Text

Broad-Scope Risk-Informed Technical Specification Amendment Request
	ML042190366
Person / Time
Site:	South Texas
Issue date:	08/02/2004
From:	Jordan T; South Texas
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	DG-1122, NOC-AE-04001666, RG-1.200
	Download: ML042190366 (120)
	v • d • e

Nuclear Operating Company South Tes iv/caiekdc ncgrabStatfon PO. Sar28.9 smyth.Tas77-4853 August 2, 2004 NOC-AE-04001666 10CFR50.36 10CFR50.90 U. S. Nuclear Regulatory Commission Attention: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852 South Texas Project Units 1 and 2 Docket Nos. STN 50498, STN 50499 Broad-Scope Risk-Informed Technical Specification Amendment Request

Reference:

1. Letter from S. M. Head to NRC Document Control Desk dated March 18, 2003, "Letter of Intent to Submit a Broad-Scope Risk-Informed Technical Specification Amendment Request" (NOC-AE-03001458)

2. Letter from Scott M. Head to NRC Document Controls Desk dated December 27, 2003, "Request for Fee Waiver as Regulatory Guide 1.200 Pilot Plant" (NOC-AE-03001654)

Reference 1 is a letter of intent for STP Nuclear Operatin'g Company (STPNOC) to submit a broad-scope risk-informed set of Technical Specification changes. This submittal is the formal license amendment request for the proposed risk-informed changes to the Technical Specifications described in the referenced letter. STPNOC has revised the original scope and content of the proposed changes to reflect the results of STPNOC - NRC discussions held on January 22, 2004. As described in Reference 2, the STPNOC submittal is also a pilot plant submittal for the industry for this initiative and a pilot submittal for Regulatory Guide 1.200 (originally DG-1 122), "An Approach for Determining the Technical Adequacy of PRA Results for Risk-Informed Activities".

The attached draft Technical Specification amendment was developed so that it conforms to the five risk-informed principles established by the NRC:

It meets current regulations.

It maintains defense in depth.

It maintains sufficient safety margin.

Any increase in core damage frequency (CDF) is small.

The impact of the change can be monitored.

Details of how the proposed changes meet the five principles are provided in the attachments.

04001666(STP RITS).doc STI:31687089 %() l

NOC-AE-04001666 Page 2 By using STP's Probabilistic Risk Assessment (PRA) to calculate the risk (i.e., CDF, LERF) from the actual plant configuration and comparing it to pre-determined risk thresholds, the configuration risk management program will be capable of providing both a technical basis and robust calculation of an acceptable configuration-specific allowed outage time (AOT). The Configuration Risk Management Program (CRMP) will be the same tool that is currently used to perform the assessment of plant risk required by 10CFR50.65(a)(4).

This proposed change is considered fitting and timely for the following reasons:

It is being submitted at the appropriate time in the overall industry plan for risk-informing the Technical Specifications. It is recognized by industry and NRC that this technological evolution of the Technical Specifications is needed for both current and future nuclear power plants and the state of-the-art in risk management technology makes it feasible now.

It is consistent with the current STP practices for risk-informed configuration management. STP has been applying risk-informed configuration management technology for the past five years to manage plant maintenance configurations and has the capability to quantify incremental changes in plant risk required for the implementation of the proposed changes.

It is consistent with the STP philosophy of optimizing safety by application of probabilistic risk technology.

It complements industry risk-informed Technical Specification initiatives and is a pilot application for a broad use of risk-informed configuration management for AOT determination.

It effectively links the risk determination required by 10CFR50.65(a)(4) to a complementary Technical Specification AOT.

NOC-AE-04001666 Page 3 The STP Plant Operation Review Committee has reviewed and concurred with the proposed changes. Because of the extent of the proposed changes, STPNOC requests 180 days for implementation after NRC approval.

There are no commitments in this application.

