm. Desanon :s Requeemord for 30 day W Report to NRC ot Reamunen of LCO Reemoment i l l f 1
r l I l j TAIN.E L-IIATRDC OF LESS ESTRICTWE CHANGES
.*ECTION 3.9,'PEFUELSIG OPERATIONS page 10 of 10
- a rhe.* of Doocription ITS See son CTS Section Category Charactortsellen [
Change ; i 3.9 L4 The requwed actions for LCO 3.9.4 3.8.1 V Unique wisi resped to the condition when any of Requwed Achoses requwed actens that ! the refueling speur.c.abons A.1 and A.2 are deleted ; were not met were relaxed to requwe that core , alterations and movement ofirradisied fuel be ; susperwied, rather than to suspend all refusiing ; operabons as was l previously requered. l 4 i P i canegone. L Reinamen of M ! N. Reimuson of Swvemence Frepency Ill. LCO eested in terme of Trains ramer than componeres IV. W Outage Tone Edension torn 24 hows to 72 hows i V. Reimuson of Requead Adiene i vt Reimanen et Sevemence nequhemert % acerte ! .! vil. Reimmeon af Aw Odage Time i i Vllt Doistan of Regubemert ser 30 day Specist Report to NRC ! i DL Reimagen of LCO Requiremert t ' { t i j I 1
a 5 TABLE L- MATRIX OF LESS RESTRICTNE CHANGES SECTION 4.0 " Design Features" page 1 of 1 Discussion of C;%": . ITS Section CTS Section Category Characterlastion Change ! 4.0 " Design Features" # a 4.0 L1 Requirements regarding 4.2.1 5.3 None Uruque with respect to Desagn Features forthe applicabihty dotads reactor core were expanded to allow for ! livrwted substdubon of filler rods and lin ed use of .; lead test assemblies i t 4 s t i i Categones
- 1. RW of Ande=Mey H. RW of Survesence Frequency '
'R LCO stated in terms of Trains rather then components IV. Atowed Outage Trne Extensson from 24 hours to 72 hours V. Relaxaton of Requred Actons to exit Appicebety t ; VI. Relaxaton of Survesence Requirement acceptance entens VB. RW of Atowed Outage Trne Vm Delebon of Requirecent for 30 day Speoul Report to NRC 4
i !
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T 'f i L , .t l:
- r. ..
, TABLE . L - ItATIWK OF LESS 54ESTf5CT1WE CHAffGES i" SECTION 5.0,"NT1WE CONTROLS" page 1 of 6 j
't i Discussion et Descripson ITS Secelon CTS Secuen Coengery Clearestertmedian >
Change i i Sechon 5.2, "Org snuskon" ! -j . . t {'f 5.0 L1 The poseen of quali6ed Seckon 52_2 6.2.3 None Uneque radekon control technoen ,'!. was aRowed to be vacant i
- j. for two (2) hours to prowde 1 1- for urW absence, .
i prended immodate aden is tehen to fu the requend i posten. j
- 5.0 L2 The aRomance for shiR Secten 5.2.2 6.2.3 None Uruque
! complement to be one less l tien Wie muumum i requwement for two (2) l hours 1ses relemed to aBoer ; tiet Wie shiR complement I can be less then the muumum requwement for two (2) hours } l L netsuden of AppEcatBy l- u. neemason er Swimmence Fseaguancy ' W. LCO atuted in tenus er Tsehs sapier men eenipaname i N. AAmmed Oisage Then Essensen tens 24 feews to 72 hows ! V. Ruemumener noemed Assenstoens M vi. neemseen er sewesence noemement osaspamme csonne j vu.- lessausener Asamed Ouesse Thee VM. Dananen er nuesomem ser 30 dWF Special flapest to NRC i i 4
, . , ~ , ,y
TABLE L - MATRA OF LESS RESTRICTWE CHANGES SECTION 5.0 "ADMMISTRATWE CONTROLS" page 2 of 6 Discussion of C;s ' ^_~ x.
. ITS Section CTS Section Category Charactortantion Change j 5.0 L3 The requrement Unt the Sechon 522 6.3.2 None Umque i Manager-operabons shall hold or have held a semor I reactor operata license for either HBRSEP or a senilar plant and that the Manager-She operahons shall hold a sernor operator license was relaxed to the 1
ManagerW or the Supenntendent in charge i of Shift Crews shall hold a semor reaClor operators i license I i i i ! I casegares L Reimaton of AM l 2 R. Reisuman of Survesence Frequency M. LCO steled h terme of Trehs remer than componeres ,. N. Amoused OiAuge Time Estensen from 24 hours b 72 hours V. Reimmeon at Requeed AcSono to og am VI. Reteason of Sunmeance Requeemert W creerte vu. Reemmean at Asamed outage The vm osasean er- _. :for 30 der W Reput to NRC
TABLE L- MATRDL OF LESS RESTRICTNE CHANGES SECTION 5.0, "ADMNSTRATWE CONTROLS" page 3 of 6 rue.* of Description ITS Section CTS Section Category Charactortsmalen Change Sechon 5.3," Unit Staff Qualdicabons* 5.0 L4 The quaincahon 5.3.1 6.3.3 None Uncue requrements for the ma%wof the radiabon protechon funcbon were relaxed from ..' ..wd 4 Regulatory Guide 1.8, September 1975, to ANSI /ANS 3.1-1951, wtwch relaxes the empeneax:e requirement from five (5) veers to four m years c- . -. L Resumusenof M E. Releuten of SurvuGente Ffoquency EL LCO stated in teams of Trans rueger tum certgemeres N. A8eused Otampe Time Edensen Deret 24 hows to 72 tews V. Relemsten af Requead Achums to se W VL Reematon of Swweence Requirement P creene Vit. Retuuston et Asommed Ouenge Tame VIR. Datuten of Reguarement for 33 day Spocal Report to NRC
( l TABLE L- MATRDC OF LESS RESTRICTIVE CHANGES i , SECTION 5.0,"ADMNSTRATIVE CONTROLS" page 4 of 6 i l Discussion of & -;^ia TTS Section CTS Section Category Characterimation Change e Sechon 5.6. "Reportug Requirements
- 5.0 L5 The due date for the Sechon 5.62 6.92.1 None Unique Om ==8-mal Radiabon 6.92.3 Evrw=mre Report was '
relaxed from March 1 to , April 30 of each year. The due date for the annual Radiological Envronmental Operahng Report was relaxed from May 1 to May 15 of each year. ' 5.0 L6 A special report requred Sechon5.6 6.9.12.1 None Unsque when reactor coolant exceeds WR actmty , Empts was deleted i j ! i capa== l
- 1. L Retoshan er M j
- u. Reemaman er seveennee rm _, i 8t. LCO stated in terms or Trains romer tien comperwen i IV. Atsused Oistage Tkne Essensen trem 24 hours to 72 tiews V. Reemseen er Mogtmed Acsers toend W VL Retouhm et Swvueurs Rogeremert areeptance creene VB. Retoshon of Asamed oimage Tene V1H Deneman er Requiremert Ser 30 der W Report to N8tC L t
. , ,, .m -m-- .. --
e,---w ---- -- -- --- n - -. , , ,-- n - - - - - - - - - , .
t TABLE L- MATRIX OF LESS RESTIUCTNE CHANGES SECTION 5.0,"ADMIPeISTRATNE CONTROLS" page 5 of 6 i then* of C.s'A. ITS Section CTS Section Category Chorectortsation Change .; 5.0 L7 The requrement for Sechon 5_6.3 6.9.1.3 None Urnque reportog informsbon in the
- Radiological Effluent Release Report was i relaxed from twnee peryear to once a year.
]
5.0 L8 The due date for the Sechon 5.6.4 6.9.1.4 None Unque l monthhr operahng report ! was relaxed from the 10th of the month to the 15th of : the month i t i i consgenes L Rotesson er Appecutely N. Reheaton er Surwomence Frupsency tu. LCO samled h terms or Troms *seier than cargonents , IV. Aassed Outage Tirne Entenelen trum 24 hows to 72 hours V. Redmenon or Regused Acmens toed W vi. Reemason er sunnamne. Roosromme % creerie l vu. Reamunen or Anomed Ouenge The vs. Deeseen or Reguramort for 30 day W Report to NRC I
i 1 l TABLE L- MATRDC OF LESS RESTRICTWE CHANGES : SECTION 5.0, "ADMINISTRATWE CONTROU5" page 6 of 6 h* of Doocription ITS Section CTS Section Category Chorectoriention Change 5.0 L9 The due date for the slear's Secbon 5.6.8 42.1.3 None Unque generator tube inservice : inspechon report was renamed from bemg included in the operahng ,
! Report for the penod in 1 which the inspechon was >
s, iG:J to the Operahng Report for the : penod begoning after the : w was u 4:.1 5.0 L10 The requremerd for the Sechon 5.6 6.9.3.1 None Unique ) Contammerd Leak Rate ! Test Report was deleted. l ! ] ! c*e" _ i i L Reimuserter W
- 11. Reimamerser Swwesence Frequency W. LCO steled h terme er Trans remer een eenquenants .
, N. W Oidspe Thee Denneen frem 24 hours to 72 hows i
- v. Reinamen er Reemed Acmens to ens W VL Reinamen er Swwumance Ressomert W creerte VII. Retuuman er M Ondage Tevie Vill. Deisten er Roemement for 30 der Speast Report to NRC *
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TABLE L - MATRIX OF LESS ESTMCTWE CHANGES SECTION 2.0 *3afety Limits (Stf page 1 of 1
%+ or osseripeian iTS Seesien cts Seceien cas gery C. m Change 2.0 "Safetv Limits (SL)"
2.0 L1 The requirements 2.1.2 22 I Unique with for Reactor respect to Coolant System Applicability (RCS? Pressure details barety Limits (SL) were reduced to exclude the time when fuel is in the reactor vessel and the rector vessel head closure bolts are not fully tensioned or the reactor vessel head is removed. cassonnes t neesseen ere
- n. Remsmann er saneamnce F#equency lit LCo :nmeed in terms or Trans ramur van coreponeres IV. Atomed Oduge Tavie Eienneen frown 24 hours to 72 hours V. Rake W Reguted Actons toest M -
vt waama sunemence Regnemere e creene Vit Whf Atomed Og Tune VIN Desa.ew. Aemmernert ter 30 day W Report to NRC
TABLE L - REATRIX OF LESS ESTMCTIVE CHANGES GECTION 3.0,"LIIIITBIG COMNTION FOR OPERATION (LCO) APPe rann ITY," page 1 of 1 , W of Doncriptson ITS Section CTS Section Category Characterization 4 Change 3.0 L1 An excephon to complpng LCO 3.0.5 3.0 None Unngue weh recuredacnons when a spoo6cahon was not met was added to : agow for teshng of inoperable egapment in , order to restore the inoperable egapment to operable status. t
~
3.0 L2 An allowance for extendog SR 3.0.2 4.0 None Umque the frequency by 1.25 3 innes aner the first cerformance of a requred achon when a spec 6cabon ' is not met was added. The frequency must be spec,fied as once per. . .- i i t , cat w ries I. Relaxation of Applicability. ,
- II.. Relamation of surveillance Fregaency I III. LCD stated in terats of Trains rather than components IV. Allowed Outage Time Extension from 24 hours to 72 hours V. Relaxation of Required Actiers to emit Applicability VI. Relaxation of Surveillance Requirement acceptance criteria VII. Relaxation of Allowed Outage TinK.
i VIII. Deletion of Requirement for 30 day special Report to NRC r a
TABLE L- MATRIX OF LESS RESTRICTNE CHANGES SECTION 3.1, "REACTMTY CONTROL SYSTEMS," page 1 of 4 ha==iaat of N:: --f2-. ITS Sochon CTS Sechen Category Charactorfmetton Change LCO 3.1.1, " SHUTDOWN MARGIN (SOM)* s 3.1 L1 The allowed time to LCO 3.1.1 3.10.8 Vil Umque with respect to
- . restore SOM to wi' fun the Requred Action allowed outage time requredlirmts was A.1 extensson only extended from no allowed l time to 15 rmnutes. i LCO 3.1.2, " Core Reactmty" 3.1 L7 A requrement was deleted LCO 3.1.2 4.9 Vill Uneque with respect to to subrmt a Special Report crcumstances of to the NRC within 30 days report of observance of a difference between predected and actual boron l
- concentrabon that is equivalent to one percent !
in reactmty I Categones f Redmaton or Aprarehany ti. Reinston or Swwusence Frequency CI. LCO etmeed h terms or Troms reiner man componeres l IV. AM Outage Time Edensen from 24 hows to 72 hours '
- V. Reimmahan or Requesd Actons to end Anter=hesy VI. Reimmeon or Survemance Requeremard =re=re=nce cribune VII. Reisuukon or Aw Outage Tone l Vm. Deemton or Requeer9ert for E day W Report to NRC t
I i i
. . .. .- . . . - . - =. . - - .. .- -- .- . . -. -
- i. ,
l 6 TAEKE L - MATIWK OF LESS fESTIWCTWE CHANGES SECTION 3.1, N CONTROL SYSTEMS," pees 2of4 h of Description ITS Section CTS Soseion Catsgery Chareetartenden [ { Changs [ t-
- LCO 3.1.3, " Moderator Tem perature Cosmoent" ;
- -- 3.1 L2 ' A requuement to make me LCO 3.1.3 3.1.3.3 None Unsque
!~ reecsorsubenmens by an Requesd Acamn ! amount greater tien or A.1 i
. @ to tie M nemen=dyinsermon from i i t ,.cww was
! reinsed to requWe test admnustranwe contma rod , wetidramellimes to i ! mainteWI h ! !' Temperature Cosmoent ! l (MTC)wieun limit witun 24 . hours ! i ? t s i I
- i
? i s l cas===
- l. L Madamesn of Appecamely ;
- l. E. Reimmemn of Sesweemion Fsopency }
HL LCO stated situnns of Tsusus sugier een conqponeres ; l j W. Aasmue Oidsge Tone Esemnemn tone 24 hears to 72 hows V. Resumeen et Regned Aceans to ese Appecademy
- vt massenen er sunessmace newsumuse anospannes creens vu. Raamaban at Aessed Guampe Thun vnt oneseen er no, msnt ser ao emy speaar nepart to nne k
a ! 4 l =.__ .--,._..-.,.,;.._.,_ _,. . . . . , . . - _ . . _ _ . _ .. ._ _;-.,._ _ _ _ _ _ _ , . , . . _ _ , _ _ . _ _ _ , . _ . . _ _ , _ _ _ _ _ . . . _ _ _ _ _ .
TABLE L - MATRIK OF LESS fEST7BCTWE CHAf0GES SECTION 3.1, *1E.ACTMTY CONTROL SYSTERAS," page 3 of 4
- Disconsion of - Descriptson ITS Section CTS Secelon Casogery Charesterimetion Change
- i _ i 3.1 L5 The time allouved for LCO 3.1.6 3.1.3 None Unngue
! shuthng doun the reactor Requesd Action ' l vehen the MTClouvorlimit C.1 is not met was extended . l from eight (8) hours to 12 hours : i " 3.1 L3 - The surveillance SR 3.1.4.2 Table 4.1-3, I, II . Unique witi respect to
- . requwement forvenfring item 2 frequency and ;
rod freedom of movement surveinance i l was reimeed to apply only M details - to rods not funyinserted only i and to be performed only
- every 92 deys recher then every 14 deys as
, previousiv reaured 4 ! r
- i i.
L Reimmhan er Apgecamer
- u. Retemmen er Surweaance Fsequency i III. LCO sensed m tenns or Trane senhor men conqueneree '
N. h Odes Tone Esaanean Irorn 24 hours to 72 hours i V. Raimumen er Requesd Achene to endt Appizabely vt Reinamen er Swwesence Rapeemere acompaanse canone . vs. Reemanen er Ammand owage rene l Vllt Deseman er Regusement ter 30 der Specul Report to NRC l 4 . i*
, . . , . ., ., . . _ . , - - . . ~ _ , . . , _ . , . . - . - . - . _ _ . . , . _ - , _ _ - . _ _ _ . . . _ _ . _ . . . _ _ _ _ - . _ _ _ . . . .
i i i
- TABLE L - IAAT54K OF LESS IESTIWCTIVE CHMfGES SECTION 3.1, *1EACTMTV CONT 500L SYSTEK /* page 4 of 4 l Discussion of . Deseription ITS Secesen CTS Secties6 Caengery CIneraseertuealen Clience LCO 3.1.6, " Control Bank Inserhon Laruts* I t t 3.1 L4 . The time agowed for LCO 3.1.6 3.10.1.3 None Unsque restonng cxmtrol banks to Requred Action
,- wnthin inserton rats when A.2 }. control banks are not witun limits was extended from one (1) hour to two l
- Q) hours I LCO 3.1.7," Rod Possbon %*
3.1 L6 Requsements were added LCO 3.1.7 Table 4.1-1; None Unsque forrod poemon n % leems e and to - which prowde alternate
- achons forinoperabie t possison wubcohon to tie i
!- requwoments for rod inserman rmes , 't '. t i , I j- ; l~
- 1 1- L. Messmeen er Appecabely l N. Malmasen orSumemence. . -- .
- HL LCO semand si tunns er Tmmes meter tien compensras J IV.
l Aesmed Oismen Tone Essenmien tone 24 tenure to 72 liows j V. Mesmemann er Mooses Acsons to se Appacabasy f 4
- w. nemer sunemence me,somme eessens '
vu. Muamsunen er Aeomed oinage Tsue ! vin. Dessaan er noenemem ser so emy spanis napset to senc 2 ! 4 _ _.__._____.t
TABLE L-MATRIX OF LESS RESTfWCTWE CHANGES SECTION 3.2, N DISTIWBLmON UMITS" page 1 of 7 1 Descussion of E::Jf_'::. ITS Section CTS Section - Cologery Charactonashen Cn.n e i . LCO 32.1, " Heat Flux Hot Channel Fador" 3.2 L1 The requrements for the LCO 32.1 3.102 I Unique with respect to heet flux hot channelfactor Appbcatsty applicat2ty details i were isted to apply only ansy to MODE 1 rather than a5 times as previously applied i 32 L2 The allowed time to reduce LCO 3.2.1 3.10 2.1.1 VII Unsque with respect to ! the overpowerand Requred Achon allowed outage time i i overtemperature aT A 2.3 extensson only. j setpoets when the heat i flux hot channet factorlimit ! cannot be met was i extervixi from 24 hours to 72 hours i-i ca ,.es l t Relemton or M i u Reineman or Swwesence Frequency M. LCO seated in terms or Trans rather een carmponeres IV. Assued Ondspe Tune Emeneen frarn 24 hows to 72 hows V. Redommhan or Requesd Actons VI. ReimmhanorSurveAunce- ., _. _ . arrageance creeria M Reenaean or Aaoused Oulage Tirne x vm. Doestan or r , _ _.: ser 30 der Spaces Report to NRC 2 P
TABLE L- MATRIX OF LESS RESTRK:TNE CHANGES SECTION 3.2, " POWER DOS TRSL' TION LitetTS" page 2 of 7 Discussion of . Descriphon ITS Sechon CTS Sechon Category Charactenzation Change LCO 3.2.2, " Nuclear Enthalpy Rise hot Channel Factor" 3.2 L3 The requirements for the LCO 3.2.2 3.10.2.1 I Uneque with respect to heat flux hot channel factor Applecabihty applicat2ty detads
, were lirnited to apply only only i
to MODE 1 rather than all times as previously apphed 3.2 L4 The requerement to LCO 3.2.2 3.10.2.1.1 11 Unsque with respect to perform a survedlance to frequency dotads only
. rify the nuclear enthalpy rise hot channel factoris ,
within limits after ;
% exceeding by 10% the power level at whsch the
, heat flux hot channel factor was last determined was del 8?ted. 4 Categones
- 1. Rad ===han of AM g it. ReW of Survetence Frequency til. LCO steled in terms of Trane rather then componerds iV. Atoned Otsege Time Estensson Imm 24 hours to 72 hours V. Reimmbon of Requred Actons -
VL Rei===han of Sunemence Requrement =rvete=nce entens ! Vll. R% of Amowed Outage Trne l Vlti. Destion of Requrement for 30 day M Report to NRC
TABLE L - MATRIX OF LESS RESTRICTIVE CHANGES SECTION 3.2, " POWER DISTRIBUTION UMITS" page 3 of 7 i I
' Discussion of Descriphon ITS Section CTS Section Category Characterization '
Change 3.2 L5 Requirements to reduce LCO 3.2.2 3.10.2.1.1 V Uruque with respect to the overpower and required actions that overtemperature aT are deleted setpoints if the nuclear enthalpy rise hot channel factoris not met within 24 hours were deleted. LCO 3.2.3, " Axial Flux Difference (AFD) (PDC-3 Axial offset Control Methodology) 3.2 L6 A requirement was deleted LCO 3.2.3 3.10.2.7 V Uneque with respect to to reduce the high neutron requered achons that flux setpoints to below are deleted 55% when accumulated penalty deviation time exceeds one (1) hour. i i CW
- l. Rel===han of AM II. Reismahun of Survedence Frequency 111- LCO stated in terms of Treens rather than corrponerts IV. Atowed Outage Time Edeneaan from 24 hours to 72 hours V. Relaxahon of Requred Achons VI. Relaxahon of Survedence Requrement accre tance creene Vll. hetarahno of Atowed Outage Time Vitt. Deishon of Requremere for 30 day Specset Report to NRC
+ TABLE L - MATRIX OF LESS RESTRICTIVE CHANGES SECTION 3.2, " POWER DISTRIEKJTION LMNTS" page 4 of 7 Discussion of Description ITS Section CTS Section Categwy Charactorm Change 3.2 L7 An allowance was added LCO 3.2.3 3.2.3 None Uneque to permit a total of 16 Applicabelsty hours of operatson to be accumulated with AFD ' outside of the target band without penalty deviatson time during surveillance of i the power range channels. ' 3.2 L8 A requirement to log AFD SR 3.2.3.2 3.10.2.10 11 Unque with respect to l every half hour after the frequency details first 24 hours that the AFD monitoris out of sennce was relaxed to once within one (1) hour and every one (1) hourwhen thermal , poweris < 90% of rated ' thermal power or O.9 Allowable Power Level whichever is less. categones I. Reimusbon of AM <
!!. Retsumbon of Swvedence Frequency til. LCO eteled in terms of Trains rather then components IV. Amowed Otdage Time Ejdenske from 24 hours to 72 hours i V. R*=*=iof Required Achons VI. Reinnahan of Survenance Requirement acceptance creene Vll. Reismahon of Afowed Otdage Tone ,
Vit!. Deishon of Requremert for 30 day Specael Report to NRC i I
i 1 I TABLE L -IRATRDC OF LESS RESTRICTIVE CHANGES SECTION 3.2, M DISTRSUTION UISITS" page 5 of 7.- Discussion of Description ITS Section CTS Section Caengory Characteriamelon 3 3.2 L9 The requrement to LCO 3.2.3 3.10.2.1.1' It Unique with respect to . perform a survemance to frequency dessas only determine the AFD target j flux ditference aner . exceeding by 10% the l t , powerlevel at which the heat flux hot channel factor was last determned was deleted _ I 7 I I I i i comoons. L RW of H
- 11. Reisekon of Sunesence Frequency !
IIL LCO stated in terrns of Trains relhor then components , IV. Aw Outage Time Edension from 24 hours to 72 hours l V. Reimatonof Requesd Actons l VL R% of Surwoesnce Requemment W criteru ! Vll. Reimaton at Assamed Oulage Tune ! VIIL Deleeci of Requrement for 30 day Specsal Report to NRC . 4 [ 1 n - , _. - , ,- - .~ - - .- -, - , , . . . , . ., -
TABLE L- MATRIX OF LESS RESTRICTIVE CHANGES SECTION 3.2," POWER DISTRIBUTION LIGAITS" page 6 of 7 Discussion of Descriptson ITS Section CTS Section C:^ gi Characteriantoon Change LCO 3.2.4, " Quadrant Power Tilt Ratio" 3.2 L10 Requrements for quadrant LCO 3.2.4 3.10.3.1 1 Uneque with respect to power tilt ratio (OPTR) Applacatwisty applicabehty details were relaxed to apply only only to MODE 1 with thermal , power above 50% rated thermal power to not include powerincreases below 50% rated thermal power. 3.2 L11 A requrement was deleted LCO 3.2.4 3.10.3.1 V Urnque with respect to to reduce the high neutron requred actions that
, flux setpoints to two are deleted percent of rated values for ;
every percent of indicated power tilt ratio exceeding 1.0 when OPTR exceeds 1.02. Categones L R % otA M
- 88. . Reimahon of Survesence Frequency lit. LCO etated in terms of Trans rather then camponents 6 IV. Aliowed Outage Time Deenoson from 24 hours to 72 hours V. Ran===8wwiof Requesd Achens VL Relemhan of Survoesnce Requremert acceptance creerte Vit Reimahan of AHowed OWege Tkne Vill Detohon of Requremert for 30 day Spedal Report to NRC
__ _ __ _ _ _ _ _ __. _ _ __ _ . _ . _ - _ ..m . . . . . . . i b TABLE L - MATRIX OF LESS RESTRICTIVE CHANGES 1 SECTION 3.2, " POWER DISTRMUTION LMAITS" page 7 of 7 T m . - .sasiof Description ITS Section CTS Section Category Charactertumelon , chenee 3.2 L12 Requwements were LCO 3.2.4 3.10.3.1 V Uneque with respect to relaxed to pemut continued requwed actions Stat - operation above 50% rated are d a a.d thermal powerwith QPTR -
- in excess ofluvuts for <
greater than 24 hours A requerement to reduce the j high neutron flux setpoents i to 55% rated thermal i powerif QPTR remawis in excess oflaruts for greater -! than 24 hours was deleted. j , 3.2 L13 Requwements were LCO 3.2.4 3.10.3 2 V Unsque with respect to i deleted that were 3.10.3.3 requwod schons that assocasted with the are deleted i condebon that QPTR is l greater than 1.09 ; i swnultaneous with a ITWsalegned rod. 5 i i t , I. Reimmemnof agger.hmey ; it Retummon of Sunmaance Frequency j til. LCO steled m tonne of Trains reiher tieri componeres j IV. Anowed Outage Time Emansion fnwn 24 hours to 72 hours V. Ralsummon of Requred Actons VI. R% of Sunmaance Respairemert =ar=r*= ice entarie - l VIL- Reimahan of M Otange Tkne vist rt= hem of Requeement for 3D day Specal Report to NRC r
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- TABLE L- MATRIX OF LESS RESTRICTIVE CHANGES ,
l SECTION 3.3,"9ISTRURAENTATION" oege 1 of 30 ' , 5 rh a + of- Description ITS SocGon CTS Section Category Charactortueelen Change .,
-1
!' LCO 3.3.1, "Contenment" , q
- 3.3 L1 Allowable values have LCO 3.3.1 2.3.1.2 None Unuque
, been W fortrip Table 3.3.1-1, .l !' setpoints in accordance Furrim 5 and 6 i l' with the licensee setpoint i- methodology procedure. The allowabie values for i the overtemperature and ; overpmssure aT setpoints -l are less restnctive i 3.3 L2 An instrument tolerance of Table 3.3.1-1, 2.3.1.2 None Unique '!
- i10% was added to the Funcbons 5 and 6 i
- time Constants for the t overtemperature and
- overpressure aT setpoints.
, M 88908 W8IB , l added for parameters in ; the overtemperature and j overpressure aT setpoints ; i i categones j t {' L Reismeben or AppScaldty -( It Reimmhon or Suneennce Frequency i 4 ist LCO mannare in tenne or Treme ressor Wien componones .j
. IV. Amoused Oulege Tens Emlension from 24 hours to 72 hours V. Reimmion or Rogered Actone to ed Appetalumy , i i
VL Reimuson or Sunemonos Requeement acceptance creerte I I~ VR Reimuseon or Am===8 Outogo Time : Vill. Dewsuun or Requeemord for 30 any Specal Report to NRC t i i b i ! - . . _ . . _ _ _ . - - - __ _. . = . . ..
TABLE L- MATRIX OF LESS RESTRICTIVE CHANGES SECTION 3.3, " INSTRUMENTATION" page 2 of 30 Discussion of Descriptson ITS Section CTS Section r":;:{i Characterisation Change 3.3 L3 The allowed time to place LCO 3.3.1 Table 3.5-2 Vil Allowed Outage Time a channelinto tripped Required Action E ACTION 6 Extension from 1 hour condRion was extended to 6 hours, from one (1) hour to six (6) hours in arzixdence with I- WCAP 10271-P-A. - 1 4 4 E L i Categones L ReW otWt.
- 18. Relexchon of Survedence Frequency lit LCO edeted in terms of Trans relhor then components i IV. Agowed Outege Time EMoneson from 24 hours to 72 hours V. R% of Requred Achone to ed Wp VI. Reimmhon of Sunatence Requiremert arraf*=nce creeis vit Ra*=-= man of Anmed outage Time Vlil. Delshon of Requrement for 30 day Special Report to NRC
?
i TABLE L - MATRIX OF LESS RESTRICTWE CHANGES SECTION 3.3, " INSTRUMENTATION" page 3 of 30 Discussion of Descriphon ITS Section CTS Sechon Ct gf Characterization Change 3.3 L4 The a8 owed time to place LCO 3.3.1 Table 3.5-2 V, Vil A50wed Outage Trne a channelinto tripped Requred Act.% Item 14 Extensum from 1 hour condsten was extended M,N,P ACTION 7 to 6 hours, retermentw1 from one (1) hour to six (6) Funchon 11 of shutdown hours in accordance with requrement WCAP 10271-P-A. The slustdown requrement for when a channel cannot be placed in trip as required was relaxed to require only that reactor power be reduced to below the P-7 interlock vethin 12 hours, rather than to be in MODE 3 in 8 hours. 3.3 L5 Mode applicability for LCO 3.3.1 Table 3.5-2 I Uruque with respect to certain reactor tnp Table 3.3.1-1 Notes and applicabity details funcbons were relaxed to *"** Notes (h) and (f) only require the funcbons only above the P-7 interlock caegones L Remcf Aar r=hday e i
- 8. Rad === man of Survedence Frequency '
RL LCO stated in terms of Trauns rather then componerts rv. Aaowed Outage Time 6sensen from 24 hatrs to 72 hours - V. Retenamon of Requred Aceans to est Apgscately VL Redameon of Survedence Requrermart arrardance creene VM. Redeehan cf Atoned Cuege Time vin, Deisten of Requremert for 30 day Special Report to NRC t
4 I. , TABLE L- MATRIX OF LESS RESTRICTWE CHANGES ~ SECTION 3.3, WASTRURRENTATION" page 4 of 30 < 1 rme. % of Description ITS Section CTS Section Category Cherseenstantion i Change s 3.3 L6 The a50wed time for an LCO 3.3.1 Table 3.5-2 Vil ANowed Outoge Tune - I inoperable manual reactor Requred Achon B ACTION 1 Extensen from 12 - I trip function was extended hours to 48 hours, '. tj from 12 hours to 48 hours atoned shutdown time ,_ and the time to be in Extenston from 20 ! MODE 3 extended from 20 hours to 54 hours
- hours to 54 hours i
3.3 L7 The requrement to LCO 3.3.1 Table 3.5-2 None Unique , monstor Quadrant Power Requred Achon ACTION 2 Tdt Ratio (QPTR) every 12 D.2.2 hours wth one excore channelinoperable is I relaxed to reqtsre motulonng only when the ; l channelinput to QPTR is ! inoperable l 4 ). I ! C6 i i I. Reimation of Apptcebaty fl. Reimation of Surteennce Frequency a. LCO stated in temas of Trans rather than aanponards IV. Anowed Oidage Time Essension from 24 hours to 72 hours V. RW of Reqused Actions to edt M ' VI. Reimuaban of Surweennce Regumement W creens
' Vit Reimaten of h Oidago Tone VM. Deleton of." __ ^ for 3) der Spodel Report to NRC
~
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l 4 TABLE L- MATRIX OF LE3S RESTRICTWE CHANGES . SECTION 3.3, *1NSTRURRENTATION" page 5 of 30 Descussion of Description ITS Section CTS Section Category Charactertmetten Change 3.3 L8 The allowed time to place LCO 3.3.1 Table 3.5-2 Vil and . Asowed Outage Time 2 a channelinto inpped Requwed Achon E , ACTION 2 elmnation of Extension from i hour '; condsbon was extended requwement to 6 hours, and unsque F from one (1) hour to six (6). with respect to~ hours in accordance with elmnation of - WCAP 10271-P-A. A r-i;-c_ ; -
't requirement to reduce thermal power to s 85%
rated thermal powerwhen i one channelis inoperable was elImenated. i
\
1 i
}
i Cetogones
- t. Reiseberiof AppNc.aNey If. ' Reinemen of Survesence Frequency !
' IIL LCO stated in tenna of Trans rather then componeres IV. Asomoct Ouesse Tone Edensen inwn 24 hows to 72 hours i V. Releashon of Required Achens to ed N M j VL Reimagen of Surwoesnce Requeement scespennee creerte l
VII. Reimahan of Aw OWege Time I i Vl41. Deiston of Rg__ __.J for 30 clay Specmf Report to NRC ' t i t
.~. ,, . , , . - , . - , . - . . .+ . a
i 3 TABLE L- MATRIX OF LESS RESTR$CTNE CHANGES SECTION 3.3, "INSTRUteENTATION" page 6 of 30 Descriphon ITS Section CTS Section Category Characterization Discussion of Char # The requkements for two LCO 3.3.1 3.10.5 None Uruque 3.3 L9 snoperable intermediate Requwed Action G range neutron nux channels were relaxed to requwe only that reactor power be reduced to below the P-6 intefiock within two (2) hours and to suspend operations involwng i positive reactivity additions, rather than to be in MODE 3 in 8 hours
]
i' Categones L Ran===hnq g( * ,, IL Reimebon of Survesence Frequency ill. LCO etened in terms of Trans romer then components IV. Agowed Outege Time Edenman from 24 hours to 72 hours V. Reimehon of Required Adlons to out Apreenhd8y VL Reimmhon of Sunemence Requirement acceptance creene Vll. Rata == man of Agowed Outogo Time VI!I. Deishon of Requrement for 30 day Special Report to NRC
TABL:. L - MATRIX OF LESS RESTRICTIVE CHANGES SECTION 3.3, " INSTRUMENTATION" page 7 of 30 Discussion of ' Description ITS Section CTS Section Category Characterization Change 3.3 L10 The allowed time to place LCO 3.3.1 Table 3.5-2 . V, Vil Allowed Outage Tune a channelinto tripped Table 3.3.1-1 Items 7,9,10, Extensson from i hour condetson was extended Functions 2a, 8, 9, 13 to 6 hours, relaxahon from one (1) hour to six (6) 12 of shutdown hours in accordance with requirement WCAP 10271-P-A. The shuidown requirement for when a channel cannot be placed in inp as required was relaxed to require only that reactor power be reduced to below the P-7 interiock within 12 hours, rather than to be in MODE 3 in 8 hours. J categones L Relaxation of AM lt Relaxauon of Sunemence Frequency lit LCO stated in terms of Trains rather then components IV. ANowed Outage Time Extension from 24 hours to 72 hours . V. Relaxation of Required Achons to est AM VI. Rd===han of Sunmuence Recpairement axoptance entens Vi!. Reb =han of Atowed Outage Time VHl. Deletion of Requirement for 30 der Specani Report to NRC
TABLE L- MATRIX OF LESS RESTR$CTIVE CHANGES SECTION 3.3, " INSTRUMENTATION" page 8 of 30 ) Discussion of Descnption ITS Sechon CTS Section c ^ g-: y Characterization ; Change 3.3 L11 The allowed time to place LCO 3.3.1 Table 3.5-2 V, Vil Allowed Outage Time , a channelinto inpped Table 3.3.1-1 Item 11 Extensson from 1 hour conditxm was extended Function 15 to 6 hours, rataw= hon from one (1) hour to six (6) of shutdown hours in accordance with requrement 4 WCAP 10271-P-A. The shutdown requirement for 3 when a channel cannot be placed in trip as required was relaxed to requere only that reactor power be reduced to below the P-7 , interlock within 10 hours, rather than to be in MODE 3 in 8 hours. casegones
- l. Reimaten of W^,. [
- 11. R=l===han of Sunemence FreqLency ;
lit. LCO eteled in terms of Trane rather then componards IV. Allowed Outege Time EMension from 24 hours to 72 hours , V. ReW of Requred Actions to est Afyhr=hd8y VI. Reimation of Sunemence Requrement accageance creerie Vll. Reimehon of ARowed Outoge Time Vill. Delegen of Requremord for 30 day W Report to NRC
TABLE L- MATRIX OF LESS RESTR$CTWE CHANGES SECTION 3.3, " INSTRUMENTATION" page 9 of 30 Discussion of Descriphon ITS Section CTS Section Category Charactortzation Change 3.3 L12 The requirements for LCO 3.3.1 Table 3.5-2 I Urwque with respect to underfrequency and Table 3.3.1-1 Items 13 and apphcabikty detads undervoltage trips have Funcbons 11 and 14 been relaxed to apply only 12 to MODE 1, rather than reactor entscal, a m i _ previously required. l 3.3 L14 The frequency of LCO 3.3.1 Table 4.1-1 11 Uruque with respect to surveillance requirements Table 3.3.1-1 hems 1,4 survedlance frequency for the nuclear power Funcbons 2a,5, range and reactor ccolant and 6 temperature trip functions SR 3.3.1.7 were relaxed from bi- SR 3.3.1.8 weeldy to 92 days in accordance with WCAP 10271-P-A. casecones L Reissatum of a.m IL ReW of Surveennce Frequency til LCO stated in terms of Trars rather than cxrnponents IV. Atomed Outage Trne Edeneson frorn 24 hours to 72 hours V. Rea ===hm or Requred Actons to end Apfer=hagy VL Raa===#wi of Survedance Regnareme t are reence entens VII. R.a. swwi or Ago ed Otdage Trne Vitt f% of Requrer,ert for 30 day Spar =8 Report to NRC
~
n TABLE L - MATRIX OF LESS RESTf8CTNE CHANGES SECTION 3.3," INSTRUMENTATION" page 10 of 30 , f
- f Flies nama% g( C:7 7:(: 3 ITS Sectiori CTS Seceori % m Chavige 3.3 L15 The frequency of LCO 3.3.1 Table 4.1-1 11 Unuque witirespect to t surveillance requwements Table 3.3.1-1. hems 2,3 surveinance frequocy i as it apphes to reactor Funchons 3 and 4 startup for the nuclear SR 3.3.1.7 intermediate range and SR 3.3.1.8 source range were relaxed from requenng the surveillance to be !
performed withri 77 days prior to startup to within 92 2 days prior to startup in accordance with WCAP 3 10271-P-A. i i ? t t 1! i l I i
- i. Reimmeon or Appbcabety ,
- 11. Reimaton or Survoesnoe Fregancy III. LCO stated in terms or Trans relhor then componerds !
N. Amowed Outese Tune EJeansion tem 24 hours to 72 hours l V. Relensbon or Requesd Actors to and At yarmhesy vi. Reimmhon or Survesence Requsemort =ce=rdance crtiene Vll. Reimenon or Amowed Outops Time i t VM. Delshon or Requremert for 30 day Spacal Report to NRC 'l L i
____ _ __ _ _ _ _ _ _~_ _ _ _ . _ __ _ , 'F i jj TABLE L - MATRIX OF LESS RESTRICTNE CHANGES - i i SECTION 3.3,"WGSTRUMENTATION" page .11 of 30 - , Discussion of' Description ITS Sechon CTS Section Category Characterisation '? i Change 3.3 L16 The frequency of LCO 3.3.1 Table 4.1-1 11 Umque with respect to
- sunmilance requwements Table 3.3.1-1 Items 5,6,7,8, survedience frequency ,
for the reactor coolant Functons 9,8,7, 11,39,40 : l flow, pressunzer pressure, 11,13, and 14 , Ramr*r Coolant Pump I (RCP) voltage, steam ! generatorlevel, '
- j. steam /feedwater flow .
4 rmsmatch, and low steam generatorlevel funchons were raiaxed from monthly
- to 92 days in accordance ,
I with WCAP 10271-P-A. ! l t 3.3 L17 The frequency of LCO 3.3.1 Table 4.1-1 11 Umque with respect to . sunmilance requwements Table 3.3.1-1 item 25 survedience frequency i for the turtune first stage Function 17e pressure function was - 4 relaxed from monthly to 18 months ! t
-l Caselpmos .
- 1. Reinemen er Appecebety it. Reimaten or Swvemenos Frequency !
1- Ill. LCO steled in terms or Trans reIher then corsponents
- IV. W Outage Time Edension torn 24 hours to 72 hows Survemence ecceptance creerte ,
Vll. Redenton or Amewed Odeos Tlrne
- i. vin. Desseen or Requsement for 30 day Specul Report to NRC i
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l 0 l TABLE L - MATRIX OF LESS RESTRICTNE CHANGES & SECTION 3.3, "NdSTRURAENTATION" page 12 of 30 Descussion of - Description ITS Section CTS Section Category Charactortantion ; Chenee ^ t 3.3 L18 The frequency of LCO 3.3.1 Table 4.1-1 11 Uneque with respect to ' ! sunellarice requirements SR 3.3.1.5 llem 27 - survedance l for actuation logic testing frequency, See LCO l were relaxed from monthly 3.3.2 L18, Bin with '
- to 31 days on a staggered . L19 ...
I test basis. ' 3.3 L19 The frequency of LCO 3.3.1 Table 4.1-1 11 Unsque with respect to i surveellance requirements SR 3.3.1.4 Item 30 survedence for reactor trip breaker frequency, Bin with ! testing were relaxed from L18 j monthly to 31 days on a staggered test basis. ( 3.3 L20 The frequency of LCO 3.3.1 Table 4.1-1 li Uruque wilh' respect to surveellance requwements SR 3.3.1.4 Item 47 sunmuence i for reactor trip bypass frequency Bin with . ' breaker testing were . L18 relaxed from monthly to 31 - days on a staggered test a basis Categones I L Rh.ot Appleately ' 1 li. Reinaban or Survesence Frequency ; i HL LCO missed h terms or Trans reiher than components IV. Aw Outage Time EAnneen frorn 24 hours to 72 hours ! V. R%orRequesd Actonstoest AM VI Reimaton or Survedence Requeement armreanos creene Vit Reimahan or Amoned Outoge Tone e Vill Deleton or 7 _. ; for 30 day Specsel Report to NRC ' i f
. ~
.a q ..
r i <
- . TABLE L - RSATRIX OF LESS ESTNCTIVE CHANGES SECTION 3.3,'WfSTRURIENTATION" . page .13 of 30 -
U rme .aasi of- Doocription ITS Section CTS Section Category Charactortsation Change ; ! 3.3 L35, Apphcatnidy was reduced Table 3.3.3-1 Note Table 3.5-2 I Unuque with respect to I in MODES 3,4 and 5 for a Note (*) reduced Apptcetuuty. i +
, manual reactor trip, source range neutron flux, reactor +
trip breakers, reactor trip , breaker uv and shut trip , mecharusm and automshe trip locc. i ' 3.3 L36 Requwed Achon was -'- LCO 3.3.1 Table 3.5-2 None Uneque with respect to : relaxed to pormat exstang Requwed Achon F ACTION 3 reducten in Required Apptcatnhty byincrossmg Actert .
- power to a P-10 setpoent. !
~ 3.3 L37 Complebon Twne was LCO 3.3.1 N/A VII Unsque with respect to i relaxed by adophng Requwed Achon O increased Comptshon i Required Achon permdtog Twne. 4 6 hours to restore channel ! where no restoration time
- was Dreviously provided -i l
Categonee i i 4 L P% or Appecatey !
. 11. Reisekon or Surveennee Fesquency i ist. LCO esmead in terme er Traiw regier een canyonerte '
- IV. Ah Ondage Tone Emoneten hem 24 hours to 72 hours ;
- v. Reemunen er Regumed Aemons to em Appmesnamy VL Reimahan er Survesence Regumement acceptance creene ,
VM. Reimamon or Amoned Oidage Time ' vs. Deesman er Regusemere ser 30 day Special Report to NRC l I
, ,. ~ ._ _m .-
TABLE L - MATRIX OF LESS RESTRICTIVE CHANGES SECTION 3.3, " INSTRUMENTATION" page 14 of 30 Discussion of Description ITS Section CTS Section C' gi Charactortantion Change 3.3 L38 Required Action was LCO 3.3.1 Table 3.5-2 V. Uneque with respect to - relaxed to permit two Required Action H ACTION 3 VII Applicabelsly Neutron flux intermedsate range channels inoperable when below the P-6 , setpoent 3.3 L39 SR frequency was relaxed SR 3.3.1.11 Table 4.1-1 11 Uruque with respect to to eliminate monthly item 1 Frequency. calabration for Nuclear Power range channels. ! 3.3 L40 SR frequences were SR 3.3.1.2 Table 4.1-1 11 Uneque with respect to relaxed to permit delaying SR 3.3.1.3 Items 1,3, & 4 Frequency. performance of certain SR 3.3.1.6 SRs until a specified SR 3.3.1.7 interval afterachieving specified unit conditions. canegones ,
- l. R% of AM II. R% of Sunemence Frequency III. LCO stated in terms of Trans rather then componeres IV. Amewed Ogdage Tyne Extensson from 24 hours b 72 hours V. Relaxobon of Requred Actons to est Applicately VI. Relaxahon of Survemance Regteromert er=reance creene '
Vti. Remenon of Asowed Ottage Time Vm. Delehon of Requremert for 30 day Specsel Report to NRC !