If you have any questions, please call Wayne Harrison at 361-972-7298 or me at 361-972-7902.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on IAq as -F#200 ,t-Date Vice President Engineering & Technical Services Attachments:

1. Table of Contents with Links

2. Description of Changes and Safety Evaluation

3. Technical Specification Mark-up Pages

4. Implementation

5. PRA Quality

NOC-AE-04001666 Page 4 cc:

(paper copy) (electronic copy)

Bruce S. Mallett A. H. Gutterman, Esquire Regional Administrator, Region IV Morgan, Lewis & Bockius LLP U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 L. D. Blaylock Arlington, Texas 76011-8064 City Public Service U. S. Nuclear Regulatory Commission David H. Jaffe Attention: Document Control Desk U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike R. L. Balcom Rockville, MD 20852 Texas Genco, LP Richard A. Ratliff A. Ramirez Bureau of Radiation Control City of Austin Texas Department of Health 1100 West 49th Street C. A. Johnson Austin, TX 78756-3189 AEP Texas Central Company Jeffrey Cruz Jon C. Wood U. S. Nuclear Regulatory Commission Matthews & Branscomb P. 0. Box 289, Mail Code: MN1 16 Wadsworth, TX 77483 C. M. Canady City of Austin Electric Utility Department 721 Barton Springs Road Austin, TX 78704

Contents NOC-AE-03001466 Table of Contents with Links This Table of Contents with hyperlinks is provided to facilitate navigating the electronic version of this submittal. : Description of Changes and Attachment 2: Technical Specification Safety Evaluation Markups Section 1: Description 3/4.3.1 REACTOR TRIP SYSTEM INSTRUMENTATION Section 2: Proposed Changes 3/4.3.2 ENGINEERED SAFETY Table 2: Detailed Description of FEATURES ACTUATION SYSTEM Changes INSTRUMENTATION Section 3: Background 3/4.3.5 ATMOSPHERIC STEAM RELIEF VALVE INSTRUMENTATION Section 4: Technical Analysis 3.4.2.2 PRESSURIZER CODE SAFETY Compliance with Design and Licensing VALVES Basis 3/4.4.4 RELIEF VALVES Defense in Depth 3/4.5.1 ACCUMULATORS Table 1: Three Train Design TS Requirements 3/4.5.2 ECCS SUBSYSTEMS - TAVG GREATER THAN OR EQUAL TO 3500 F Safety Margin 3/4.5.5 REFUELING WATER STORAGE Table 3: STP Systems with Reduced TANK Design-basis Capability in Single Train Operation 3/4.5.6 RESIDUAL HEAT REMOVAL (RHR) SYSTEM Section 5.1: No Significant Hazards 3.6.1.7 CONTAINMENT PURGE SUPPLY Section 5.2 Applicable Regulatory Criteria AND EXHAUST Section 6: Environmental Assessment 3/4.6.2 DEPRESSURIZATION AND COOLING SYSTEMS - Containment Spray 3.6.2.3 REACTOR CONTAINMENT FAN COOLERS 3.7.1.2 AUXILIARY FEED WATER 3.7.1.3 AUXILIARY FEEDWATER STORAGE TANK

Contents NOC-AE-03001466 3.7.1.5 MAIN STEAM LINE ISOLATION VALVES 3.7.1.6 ATMOSPHERIC STEAM RELIEF VALVES 3.7.1.7 MAIN FEED WATER 3/4.7.3 COMPONENT COOLING WATER SYSTEM 3/4.7.4 ESSENTIAL COOLING WATER SYSTEM 3/4.7.14 ESSENTIAL CHILLED WATER SYSTEM 3/4.8.1 A.C. SOURCES 3/4.8.2 D.C. SOURCES 3/4.8.3 ONSITE POWER DISTRIBUTION 3.13.1 ALLOWED OUTAGE TIME DETERMINATIONS Bases for Specification 3.13.1 : Implementation : PRA Quality

Description of Changes and Safety Evaluation NOC-AE-04001666 Page 1

1. Description of the changes being proposed and the reasons for seeking the changes.

(Back to Table of Contents)

STP Nuclear Operating Company (STPNOC) is proposing in this application to implement a risk-informed process for determining allowed outage times for'South Texas Project (STP)

Technical Specifications (TS). The risk-informed process involves the application of the STP Configuration Risk Management Program (CRMP). The STP CRMP is a procedurally controlled program utilized by STPNOC for the implementation of 10CFR50.65(a)(4). The details of the proposed changes are described in Section 2 and in the mark-ups of the TS.