TABLE L- MATRIX OF LESS RESTRfCTNE CHANGES SECTION 3.3," INSTRUMENTATION page 15 of 30 i Discussion of Descriphon ITS Section CTS Section C ^g--:{f Charactormention Change 3.3 L41 Surve:Bance requirements SR 3.3.1.11 Table 4.1-1 None Unsque with respect to are relaxed by excluding items 1,2,3 SR scope. neutron detectors from Calibration. Categones L Reisehonof AM st Reimmioon of sunemence frequency IIL LCO stated in terms of Trans rather than m.wa.G IV. AEowed Osdage Trne Estensson from 24 hours to 72 hours V. Reimmhan of Requred Actons to est AM VL Retamaton of Survemance Requremert arcareance cntens VII. Retamahon of ANowed Outage Tone VI!L Deisson of Recuremert for 30 day 9 pac ==l Report to NRC i
TABLE L - MATRIX OF LESS RESTRICTNE CHANGES SECTION 3.3," INSTRUMENTATION" page 16 of 30 Discussion of Descriphon (TS Section CTS Section C ^ ;:-i Charactonsabon Cha'qpe LCO 3.3.2, *ESFAS instrumentabon" 3.3 L13 Requirements for LCO 3.32 Table 3.5-4 VI Unsque wath respect to automabc actuabon logic Table 3.32-1 aNowed outage time and actuabon relays for the Funchor.s 1.b. 2.b. details Eng;r. cered Safety 3.a(2), 3.b(2). 4.b. Features Actuabon System and 5.a were added, which include Requeed Acbons C aBowed outage tunes and G which were not previously permitted. , 3.3 L18 The frequency of LCO 3.32 Table 4.1-1 It Unsque with respect to surveiBance requrements SR 3.322 Item 27 surveiBance for actuabon logic testing frequency. See LCO - were relaxed from mor.thly 3.3.1 L18 to 31 days on a staggered test basis cassonnes L R% of AM E. Rm of Seneennce Fresp;ency ;
- 11. Lc0 stased ri terms et Traris rather rien r-N. Akused outage Time Esemneson imm 24 hours to 72 hours
. V. R=====han of Respred Actone .3 emag am VL Rh of Suneennce Recasement arrate=nce creens Vit Reensehen at Anoised Odsce Tene Vt3L Doestion of Recparemere tar 30 day W Report to NRC ,
.. . . . . .-. . - ~ . - - . . . . .. . . . _ - _ _ _ _ .
L TABLE L- MATRIX OF LESS RESTRICTWE CHANGES SECTION 3.3, " INSTRUMENTATION" page .17 of 30 - , rhea ==% of Description ITS Section CTS Section Category Charactertention . 3.3 L21 The alkmed tune for an LCO 3.3.2 Table 3.5-3 Vil Unique wilh respect to
- inoperable channel to Requred Achons ACTION 12 atowed outage time roman 1 in the inpped C, D, E, and G dotads condsbon was relaxed from the sunNMllance frequency mterval to conbnuous operabon. The allowed
- time to place a channel intoinpped condetson was '
extended from one (1) i , hour to six (6) hours in . , accordance with WCAP 10271-P-A.
- 3.3 L4'. Applicabshty for steam line LCO 3.3.2-1 Note e Table 3.5-4 I Reduced applicabshty i
isolabon funchons was Funchons 2A, due to posilson of ; i reduced to exclude when 28,2C & 2D actuated equipment. .! , MSIVs are closed. Bin with L43, L46 and .I L49. ; t i M "
- l. Reimaton of AM
- 11. Reimaban af Sunmeance Frequency W. LCO eteled in terms of Trains ralhar then components ;
) N. Agowed Outage Time Estension frorn 24 hours to 72 hours V. Retesman of Regtered Actons to est Apptestimy .i VI. R% of Sunemence Requirement =crardance creerie Vll. Reissation of Alloused Outage Time ' l vs. Deismonof M _ ser30derSpecuiReportto NRC t
l TABLE L - MATRIX OF LESS RESTalCTNE CHANGES ' l SECTION 3.3," INSTRUMENTATION" page 18 of 30 r Discussion of . Descnphon ITS Secuon CTS Sechon C_^ ;:-y
- Characterizadon Change 3.3 L43 Applicability for feedwater Table 3.3.2-1 Note 3.0 i R=*M appicatnisty ,
isolabon funchons was f' due to posebon of reduced to exclude when actuated equipment. MFIVs MFRVs and bypass Bin with L42, L46 and valves arer closed or L49. isolated by a closed . manual valve. i t l' i l 6 Categones
- 1. R % cfA M
- 11. Reem=han of Survessence Frequency II!. LCO etsted an terms of Trans rather than components ,
IV. Anowed Outoge Trne EAension from 24 hours to 72 hours ! V. RW of Requred Actons to exit Appbcatuhly . I VI. Reimalmn of Suneinance Requremert arcardance creene Vil Reisehon of Atowed Oulage Time i Vllt. Delsbon of Requrement lor 30 day Specsel Report to NRC i k
.-n
TABLE L- MATRIX OF LESS RESTRBCTNE CHANGES . SECTION 3.3, " INSTRUMENTATION" page 19 of 30 Discussion of Descriphon ITS Section CTS Section C1^ : ;-:-y Characterization Change 3.3 L50 Requerements relaxed to LCO 3.3.2 N/A - None Uneque with respect to pemut all channels of a Required Actions Achon +1.Aaxabon. ESFAS instrument funchon Note 2 or a single ESFAS instrumentation train (except for manual l Actuation funchons) to be inoperable for maintenance or surveillance testing for up to 12 hours. Categomm L Ran===mari et ra yar.hany IL Rei==hno of Survedence Frequency ill. LCO etened in terms of Troms rather than componerts N. AEomed Outage Time Eisenosan from N hotss to 72 hairs V. R.a nn,i of Requesd Actens to eng agywg VI. R% of Sisvemence Requeemort acceptance entens VII. Ran=== news of Asowed Outage Trne Vill Deleecn of Requremert for 30 day Special Report b NRC
l TABLE L- MATRIX OF LESS RESTRICTNE CHANGES SECTION 3.3,'1NSTRUMENTATION" page 20 of 30 Discussion of Descriptkm ITS Section CTS Section Category Charactortention ; Change i LCO 3.3.3, " Post Acodent Monitoring (PAM) instrumentabon" l 3.3 L22 The allowed time for an LCO 3.3.3 Table 3.5-5 Vil Uneque with respect to moperable contamment Table 3.3.3-1 allowed outage time
, high range radiation Funchon 10 mondonng channelwas extended from 7 days to 30 days. .
3.3 L23 The allowed time for an LCO 3.3.3 Table 3.5-5 V!! Urwque with respect to moperable auxdsary Table 3.3.3-1 Note 1 allowed outage times . feedwater(AFW) flow Funchon 19 only, Bin with L22 indicator channel was extended from 7 days to 30 days. i f Categories
- 1. R % of W p. !
II. RW of Sunodence Frequency ! lit. 1.CO stated in terms of Treins rather than components IV. Aameed Outope Time Edension frorn 24 hotro to 72 hours V. ReW of Requared Actone to endt Appfr:ebaty s VI. Relausson of Sunemance Requeement e cremna Vll. Reinsehon of Anovuod Outage Time Vill. Delshon of Requrement for 30 day W Report to NRC i i I
i l r TABLE L- MATRIX OF LESS RESTRICTWE CHANGES ! J SECTION 3.3,"INSTRURIENTATION" page 21'of 30 ru. ,.= % or oneeription iTS section cts secuen casee ry cherecometension
; chano.
) 3.3 L24 - The requwements for both LCO 3.3.3 Table 3.5-5 V Unugue with respect to inoperable contenment Requwed Action E Note 6 requwed achons only !
- hydrogen mondonng '
channels were relaxed to
- requwe only that MODE 4 j be reached within 6 hours, l
rather than MODE 5 within i 36 hours as was previously '!. . requaed ' i' 3.3 L25 The allowed time foran LCO 3.3.3 Table 3.5-5 Vil Unique with respect to ' j snoperable thermocouple Requwed Achons A Note 8 allowed outage time, ;l channel was extended and B unsque with respect to - from 7 days to 30 days. If removal of shutdown , the channel cannot be requwament l i restored as requwed, t
- requwements were relaxed i to requwe only a special }jl report to the NRC, rather .j!
than to shut down the j reactor '{j
- i t
Categorms ; L R%of Applicately N. Reisekon of Surwomence Frequency [ l Ill. LCO edeled in terms of Trains redher Wien camponents ! IV. Aa,==d 0% Tone Edensen imm 24 hours to 72 hours .[ ! V. Reimaton of Requend Actons to est M VL Rehembon of Survedence RequeemorW ==f d e cnterie VM. Reimahan of An'==d Outege Time - VNL Delskan of Roquesment for 30 der Spedal Report to NRC S
'f i
TABLE L - MATRIX OF LESS RESTRICTNE CHANGES SECTION 3.3, *1NST7tDMENTATION" page 22 of 30 Descussion of Description ITS Section CTS Section Category Characterization Change 3.3 L26 The allowed time for an LCO 3.3.3 Table 3.5-5 VII Unque wnsh respect to inoperable thermocouple Table 3.3.3-1 Note 8 atowed outage time channelwas extended Fur.:: bons 15-18 details from 48 hours to 7 days. 3.3 L27 A refuenng interval test LCO 3.3.3 Table 4.1-1 None Unsque. requirement for pressurizer items 35,36, Power Operated Relief 37 ' Valve (PORV) posshon endscabon, block valve posstson arxbcation, and safety Valve position irxhcahon was relaxed was ' elemenated. ! caeagones L R% of a yar.hasy r IL RW of Sunemence Frequency til LCO stated in terms of Trans rusher then componerts IV ABoned Outage Time Ejeenemn from 24 hatru to 72 hours V Rem of Requred A:hons to ed Apr r=hasy a V1 R% of Survueence Regtsremert arr pannee creau Vil RW of Aw Otange Trne VUI Desseen of Regurernert for 33 doy W Report to NRC i
. - - .. . . .. =. - . - - - - - - -. -- - - _ . - - . - .
i i i i
\
q'. TAEKE L-MATIWK OF LESS fEST15CTWE cHAf0GES ' l SECTION 3.3, *W85TRUINENTATION" page 23 of 30 ' j r ; 1 I Discumelen of Description ITS Section CTS Session Category CanaraseerimeMon , channe i , 1 3.3 L44 Requwements two PAM LCO 3.3.3 Tatde 3.5-5 Val Urugue wist respect to
- channels inoperable were ~ W Acton H Note 5 Requi.W Achens.
r reimmed to alwrunste l shutdown requwements l when sruhahon of altometwo mondanng is not estatdiohed winun7 i L 4 ders- I l i ! 3.3 L49 4.. e.forsie TatWe 3.3.2-1 Tatdo 3.5-4 I Urugue wini respect to ! t steam line isotaeon- Funcbon 4.c Ilom 2.c regusedattens. Sin .[ i contanment presswo- witt L42 L43 and L46. t i high-ingh funchon were relaxed to excdude MODE l 3 when a5 MSNs are ' { dosed and to esclude ; i MODE 4. I l i , categonne > L nesmenenerApphumumy 4 E. metamaan er SummeWm Ffeganncy ,
- n. 1.CO sensed in tonna er Tsuse sumer man casuponeses ;
N. Aasned Oulmen Tene Emunesen toen 24 hense to 72 hauss V. - naammaanerneupsed Acametoed Apptimmer ] vt naammaan er sesweennae neweesume asempamme eseems vu. maamaann er Aammed oempo Tune .
- vm. osammen er newmement sur an emy speous napest to mac i
)
i
- i. . , , 4 . . . . . . . - - - - , .~-u,~,,,., - . ~ . . - - _ - . . _ - . - - , , _ , , _ . , . _ . , .--._,,,,.,----.w.._.. , _ . . - - , . . , , . - - . y-,,--.....-.-..- - , . _
TABLE L- MATRIX OF LESS RESTRICTNE CHANGES SECTION 3.3, %STRUMENTATION" page 24 of 30 Discussion of Desw A i ITS Sechon CTS Section Category Characterizabon Change LCO 3.3.4
- Remote Shutdown System" None LCO 3.3.5, " LOP DG Start instrumentation" 3.3 L28 Requirements for Diesel LCO 3.3.5 Table 3.5-3 V. Vil Reductaon in Required Generator (DG) start Requ: red Acbons A Funct. aunt Unit Achons by entenng instrumentation were and D 3.a ACTION 14 Conditson and relaxed by allowing entry Required Acbon of into the required actions supported equipment for the DG made Bin with L"9.
moperable instead of requinng the unit to be shut down. AN allowed outage time of one (1) was permitted to restore one or more inoperable channels. 1 Categones l_ Redanation of M7, it Reimushan of Survemance Frecuency til. LCO stased in terr.a of Travis rather than -ww e. IV. Amowed Odage Tm:e Essensson frorn 24 hours to 72 tours V. R*4===r wiof Required Adons to ed AprJcat2fy VI. Retar_ _n of Survemance Requrement acceptance creena Vu Reimuahon of A50wed Oirage Tame Vut. Desehon of Recuremerit for 30 der Species Report to NRC
i .i 4 ! TAEM.E L- MATidK OF LESS IEST5WCTNE CHANGES i SECTION 3.3,"30STNATsON" page 25 at30 . r 1 t j; h of .- Domestpelen ITS Section CTS Soesien Category C8tesentertemeten i L Change i
.j i . .
!- 3.3 L29 The ancnsed outage time ' LCO 3.3.5 Table 3.5-3 V, VM Reduchonin Regumed ! ! for an inoperalde degraded Requwed Actons B Functonet Unit Actons tuy entenne
- i. voltage diennel to be and D 38 ACTION 14 Conetton and Requwed Acton of T
- placed in trip wuss relemed l from one (1) hourto sin (6) '
suoported equipsnent. i hours. Sin ungt L28. . t b -.. b M relemed try aEsnung entry , into the respied actnns ! e for Nie DG made i+ ! regwnng the unit to be i i i i shut down l i I A i !
- i i
1 i i i' L nela G ueer M l neemmesaatsewsmuse Feesary
- n. [
-NL LCO stated ki temas at Trases regner omri comennants ;
N.. Asmund Onassa Tese Edenman tone 24 humes to 72 homas i V. netmaten er noesed Athene to ame Appleakey [ vt naammen er sww.aume neemumme acompennie cuesne ! vu. naammaan er Asened Oiamse Tune ! vut ouesman er nessenene ser ao my spaans neport to anc > [. l i. I i I J i
!....._.. . _ ~ . _ . _ . . , . _ . . . _ . . _ . - ~ . . , . , . . . . . _. . , ,
)
d TABLE L- BIATRIX OF LESS EST14CTWE CHAfdGES SECTION 3.3,"9sST7WIAENTATION" page 26of 30 4
- Discussion of Doocripesen ITS Section CTS Section Cosegory CIteractortooglen Change !
l l 3.3 L30 Requrements foran LCO 3.3.5 3.5.1 None Uneque inoperable degraded Requred Action , voltage channelwere B.1 Note reiamed by adoption of Note wtuch penruts < bypassing the inoperable < 4 channet for up to four ; 4 hours for teshng of other channels ! l 2 ! 3.3 L45 Surveitance teshng SR 3.3.5.1 Table 4.1-1 VI ' Unsque mari respect to regurements were renamed item 32 acceptance crimenst i to permd M=*ng Bin witi L48. inpochon of the test segnal [ into channel dunng the ! i funcbonal test. i
! i 4
i l L Reemsten er Apphcehmy R. Roemeten er Surteennee Fe.apuency !
- m. Leo sensed in tenne er Trans esmer een componeres sv. Asomed Odage Tane EAnnman #wn 24 hows to 72 hows ;
- v. Retamen er Re,ned Acnons to me am i vs. Releaban er sw sesee Re,nement e creene .
VM Rahmaton er Atomed Ouempe Tene ' VNI. Delston at Regmemore for 30 asmy Spaces Rupert to PIRC j l !
t i TAEILE L-MATIWK OF LESS N_ CHANGES . SECTION 3.3, NATION" page 27 of 30 i i ' + h et Doocription ITS Section CTS Session Catagery Charaetoriention Change i ! LCO 3.3.6, TAntamment Veneisbon lenamhant instrumentaten* ' i t 3.3 L31'. The surveusence frequency LCO 3.3.6 3.8.1.b 11 Unsque witi roeped to
- for teshng Wie contanment M_ _ q.
1 ventishon isolshon j- instrumentaban was reiemed try ahminetmg
- . teshne immodatelypoor to refuehng
- 3.3 L46 The requirements for an LCO 3.3.6 Table 3.54 V lam,marens a pplicahikey i inoperable Contamment Required Acton A Item 1.C.iii due to position of j Venhishon isoinhan Phase =rhammad equipment.
A funcaen were reiemed to Bia witt L42, L43 and i permit conemuod operaten L49.
- witi the purge and vent f valves closed and maintamed closed i I
j LCO 3.3.7, "CREFS Actueeson Instrumentshon" l l uone I
- 8. ' naimagen er Appecebesy I
- a. naammen er sweemune.F,oguancy
! Ili. LCO sensed bi tunns er Tessie sesor seen componeNs i N. Atened Ondage Tsus Emmsumen tresn 24 hows se 72 hows
- - v. nessman er negused Acnons to em Appscobesy .
- vs. maammmen et sweeannce nessamme anospannee creens
+ vn nesmenn er Amosos ondues Tone viel- Desumen er nespeement sur 30 semy Speed napart to penC ) a ?
TABLE L- MATRDC OF LESS RESTRICTNE CHANGES SECTION 3.3, *TdSTRuaIENTATION" page 28 of 30 Descussion of C::: ' ^2:3 ITS Section CTS Section Category Cm Change LCO 3.3.8, *AFW System instrumentahon" 4 3.3 L32 Requrements for the LCO 3.3.8 Table 3.4-1 None Itaque vnth respect to Amaliary Feedwater(AFW) Requred Achon B Funcaen 1 Requesd Achons estrumentabon were relaxed by pemuthng placmg channelin tnp vnehm six(6) hours . mstead Of mamtameng the > unit in hot shutdown t i I i Categones L Reimummonof AM IL Reiseben of Swweemnce Ffessency Ill. LCO sensed m terms of Trans rumor vien components IV. Anowed Oiduos Trne Launmen from 24 hours to 72 hours V. Rasmustan of Regured Actons to est " -f . W Reisekon of Surweennce Rossemert arragemece creene vu. Reimenon of Adoused Oidnge Trne vin. Densman of Reenement sur m derspaces Report to NRc i
k. i-i I TABLE L - 0 SAT 5EK OF LESS fESTIUCTWE CHA80GES [ i SECTIOff 3.3,WTNATION" page 29of 30 l t t t rum a et. Danorfytlen ITS Seselon CTS SocGon Category Camereneestension ! C8 tense i , 3.3 L33 L The atooed outage time LCO 3.3.8 Tatile 3.4-1 V, VII Unuque witnespect to i
- . foran inoperatse relaywas Requesd Acton B Note 1 asowed outage time
- . retmed from four(4) hours l j' to sin (6) hours for pleang M dimMel N N- .
Requeements for an l i inoperande retoywere ; reimmed to etnannte em requaement to restore ,
- reiny to OPERABLE mamm
}
h save (7) days. {, F 3.3 L47 The surveElence method SR 3.3.8.3 Table 4.8-1 V Uruque widh respect to i l was reemend to pommt use Funchonal Unit aa:mpeanos catene l 3 . . .co.ai sm.nsiin . t'
- estremari to a simulated
, segnal for Wie funchonal , i test. ! 1 j' f I l. 4 ? L ! f i, Casagenes ( ! i i~ L nelmsmanerAppesemy ; i n. mannemenerasnenhue Fsemency l 1R. LCO mamand m tunns er Tsemus smear sun casapenoms j IV. Assued Ondage Tone Essenman toen 24 lemame to 72 homes 7
- v. nutmetenaf mammed Asamnstoest Appecebey {
vl. maamenen er senseense mapsesnam amespannme esemne i VII . nelmannen er AAmumme Oneuge Ttme l vat omainen er amonemum sur a emy speam napest to nne j I f 1 i t
. . . . _- . _ _ _ - - - , . - . _ _ _ - . , _ . _ . _ ., _..._ . - ~ _.._._- _ ._ _.._...,.. ..._...__ _ .- _... _ .- . .
t l TABLE L- MATRIX OF LESS RESTNC:TIVE CHANGES SECTION 3.3, MTRURGENTATIOff* page 30 og30 nime.amewwiog c:::-;1:.. ITS Section CTS Section Category Charactortsatsen Change 1 3.3 L48 The surveillance SR 3.3.8.3 Table 4.8-1 V Unique witi respect to j requrements were relaxed item b and d e cneena. to permd excluding Bin with L45. inrechon of a test segnal , j into the channot dunng the
- funchonal test. l 1 i 1 i l
t i ) 4 1 l i cm ipine ; I 4
- 1. Relmotonof ApptcetWey R. Reimmann of Suneennes Freepsoncy .
IIL LCO semend in terms of Trans reew than canyonores i N. Aeoned Omege Tone Denneen from 24 hours to 72 hours l V. Reimmhanof Regsod Actonstoena Appbcahday L ' Reemenon of suneemmoe Regaremert acceptance creens VL i ! VIL Rehmehanof wOsageTone Vist Datuten of Roqueament har 30 slay Speaal Report to 98RC i i 4 i
TABLE L- MATRIX OF LESS RESTRICTWE CHANGES SECTION 3.4, " REACTOR COOLANT SYSTEM," Shoot 1 of 12 Descussion of N:::@ ITS Section CTS Section Category Characteriansson Change l LCO 3.4.5, *RCS Loops-MODE 3-LCO 3.4.6, *RCS Loops-MODE 4* LCO 3.4.7,"RCS Loops-MODE 5. Loops Faler LCO 3.4.8 *RCS Loops-MODE 5. Loops not Faler 3,4 L1 An aEowance was added LCO 3.4.5, 3.3.3.1, None Unsque for Reactor Coolant Pumps LCO 3.4.6 3.3.1.4 i (RCPs) and Resu$ual Heat LCO 3.4.7 ! Removal (RHR) Purnps to ; be de-etwrspzed for up to : j one hourin any eight (8) } hour penod. 3.4 L18 An anowed outage time of LCO 3.4.5 3.1.1.2 Vil Unsque with respect to , 72 hours for a sangle RCS Required Achons allowed outage time : Loop was added and an A.1 and B 1 details only, achon to be in MODE 4 if the loop was not restored within 72 hours was 'l added , L Categones 1 L Rehmenonof ap.hany Rasmehon of Surwesence Freesency ; II. til LCO stated in terms of Trans rusher then components IV. Aw Odege Tone Ebdenervi from 24 hours to 72 hours j
- v. Reememen of Requead Aceans to see am ;
naimunen or surweserum neguremere -~=re nos anons vt Vit Reimmhan of Asowed Odepe Tone Vllt Deleton of Respremers for 30 der W Report to NRC i I
TABLE L- MATRIX OF LESS RESTRICTWE CHANGES SECTION 3.4, " REACTOR COOLANT SYSTEM," Sheet 2 of12 h===3ast of E =-:- ^':-5 ITS Sechon CTS Section C a ::y Characterianton ; 3.4 L19 An allowed outage time of LCO 3.4.5 3.1.1.2 VII Uneque unth respect to one (1) hour was added for Requred Achon allowed outage tme the condihon where C.1 details only, seed;,itf requrements are not rnet in the spedTn isea
- 3.4 L2 Achons in response to no LCO 3.4.6 3.1.1.1 Vill Uraque with respect to
- RCPs or RHR pumps in crcumstances of operabon are changed report
- from establistung a requered shutdown margen to suspensaco of operations 8Wohnng t reduchon in boron w n.cnm ai m . l l l 4
i 1 i I I
- 1. Reimasum or Apptcatmey l IL Reimuuton or Survesence Frequency
, Ill. LCO stated in terms or Trans remer man componeres 1 IV. Aw Odage Tkne Edenman from 24 hours to 72 hours V. Reteston or Reqused Actons to ad AM , VI. Reimmhon or Sunr Amnee Reguremert arr=ge=nce creene ; , Vil Reimmeon er Aeoned Odage Tyne l i Vill. % orI ; _. .: for 30 day W Report to NRC j , i f
i i
}
. TABLE L - RAATNK OF LESS fESTNCTWE CHM 0GES , SECTION 3.4, *1EACTOR COOUWT SYSTERE," Sheet 3 et12 l Discussion of Dooeription ITS *arel== CTS Secesen Cotagory N 1-channe ! 3.4 L3 A requwement was doloted LCO 3.4.6 3.1.1.1 VIII Unuque unes romped to [
- i. to sutuvut a W Report cuannstances of [
to the NRC unihn 30 days report i: of soiture to restore one i RCP or Rift pump to - i operatum anor one (1) hour dunna shutdown. 3.4 L4 Requwement was deleted LCO 3.4.6 3.3.1.4 None Unuque l to does contenment prior f i to % 200*F when i
- both RHR pumps are . I incoerable l
f i 1 l I r I i t i L Rehammenof M [ M. Rehuuten of Swwesence ."-- , 4 i , IM. LCO stened in tonne er Tsums sessor sien conquenants ! ! N. Asemed Odege Thine Eisension test 24 hows to 72 hours V. Retusseenof RW Athenstoese am I
' VI. - Rotmanen d Sarh Hagusanusa acceptusos czeans
[ 1 VII. Reimaten of Aw Onasse Tens ; Vul Datenc;n of Reg.senusit ser El day SpooW Hepart to NRC [ !' l L : k
,, - . - ~ . . - r. . . . _ . .. . , . . . ,. -. -- , ---.., . ..,_ _ _. .. .. _ ,_ . ,. _ .- ,, ,._ ,.._ _ ,,_. .~.. _., _ _. - . _ _ . .
l TABLE L- MATRDC OF LESS RESTRICTitT CHANGES , 1 SECTION 3.4, NOR COOLANT SYSTEM " Sheet 4 of 12 i 4 . j rhe===&ast of Descripteen ITS Section CTS Sectmen Catogery Chereseenumeson ! Change ' l 3.4 L5 Note 1 was added to LCO LCO 3.4.6 3.3.1.4 None Unuque ; 3.4.8 that agows all RHR LCO 3.4.7 pumps to be doeneryzed for up to 15 rrunutes under certan condsons. Note 2 was added to LCOs 3.4.7 j and 3.4.8 which a50ws one RHR train to be inoperable ?' for up to two (2) hours for , surve:Eance testing 3.4 L6 An a50wance was added LCO 3.4.7 3.3.1.4 None Unique to permd use of a steam i generatorinstead of an RHR train for decay heat removalin MODE 5. i t 1 } i i i 1 j I i . L Reimatonof M ! R. Reimahan of Sunsommnce Frespsency 1 lit. LCO messed h tenus et Trare setier than corvonares N. Aw Oidage Tune Esesnesen torn 24 hours to 72 hours V. Reineman cf Rosymed Acsone to est Appkombety ; VI. Reinsten er sinamenee Roewomere occapannae aasne Vit. Raimuhen of Assued Oienge Tene VHl. % of Requeenumre for 30 emy Speemi Report to NRC I l 1 i i J
TABLE L- MATRIX OF LESS RESTMCTNE CHANGES SECTION 3.4,
- REACTOR COOLANT SYSTEM " Sheet 5 of 12 Discussion of Descriphon ITS Sechon CTS Sechen Cacogery Charactenamenen ! ,
change 3.4 L16 A requrement was deleted LCO 3.4.7 3.3.1.4 Vill Unsoue weh respect to to sutet a Specal Report LCO 3.4.8 orcumst.snus of to the NRC wdfun 30 days report of falure to restore an anoperable RHR train to opershon after 14 days dunna shutdown , 3.4 L17 A requrement to venfy a LCO 3.4.7, 3.3.1.4 None Uneque har*>f method fordecay LCO 3.4.8 heat removalwhen one
- RHR train is inoperable i
- was deleted I
=
i congene. . L Resuustonof Apptcabesy
- a. Reemanan of Survueence Fsespanney at LCO stated m hrms at Trans remer em cangianares N. Aaoused Oulage Trne Oeunman tem 24 hours to 72 hours i V.. . Reimmannof Regured Achanstoed M VL Reimmhan of Survumance Respsumard e creens VM. Roemenon of Asamed Odage Tame VRL Delston of Reguremert for 30 any -W Report b NRC i
i p , -w-- ,-1"-w- w ,w wr y
TABLE L- MATRIX OF LESS RESTRBCTIVE CHANGES ! SECTION 3.4, " REACTOR COOLANT SYSTEM," Sheet 6 of 12 i r w .m.sa. og' Cm;^2 --; ITS Section CTS Seceson Category Chorectoriastben . Change LCO 3.4.10, *Pressuruer Safety Va!wes* , 3.4 L7 The operabikty Imts for LCO 3.4.10 3.1.1.3 None Uneque ! the pressunzer code safety valve lift sethngs were screased frorn 2485 psig and 2560 psig to 2410 psig and 2560 psig. 3.4 L9 A note was added which LCO 3.4.10 3.3.1.3 None Unique allows the pressunzer ; safety vuves Eft settogs to [
- be outside operabihtylimits ;
I for the purpose of teshng ! under Certsen COid'uG65. t i t j l a. i L Reimmeonora m 5 Reinsten er Surwomance Frequency r { RL LCO seated in terms or Troms t Ihar sien componeres IV. Aw Odage Time Leonman tem 24 hours to 72 hours < , v. Reemason at pequred Actons to est Appecamery vt Reimenon or sww.amnoe Regmement =~=ra-me creenn VE. Pelmaban or Aw Odage Tene 7 VIst % or Regmement for 30 day W Report to NRC I
TABLE L- MATRDC OF LESS RESTNCTIVE CHANGES SECTION 3.4,
- REACTOR COOUWT SYSTEas," Sheet 7 of 12 ,
Descussion of Doocnpeson ITS Section CTS Section Category Charactortantion Change ; j LCO 3.4.12. " Low Temperature Overpressure Protecmon (LTOP) System ; i 3.4 Ltt An allowance was added LCO 3.4.12 3.3.1.3 None Unique i for one Safetyinsection (SI) pump to be capable or irigochng into the Reactor Cooient System (RCS) , when the RCS is > 175'F. ; 4 4 I l I l i i l l .; comesw l
- I. Reimsubenof M [
- It. Reimahan of Surweemce Frequency [
W. LCO sessed ki terms of Troms recher enn corequeneres ; IV. .aw Odege Tone Essensen fron 24 hours to 72 hours 7 V. Reimaton of Respared Actonstoout Arter=hany b , VL Reimmeon of Sunemence Rogmernard W creano I Vll. Reinsten of W Odege Tene [ VIK. Doeten of Requeurnert tar 30 day Spocal Report b NRC r i 1 4 t
( m. E . ) C m4E,. M. .- i i: J. r k i
, f f ,
0 TAEKE L-IAATfuK OF LESS fESTfuCTNE CHANGES SECTION 3.4, N COOUffT SYSTEM," Sheet 8 or12 l i ! et. Dee@ ITS Secuen CTS Soeden CM N :
- Change
- ' t LCO 3.4.13, "RCS Opershonsi Leekage" t
. 3.4 L10 A time was asowed for LCO 3.4.13 3.3.1.3 VII Ureque wist seapoct to ,
.. pnmary to secondary dessas atessended l inskaos to exceed Amowed outeos renes i requwements at sour (4) !
hours and t'ne time p regured to readiMODE 5 . i it sw inskage is not I l restored to requwed limes
- .es . den.ed emrn 30 i
! hours to 36 hours 3 i 3.4 L11 The Survenance SR 3.4.13.1 Tatdo 4.1-3, M Unupse wiIh respect to j , Frequency for posfomung a Item 9 deemds of T. ,- - 4 ; F pnmary system weser [- wwontory botence was i t j esdended fmm daily to . j: ance everv 72 hours i 4 i. ]' i , , C8's""' .! ! i l L naammeenafAppecshmer l l n. noemeen erSummemus Fseemacy
- m Leo seemd in asum er Tsuem semier een emmesneen
! nr. Aansed Onesse Tsee Endonman tous 24 hense as 72 hows
- v. naamaman er nueses Asenns to em Assammessy
?
vt naammen er saneamise amosense now cseens , vu. Rasmusen er Aassed OndseeTtne
- vut osammen er nessense sur so esy spese mayst to NRC !
t,,-_.... , , , -.-.._..m , _ . . . . . . . . . . . . . . _. .,,_. .,,_ _ _ __, .___.._._,,,.,....._._....,...._._.___,..-._.,_....,..-~._,!
1 i t TAEK.E - L - MATNK OF LESS IEST7WCTIWE CHANGES : , SECTION 3.4, w enna mast SYSTEGE," Sheet 9 of 12 ! i h et Dameripelen ITS Session CTS Session Caengary Cherasemelanden channe
}
3.4 L12 - The agomence fora LCO 3.4.14 3.1.5.4' None Unugue ; ,. . Pressure Isoinhan Valve ! 1
- j. (PfV)witileakage tiet e t
==r== wen lunes to roman ,
i unisolated by two valves ;
- was extended to four(4) 'i' j'
hours and to roment isoisted by only one valve : F was essended to 72 hours. j
- ~
3.4 L13 The longet of time that #ie SR 3.4.14.1 Table 4.1-3, None
~
Unngue . plant can be shut down llem 17 before #te Survedence ll Rocquwement for . ! perfornung PlV testng was j extended fror. r2 hours to 7 dars. ! l i i ? l -- i Calmganus i l I
, L fleimagen er Appecebey
- s. . naammesaer swuumance Fsegancy M. LCO sembed in tems er Tsesus seemt een P
! fV. AAssed Oisage Time Estenman teen 24 homes to 72 hauss
- v. maammmen er nuoses Aensne to est Appacenser j VI. Itabaumon er Sunemence llegmenuut accepAmnce estens ;
i VR. Itsemmuhun er h Ondage Thus i Vul. Duesten er llegmement for 30 dmy Speami nopest to feRC i. 4 I t ! t i I i <
- . _ . . . , , - . - , . . - . _ _ , . . . . . - . .,m , _ _ . _ ., _ _- - ~ . . . ,_.,.,-_4._~ . ~ , _ _ . . . . -~,_,_~.~.-.,___._,...,...,..,_._.-_.,,-.__..,_.,~-_m.____-__.:
i< 1 i I
- TABLE L-ISATNK OF LESS fESTMCTWE CHANGES i '
SECTION 3.4, N COOLANT SYSTEM " Sheet 10 of 12 ! f !. 1 !
% of Description ITS Secelen CTS Secelon Category Charentertemmon ,
change
- 3.41.24 Requwements were LCO 3.4.14 Table 4.1-3 None Unsque .
; doisted to record deity the item 17 i snlognty of a romannung PfV ; and record daily the i poestion of Wie otter domed I ; valve in a line where Wie insegnty of a PfV cannot be
- determined. }
I 3.4 L14 The requwements for RCS LCO 3.4.16 3.1.4 I Unsque waist respect to l specific Aceveywere Apphcotzhty deleils of applicabibly l l reduced to be applicable
- only to h400ES 1. 2 and 3 }
wiWI RCS terrgarature 2 2 500*F. t i I 1 . i i i
- j. i 1 -
i I L notammenerAppAcabar
, 5. noemanon er Semeannae Fsegmency
[ NL LCO eested in tunne er Teodne esser Sinn compenoms [ 4 fV. Aessed Oiesgo Time EAnnesen essa 24 tienes to 72 tiense <
- v. _. naamammen er noemed Aesna to me Aspecamany -
, - vt naamamun er suneennae neomenium acompounce asons !
- vs. Messeman er Asemed oimuse Tsue j' vm. Desumen er neomenism ser ao emy speces nopen to seRC
. . - , , .y., . , , . .w.,,..m.. , . , . , , ,%. ,,,4 c . . . , e ,.,.~.v., , _ . . . - , , _ . . . , , ,,c,,_.s.-,-..._ ...n,. , , ~ , . . . , - . --_.~,v. ,,m.,m.,,_,-- ,,-...m%.,.m.,m,---
TABLE L - MATRIX OF LESS RESTRICTNE CHANGES SECTION 3.4, ' REACTOR COOUWT SYSTEM." Sheet 11 of 12 k i h===iani of Csfls ITS Section CTS Sechon Category Charactoruushen Change 3.4 L15 The SurveiRance SR 3,4,16.1 Table 4.1-2, 11 Uraque vnih respect to Frequency for venfymg item 1 frequency dotads only. reactor coolant gross l sp+44 actrysty was extended from once every 72 hours to once per7 days. LCO 3 4.17, "Chenwcal and Volume Control System fCVCS)* 3.4 L20 Requerements to bring the LCO 3.4.17 3.2.3 None Uneque
, plant to MODE 3 and cool Requwed Achons down and depressunze the D.1, D2, and D.3 RCS were added where no actions preM existed t
i Categorums
- 1. Reinemen of Aryer=May R. Rmof Survemence Frogsency
- 18. LCo stated ei terms at Treen remer tum caraponeres IV. Aeoused Oulage Tene Emerman frern 24 hours to 72 hours V. Reemuseon of Requesd Actonstoed Apr e r=May VI Reimehen of Servestenm Rec >mernerit P creene Vu. Reimehan of Aaoused OtAnge Tene VR
^
Detehen of , .. for 33 day Specud Report to NRC
-= . _ _ . . .- _
TABLE L - MATRIX OF LESS REST 7WCTNE CHANGES SECTION 3.4, " REACTOR COOLANT SYSTEM." Sheet 12 of 12 ; Docussion of . Description ITS Section CTS Sochen Category Characterimetion Change
.4 L21 Speedic requwements for LCO 3.4.17 3.2.2 None Unnaue c-;-- AMi of boron
- _- _ . p .;. p were M reiemed to apply only to two path ys of makeup water from the Refueling Water Storage Tank (RWST) 3.4 L22 Tne anowed time for orie LCO 3 417 n92 tv m- - 4 es a =_ r
~
C , .v pump to be Rn#ed Achon Extensson from 24 ,
- inoperable was extended A.1 hours to 72 hours i from 24 hours to 72 hours I 3.4 L23 A requwement was added LCO 3.4.17, 3.2.3 None Unique l A which abowed 72 W far " : ,__ d A -- . __ t i'
(/ - onc mazeup water B.1 i
/ pathway from the RWST to be inoperable.
j i i i Catogarns i
~
- 1. neluumban or Apptcatulty N. Reinemen of Surtemance Frequency
- m. LCO samend h terms of Trams sesher pian congsenenes
= IV. W Odmes Tune Enlanmen from 24 hours to 72 hours
- v. asimmeen or Regared Actons to se Appbceluny ;
vt Reemmann of Swwemance Rommemort P creerte Vit. Reemoulionof awOdageTene VIII. Desukon of Requsemart for 30 day Specut Report to NRC l , i , r [ f
TABLE L- MATRDC OF LESS RESTRICTIVE CHANGES SECTION 3.5, TRIERGENCY CORE COOUNG SYSTEMS (ECCS)" page 1 of 5
\
th e= W of C;s'rl's ITS Section CTS Section Catogery Charactortemelon Change LCO 3.5.1, " Accumulators
- l 3.5 L1 The aNowed time for an LCO 3.5.1 3.3.12 VII tJnuque with respect to accumuistor to be Requwed Acbon aBowed outage time i i inoperable due to boron A1 extensson ordy !
concentrahan not wenn +
% ,,, m %
four(4) hours time to 72 4 hours t f i. 4 1 1 4 4
?
E' i I
TABLE L - MATRIX OF LESS RESTRICTNE CHANGES SECTION 3.5,"ElfERGENCY CORE COOUNG SYSTEMS (ECCS)* page 2 of 5 Discussion or c;; J r. rTS Section CTS Section Category Charactortantion ~ Change LCO 3.52, TCCS-Operahng" 3.5 L2 The condibon assooated LCO 3.52 3.3.1.2 m,IV with an inoperable Requwed Achon Oiever.cy Core Coohng A.1 System (ECCS) ccings.r,esit was extended to allow one or more trains ! of ECCS to be inoperable as long as 100% of the l ECCS flow equivalent of a segle operable train is
- available. The a50wed 4 time for one or rnore ECCS trains to be inoperable was l relaxed from 24 hours to l 72 hours !
3.5 LB A note was added to LCO 3.52 3.3.1 2 None Unsque Permit opersbon in MODE 3 with one requwed Safety i Ai(SI) pump inoperable for a limited penod of four(4) hours pursuant to the ! sr,eciTrc isis for Reador Coolant System ; overpressure sicitect;cs.. k
TABLE L- ReATRIX OF LESS REST 14CTTWE CHANGES SECTION 3.5,"ERIERGENCY CORE COOUNG SYSTERIS (ECCS)" page 3 of 5 oiscussion or t x- 4 :.. ITS section CTS section casesary Chareceertamelen
- i. Change -
! 3.5 L3 A requrement to restret SR 3.5.2.4 4.5.1.1 None Uruque survealance testeg of the SR 3.52.5 i ECCS such that the ECCS , is r..e. wd from 'wigechng i [
- into the Reactor Coolart ;
i System (RCS)was i deleted 3.5 L4 Detailed requrements for SR 3.52.4 4.5.1.2 None Uruque i performance of SR 3.5.2.5 surveilience teseng reiseng to control board l indicebon and visual observahon that a5 ! components have r5ce:.;d the safetyinfechon segle in the pmper sequence and twrung were deleted : 3.5 LS Detailed requrements to SR 3.5.2.1 4.5.2.1 None Uruque monitor control room
'mdicabon and controls during performance of i survealance testeg were l deleted l t r
TABLE L - RIATRIX OF LESS IESTRBCTNE CHANGES
- SECTION 3.5,"EIAERGENCY CORE COOLMG SYSTEteS (ECCS]" page 4 of 5
% or Descripeton iTS Section cts Section Csessory characteriamelen 1-LCO 3.5.3. *ECCS-Shutdown" 3.5 L6 Requrements for the LCO 3.5.3 3.3.1.2 None Unique ECCS dunng MODE 4 Requred Achon 3.3.1.3 were relaxed to requred A.1 only one t.ain of ECCS to be recured i
d 1 f i i
4 TABLE L - MATRIX OF LESS IWEST7WCTIVE CHANGES SECTION 3.5, N CORE COOUNG SYSTEMS (EsX y page 5 of 5 i Discussion of Doocription ITS Section CTS Sechon r ^ ;: j Characterimetion Change , [ LCO 3.5.4 "RefueEng Water Storage Tank" 3.5 L7 An allowed outage time of LCO 35.4 3.3.1.1 None Unsque 8 hours was added to the Requeed Achon requrements for the A.1 Refuehng Water Stonsge : Tank (RWST) to be , inoperabie due to boron - concentrabon not wdhen lirnds - I .i 1 1 i i , f i
TABLE RL - RELOCATED SPECIFIC 4 TEM MATRIX page 1 of 51 ITS & DOC CTS Desenphon General Location Change Charactensabon Charactonnesson Reference Reference Controis Type ITS 2.0 LA1 6.7.1.c d.e Safety Limit reprt&q Quakty Assurance 10 CFR 50.54(a) Relocahon of requrem6nts Prvvisn Descnphon reportmg 1 (UFSAR Section 17.3) requrements ITS 3.0 LA1 4.0 *Pnor to retummg the Bases Bases Control Relocahon of system to sennce, the Prvyen in ITS teshng details spec 6ed cahbrabon and Sechon 5.5.14 testing survesliance shall 3 be performed." ITS 3.1 LA1 3.10.G.3 and Shutdown Margin Core Opwir."dg Lumts 10 CFR 50.59 Relocahoa of Figure 3.10-2, requirements foren Report (COLR) values moperable fuB length assooated vnth l control rod requrements ! ITS 3.1 LA1 3.10.8.1 ' Shutdown Marge - Hot COLR 10 CFR 50.59 Relocahon of Shutdown- vaiues assocated vnth requwements !