STPNOC is proposing this change as a pilot plant for the industry Risk-Informed Technical Specifications (RITS) and for evaluation of RG 1.200, as described in the cover letter. The industry has been discussing the development of RITS with the NRC for about three years and has proposed eight initiatives. This particular initiative is commonly referred to as Initiative 4B, "Risk-Informed Technical Specifications with a Backstop." Initiative 6 addresses the applicability of TS 3.0.3. Because of plant-specific three-train design features, a portion of the STP application necessarily addresses conditions where TS 3.0.3 currently applies. The STP TS typically do not have an action for conditions where more than one of the three required trains of a function are inoperable and TS 3.0.3 must be applied to those configurations. Consequently, STP's application includes a risk-informed action for configurations with more than one inoperable train. STP's application also includes a provision to apply the risk-management process to situations where more than one channel of instrumentation actuation logic is inoperable. Because TS 3.0.3 previously applied to this situation, this is also an extension of Initiative 4B into Initiative 6. This is discussed in more detail in Section 4. The description of the changes will delineate to what extent the STPNOC application addresses TS 3.0.3/Initiative 6.

STPNOC believes it is appropriate for the CRMP to be able to determine the time that can be allowed in a configuration that previously required entry into TS 3.0.3. For many cases, the current TS would require application of TS 3.0.3 simply because the configuration is outside of that defined in the TS although the plant is unlikely to actually be in a seriously degraded condition. Even in unusual cases where all trains or channels of a system required by a Limiting Condition for Operation (LCO) are inoperable, a risk assessment to determine the appropriate action time is preferable to application of TS 3.0.3. In such situations, there are often functionally redundant capabilities or the degree of degradation of the inoperable equipment would not prevent the plant level function from being achieved.

Industry Initiative 7 addresses conditions where a TS system might be declared inoperable for administrative reasons or for very low probability design-basis considerations but is otherwise able to perform its design-basis function. Application of the STPNOC CRMP may consider the degree of functionality in the determination of the calculated allowed outage time (AOT). For instance, a component that is inoperable because it is disassembled (i.e.,

nonfunctional) may be calculated to have a shorter AOT than the same component that is inoperable solely because of a seismic design issue or an internal flooding issue. This is due to the fact that the component's functionality is only called into question for a specific initiating event (e.g., seismic event). When the likelihood of the seismic event is

Description of Changes and Safety Evaluation NOC-AE-04001666 Page 2 incorporated into the calculation, the result is a longer AOT, since for all other initiators the component remains capable of performing its intended function(s).

This change proposes the establishment of a new specification, TS 3.13.1, to determine risk-informed AOTs applicable to a number of identified LCOs. The proposed new TS 3.13.1 would be a separate specification in the STP Technical Specifications and would be referred to in the ACTION statement of the referencing specifications as an option to the "normal" required action. Complementary changes would be made to specific TS to reference TS 3.13.1 to allow for application of the CRMP to determine the AOT.

STP's use of TS 3.13.1 is somewhat different in format from the proposed Improved Technical Specifications (ITS) format, which incorporates the description of the alternative action directly into each LCO in the scope of the change. TS 3.13.1 accomplishes the same purpose with a "shorthand" approach to accommodate the format difference between the "old" NUREG-0452 STP Standard Technical Specifications and the ITS. However, the concept and implementation are the same.

The operator will have the option of using the existing TS AOT for routine plant activities and emergent conditions that would not be expected to require an extension of the AOT.

This existing AOT will be referred to in this application as the "frontstop" time. The frontstop time also provides the operator sufficient time to determine and apply an appropriate extended time from the application of the CRMP for those situations where it is determined that an extended AOT is necessary. Once the CRMP is applied and a component has exceeded its frontstop time, the CRMP must be applied to all subsequent inoperable TS components within the scope of the CRMP to determine the AOT for the new configuration until no components are in ACTIONS beyond the frontstop time. Since the CRMP is the implementing process for 10CFR50.65(a)(4), this achieves consistency between the regulations and the Technical Specifications.

The CRMP will establish a set of risk thresholds reflecting increasing risk significance with commensurate levels of severity and actions. These actions would range from restoring equipment to service, installing temporary modifications, or rescheduling maintenance activities, up to and including transition to safer plant operating modes. The CRMP establishes a core damage probability (CDP) "Non-Risk-significant Threshold" of 1.OE-06 as the first level of threshold severity. Below this threshold, routine work controls are adequate. At or above this threshold, the operator is required to initiate action to reduce or manage the risk in accordance with the CRMP. A "Potentially Risk-Significant Threshold" is established with a CDP of 1.01E-05 to define the limit for the AOTs for plant configurations. The AOT would be calculated as the time required for the cumulative risk associated with a plant configuration to cross the threshold. Should the Potentially Risk-Significant Threshold be exceeded, TS 3.13.1 would immediately impose the required action of the most restrictive TS where the action time had been extended beyond its frontstop.

In accordance with the guidance in the NEI Risk-Managed Technical Specifications (RMTS)

Guide, STP's Non-Risk-significant Threshold will be the limit for planned maintenance.

Description of Changes and Safety Evaluation NOC-AE-04001666 Page 3 However, the AOT permitted by the TS is necessarily based on the Potentially Risk-Significant threshold to account for emergent conditions.

The new TS 3.13.1 introduces the concept of overall plant configuration risk management into the Technical Specifications. Allowable action times would be replaced for the affected specifications with an action requirement for the overall plant configuration based on the CRMP. A backstop AOT limit of 30 days is provided in the new specifications for those cases where the risk analysis by itself would allow excessively long allowable outage times for a loss of function of a TS component. The 30-day backstop would be applied individually to each LCO for which TS 3.13.1 has been invoked.

The proposed change may be applied to those structures, systems, and components (SSCs) that are supported by a plant-specific CRMP. All of the components within the scope of the proposed change are modeled in the PRA such that the revised AOT can be calculated. The LCOs and ACTIONs to which this proposed specification applies would each be modified to reference TS 3.13.1. This submittal only addresses specifications that are applicable in operating modes 1 through 4 because an approved PRA model is not yet available to cover shutdown configurations.

Approval of the changes proposed in this submittal will allow the plant to concentrate efforts in restoring and maintaining plant SSCs with the objective of maintaining low overall risk profile and reducing the likelihood of plant transients. In this way, the focus and attention to items most impacting nuclear safety are enhanced. Maintenance actions can then be prioritized based on how to most effectively limit or reduce risk due to the specific plant configuration at a specific time. This ability represents a significant and substantive technological improvement over current TS methodology. With multiple SSCs out of service, the operator would be able to prioritize efforts to address equipment that would have the biggest effect in reducing the incremental risk. If the operator cannot restore the inoperable equipment, the proposed risk-informed Technical Specifications would require the plant to transition to lower operating modes should the overall risk accumulation exceed the 1.OE-05 CDP level (Potentially Risk-Significant Threshold).

In general, the implementation of the STP Risk-Informed Technical Specifications would be consistent with the guidance in the NEI Risk Managed Technical Specifications Guide.

As shown in Table 2, STPNOC believes there can be emergent circumstances in which it is appropriate to apply the CRMP when all trains of a function are inoperable (i.e. the requirements of TS 3.13.1 may be applied to allow longer AOT than TS 3.0.3). However, STPNOC would not propose to pre-plan entry into a condition in which there is a loss of function other than relatively routine actions that have already been accepted (e.g., opening a common HVAC plenum for inspection).