' i ITS 3.1 LA1 3.10.82
- Shutdown Margin - Cold CCLR 10 CFR 50.59 Relocahon of Shutdown" values I 8
assooated with ! requirements ITS 3.1 LA1 3.10.1.4 "At 50% of the evcle as COLR 10 CFR 50.59 Relocaten of defined by bumup L'e procedunal detail rnnits shas be adjustea ic I the end-of-core values as speofied in the i COLR.* l l
, m. -..m
TABLE RL-RELOCATED SPECIFIC 4 TEM MATRIX page 2 of 51 ITS & DOC CTS Descripbon General Locabon Change Charactenzabon Characterizatson Reference Reference Controis Type ITS 3.1 I.A2 3.10.1.3 "If bank insertion is not Bases Bases Control Relocation of restored to the speofied Program in ITS detads regardwig limits"..."the reactor shall Sechon 5.5.14 how requ, red be placed in the hot shutdown cordten acbon is acgs. Ashed. ] utilizing normal operating procedures within six hours." ITS 3.1 R1 3.10.7 Restrictions placed on UFSAR 10 CFR 50.59 Relocatxn of power ramp rate methodol.m for following a shutdown reactor power where core fuel changes assemblies have been handled ITS 3.2 LA1 3.102.1 Algorithms desenbing the COLR 10 CFR 50.59 Relocatxn of limits of Fa(Z) descriptive ( informaten ITS 321.A1 3.10.2.2 Algonthms descnbing the COLR 10 CFR 50.59 Re!ocation of limits of Fa(Z) with core desenptive penalty factor, V(Z), l information included ITS 3.2 LA2 3.10.2.1 Algorithm describing the COLR 10 CFR 50.59 Relocation of limits of FAH, uncertainty desenptive f factor, and power factor information Mu!!iplier
(
- i. i
- .. t i
l TABLE RL - RELOCATED SPECFIC 4 TEM MATRIK pese3 af51 i l ITS & DOC CTS Desesipteen General Location Change Cherastisriendien Chesentestenden 5 Reference flofosence Centrees Type i: ; ITS 3.2 LA3 3.10 2.11 Dotads concorrung the Bases Bones Control Relocatran of !
- redefinition of the axial Programin ITS descrytve
]- Ikst target bands Sechon 5.5.14 infonneton and j meshadobgy ;
- details !
3.102.2.2 ITS 3.2 LA4 naemas concommg the Bases Bases Control % of i desenphon of Program in ITS descnghe
- __ i s.y Fo(Z) from a
"^
Sechon 5.5.14 shan and Power disenbubon map in methodobgy
- terms of measurement detets j and engmeenng factor uncertambes, and 1
l l
- Allometne Power Level !
- 5. . [
ITS 3.3 LA1 2.3.1.2.d Details concommg how Bases Bases Control Paaae=aw=tof i l the electrorme dynamic Program in ITS descrytme ! compensabon and delta W 5.5.14 infomuiban ! j' . nux input to the g l Overtemperature AT I t i Ra=cear Protecton ! 1 System (RPS) funcbon ! affects its setpoint ! l l i ITS 3.3 LA1 2.3.1.2.e Dotads concemeng how Bases Bases Control P=ancmai,m og i l the electrorme dynamic Program in ITS der riperm i comper sahon and desta Secton 5.5.14 informaton t
- s in,ot to ine { -
Overpower AT RPS funcnon anects its , ! SetDomt !
- {
- i. i
- f t
~. -_ - _ ___ _ _ _ . . . . _ _ . - . __ .__ _-. _ - _ . . . - - - - - _.
4 TABLE RL - RELOCATED SPECIFIC-ITEM MATRIX page 4 of 51 ITS & DOC CTS Descriphon General Location Change Characterization Characterization Reference Reference Controls Type iTS 3.3 LA2 2.3.3 "The RCS narrow range Bases Bases Control Relocation of tamperature sensors Program in ITS testing details response time shall be Section 5.5.14 l less than or equal to a - 4.0 second lag constant." iTS 3.3 LA3 3.10.5.1.b "The reactor shall not be Bases Bases Control Relocaton of , made entical"..."unless Program in ITS procedure details the reactor trip bypass breakers are racked c,ut Section 5.5.14 3 or removed." , L ITS 3.3 LA4 Table 4.1-1, instrument channel Technical 10 CFP 50.59 Relocation of Testing Requirements. Requirements Manual tests not required (TRM) to demonstrate operability Offsite Dose Calculation Manual (ODCM) l ITS 3.3 LAS Table 3.5-5, Preplanned attemate Bases Bases Control Relocation of Note 5, method of monitoring be Program in ITS details available Sechon 5.5.14 conceming availability o' b PrePbW attemate method of monitorina i 4
4 6 TABLE. RL - RELOCATES SPEQFIC-4TEtt ABATRIX pay 5 of 51; ; . j ITs a poc cts Description General Location Chenge Charactoriention Charesterlantion Reference Reference Centrots Type !- ITS 3.3 LA7 . Table 3.5-2 Control Rod TRM 10 CFR 50.59 % of Item 15A. "?- "yi.wd Morator dotaded '! . funchon as provided by requwaments i the "ERFIS Rod Possbon Deviabon feature and relehng to systems not . [- : related ACTION No. 9. requwau for . . .. : operabigty erto ~ mentain requwed . f inuts "! ITS 3.3 LA7 Table 3.5-2 ' Control Rod TRM 10 CFR 50.59 Relocahon of ! Item 158. Minngnment Morutor
~
detailed l furrJori as provided Dy requwements ' the " Quadrant PowerTilt reachng to [ Monitor" and reisted systems not 1 ACTION No.10.. requwed for . operability or to mentam requwed ., hmes a i n i l, i 9, i i l i
. . - . .. ~ . - -- .
. - . . . - - . . . . - . - = - .. ~ . . - . . = . . . . - - ~ . -
=
L TABLE RL - RELOCATED SPECIFIC 4 TEM MATRIK page 6 af 51 a ITS & DOC -- CTS- Description General Location Change Charactortamelen Charactorfamilen i Reference Reference Controls Type
.I ITS 3.3 LA8 - Table 4.1-1 Remark assoosted with . Room forITS Bases Control % of. '
itein 4, . RTD cross cahtrabon SR 3.3.1.4 and Program in ITS . teshng detah
- k. Remark (4)- and Ramark ===emaad SR 3.3.1.12 hr*an 5.5.14 '
==* e mand with teshng of the RTB ' i with RTD W and shunt trips. -
o cross - CaMKation
- and Table 4.1-1 Mem 30, Remark (1)
! associated i with teshng of j the RTB W
- j. and shunt trips.
9
'ITS 3.3 LA9 Table 3.5-1 ._ The Funchons' channel UFSAR 10 CFR 50.59 Relocahon of g i-Items 6.a and 6.b-schon is " Trip normal supply brealw."
desenptve informahon I l ITS 3.3 R1 Table 3.5-5 Requerements for the TRM 10 CFR 50.59 Speedicahons ;;
- Item No. 3 RCS Subcooling Monitor that do not most
, and 12 Notes and Reactor Vessel 10 CFR 50.36 1 2 2 and 7 LevelInstrumentshon entena System (RVLIS)
~
f r... _ - . . . .m . _ _ , . - . . . . _ . . , - . , , , . --.
I TABLE RL - RELOCATED SPECIRC4 TEM IRATRDC page7of51 ITS & DOC CTS Doocription General Location Change Characteriantion Charactertantion Reference Reference Controls Type ITS 3.3 R1 Table 3.5-5 Requirements for the TRM 10 CFR 50.59 Spec 6cahons item No. 7 Noble Gas Effluent - that do not meet and Note 4 Monitor- Main Stea.n 10 CFR 50.36 Line, Noble Gas Effluent entena Monitor- Main Vent .! Stack-High Range, and , Noble Gas Efiluent Monitor- Spent Fuel Pit Lower Level - t ITS 3.3 R1 Table 4.1-1 Testing requirements for TRM 10 CFR 50.59 Spec 6cahons item No. 38 the Noble Gas Effluent that do not meet Monitor- Main Steam 10 CFR 50.36 Une, Noble Gas Effluent entena Monitor- Main Vent Stack-High Range, and > { Noble Gas Effluent t ! Monitor- Spent Fuel Pit Lower Level ' : s ITS 3.3 R1 Table 4.1-1 Testing requerements for TRM 10 CFR 50.59 Speedications ; Item No. 34 the RCS Subcooling that do not meet i and 48 and Monitor and Reactor 10 CFR 50.36 . associated Vessel Level cntena ! testing instrumentation System i require- (RVLIS) ments i t t l'
TABLE RL - RELOCATED SPEC 8FIC-ITEM MATRIX page s of 51 ITS & DOC CTS Descriphon General Locahon Change Characterizabon Charactortsation Reference Reference Controls Type ITS 3.4 LA1 3.1.2.1.a *Over the temperature Bases Bases Control Relocahon of range from cold Prvy. i. in ITS ' methodology for shutdown to hot Sechon 5.5.14 heatup of reactor . operating conditions, the heatup rate shall not J ! exceed 60 F in any one hour." ITS 3.4 LA1 3.1.2.1.b " Allowable combinahons Bases Bases Control Relocahon of of pressure and Program in ITS methodology for ! temperature for a Sechon 5.5.14 cooldown of speofic cooldown rate reactor and are below and to the right of the limit lines for desenptive mformabon [ that rate as shown on Figure 3.1-2. This rate shall not exceed 100 F/hr in any one hour. The limit lines for cooling rates between those shown in Figure 3.1-2 may be obtained by interpolation." l t
, - _____m _ _ . . _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ . . _ _ _ _ _ . . _ . _ . . . .
TABLE RL - RELOCATED SPECIFIC 4 TEM MATRIX page 9of 51 ITS & DOC CTS Description l General Locahon Change Characterization Characterizabon Reference Reference Controis Type , ITS 3.4 LA1 3.1.2.1.c " Primary system Bases Bases Control Relocaton of hydrostatic leak tests Program in ITS testing details may be perfomed as Sechon 5.5.14 necessary, provided the temperature limitation as noted on Figure 3.1-1 is not violated. Maximum hydrostatic test pressure should remain below 2350 psia." ITS 3.4 LA1 3.1.2.4.a Requirements for UFSAR 10 CFR 50.59 Relocation of maintaining the details pressure-temperature concemeng limit curves in TS Figures maintaeneg RCS 3.1-1 and 3.1-2 P/T curves , ITS 3.4 LA1 3.1.2.4.b Reporting requirements UFSAR 10 CFR 50.59 Relocaten of of results of irradiated reportog specimen samples requirements analysis and updated heatup and cooldown curves ITS 3.4 LA2 3.1.1.1.a.1 The specific 4% COLR 10 CFR 50.59 Relocaton of , shutdown margin when < values 2% Rated Thermal associated with Power (RTP) and < 2 requirements reactor coolant pumps operatina
TABLE RL - RELOCATEBSPECIFIC-ITEM MATRIX page 10 of 51 ITS & DOC CTS Description General Locahon Change Characterization Charactonastion Reference Reference Controis Type ITS 3.4 LA3 3.1.1.3.a "At least one Pzr code TRM 10 CFR .50.59 Relocahon of safety valve shall be detaded operable whenever the requirements Reactor Head is on the relahng to vessel and the RCS is systems not not open for maintenance." reoured for operabehty or to b maintain requwed limits ITS 3.4 LA4 4.2.4.1.a Requirement that each TRM 10 CFR 50.59 Relocabon of Pressurizer Power detads Operated Relief Valve conc Tkg (PORV) be demonstrated testing methology operable by performing a not requwed for channel calibration at- operabdity each refueling ITS 3.4 LA4 4.2.4.3 Requirement to Bases Bases Control Relocation of demonstiate that the Program in ITS details nitrogen accumulators Sechon 5.5.14 conc Ti.g
- for the Pressurizer testing PORVs are operaDie by methodology '
cycling the PORVs , through one complete cycle at each refuelino L
- _ _ _ _ _ _ _ . . _ _ _ _ . . _ _ _ . . _ _ - _ _ __ .-._ _ _ - . . - _ _ _ _ __~ .. - _ . < . - - - . - . - . -.._ . -
TABLE RL - RELOCATED SPECIFIC-ITERR BRATRIX ' pese 11 of 51 i !. ITS & DOC CTS C::::W GeneralI % Change Charactortmellen CherastertunNon '(, Reference Reference Contrets Type l- ITS 3.4 LAS 3.1.5.4.a. Requrement that all Bases Bases Control R % of pressure isotahon valves Prograrn in ITS desenptrve ! i ksled in Table 3.1-1 de Sechon 5.5.14 details funcbonal as a pressure concoming . . i- asoishon device except operability . .. lz l as specsfied in TS -
- Sechon 3.1.5.4.b dunng l reactor opershon and hot shutdown condshons
- ITS 3.4 LAS 3.1.5.4.b The compensatory Bases Bases Control RW of rnesaure for a non- Program in ITS doecnphve i funchonal pressure Sechon 5.5.14 dotads -
solabon valve; *14anual assocasted with j valves shall be locked in talung a required , the closed posshon " achon ;i i ITS 3.4 LAS - Table 4.1-3 Requrement to perform Bases Bases Control RW of . i; l ltem No.17 Pnmary Coolant System Program in ITS. dotads . l check valve tests after- Sechon 5.5.14 =N with
- masnienance. repa.c or posi l replacement work is maintenance
! performed teshng to declare i oper=h Wy i l i i
- ?
I
; i t
.P
. . , __.___w - - .~_.m*, _ _ _
TABLE RL-RELOCATEDSPECIFIC-ITEM MATRIX page 12of 51 l ITS & DOC CTS Desetiption General Location Change Characternahon Charactorushon ; , ,neterence Reference Controis iype : ITS 3.4 LAS Table 41-3 AI!owance that Pressure Bases Bases Control Relocation of '! liein No.17.1 Isolation Valve (PlV) Program in ITS details Note a. leakage may be Section 5.5.14 cor%Tsg measured indirectly if testing , accomplished ira methodoigy accordance with i approved procedures and supported by > computctions showing that the method is capable of demonstrating l valve leakage compliance ITS 3.4 LAS Table 4.1-3 Minimum test differential Bases Bases Control Relocation of item No.17.1 pressure for PlVs shall Program in ITS details Note b. be 2150 psid. Section 5.5.14 conceming testing methodoigy ITS 3.4 LAS Table 4.1-3 Allowance that more Bases Bases Control Relocaten of item No.17.1 than one PlV may be Program in ITS details ! Note c. tested in parallel Section 5.5.14 cor% Tag i provided the total testing leakage does not exceed methodoigy l 5gpm ITS 3.4 LAS Table 3.1-1 Listing of safety injection Bases Bases Control Relocaten of system PlVs Program in ITS desenptive . Section 5.5.14 system f' ! information , i I
TABLE RL - RELOCATED SPECIFIC-ITEM MATRIX page 13 of 51 ITS & DOC CTS Description General Location Change Charactorumbon Characterization Reference Reference Controls Type ITS 3.4 LA6 Table 4.1-2 Requirement to perform TRM 10 CFR 50.59 Relocate of item No.1 reactor coolant details radiochemical test on a concerning monthly frequency testing r.wthology not requered for operability ITS 3.4 LA6 Table 4.1-2 Requirement to perform TRM 10 CFR 50.59 Relocation of item No. 2 reactor coolant boron details concentration test on a twice/ week frequency corgnTW,g testing methology Q not required for operability ITS 3.4 LA6 Table 4.1-2 Description of a gross ."ases Bases Control Relocation of Note (1) activity analysis. Program in ITS details Section 5.5.14 conceming testing methodolgy ITS 3.4 LA6 Table 4.1-2 Description of a TRM 10 CFR 50.59 Relocation of Note (2) radiochemical analysis details conceming testing methodolgy ITS 3.4 LA7 Table 4.1-2 Requirement to perform TRM 10 CFR 50.59 Relocate of item No. 4 Boric Acid Tank boron details concentration test on a conceming twice/ week frequency testing methology not required for operability v
i. i i i ! TABLE RL - RELOCATES SPECIFICMEM MATRIX pese 14 af'51 F iTs s'poc cts Description General Location Change Charactertantion Charactortsmuon i! Reference Reference Contrets Type ITS 3.4 LA8 Table 4.1-3 Requwement to perform TRM 10 CFR 50.59 Relocaten of ; i item No.14 RHR compartment fan - detals
; funchonal test and concommg
- laboratory tests of filter testeg melhology j media on a once per not requand for ,
operahng cycle operainhty frequency ! i ITS 3.4 LA9 Table 4.1-2 ' Requwement to perform TRM 10 CFR 50.59 Relocahon of f Item No.10 S/G samples 5 detais ; daystweek concomme teshng methology h ~t j ' not requwed for ! operatmhty _ ITS 3.4 R1 - Table 4.1-2 Requwement to sample TRM 10 CFR 50.59 P% of , ltem No.1 the reactor coolant detmis - , system for Chionde and concommg .l
- Oxygen on a frequency testeg methology of 5 tunes per week not requwed for i ITS 3.4 LA10 Table 4.1-2 Requwement to sample ODCM ODCM in ITS : RW of Note (3) Stack Gas lodme and Sechon 5.5.1 detals :
, Parbculate on a weekly concommg ' l bases when mdme or parbculate radioachysty Radelogscal
~ '
j 1 Effluent levels exceed 10% of the . Technmal .! limit in TS Section Spec 6 cations l 3.9.2.1, the samphng samping , frequency shan be , I increased to a rnensmum of once per day l l l
- i. y l I
TABLE RL-RELOCATEDSPECIFIC-ITEM MATRIX page 15 of 51 ITS & DOC CTS Description General Locabon Change Characterizabon Characterization Reference Reference Controls Type ITS 3.4 LA11 3.2.1 Requirement for an TRM 10 CFR 50.59 Relocaten of injection flow path and detailed bonc acid equivalent to requwemords that supplied from the relating to RWST in all plant systems not conditions with fuelin the requred for f vessel operabelsty or to ( mamtaen requwed innits ITS 3.4 LA12 3.2.2.b,c.e, & Requirements for boric TRM 10 CFR 50.59 Relocaten of f acid transfer pump, boric detaded acid tanks, heat tracing requremen's and primary water relatog to , storage tank systems not required for , operabildy or to maintain requaed limits ; iTS 3.5 LA1 3.3.1.2.e Specific exclusion of the Bases Bases Control Relocation of safety injection hot Program in ITS detailed injection pathways and Section 5.5.14 requwements i valves from the relating to i requirements of TS systems not Section 3.3.1.2 required for operability or to maintain required limits J
TABLE RL - RELOCATESSPECIFIC-ITEM MATRIX page 16 of 51 ITS & DOC CTS Description General Location Change Characterumbon Characterizabon Reference Reference Controis Type ITS 3.5 LA2 3.3.1.1.c, d. Details of ECCS Bases Bases Control Relocation of e, & f Operability Program in ITS system I Sechon 5.5.14 description I details ITS 3.6 LA1 1 7.a Details specifying non- Bases Bases Control Relocation of automatic isolation Program in ITS details valves be closed and blind flanges be property Section 5.5.14 conceming methodology for g installed meeting requirements
!TS 3.6 LA2 4.5.1.3 "The test shall be Bases Bases Control Relocation of performed with the Program in ITS details isolation valves in the Section 5.5.14 conceming spray supply lines at the testing containment and spray methodolgy additive tank blocked closed."
ITS 3.6 LA3 1.7.d * " Manual valves qualifying Bases Bases Control Relocation of as automatic Program in ITS details containment isolation Section 5.5.14 conceming valves are secured methodology for closed." meeting requirements ITS 3.6 LA4 3.6.4.3 Details of testing of 42 Bases Bases Control Relocation of inch purge valves Program in ITS details Section 5.5.14 conceming testing methodoloay
_ ___ . _ .~ _ - TABLE RL - RELOCATEI7 SPECIFIC-ITEM MATRIX page 17 of 51 ITS & DOC CTS Description General Location Change Characterumbon Characterization Reference Reference Controls Type iTS 3.6 LAS 1.7.d " "All automatic trip valve Bases Bases Control Relocabon of required to be closed Program in ITS details during accident Sechon 5.5.14 concemog conditions are operable methodology for or are secured closed." meeting requrements ITS 3.6 LA6 1.7.b " Equipment dooris Bases Bases Control Relocatxm of property closed and Program in ITS details sealed." Sechon 5.5.14 conceming < 1.7.c " Bases methodology for At least one doorin the meeting personnel airlock is requerements properly closed and sealed." ITS 3.6 R1 3.3.5 "The reactor shall not be TRM 10 CFR 50.59 Relocation of made critical unless the detailed valves of the post requirements ! accident containment relating to venting system are systems not operable." required for 'I operability or to maintain required limits ITS 3.7 LA1 Table 4.1-3 Requirement to check TRM 10 CFR 50.59 Relocation of j liem No.12, closure of Turbine Steam details q ' Stop, Control, Reheat conceming cF Stop, and Interceptor testing not Valves on a quarterly required for frequency operability
TABLE RL-RELOCATEDSPECIFIC-ITEM MATRIX page 18 of 51 ITS & DOC CTS Description General Location Change Characterizatson Charactenzation Reference Reference Controls Type ITS 3.71.A2 3.13.1.a Requirement that when TRM 10 CFR 50.59 Relocation of the reactoris at power or desenptive hot shutdown,if a details snubberis determined to corn 6i&q be inoperable and an components that engmeering evaluation support cannot validate the operability operability of the supported component then the supported component shall be declared inoperable. If operability can be validated then the snubber shall be retumed to operable status within 72 hours. ITS 3.7 LA2 3.13.1.b "If a snubberis TRM 10 CFR 50.59 Relocabon of determined to be testing details inoperable while the conceming reactoris in cold components that shutdown, the snubber (if support needed for a supported operability component projection) shall be repaired and reinsta!!ed or replaced prior to reactor startup."
i TABLE RL-RELOCATEDSPECIFIC-ITEM MATRIX page 19 of 51 - ITS & DOC CTS Descnption General Location Change Characternehon Characterization Reference Reference Controls Type ! iTS 3.7 LA2 4.13 SnubberTesting TRM 10 CFR 50.59 Relocation of Requirements testing details concermng components that support operabety ITS 3.7 LA3 4.15.a . Requirements to venfy TRM 10 CFR 50.59 Relocate of Control Room air details - temperature every 12 hrs concerning testing not required for operabety ITS 3.7 LA4 5.4.3 "This minimum boron UFSAR 10 CFR 50.59 Relocatm of concentration ensures details subcriticality under worst cor*cermng case design events," and j. % 7 for references : irs".sg ; I requwements ; ITS 3.7 LA5 3.12 Seismic shutdown TRM 10 CFR 50.59 Relocation of desenptwe > actions and procedural detail associated with a ! seismic event ITS 3.7 LA6 5.4.2.1 New Fuel Storage Rack UFSAR 10 CFR 50.59 Relocation of , secured location system ' restrictions desenption details i i
l l TABLE' RL - RELOCATES SPECIFIC-1 TEM MATRIX page 20 or51 - i ITS& DOC CTS. Descriptoon General Locabon Change Characterizatson Characterization Reference Reference Controls Type ITS 3.7 LA7 CTS 4.8.1 Requirements to test inservice Testing 10 CFR 50.59 Relocahon of and 4.8.2 AFW pumps monthly Program - detads concemeng testing not regured for operabddy ITS 3.7 LAB CTS 4.12.3 Requwement to monitor TRM 10 CFR 50.59 Relocahon of relative humidity of air estails processed by spent fuel conc.ir.ir.g ventilahon portion of the _ _ testing not Refuehng Filter System requred for operabdity ITS 3.8 LA1 3.7.1.d Desenphon of specife Bases Bases Control Relocahon of automaticinps that are Program in ITS system ! required to t>e bypassed Section 5.5.14 desenphon for an operable detads Emergency Diesel < Generator (EDG). ITS 3.8 LA1 3.7.2.e and Description of specific Bases Bases Control Relocation of 4.6.1.3 automatic trips that are Program in ITS 'istem required to be bypassed Secten 5.5.14 wraiphon for an operable EDG. details T (As referenced to CTS 3.7.1.d) l
l l TABLE RL - RELOCATED SPECIFIC 4 TEM MATRIX page 21 of 51 i ITS & DOC CTS Descnphon General Locahon Change Characterization Charactensation Reference Reference Controls Type 1 l ITS 3.8 LA2 3.7.3 Restriction allowing the Bases Bases Control Relocahon on back-feeding of the Program in ITS detaded emergency busses via Sechon 5.5.14 requirements the unit auxaary relahng to transformer only while systems not the reactoris in cold required for shutdown unless nuclear operabikty or to safety consideratxms maintaen requered require it to be done hmits during hot shutdown ITS 3.8 LA3 4.6.1.3 Details describing how Bases Bases Control Relocahon of the testing of the EDG Program in ITS details automatic trips " trips Section 5.5.14 conc 6Wg ; defeat" feature is testing acnplished methodology ITS 3.8 LA4 4.6.1.3 "Each diesel generator UFSAR and TRM 10 CFR 50.59 Relocation of shall be inspected at detads least once every concerning refueling interval." testing ITS 3.8 LA5 4.6.1.4.a Details describing the Bases Bases Control Relocation of , b" continuous load limits of Progirin in ITS details the EDGs and restriction Section 5.5.14 concemog preventing the testing continuous operation of methodolgy the EDGs above these limits
TABLE RL - RELOCATEIISPECIFIC-ITEM MATRIX page22of51 ITS & DOC CTS Descnphon General Locahon Change Charactorumbor Characterization Reference Reference Controls Type ITS 3.8 LAS 4.6.1.4.b Details describing the Bases Bases Control Relocaten of short-term load Program in ITS details limitations of the EDGs Sechon 5.5.14 concemeng and restriction preventing testing the operation above this methodoigy limit ITS 3.8 LAS 4.6.1.5 Details descnbing how Bases Bases Control Relocation of the EDG is started and Program in ITS details synchronized to the bus Secton 5.5.14 concemeng in preparation for the 24 testing hour full load test methodolgy ITS 3.8 LA6 Table 4.1-2 Items No.11 and 12 Bases Bases Control Relocation of details of EDG fuel oil Program ki ITS desenptive testing (tanks to which Section 5.5.14 details / testing requirements ( apply) ITS 3.8 LA7 4.6.3.2 Detail describing the Bases Bases Control Relocation of precision at which the Program in ITS details ceit voltage must be Sechon 5.5.14 conceming determined and the testing ; requirement that the methodology i amount of water added to each cell be measured and recorded.
TABLE RL-RELOCATEDSPECIFIC-ITEM MATRIX page 23 of 51 B ITS & DOC CTS Descnptson General Location Change Charactonzation Characterization Reference Reference Controis Type ITS 3.8 LA7 4.6.3.4 Requirement that when Bases Bases Control R6L*shon of battery data is recorded, Program in ITS details ! the new data shall be Sechon 5.5.14 conc.iTsag compared to previous testing data in order to detect methodology signs of abuse or . detenoration. ITS 3.8 LA8 3.7.1.a and Regarding 110 KU-4160 Bases Bases Control Relocaten of 3.7.1.c V startup transformerin Program in ITS system . service and 4160 V Sechon 5.5.14 6esenpton buses 2 and 3 energized. details ITS 3.8 LA9 3.7.1.b Regarding 480 V buses Bases Bases Control Relocation of i E1 and 2 energized Program in ITS system Secten 5.5.14 desenpton ; details ITS 3.8 LA10 3.7.1.e Regarding details of the Bases Bases Control Relocation of batteries and battery Program in ITS system I charger Sechon 5.5.14 descnpbon details l ITS 3.9 LA1 3.8.1.f Reference to specific COLR 10 CFR 50.59 Relocahon of boron concentration of values 1950 ppm to be assocated with maintained during head requirements , removal or movement of l fuelin the reactor l s
TABLE RL-RELOCATEDSPECIFIC-ITEM MATRIX page 24 of 51 ITS & DOC CTS Description General Location Change Charactenzation Charactenzatson Reference Reference Controls Type ITS 3.9 LA2 Table 4.1-3 Requirement to test TRM 10 CFR 50.59 Relocaton of , item No. 6 refueling system details interlocks prior to each conceming / refueling system testing not (L shutdown required for I A operabildy ITS 3.9 LA3 3.10.8.3 "When the reactor is in COLR 10 CFR 50.59 Relocation of the cold shutdown values I condition, the shutdown assocated with ( margin shall be a least 1 requirements percent Ak/k." ITS 3.9 LA4 3.8.1.d Requirement that Bases Bases Control Relocation of whenever core geometry Programir ITS details is being changed that the Section 5.5.14 conceming r source range channels methodology for l provide " continuous ir.ce;ing {f visual indication in the requirements a control room and one with audible indication available in the , containment" l ITS 3.9 LA6 3.8.1.e Requirement that during TRM 10 CFR 50.59 Relocation of refueling operations, T. detailed shall be maintained requirements s 140* F relating to systems not U
)
required for operability or to maintain required limits i
TABLE RL-RELOCATEDSPECIFK:-ITEM MATRIX page25 of 51 ITS & DOC CTS Description General Location Change Characterization Characterization Reference Reference Controls Type ITS 3.9 LA7 3.8.1.h " Movement of fuel within TRM 10 CFR 50.59 Relocahon of the core shall not be detailed initiated prior to 100 requwements hours after shutdown." relating to systems not required for l operatnkty or to mentain requwed limits ITS 3.9 R1 3.8.1.c Requirement that during TRM 10 CFR 50.59 Relocahon, does refueling operations not meet 10 CFR
" Radiation levels in the 50.36 criteria containment and spent fuel storage areas shall ,,
be monitored continuously." ITS 3.9 R1 3.8.1.g Requirement that TRM 10 CFR 50.59 Relocation, does whenever core geometry ' not meet 10 CFR is being changed, direct 50.36 criteria communications between the control 7 _4 room and the refueling cavity manipulator crane shall be available
TABLE RL-RELOCATERSPECIFIC4 TEM MATRIX page 26 of 51 ITS & DOC CTS Description General Location Change Characterization Characterization Reference Reference Controls Type ITS 4.0 LA1 5.1 Specifics describing the UFSAR 10 CFR 50.59 Reicr iico of location of H. B. details Robinson Steam Electric concemeng Plant (HBRSEP), Unit location of plant No. 2 in relation to 8 HBRSEP Unit No.1 and the fact that Unit No. 2 is I owned and operated by < Carolina Power & Light Co. In addition the statement describing site exclusion boundary (per 10 CFR 100.3) as being a circle of 1400 ft radius from the reactor center line. ITS 4.0 L.A2 5.3.1.1 Specifics describing the UFSAR 10 CFR 50.59 Relocation of reactor core i.e. system "approximately 68 metric descnption tons", fuel rods "which details , are pre pressurized," and f fuel assemblies each [ contain "204 fuel rod locations occupied by rods consisting of natural or slightly enriched uranium pellets, solid inert materials, or a combination of the aforementioned"
TABLE RL-RELOCATEUSPECIFIC-{ TEM MATRIX Pese 27 of 51 ITS & DOC CTS Desenption General Location Change Characterization Characterianteen Reference Reference Controis Type ITS 4.0 LA2 5.3.1.3 Desenpbve details of UFSAR 10 CFR 50.59 Resocahon of reload fuel system p. desenphon details ITS 4.0 LA2 5.3.2.1 Design code UFSAR 10 CFR 50.59 Reiocahon of requwements of the RCS system , desenphon detains i ITS 4.0 LA2 5.3.2.2 Desenpbve informahon UFSAR 10 CFR 50.59 Relocahon of cor.c.irdrq the piping system and curprsits of the desenphon RCS meet Amencan details Sooety of Mechanecal Ergirac s (ASME) Boiler i ; and Pressure Vessel Code (B&PV) Class I requrements ITS 4.0 LA2 5.3.2.3 Desenptive informabon UFSAR 10 CFR 50.59 Relocahon of concemsng the nomuut system a volume of coolant desenphon - contained in the RCS at details rated operating I conditions h
.- . . . . _.. . .- ._ . . _ . . _ -- _ . _ _ _ _ _ _ _ . . _ _ . _ . . - ~ . _ _ _ _ - -
4'
; 1 -
q. , ..-- i
.i i l TABLE . RL - RELOCATED SPECIFIC-ITEM MATRIK page2s of 51 ;
ITs a poc cts Descripsion General Location Change Charactorhamen Charactertmedien Reparence Reference Centrols Type i ! - ITS 4.01.A3 - 5.4.1 ' "The new and spent fuel UFSAR 10 CFR 50.50 N of Pi t structures are system .j
- desoned to wahstand desenpten j i- .
the anexapated details .- earthquake loedmos as 1 I' ASME B&PV Code Class [ .! I structures. The spent ! j' fuel pit has a stanless L' ; steelliner to ensure agamst loss of water." i ITS 4.01.A3 5.4.2.1 Dotads desenbeg UFSAR 10 CFR 50.59 % of features of the new fuel system i- storage th that descnplan mentam K , <0.95 detail = - p ; - assummg the racks are J 4
- flooded with pure water ,
i.e., "._ N separabon is mantamed by use of the storage i rack secured W restnchons"..."m' order to ..' estatch a geometry ; . whch ensures that.. * ! l [ i i
. ,, . . . . , w , . , - . , , . - _ , .
TABLE RL - RELOCATEDSPECIFIC-ITEM MATRIX page 29 of 51 ITS & DOC CTS Description General Locahon Change Characternation Characterization Reference Reference Controls Type ITS 4.01.A3 5.4.2.2 Details desenbing UFSAR 10 CFR 50.59 Relocaten of features that maintain K, system less than 0.95 in the description spent fuel pool i.e., "a details combination of nominal assembly spacing, 7 neutron absorber material between the assemblies, and restrictions on fuel design, integral bumable absorber content, reconstitution, and storage is required to assure that..." ITS 4.0 LA4 5.2.1.1 Descriptive information UFSAR 10 CFR 50.59 Relocation of conceming the purposes system of the containment desenption > building deta;is ITS 4.0 LA4 5.2.1.2 Descriptive information UFSAR 10 CFR 50.59 Relocatun of . conceming the design system pressure ratings of the description g containment building details P ITS 4.0 LA4 5.2.2.1 Descriptive information UFSAR 10 CFR 50.59 Relocaten of conceming the design of system the containment desenpbon i penetrations for electrical details and mechanical systems i
TABLE RL-RELOCATESSPECIFIC4 TEM MATRIX page 30 of 51 ITS & DOC CTS Desenption General Location Change Characterizabon Charactensatson Reference Reference Controls Type ITS 4.01.A4 5.2.22 Descriptive information UFSAR 10 CFR 50.59 Relocate of conceming the Phase A system and Phase B desenptm containment isolation details signals and the fact that they must be capable of f withstanding a single component failure and still maintain containment isolation ITS 4.0 LA4 5.2.3.1 Descriptive information UFSAR 10 CFR 50.59 Relocatm of conceming the system containment spray descnphon g system and its purpose details ITS 4.0 LA4 5.2.3.2 Descriptive infonrWdon UFSAR 10 CFR 50.59 Relocatm of conceming the system f containment intemal air description L recirculation system and detads its heat removal capability t i
TABLE RL - RELOCATED SPECIFIC-ITEM MATRIX page 31 of 51 1 ITS & DOC CTS Description General Location Change Characterization Characterizatson , Reference Reference Controls Type ITS 4.0 LAS 5.5 Desenptive information UFSAR 10 CFR 50.59 Relocahon of conceming the design of system the containment building, desenphon auxiliary building, ASME details B&PV Code Class I
~
turbine bay, and all I contained Engineered Safety Feature (ESF) systems be designed for 1 a maximum credible i earthquake with an acceleration of 0.20 g ITS 4.0 LA6 1.19 Definition of Site UFSAR 10 CFR 50.59 Relocahon of I Boundary and Figure 1.1- details 1 " Plant Site Boundary concemog . and Exclusion Zone." location of plant ITS 5.0 LAi 6.5.1.1.2 Requirements Quality Assurance 10 CFR 50.54(a) Relocation of concerning how safety Program Description edministrative analysis shall be (UFSAR Section 17.3) details prepared for all procedures, tests, and experiments covering procedures identifed in TS Section 6.5.1.1.1 and procedures that affect nuclear safety _ _ _ _ ._m_ _ . _ _ _ _ _ _ _ _ _ _ _ _
TABLE RL-RELOCATEI1 SPECIFIC-ITEM MATRW page 32 of 51 ; ITS & DOC CTS Desw W General Locabon Change Characterumbon Charactorumbon Reference Reference Controis Type ITS 5.0 LA1 6.5.1.1.3 Requirements Quality A-surance 10 CFR 50.54(a) Ratt e of conceming when a Program Desenption e&TaGtranve second safety reviev (UFSAR Sect:on 17.3) detads shall be perfein-M on proce.tures affechng nuclear safety ITS 5.0 LA1 6.5.1.1.4 Requirements for Quality Assurance 10 CFR 50.54(a) Re;c Lon of approvalof procedures Program Desenption M Tashebve that do not involve an (UFSAR Sechon 17.3) details unreviewed safety question as defined in 10 CFR 50.59 nor a change to the TS ITS 5.0 LA1 6.5.1.1.5 Requirements Quality Assurrice 10 CFR 50.54(a) Relocaten of conceming approval of Progem Desenption a&Tistrat:ye temporary changes to (UFSAR Sechon 17.3) details procedures and the maximum time it may be in effect i.e.,21 days ITS 5.0 LA1 6.5.1.1.6 Requirements Quality Assurance 10 CFR 50.54(a) Reloc.Lon of ; conceming changes to Program Desenpbon a&TaL L.Uve procedures that (UFSAR Sechen 17.3) detads constitute an unreviewed safety question, or involve a change to the i TS i
TABLE RL-RELOCATEDSPECIFIC4 TEM MATRIX page 33 of 51 I ITS & DOC CTS Desenptson General I ac=han Change Characteriaatson Charactensatsen Reference Reference Controis Type l ITS 5.0 LA1 6.5.1.1.7 Requrements Quehty Assurance 10 CFR 50.54(a) Relocahon of conc =>cong changes Program Desenphon admrustratrve 4 which constitute a (UFSAR Sechon 17.3) details 1 change to the facdsty as f desenbed in the UFSAR
, ITS 5.0 LA1 6.5.12.1 Requrements Quahty Assorance 10 CFR 50.54(a) Relocahon of
- concerno,g plant Proy An Desenphon admwwstratrve 9 rnct4.c.GO is that affect (UFSAR Section 17.3) details y nuclear safety ITS 5.0 LA1 6.5.12.2 Requrement conceming Quahty Assurance 10 CFR 50.54(a) Relocahon of tfw second safety review Progirmin Desenpbon admrustrative x all modifications that (UFSAR Sechon 17.3) details ;
affect nuclear safety ITS 5.01.A1 6.5.12.3 Requerements Quahty Assurance l 10 CFR 50.54(a) Relocahon of conceming approval of Picy AT. Desenpbon administrative fn modificabons that do not (UFSAR Sechon 17.3) details myolve an tm se.-k and safety question or a C~ change to the TS ITS 5.0 LA1 6.5.1.2.4 & Requirements Quality Assurance 10 CFR 50.54(a) Relocahon of 6.5.12.5 corn.ccrung approval of Program Descnphon admrustratrve , inct4n bcas that either constrtute an urge.-k;;d (UFSAR Sechon 17.3) detaiis g safety question or a chance to the TS ie !
TABLE RL-RELOCATEDSPECIFIC4 TEM MATRIX page 34 of 51 ITS & DOC CTS Desc. W 7 General Locatsen Change Characterumbon Charactorumbon Reference Reference Controis Type iTS 5.0 LA1 6.5.1.3.1 "Each proposed Quakty Assurance 10 CFR 50.54(a) Reloc Loriof Technical Specificabon Program Desenpts MTwistratrve or Operating bcense (UFSAR Secison 17.3) detads change shall be reviewed by the Plant Nuclear Safety Committee and submitted to the NRC for approval." iTS 5.0 LA1 6.5.1.4.1 Requirements Quality Assurance 10 CFR 50.54(a) Relocata of conceming Tedaacol Program Description M Twob.Gwe Specification violations (UFSAR Sechon 17.3) detads ITS 5.0 LA1 6.5.1.5.1 Qualificata Quakty Assurance 10 CFR 50.54(M Relocate of requirements for Nuclear Picwi.n. Descriphon M Twob Uve Safety Reviewers (UFSAR Sechon 17.3) details ITS 5.0 LA1 6.5.1.6.1.a Requirements for Quahty Assurance 10 CFR 50.54(a) Reicc.Lun of and b establishing a Plant Program Desenption M Twob.Gve Nuclear Safety (UFSAR Sechon 17.3) detads Committee (PNSC) and the advisory role it plays to the Plant General Manager ITS 5.0 LA1 6.5.1.62 Requirement for the Quakty Assurance 10 CFR 50.54(a) Relocation of composition of the PNSC Program Description admmistratve (UFSAR Sechen 17.3) detads ITS 5.0 LA1 6.5.1.6.3 Requirements for PNSC Quahty Assurance 10 CFR 50.54(a) Relocation of members and attemate Program Description administratrve , members (UFSAR Section 17.3) details
TABLE RL-RELOCATEDSPECIFCITEM MATRIX page35 of 51 ITS & DOC CTS Description General Le% Change Charactonashon Charactonestion Reference Reference Controis Type _ ITS 5.01.A1 6.5.1.6.4.a Defirwton of
- quorum" as Quabty Assurance 10 CFR 50.54(a) Relocabon of and b it pertains to the PNSC. Prvy.in Descr;yiics admrustrative Also limits the number of (UFSAR Sechon 17.3) details 9 allemates that may @
cviv@se a quorum , ITS 5.01.A1 6.5.1.6.5 Mrumum PNSC u._ v QuaktyAssurance 10 CFR 50.54(a) Relocahon of requrements Prvy.in Desenpbon admrustrative (bFSAR Sechon 17.3) detads ITS 5.0 LA1 6.5.1.6.6.a-k Listing of actmbes Quahty Assurance 10 CFR 50.54(a) Relocahon of I requring PNSC Proyen Desenpbon aamanstrative wtvolvement (UFSAR Sechon 17.3) decads ! ITS 5.0 L.A1 6.5.1.6.7 Requred achons to be Quahty Assurance 10 CFR 50.54(a) Relocabon of taken upon disagreement Pic9i n Desenpbon admrustrahve between the PNSC and (UFSAR Sechon 17.3) details 1 acbons contemplated by the Plant General Manager ITS 5.0 L.A1 6.5.1.6.8 Requrement for Quahty Assurance 10 CFR 50.54(a) Relocabon of I maintaining mnutes of Proy.iu Desenption admrustrat:ve PNSC rr.;;^29s and their (UFSAR Sechon 17.3) details t rnenrnum content ITS .S.O LA1 E.52.1 Desenpbon of the Quakty Assurance 10 CFR 50.54(a) Relocahon of i function of the Nuclear Proy.iu Desenpbon admrustrative Assessment Sechon (UFSAR Sechon 17.3) details (NAS) , t I i e
TABLE RL-RELOCATESSPECIFIC-ITEM MATRIX page 36 of 51 ITS & DOC CTS Desenpbon General Whi Change Characterumbon Charactonsabon Reference Reference Controis Type ITS 5.0 LA1 6.52.2.1 Qual (catens of Quahty Assurance 10 CFR 50.54(a) Relocation of mdanduals for independent renews in Program Desenpbon (UFSAR Secbon 17.3) aGT.-JA.hve detads
]
cr-- the NAS ITS 5.0 LA1 6.5.2.22 Quahfcatens of the Quakty Assurance 10 CFR 50.54(a) Relocaten of n Manager-Nuclear Prograni Desenption a&ima2L.Lve
/
Assessment Seebon detads ' (UFSAR Seebon 17.3) ITS 5.0 LA1 6.522.3 Qualificabons of Quahty Assurance 10 CFR 50.54(a) Relocation of n irdnduals podccrim,9 Pic urosi Desenptron a&r-us sve J mdependent safety (UFSAR Sechon 17.3) detads F reviews ITS 5.0 LA1 6.52.2.4 Acbons to be taken when Quahty Assurance 10 CFR 50.54(a) Relocaten of suffcient expertise does Picyr.in Desenpton admirustratnre not exist withm the NAS. (UFSAR Sechon 17.3) details - Also a!!ows an indmdual to be " competent
- in more than one speoatty ITS 5.0 LA1 6.5.22.5 Quahfcations for Quahty Assurance 10 CFR 50.54(a) Relocation of indmduals performing Program Desenpton adm:rustratrve reviews of documents (UFSAR Sechon 17.3) details submrtted under TS Secbon 6.5.2.3 ITS 5.0 LA1 6.522.6 Requironents for Quahty Assurance 10 CFR 50.54(a) Relocaten of independent safety PrWrern Desenpbon a&r-n=L.Lve rewews in NAS (UFSAR Sechon 17 3) detads
.. . - _ _ _-- = . .- . .. - . . - .- - - .. . . . . . .
I 1- ! 1- l 4 , 1 < t !