Implementation is addressed in more detail with specific examples in Attachment 3.

Description of Changes and Safety Evaluation NOC-AE-04001666 Page 4

2. Detailed Description of Proposed Changes (Back to Table of Contents)

Table 2 describes the proposed changes to the Technical Specifications. It includes the basis for each proposed change. The table also indicates where the STP application is extended to Industry Initiative 6 (TS 3.0.3 initiative).

The risk basis column provides the calculated AOT for the inoperable condition existing with no other SSC within the scope of the CRMP (i.e., PRA) being inoperable. To illustrate the "risk margin" a number of the functions in Table 2 depict the AOT without the application of the proposed 30-day backstop. The AOTs in this column represent "base case" and are calculated using the i.0E-05, Potentially Risk-significant Thresholds. When "inoperable" is used in this column, it means that SSC is not capable of performing its intended function.

Application of the CRMP to those conditions where the function is degraded or where operator action can be procedurally credited to restore adequate capability could result in longer AOT. The AOTs in Table 2 were determined using information from the PRA model current at the time of this application. They provide insight into the available margin. To determine AOTs for actual plant configurations, STPNOC will use the PRA or the Risk Assessment Calculator (RasCal), which is an extensive database of over 20,000 pre-calculated maintenance states.

3. Background

(Back to Table of Contents)

STPNOC is proposing in this application to implement a risk-informed process for determining AOTs for STP Technical Specifications. The risk-informed process involves the application of the STP CRMP. The STP CRMP is also utilized by STPNOC for the implementation of 10CFR50.65(a)(4).

The current STP Technical Specifications are based on Westinghouse Standard Technical Specifications (Draft NUREG-0452 Rev. 5), which assume a two-train Engineered Safety Features (ESF) design. However, the STP utilizes a three-train ESF design. Therefore, although the STP maintains an additional ESF train above the standard Westinghouse design, the South Texas TS Limiting Conditions for Operation and associated Action Statements have not effectively addressed the availability of the third ESF train. Furthermore, traditional Technical Specifications are component and system-specific in the sense that the designated AOTs do not take into consideration the cumulative risk of various other components being in their associated individual Action Statements concurrently; instead, each Action Statement is independent of the other.

The Configuration Risk Management and Maintenance Rule Programs establish the means and methods to assess the risk due to out-of-service equipment associated with various plant configurations, including those in which multiple Technical Specification related systems are affected. Therefore, the intent of the changes to the Technical Specifications proposed in this submittal is to integrate the availability of the third ESF train along with the insights provided by the CRMP to establish risk-informed AOTs for selected Specifications and

Description of Changes and Safety Evaluation NOC-AE-04001666 Page 5 which take into consideration the cumulative risk associated with each entry into an Action Statement.

Regulatory Guides (RG) 1.174 and 1.177 provide guidance on risk-informed licensing applications. The criteria of both of these guides are primarily oriented toward permanent changes to the Technical Specifications.

STP's operating history has shown that the extension of the AOT beyond the frontstop will not be done for most entries into the TS, whether for planned or emergent work. While the criteria of RG 1.174 and RG 1.177 would be appropriate for extensions to the frontstop, it is more appropriate to view entry into these risk-informed TS AOT extensions as occasional events where the guidance of RG 1.182 for assessing risk from maintenance activities should be applied.

RG 1.182 and RG 1.160 are used in conjunction with NUMARC 93-01 as standards for implementation of 10CFR50.65 (Maintenance Rule). Section 11.3.7.2 of NUMARC 93-01 includes recommended quantitative risk action thresholds for maintenance activities, as reproduced in the table below.

Incremental [Conditional] Incremental [Conditional]

Core Damage Probability Large Early Release (ICCDP)_ Probability (ICLERP)'

> lE-05 Configuration should not > IE-06 normally be entered voluntarily IE lE-05

Assess non- 1E IE-06 quantifiable factors

Establish risk I management actions

< IE-06 Normal work controls < IE-07 Note 1: For clarity and consistency of terms, the term "conditional" is added to the table heading. The calculated ICDP includes the quantified effect of the maintenance configuration (condition).