- j. TABLE RL-RELOCATEDSPECFIC4TERIIIATRIK page37e(51 -
- _ ITS & DOC CTS Demonytten General Location Change Charentertesdien N Centrees Type ftsforence Reference }
1 ITS 5.0 LA1 6.5.2.2.7 Roqueement that the - Quality Assurance 10 CFR 50.54(a) Raiocahon of procedures NAS Independent Safety Program Descnphon . admsustrahve ; Renew Prograrn be (UFSAR Sechon 17.3) details cord =1 arf in accordance ! wnIh wntlen. -;-- c;;d 3 procedures i j l ITS 5.0 LA1 6.5.2.3 a-o Lishng ofitems in whsd QuakeyAssurance 10 CFR 50.54(a) Relocahon of tw NAS shed perform Program Desenphon adminstrahve l l renews (UFSAR Secsson 17_3) deemils .& r . ITS 5.0 LA1 6.5.2.4 "Results of Nucieer Quakey Assurance 10 CFR 50.54(a) % of l' Assessment W Program Desenphon adsunstratwo
- l. independent safety (UFSAR W 17.3) detets ,
i rewours shaE be j . documented and
- retened - i ITS 5.0 LA2 6.2.1.e Requwement that the (FSAR 10 CFR 50.50 % of health physacs manager admsustratwo !
har.1r arrm== to the dotats i osaraE unit manager and ! the heellh physses I
- - techniciarfs *stop work" l
- autaty I 4
f I i t l t 6 I s l t- ;
j ' l
! t j I
[ TABLE M.-RELOCATE 53SPECW9C-ITEM MATNK page 38 of 51 [
- j. t 4
i e
- ITS & DOC CTS: Doncription General Locaben Change Characterimetion Cherasterimetion l Reference Reference Centrets Type I- ITS 5.0 LA3 6.2.3.h Resencton that nunwnum UFSAR 10 CFR 50.5g p.an,.mn.i of ;
i j shift mennng admrustrative '
! requwements canrx2 be detains , ; used tojusefy W= ; , shift complement upon !
stuft relief when a ! ]' requwed memberis rut avaimble for relief -
}
t^ ITS 5.0 LA4 6.5.1.1.1.j Reference to Regulatory QuaktyAssurena 10 CFR 50.54(a) % of i Guuse 4.15. Dec.1977 Program Descnphon adnunstratwo i l unth regard to the Quehty details l (UFSAR Seckon 17.3) ! (3 Assurance Program l, 4 iTS 5.0 LA6 4.4.3.a-h Requwement to perform TRM 10 CFR 50.50 Relocahon of leakage teshng and detains .; 4 mspectens of tie Post concomme , ! ) Accahnt Recwcuishon teshng Heat Removal System methodology l and she apphcebee j e entene. [ Addeonel regterament to j perform repers as m to m anteri . { leakage witun the stated i> cntene l ITS 5.0 LA7 4.4.4.1 Requwement to inspect TRM 10 CFR 50.50 % of contenment survemence = 1- =ndons - ! teshne i ! meGlodoloGr i I. i _.__ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ____.% _ _ . _ _ .e__ . _ .._ _ _ _ _ 5.-, ..~ _ . - . , . . - , . _ , _ , -.5 ..,~ , , . . _ .y- - , mm _m.__,, , ,, _.m._ .,.,,.,..#.y. ,%m._ _ _ _ . . - _ _ , _ . _.
.. - . .~ - . . . . .- -. .. . . - . .. . .. - . -
I i TAIRE IL-IELOCATE5DSPECRC4 TEM MATfuK page 30 of 51 l rTs a poC CTsi om cripsien senerasL non Cases. w charassarememme
- Rafosence Reference Centrols Type
!. ITS 5.0 LA7 4.4.4.3.a naanik desentmg TRM 10 CFR 50.50 % of l analyses to be performed d=tmaa , on Contamment canamne Sunminance Tendons tasang . meshodotour !' ITS 5.0 LA8 42.3 Requrement to perform insonnce e 10 CFR 50.50 % of - i- reecaor coolant pump Pmgram dotads i., } St aheele concomme testag Q
./
i meshodoloar 4 i ITS 5.0 LA9 3.8.2.c Requwement that the TRM 10 CFR 50.50 % of ;
- . spent fuel buddmg and d=amik !
l contemment buildag siner fans shes be sho-n ancomme leseng
?>
to operate witun 110% rnetiodology i j- of desagn flour ITS 5.0 LA9 4.15.d Requwement that the TRM 10 CFR 50.50 Retocahon of conomi room sinramon details ,
;_ _.i be tested
^
h unti 4 =ao- no any *=urai poet i mensenance on the siner momennance houssngs or fogouang tooteg to dociare i panemg. sire, or chemeal opwabiney reisese in tie Control t Room erwelope ! i l I ! l - t kt
TABLE RL-RELOCATEiEBSPECIFIC4 TEM RIATRIX page 40 of 51 ITS & DOC CTS Desenytson General I ne=*iant Change Characterisatson Characterisation Reference Reference Controis Type ITS 5.0 LA9 4.15.f Requrement that the TRM 10 CFR 50.59 Relocaten of Contml Room filtrabon detads system be tested every concerning 18 months teshng methodology ITS 5.0 LA9 4.15.g Requeement that the TRM 10 CFR 50.59 Relocahon of Control Room filtrabon detads system HEPA filters be = N vnth tested after cv64:e or post partsal replacement and mantenance assocated test teshng to dedore ccrevons operabikty ITS 5.0 LA9 4.15.h Requwement that the TRM 10 CFR 50.59 Relocahon of , Control Room filtrabon detads ! s; stem charcoal filters associated westh be tested after each post partsal or csTG;; maintenance replacement and leftmg to declare assocated test operatniity condebons ITS 5.0 LA9 4.12 Refueling filter systems TRM 10 CFR 50.59 Relocahon of i Appbcabelity and desenpbve Obrechve details i , ITS 5.0 LA9 4.12.1 Requerement that the TRM 10 CFR 50.59 Relocahon of l Refueling Filter System desenptrve be demonstrated detads ! operable every operatog . cycle 1 -
- t
k L i i I TABLE RL-RELOCATED SPECIRC4 TEM MATRIK page 41 e(51 i ITS & DOC CTS Description General Lacetion Change Choresterimetion Chosestostenden j Refusense Referense Centrees E Type j ITS 5.0 LA9 4.12.2.a Requwement that the TRM 10 CFR 50.50 % of ; Refueling F50er System esents j be tested irutney, and at concenung I loest once peroperaung teseng - cycle priorto each enstuntology resuenne outage oraner 720 hours of system i operamon whchever i comes first [ t ITS 5.0 LA9 4.12.2.iMr Details concommg hour TRM 10 CFR 50.50 pa-anc mn ,at j meRea m Sraem emen i l Enraten system is to be concorrung l tested and what tests are teshng^- to be performed - i
- I ITS 5.0 LA10 3.16.2.1 Resencton on the TRM 10 CFR 50.59 Relocahon of i quantly of r==6a=r*ve amemam motonal contamed in the concommg i heled tanks shall be melhodology for -
iimmed at as ames ensomng i[it
,7
%I i
i I i i ( i I l
{ TABLE RL-RELOCATE 42 SPECIFIC-ITEM MATRDC page 42 c(51 ITS & DOC CTS Cm 42-. General f ae=8ir=t Change Characteriantion Characternanteen Reference Reference Controis Type ITS 5.0 LA10 3.16.2.2 Requrement that when TRM 10 CFR 50.59 Relocahon of the quantty of detais t radioactrve malenalin concemog , any ksted tank exceeds methodology for ! the limit, suspend as meebng addibons to the tank, and requrements take achons to reduce the amount of radioactrve matenalin the tank to vnthm lets vnthin 48 hours ! ITS 5.0 LA10 3.162.3 Requrement that if the TRM 10 CFR 50.59 Relocanon of radsoactrve content of reporting
- any of the listed tanks requrements ,
cannot be reduced to , withen kmsts vnthin 48 i I hours then the NRC shall be nobfied in accordance , vnth TS Sechon 6.6 ; ITS 5.0 LA10 3.16.2.1.f Definsbon of" Temporary TRM 10 CFR 50.59 Relocahon of Tarr as it appbes to TS desenpbve Sechon details t
t i i l ! a ; TABLE RL-RELOCATEDSPECFIC4 TEM MATRIK page 43 of 51 i s }- ITS & DOC CTS Description General Location Change Charactorfastion Chasestertaneen i 54mfesence ftsfesonoe CongreIs Type ! t I'
- ITS 5.0 LA10 3.16.4.1 Resencticns on hydrogen TRM 10 CFR 50.59 Relocation of 3' and oxygen content in detailed !
- the Waste Gas Decay requwements i
!- 1anks relating to i systems not i requesd for ) ! operatuility orto sneunteen requwed . ! Isruts [ I i ITS 5.0 LA10 3.16.4.1.a Actions to be taken when TRM 10 CFR 50.59 % of ; i corygon or hydrogen detailed ' . concentrabon in the requwernents I Waste Gas Decay Tanks reisting to l e Isruts systems not .! j requwed for [
- operatutty or to l mainteri requend i irruts -l 1
- ITS 5.0 LA10 3.16.4.1.b Actions to be taken when TRM 10 CFR 50.59 % of t oxygen and hydrogen detailed I 3
concentrabon in the - requesments :I Waste Gas Decay Tanks reistng to !
- - +=inats systems not [
- , requwed for i operatiility or to j rasentant requwed
- linues I j . l + l ! i- i I i
- t f
i _ . . _. . _ _ . _ _ _ . . . . , _ _ _ _ . _ _ _ _ _ _ . _ . ~ _ _ _ . . . _ _
..;._._,__..____.__._,_._.___.___..I
TABLE RL-RELOCATEDSPECFIC-ITEM MATRot page44 or51 ITS & DOC CTS Description General L-=a% Change Characterisation Characterisation Reference Reference Controis Type ITS 5.0 LA10 3.16.4.2 Reportog requreme.W TRM 10 CFR 50.59 Relocahon of for oxygen and/or reportog hydrogen bemg out of requrements spedTGiin the Waste Gas Decay Tank (s) for > 48 hours ITS 5.0 LA10 3.16.4.3 Reportog requrements TRM 10 CFR 50.59 Relocahon of ' for condibon where reportog achons requwed to be requrements taken by TS do not result in retumeng the hydrogen or oxygen concentrabon in the Waste Gas Decay Tank (s) to s 6% withm i 24 hours ITS 5.0 LA10 3.16.5.1 Lrnstation on the amount TRM 10 CFR 50.59 Relocahon of r of radioactive material detailed that may be stored in arry requrements one Waste Gas Decay relehng to Tank shall be limited io systems not s 1.9 E+4 curies noble requred for gas (conssdered as Xe- operabdsty or to 133) mamtman requred o rmes i (
!. i i i j TABLE RL-RELOCATEDSPEQFIC-ITEM MATRIK page 45 of 51 ! ITS & DOC CTS Description General Lacetion Change Characterisahen Cherastertention
- Reference Asserence Centrats Type .
L ITS 5.0 LA10 3.16.5.2 Requrerrent to suspend TRM 10 CFR 50.59 PW of ; i as addskons to any detailed ; Waste Gas Decay Tank requwemorts ! that exceeds the limit in reishng to l TS Sechon 3.16.5.1 and systems not inthm 48 hours reduce reqused for the tank contents to operabikty or to l vnthm hmds mentem requwed [ iets ITS 5.0 LA10 3.16.5.3 Reportog requwements if TRM 10 CFR 50.59 R W of
- the Waste Gas Decay repostmg i Tank contents are not requwements !
reduced to vnthen iets i vnehm the time penod anowed by TS Sechon ! ! 3.16.5.2 i ,- ITS 5.0 LA10 4.20.2 Note speedying whidi TRM Bases Control P % of' j tanks are to be induded Program in ITS system , in intahons M= sad by W 5.5.14 desenpten
- TS Sechon 4.20.2.1 dateds ;
!' ITS 5.0 LA10 420.2.1 Requrement to venty the TRM 10 CFR 50.59 P % of t e radioechve matensi detened teshng i
- content of tanks hsted in requwements l TS Sechon 3.16.2.1 by reistag to
- samping systems not l required for 5 M orto
}- mentem requesd l lim'as i. } 4
,m -. <w r w- ein % g an.e-, ..,rw - .,. - - . -.,py-s.w .u.m :r - =' .. y
- vd.r-' 4W 9-pT'-Pd- -+qs1-Ww w + 9gi
l [ t
?
l i
' TABLE RL - RELOCATESSPECFIC-ITEM MATRIK pay 46 a(51 l
I ris a Doc cts , Descripelen General Location Change Centrets CherastestmeAlan Cherastertesten Type j Reference Referer oe t 420.4.1. Requwement to venfy the TRM 10 CFR 50.50 % of ; ! ITS 5.01.A10 ! hydrogen and oxygen detaged toshng [ !- concentrabon in the requwements ! Waste Gas DecayTanks reichng to no be watunlinnes by systems not morntonng contents with requesd for l hydrogen and oxygen operabihty or to i i monnors or samphng manten requesd j hmes , i ; iTS 5.0 LA10 420.5.1 Requwement to sample TRM 10 CFR 50.50 % of the contents of the detailed teshng i Waste Gas Decay Tanks requrements ! every 24 hours when relemng to } Reactorcardarit Actrvey systems not ! is 2100 uCWml reqused for ! operabikty orto mentam reqused lim *5 ITS 5.0 LA11 6.9.1.4, rime =k of format of TRM 10 CFR 50.50 % of I Monthly Operahng Report reportmg requeements 3 ' ITS 5.0 LA12 6.5.3.1 Requirement to perform QualWy Assurance 10 CFR 50.54(a) % of f; s certam types of Program Descnpton admrustratwo j assessments at a (UFSAR Sechon 17.3) details j frequency not to exceed 24 months, by the NAS as Ested in TS Sechons 6.5.3.1 M i t i I
. . - , - . . , . ~ . . , . , . _ . _ . . , , _ _ _ _ - .- . . . _ . .
i !L TAEILE RL-RELOCATEDSPECFIC-ITEM MATRIK pese47of51 .i L ' i; iTs a Doc cts Deseripme. seneran.e. amen cm ge ener.ete-tion cm==am-se- ! Reference Refosence Centrols Typs j ITS 5.0 LA12 6.5.3.2 Requirement for the NAS Quahty Assurance 10 CFR 50.54(a) % of ! to perform assessments Program Desenphon adnunneratwo 1 l in accordance with the' (UFSAR W 17.3) detains Code of Federal Ey% specdcany in the areas of Emergency i j Preparedness, Secunty, and Radsabon Protechon i ITS 5.0 LA12 6.5.4.1 & . Requrements for Quakly Assurance 10 CFR 50.54(a) % of 6.5.4.2 independent fire Program Descnpton adnunestraeme prosar*ari and loss (UFSAR W 17.3) detets i preventon espechon l and audit l ITS 5.0 LA1 6.6.1.b) & Review requirements Quakty Assurance 10 CFR 50.54(a) % of , 6.6.2.b) with Program Desenphon adminsstratwe reportable events (UFSAR Sedan 17.3) dotats l' ITS 5.0 LA13 6.9.1.1 Reporkng regurements TRM 10 CFR 50.59 % of j for piant startup and reportne . [ . ITS 5.0 LA14 6.9.1.3.7 Reportmg and approval ODCM ODCM in ITS % of requrements for secton 5.5.1 reparkng 4 crianges to the requeements
- r=aa=reve waste % of i systems adiransstralwe
!. datams !- l i __ . _ _ _ . . _ _ . , . ._ _. -_ .- _ _ _ _ _ _ _ __ _ ___- _ . _ . - . ~ . . . _ . _ _ _ _ . , _ _ _ _ _
1
, i i
c . i j' TABLE RL-RELOCATEDSPECRC4 TEM MATRIK peer 4s of51 t t
- . 3
- ITs & DOC CTS Desedpuen General LaceAlan Change Charactedsmeen N l 1 noserence puserence cenereas Type !
I t i ITS 5.0 LA14 6.17.1.1. Reportmg requwements OOCM rvrna in ITS Rebecoton of j i for mapor changes to the Secton 5.5.1 reportmg ; i radioeceve hqwd, requeements F gaseous, or solid e j treatment systems. j indudes aBowance that ! i limnese may sutwrut the ! l requwed h.shon as
- part of due nesd UFSAR t
! Update ! i i ! ITS 5.0 LA14 6.17.1.2 Mayor changes to OOCM OOCM in ITS Raiocchen of r % w esse secnon 5.5.1 am process syssoms shen detets , become effective upon , _ a,.tappre y the PNSC t
- iTS 5.0 LA15 6.9.3.3.b Lising of TS COLR 10 CFR 50.50 % of I
! requwements applicable admmiseramve !- to each listed " dessies ' l motiodology as they
- pen.n to c_:_1. se l core operatmg hmds t I
ITS 5.0 LA16 6.9.32- Requwement t;s generate OOCM 10 CFR 50.50 - % of wrinen reports for the reportng ! listed specist radelogcol requwements ! emuent reports sisted and i sutput to the NRC wdhm l 30 days of Rur
- occunence or event ,
i ! I r l-I
-. - . . - . . . . - . - . - - . - . _ ~ . . . . .- . . . . - , . -.- . . . ,
4 l' TABLE RL-RELOCATEDSPECRC4 TEM MATIWK page49 of 51 i f ITS & DOC CTS Descriphon General Locaten Change N ; ! Reference Refusence Centrats Type
- ITS 5.0 LA17 1.15 Requrements fortw TRM 10 CFR 50.50 Raiocahon of l- Procmss Control Program admruokahve j
- (PCP) to assure detets w - - s with 10 CFR .
l 20,10 CFR 17 and ! Federal and State - reguistons { {. ITS 5.0 LA17 6.15.1 Requrement that the TRM 10 CFR 50.50 Relocahon of 4 PCP shes be approved admrustratrue n !- by the NRC prior to deines d I- N
.l iTS 5.0 LA17 6.152- Reportng and approval TRM 10 CFR 50.50 Relocahon of
- requrements for reportas e l
changes to the PCP requwements l
- h of d
! admrustrahve
- j. dotats I
ITS 5.01.A18 6.4.1 Requrements for a UFSAR 10 CFR 50.50 PW of
^
1 i--- ~ --:-i and admrustramve i W trarung details program fqr the plant ] staff that shat meet the requrements of Sec. 5.5 j
, of ANSI N18.1-1971 and j 10 CFR 55. Appenckx A
- ITS 5.0 LA19 6.10.1.a-i Laseng of fachty records Quatty Assurance 10 CFR 50.54(a) PW of i that must be retaned for. Program Desenpeon admrustrative j at least frve voors (UFSAR Sechon 173) detaBs 4-g i'
s
- t i
,. -- - - - - . , . . - - , - ..- _- . . , . ~ . - - - - - - - ,. . . . _ . - - - - . . , - . . _ - . , . - _ _ - . . - . - . - . . - -
TABLE RL-RELOCATEDSPECIFIC-ITEM MATRIX page 50 or51 ITS & DOC CTS Descriphon General Locahon Change Charactonashon Characterischen Reference Reference Controis Type ITS 5.0 LA19 6.10.2.a-m Listing of facdity records Quakty Assurance 10 CFR 50.54(a) Relocabon of p that must be retained for Program Descnphon admwustratrve l the duraton of the facihty (UFSAR Sechon 17.3) detals d-Opwstig license ITS 5.0 LA20 6.11 Requerement that UFSAR 10 CFR 50.59 Relocahon of procedures for personnel admnstrahve , radiation protechon for detads the Radiahon Protection ! Program be prepared , consistent with the ! requirements of 10 CFR 20 and that they be approved, mantained, and adhered to for all operations invohnng i personnel radiaton exposure ITS 5.0 LA21 6.1.1, Detailed plant UFSAR 10 CFR 50.59 Rhiiion of
' 6.5.1.1.4, cig ru.iion titles admastratrve 6.5.1.2.3, details 6.2.1(b),
6.2.3, 6.3.1, p 6.16.2, , d 6.13.1, and 6.13.2, With respect to detailed plant org*nization tdles
i t TABLE RL-RELOCATED SPECFIC4 TERE MATRIK page51 of 51 Doncription GeneralLocation Change Charentedeogion Caterestarimogen ITS & DOC CTS ; asserence asserence Congress Type ITS 5.0 LA22 6.9.1.2, Reportng requrements ODCM 10 CFR 50.50 % of ; 6.9.1.2.3, and for radiologcol ofnuents reportng : 6.9.1.3, With requwaments regard to ' reportng regurements for radiologcol effluents t ITS 5.0 LA23 6.9.3.3.s With Melhomabcal terms COLR 10 CFR 50.59 Relocahon of regard to . utilmed in the CCXR descnptwo mothematcol details terms utlized in the COLR , 6 i!; i i
TABLE R - RELOCATED ITEMS MATRIX page 1 of 14 CTS DeswS4kwi General Locabon Change Controls Charactorumbon 3.1.1.4.A Requirement that when the RCS temperature is TRM 10 CFR 50.59 Does not meet 10
>200*F RCS vent paths from the reactor vessel head CFR 50.36 and pressurizer steam space shau be operable entena 3.1.1.4.B Requirement that when the RCS temperature is TRM 10 CFR 50.59 Does not meet 10
>200 F. valves RC-571 and 572 shall be closed with CFR 50.36 the allowance that the valves may be cycled enteria penodically in order to depressurize the vent system should the system pressunze due to " root" valve leak -
by 3.1.1.4.C.1 *With the Reactor Vessel Head vent path inoperable, TRM 10 CFR 50.59 Does not meet 10 restore the vent path to operable status within 30 CFR 50.36 days or be in Hot Shutdown within 6 hours and Cold cntena Shutdown within the followng 30 hours." _ 3.1.1.4.C.2 Reporting requirement that with the Pressurizer TRM 10 CFR 50.59 Does not meet 10 steam space vent inoperable, restore it to operable CFR 50.36 status within 30 days or prepare and submit a special cnteria report to the NRC within the following 14 days detailing the cause of the inoperability and the achon being taken to restore operability l 3.1.6.1 "The concentration of oxygen in the reactor coolant TRM ' CFR 50.59 Does not meet 10 shall not exceed 0.1 ppm when the reactor coolant CFR 50.36 temperature exceeds 250*F." cntena 3.1.6.2 "The concentration of chloride in the reactor coolant TRM 10 CFR 50.59 Does not meet 10 shall not exceed 0.15 ppm when the reactor coolant CFR 50.36 temperature exceeds 250 F." cnteria i
TABLE R - RELOCATED ITEMS MATRIX page 2 of 13 CTS Descnphon General Locatum Change Controls Characterumbon 3.1.6.3 Requirement that if out of spes Matian reactor TRM 10 CFR 50.59 Does not meet 10 coolant oxygen or chloride concentraWannot be CFR 50.36 restored to within specifications within 24 hours the cntena unit sha!! be placed in the cold shutdown condition using normal operating procedures 3.1.2.2 "The secondary side of the steam generator must not TRM 10 CFR 50.59 Does not meet 10 be pressurized above 200 psig if the temperature of CFR 50.36 the vessel is below 120 F." cnteria 3.1.2.3 "The pressurizer shall neither exceed a maximum TRM 10 CFR 50.59 Does not meet 10 heatup rate of 100T/hr nor a cooldown rate of CFR 50.36 200T/hr. The spray shall not be used if the criteria temperature difference between the pressurizer and the spray fluid is greater than 320*F." 3.5.2.1 Requirement that the equipment listed in TS Table OCCM ODCM in ITS R. dica,9;c.I 3.5-6 shall be operable with their alarm /inp setpoints Sechon 5.5.1 Emuent Technical set in accordance with the ODCM Specifications (RETS) relocahon, does not meet 10 CFR 50.36 cnteria 3.5.2.2 Requirement that with the channel setpoint less ODCM ODCM in ITS RETS rekx lics conservative than that required in TS Section 3.5.2.1, Sechon 5.5.1 does not meet 10 immediately suspend releases via the associated CFR 50.36 pathway and restore the channel setpoint to that cnteria required by the ODCM or declare the channel inoperable 3.5.2.3 "With less than the minimum number of radioachve ODCM ODCM in ITS RETS relocation, liquid effluent monitoring instrumentation operable, Sechon 5.5.1 does not meet 10 take the action shown in Table 3.5-6." CFR 50.36 cnteria
t TABLE R - RELOCATED ITERBS MATRIX page 3 of 13 CTS N::- ^l: a General Locatson Change Controis Charactertmetion 3.52.4 "The provissons of the Speedicahon 3.0 are not OOCM OOCM in ITS RETSr % . app 6 cable? Sechon 5.5.1 does not meet 10 CFR 50.36 cntens 3.5.3.1 Requrement that the equipment Ested in TS Table ODCM OOCM in ITS RETSr % 3.5-7 shas be operable with their alarmftnp setponts Sechon 5.5.1 does not meet 10 set in accordance with the ODCM CFR 50.36 cntens ! 3.5.32 Requirement that with the channel setpoet less ODCM ODCM in ITS RETSr % conservative than that requred in TS Sechon 3.5.3.1 Seckon 5.5.1 does not meet 10 l
. i '":'i suspend releases via the assooated CFR 50.36 1
pathway and restore the channel setpoint to that cntena ) requwed by the ODCM or declare the channel ! inoperate 1 3.5.3.3 "With less than the rnmemum number of radcoctrve ODCM ODCM in ITS RETSr W gaseous effluent morutonng instrumentahon operable. Sechon 5.5.1 does not meet 10 ; take the achon shown in Table 3.5-6? CFR 50.36 i clitons 3.5.3.4 "The provisens of the Speedicahon 3.0 are not ODCM ODCM in ITS RETS rudac= hart. applicable? Sechon 5.5.1 does not meet 10 CFR 50.36 , entens ! l l I i .(
- - ~ . - - _ . _ _ _ _ - _ _ _ _
m- , i l TABLE R - RELOCNI'ED ITEMS MATRIX page 4 of 13 CTS E :- ^2: n General Location Change Centrets Charactertention ; Table 3.5-6 "P% tsqud Emuent Mondonng ODCM ODCM in ITS RETS relocahon, instrumentabon," whsch lists those mondors requred Sechon 5.5.1 does not meet 10 i to mondor the vanous bqued radioachve release CFR 50.36 pathways and the requred achons to be taken when cntene the mondonng channelis inoperable. The table also prendes the necessary compensatory achon that ' must be taken if it is desned to mantam the release j via the pathway with the assocsated mondor i a t Table 3.5-7 "P% Gaseous Effluent Mondonng ODCM ODCM in ITS RETSr % !
- instrumentation," which lists those mondors requred TRM Sechon 5.5.1 does not meet 10 .
to mondor the vanous gaseous radioachve release CFR 50.36
- pathways and the required achons to be taken when cntene i the mondonng channelis inoperable. The table also 10 CFR 50.59 for prowdes the necessary compensatory action that TRM -
must be taken if it is dested to mantam the release l via the pathway with the assocated mondor snoperable I i . 3.8.3 Requrements for spent fuel rod water temperature TRM 10 CFR 50.59 Does not meet 10 CFR 50.36 t l cntena t } 3.8.4 Spent fuel cask handling crane requrements TRM 10 CFR 50.59 Does not meet 10 i CFR 50.36 j 4 crdens ; l t i i l !
TABl.E R - RELOCATED ITEMS MATRIX page 5 of 13 CTS Desenphon General Locahon Change Controts Charactenzabon 3.9.1.1 Recuirement that the OEsn.h.Ucai of radicarh' ODCM ODCM in ITS RETS rir;ca hi, rnaterial in hquid effluents released at any time from Section 5.5.1 does not meet 10 the site to unrestricted areas shau be hmited to the CFR 50.36 concentrations specified in 10 CFR 20 App. B. Table enteria 11 Column 2 for radionuchdes other than dissolved or entrarned noble gases. For dissolved or entraced nob ~e gases, the concentration shad be Hrnsted to 2x10' uCi/mi total achydy 3.9.12 Requii=6ient, with the concentration of requid effluents ODCM ODCM in ITS RETS r=-ka ucs, in excess of that aHowed by TS Sechon 3.9.1.1, Secbon 5.5.1 does not meet 10 without delay to restore the concentration to within CFR 50.36 krrats and not.1y the NRC in accordance with TS cnteria Secbon 6.6. 3.9.1.3 Requirement that in the event the requirements of TS ODCM ODCM in ITS RETS relocahon, Sechon 3.9.1.2 cannot be met the unit shau be placed Sechon 5.5.1 does not meet 10 in the hot shutdown condition. CFR 50.36 cnteria 3.9.1.4 "The provtsions of Specification 3.0 are not ODCM ODCM in ITS RETS.wicc hi, applicable." Section 5.5.1 does not meet 10 CFR 50.36 cnteria 3.9.2.1 Requirement that the dose commitment at aR times to ODCM ODCM in ITS RETS relocabon, a member of the pubib from radioachve materials in Sechon 5.5.1 does not meet 10 tiquid effluents released to unrestricted areas shall be CFR 50.36 1 limited as stated in (a) and (b) cnteria
TABLE R - RELOCAiTED ITEMS MATRIX page 6 of 13 CTS Desenption General Locatsan Change Controis Charactonambon 3.9.2.2 "Mth the calculated dose commitment from the ODCM ODCM in ITS RETS relocahon, release of raeoactrve matenals in Lquid emuents Sechon 5.5.1 does noimeet 10 exceeding any of the limits presenbed by CFR 50.36 Spears ^uen 3.92.1 above, prepare and sutmt a cntena , report to the Commission in accordance with Speere^ uc6 6.9.32.* 3.9.3.1 Requrement that the dose rate at as times to a ODCM ODCM in ITS RETS relocaton, ,
, member of the public from ra&oactrve matenals in Sechon 5.5.1 does not meet 10 i gaseous effluents released from the site boundary CFR 50.36 l shaR be limited as stated in (a) and (b) cntena [
3.9.3.2 "With the dose rate (s) exceeding the above limits. OOCM ODCM in ITS RETS relocahon. without delay decrease the release rate to wittm the Sechon 5.5.1 does not meet 10 I above bmsts. In addshon, a notificabon must be made CFR 50.36 to the Commission in accordance vnth Specisexi cntena 6.6." 3.9.3.3 Requrement that in the event the requrements of TS ODCM OOCM in ITS RETS relocahon, Sechon 3.9.3.2 cannot be met the unit shall be placed Sechon 5.5.1 does not meet 10 in the hot shutdown condshon CFR 50.36 cntena 3.9.4.1 Requrement that the air dose commitment due to ODCM ODCM in ITS RETS relocahon, ; ra&onoble gases released in gaseous emuents to Sechon 5.5.1 dous not meet 10 areas at and beyond the site boundary shall be limited CFR 50.36 i as stated in (a) and (b) cntena l 3.9.4 2 Requirement that with the lets of TS Sechon 3.9.4.1 ODCM ODCM in ITS RETS relocahon, t exceeded, prepare and sutmi a report to the NRC in Sechon 5.5.1 does not meet 10 l accordance with TS Sechon 6.9.32 CFR 50.36 l [ i c , I i l l l
1 t 1 l l TABLE R - RELOCATED ITEMS MATRIX page 7 of 13 i I CTS C==- - f -i_ General Location Change Controls Characterusation 3.9.5.1 Requwement that the dose to the public from !-131, I- ODCM ODCM in ITS RETS r=anc nnni, 133, tnbum, and radeoactrve matenals in parbculate Sechon 5.5.1 does not most 10 form, with half-irves greater than eight (8) days be CFR 50.36 t ' imted in accordance vnth lensts stated in (a) and (b) cntena 3.9.52 Requwement that with the iets of TS Sechon 3.9.5.1 ODCM ODCM in ITS RETS r=aar= hart, i exceeded, piepare and submit a report to the NRC in Sechon 5.5.1 does not meet 10 accordance with TS Sechon 6.9.3.2 CFR 50.36 cntens ; 3.9.6.1 Requwement that the dose commrtment to any ODCM ODCM in ITS RETS reinemanvi,
- member of the public, due to releases of licensed Sechca 5.5.1 does not meet 10 l rnatenais and radeabon, from urarwum fuel LA CFR 50.36
- umrces shas be limded to s 25 rnrem to the total cntena i
{ body or any organ except the thyrood, which shall be limited to s 75 mrem over 12 consecutive months ~ i 3.9.6.2 Reporbng and analysts requwements when any of the ODCM ODCM in ITS RETS relocahon, limds stated in TS Sechons 3.9.2.1.a or b,3.9.4.1.a or Sechon 5.5.1 does not meet 10 l b, or 3.9.5.1.a or b are exceeded by a factor of 2 CFR 50.36 ; j creene i
- 3.9.6.3 "The provisions of SpecTwinn- 3.0 are not ODCM ODCM in ITS RETS r=anc.a ws, i
applicable
- Sechon 5.5.1 does not meet 10 CFR 50.36 ;
r m t 3.11.1 *A menemum of 15 total accessible thembles and at TRM 10 CFR 50.59 Does not meet 10 ! I least 2 per quadrant sufficent movable in-core CFR 50.36 detectors shall be operable dunng recalibrabon of the entena , excore symmetncal offset detechon system ~ i i i i i
TABLE R - RELOCATED ITEMS MATRIX page 8 of 13 CTS DesenpGon GeneralLs ias. Change Controis Characternatson 3.11.2
- Power shall be limited to 90% of rated power if TRM 10 CFR 50.59 Does not meet 10 recahbraton requ:rements for the excore syu...wir.cisi CFR 50.36 offset detechon system idenbfied in Table 4.1-1 are cntena not met."
3.16.1.1 Requirement that the radioachve hquid waste system ODCM ODCM in ITS RETS r=;cc Gr., be utilized to minimize offsste doses due to releases Secbon 5.5.1 does not meet 10 of hquid radioactive emuents CFR 50.36 cntena 3.16.1.2 Requirement that with liquid wastes being discharged ODCM ODCM in ITS RETS reLLors without treatment while in excess of the limits in TS Sechon 5.5.1 does not meet 10 Sechon 3.16.1.1, prepine and submrt a report to the CFR 50.36 NRC in accordance with TS Sechon 6.9.32.b cnteria 3.16.3.1 Requ;ternent that the radioactrve gaseous waste ODCM ODCM in ITS RETS relocaton, system be utdized to minimize offsite doses due to Secbon 5.5.1 does not meet 10 releases of liquid radcachve effluents CFR 50.36 cntena 3.16.32 Requirement that with the gaseous waste treatment ODCM ODCM in ITS RETS r=;0c.Lvn. system inoperable and gaseous releases in excess of Sechon 5.5.1 does not meet 10 the limits in 3.16.3.1, prepare and submit a special TS CFR 50.36 Section report to the NRC in accordance with TS cnteria Sechon 6.9.32.b 3.16.6.1 "The Solid Radioactrve System shall be used in TRM 10 CFR 50.59 RETS reia Rin, accordance with a Process Controi Program (PCP) to does not meet 10 process wet radioactive waste to meet shipping and CFR 50.36 burial ground requirements." cnteria 3.16.6.2 "With the provisions of the PCP not satisfied. TRM 10 CFR 50.59 RETS relocaton, suspend shipments of defectively processed or does not meet 10 defectively packaged solid radioachve waste from the CFR 50.36 site " . criteria
TALR: R - RELOCMED ITEMS MATRIX page 9 of 13 CTS Description General Location Chaw Controls Charactertration , 3.16.6.3 Requirement that if a test speomen fails to venfy TRM 10 CFR 50.53 RETS r% soldfication, the sohdification of the batch under test does not meet 10 > CFR 50.36 shall be suspended until such time as additonal test specamens can be obtamed, attemative solidification entena parameters can be determoed in h&,cc with the PCP, and a subsequent test verifies soidfication 3.17.1.1 "The Radiological Environmental Monitoring Program ODCM ODCM in ITS RETS relocahon, shall be conducted as specified in Table 3.17-1." Sechon 5.5.1 does no: meet 10 CFR 50.36 cntena 3.17.1.2 Actions to be taken when the Radiological ODCM ODCM in ITS RETS relocahon, . Environmental Monitoring Program is not in Sechon 5.5.1 does not meet 10 ! accordance with TS Section 3.17-1 CFR 50.36
- w q 3.17.1.3 Actions to be taken when the level of radioactmty in ODCM ODCM in ITS RETS relocahon, !)
plant effluents as indicated by environmental Section 5.5.1 ' does not meet 10 f sampiing is greater than the reporting levels of TS CFR 50.36 , Table 3.17-2 criteria 3.17.1.4 Requirement to obtain replacement samples of dk ODCM ODCM in ITS RETS relocation, and leafy vegetables when the sample locahons Sechon 5.5.1 does not meet 10 specified in TS Table 3.17-1 cannot be obtained CFR 50.36 criteria 3.17.1.5 "The provisions of Specification 3.0 are not ODCM ODCM in ITS RETS. h , applicable." Sechon 5.5.1 does not meet 10 CFR 50.36
! criteria l
i ;
' . TABLE R - RELOCao'ED ITEROS MATRDC page 10 of 13 l CTS- C::: 'Z:a General Location Change Centrees Charactortsetion 3.17.1.6 Allowance for deviabons from the requred ODCM ODCM in ITS RETS relocaten, t envronmental sampisng schedule Secten 5.5.1 does not meet 10-CFR 50.36 1 4
cntens
- 3.17.2.1 Requrement to perform a land use census and ODCM O3CM in ITS RETSr % ,.
related content Sechon 5.5.1 does not most 10 .i CFR 50.36 . -! C***** 3.17.2.2 Reporting requrement for land use census that ODCM OOCM in ITS RETSr % ,. l , idenhfies doses greater than the values curnmtly Sechon 5.5.1 does not most 10 i bong calculated in TS Sechon 4.10.4.1 CFR 50.36 1 i cah"= j 3.17.2.3.a-c Achons to be taken when the land use census ODCM OOCM in ITS RETSr % , , identifies a location whsch yields an annual calculated Sechon 5.5.1 does not most 10 * . dose or dose commstment of a specsfic pathway CFR 50.36 -l which is 20% greater thart that at a cunent samping cntens locahon . t 3.17.3.1,2,3, Requrement for analyses supplied by U. S. ODCM ODCM in ITS RETS r=lae=8-wt, ; and 4 Envronmental Protechon Agency (EPA) as a part of Sechon 5.5.1 does not most 10 l Intertaboratory Compenson Program CFR 50.36 . entene .! Table 3.17-1 Table and associated notation descnbeng the ODCM ODCM in ITS RETS rudarmanwi, j Radelogeal Environmental Monstonng Program Sechon 5.5.1 does not meet 10 CFR 50.36 'i' cntens
- Table 3.17-2 Table desenbeg reportog levels for radioactiv
- ty ODCM ODCM in ITS RETSr % ,,
concentrations in enviror. mental samples Sechon 5.5.1 does not most 10 . CFR 50.36 - l l l 3
._ _ . _. _ _ - . _ _ _ _ J
TABLE R - RELOCATED ITEMS MATRIX page 11 of 13 General Location Change Controls Characternation CTS Descd E=ri ODCM OOCM in ITS RETSr
- m ,
Table 3.17-3 Table with maximum values for LLDs Sechon 5.5.1 does not meet 10 CFR 50.36 cntena TRM 10 CFR 50.59 Does not meet 10 Table 4.1-1, item Requirement for testing high point vents CFR 50.36 45 cntena ODCM ODCM dn ITS RETS refocahon, 4.10.1.1 Sampling requirements for batch liquid releases Sectu 5.5.1 does not meet 10 CFR 50.36 criteria ODCM ODCM in ITS RETS relocahon, 4.10.1.2 Analysis requirements for samples of batch liquid Sechon 5.5.1 does not meet 10 releases CFR 50.36 cntena ODCM ODCM in ITS RETS relocahon, 4.10.1.3 Requirement that liquid batch samples be taken and analyzed in accordance with TS Table 4.10-1. Sechon 5.5.1 does not meet 10 Requirement that the concentrabons at the point of CFR 50.36 release be within the limits of TS Section 3.9.1.1 criteria CDCM ODCM in ITS RETS relocahon, 4.10.2.1 Requirement for determining the dose rate due to radioactive materials in gaseous effluents to be within Sechon 5.5.1 does not meet 10 the limits of TS Section 3.9.3.1 by performing CFR 50.36 sampling and analysis in accordance with Table 4.10- criteria 2 ODCM ODCM in ITS RETS relocation, d .10.3.1 " Cumulative dose commitments for the current calendar quarter and current calendar year shall be Sechon 5.5.1 does not meet 10 determined in accordance with the ODCM once per CFR 50.36 31 days." criteria
_ . . . = _ _ . . . . . ._. . . _ . _ _ _.
+
i TABLE R '- RELOCA7ED ITERIS MATRIX page 12 of13 l
.i CTS C a ^~_ a_ General Locahon Change Controis Charactortestise_e .
4.10.4.1 Requrement to determee cumulative dose ODCM ODCM in ITS. RETSr h ., contnbutsons for the cummt quarter and cummt hr*ari 5.5.1 does not most 10" calendar year for 1-131,1-133, tntium, and CFR 50.36 radeor=w-iwta= in particulate form with half lives greater cntene , than 8 days 'i i 4.10.5.1 Requrement to determene cumulabve dose ODCM OOCM in ITS RETS solocahon, 1 contnbubons from hqued and gaseous emuents in hr+wwi 5.5.1 does not most 10 , accordance with TS Sechons 3.9.2.1,3.9.4.1, and CFR 50.36 ; 3.9.5.1 cntono : _c 4.10.5.2 Requrement to determme cumulatrve dose ODCM ODCM in ITS RETS r=arv auvi, , contnbubons from drect radsabon from the reactor Secten 5.5.1 does not most 10 ~! c unit and from radweste storage tanks as set forth in CFR 50.36 ; the apphcabehty of TS Sechon 3.9.6.2 cntene . Table 4.10-1 Table and associated notabon desenbeng the ODCM ODCM in ITS RETS relocahon, Ratin r*ve Lsqued Waste Samphng and Analysis Secten 5.5.1 does not most 10 ! Prcy ii CFR 50.36 : cntena { i Table 4.10-2 Table and a=v =ted notabon desenbeng the ODCM ODCM in ITS RETS r%, l Radmactive Gaseous Waste Samphng and Analysis Sechon 5.5.1 does not meet 10 ! Program CFR 50.36 ' [ t 4.16 Requrements for Radsoachve Source Leakage TRM 10 CFR 50.50 Does not most 10 'i Teshng CFR 50.36 cntens .! 4.19.1.1 Requrement to perform radmactive hqued emuent ODCM ODCM in iTS RETS rW .! morutonng instrumentation operatnhty survedances in Secten 5.5.1 does not meet 10 I accordance with TS Table 4.19-1 CFR 50.36 - i cntena t f
TABLE R - RELOCATED ITEMS MATRIX page 13 of 13 Description General Locstion Change Corms Characternation f CTS ODCM ODCM in ITS RETS relocation, 4.19.2.1 Requirement to perform radioactive gaseous effluent monitonng instrumentation operability survei!!ances in Sechon 5.5.1 does not meet 10 CFR 50.36 accordance with TS Table 4.19-2 cnteria ODCM ODCM in ITS RETS relocation, Tab!e 4.19-1 Table and associated notation desenbing the I rad.eactive liquid effluent monitonng instrumentation Sechon 5.5.1 does not meet 10 surveillance requirements CFR 50.36 cnteria ODCM ODCM in ITS RETS relocation, Table 4.19-2 Table and associated notation describing the radioactive gaseous effluent monitoring Section 5.5.1 does not meet 10 instrumentation surveillance requirements TRM 10 CFR 50.59 for CFR 50.36 TRM cnteria ODCM ODCM in ITS RETS relocation, 4.20.1.1 Requirements to perform projected dose commitments at least every 31 days to ensure the Section 5.5.1 does not meet 10 requirements of TS Section 3.16.1.1 are satisfied CFR 50.36 when the Liquid Radwaste Treatment System is not enteria used ODCM ODCM in ITS RETS relocation, 4.20.3.1 Requirements to parform projected dose commitments for gaseous releases at least every 31 Section 5.5.1 does not meet 10 days to ensure the requirements of TS Secbon CFR 50.36 3.16.3.1 are satisfied enteria TRM 10 CFR 50.59 RETS relocation, 4.20.6.1 "The PCP shall be used to veriff the solidification of one representative test specimen from every tenth does not meet 10 batch of wet radioactive waste." CFR 50.36 cnteria Actions to be taken when a test specimen from a TRM 10 CFR 50.59 RETS relocation. ) 4.20.6.2 batch of waste fails to verify solidification does not meet 10 t CFR 50.36 cnteria
i' j i,* l l' .
- - ' TABLE R - RELOCMED ITEMS MATRDC page 14 of 14 - '!
- j. i
- CTS N: - " ^* a General Locahon Change Centrets Characterisation i
- 4.21.1.1 Requisament to collect environmental samples in ODCM ODCM in ITS ' RETS relocahon, accordance with TS Table 3.17-1 and analyze them in Sechon 5.5.1 does not most 10 .,
accordance with TS Tables 3.17-2 and CFR 50.36 ; ! 3.17-3 cntone
.t 4.21.2.1 Speedicahon of how the land use census shall be ODCM ODCM in ITS RETSr % ~i i- conducted Sechon 5.5.1 does not rnoet 10 !i '
- CFR 50.36' .
cntens a 1 4.21.3.1 Requirement to perform analyses as part of the EPA ODCM ODCM in ITS RETS r=anc anwi, _ ji i interlaboratory Compenson Prognen Seckon 5.5.1 does not most 10 ; CFR 50.36 -! i TS Appendix B " Radioactive Effluent Releases" requerement to report ODCM ODCM in ITS Does not meet 10 ! 4 on a monthly tmsis the quanbhes of radioactive Sechon 5.5.1 CFR 50.36 effluents released from the plant cntena t I! 4t iI d 4' 6 L; ii i i ~ !- t f ) i
A w. .A. - A..-_- 4a es,( 4W4 4 44 6 4 4 4 --u-#4m.- - % NRC FORM SC (7 94) NRCMD 3.57 l COVER SHEET FOR CORRESPONDENCE USE THIS COVER SHEET TO PROTECT ORIGINALS OF MULTI-PAGE CORRESPONDENCE d 4 m}}