Although STPNOC does not believe RG 1.174 and 1.177 are directly applicable to this submittal, the format addresses the Principles of Risk-Informed Decision-making set forth in those RGs. Specifically, justification is provided which demonstrates that:

1. The proposed change meets the current regulations. No exemption or rule change is being requested.

The proposed changes provide a risk-informed methodology for determining the AOTs associated with selected Technical Specifications. The proposed changes are in compliance with current regulations. The evaluations provided in this application confirm that the proposed changes maintain adequate defense-in-depth, safety margin,

Description of Changes and Safety Evaluation NOC-AE-04001666 Page 6 and the capability to meet plant design-basis. Additionally, the risk-informed AOTs proposed are consistent with the CRMP and the Maintenance Rule in ensuring adequate margin to core damage and/or radiation release. Therefore, the proposed changes to the Technical Specifications are in compliance with all current regulations while meeting all license conditions.

Refer to Section 5.2 of this submittal for a detailed justification.

2. The proposed change is consistent with the defense-in-depth philosophy. Traditional engineering considerations have been used to demonstrate this consistency.

The proposed Technical Specification changes preserve the existing balance between prevention of core damage, prevention of containment failure, and consequence mitigation by ensuring that AOTs are based upon the cumulative risk associated with the current plant configuration. The CRMP, in conjunction with the PRA, explicitly measures and accounts for the level of defense-in-depth from both an instantaneous and a cumulative basis. It considers plant design features, operating philosophy, and equipment capability. The ability of the CRMP to assess the level of defense-in-depth is a substantial technological improvement over current methods.

The risk assessment will adequately consider defense-in-depth, quantitatively in the PRA model and by a qualitative assessment of the specific configuration. For most plants, application of the risk assessment will allow sufficient extension of the frontstop time to meet station needs for maintenance and corrective action. Due to the availability of STP's third ESF train, in situations where TS 3.13.1 is applied, the CRMP will generally allow a significant extension of the frontstop completion time. However, for situations in which more than one Technical Specification SSC is inoperable, the AOTs will be similar in magnitude, and in some cases shorter, than existing AOTs.

Refer to Section 4 of this submittal for a detailed justification.

3. The proposed change maintains sufficient safety margin.

The AOT changes proposed represent a risk-neutral to risk-beneficial change. Therefore, sufficient margins are maintained as a result of the proposed changes. Since this is a risk-informed application, no change is proposed on design-basis features of the station.

There are no changes to plant safety limits or setpoints.

Refer to Section 4 of this submittal for a detailed justification.

4. The proposed change does not measurably change overall average core damage frequency for STP. In fact, the proposed change implements a mechanism to ensure any change from any modeled core damage contributor is identified and monitored.

Therefore, it can be stated that the proposed change itself does not significantly impact core damage frequency and is consistent with the Commission's Safety Goal Policy

Description of Changes and Safety Evaluation NOC-AE-04001666 Page 7 Statement. In fact, the proposed changes will ensure that AOTs are based on and evaluated against established risk thresholds consistent with the Safety Goal Policy.

Refer to Section 4 of this submittal for a detailed justification.

5. The impact of the change should be monitored using performance measurement strategies.

Changes to core damage frequency and cumulative risk associated with Technical Specification related equipment being out of service will continue to be monitored in accordance with the CRMP and Maintenance Rule Programs. Plant-specific performance indicators have already been identified and developed and have been in use for several years at STP.

Refer to Section 4 of this submittal for a detailed justification.

4. Technical Analysis (Back to Table of Contents)

STPNOC proposes to apply a risk-informed process to determine the AOT for a number of Technical Specifications. The risk-informed process would apply the CRMP to evaluate plant configurations and determine the time required for the risk to exceed the Potentially Risk-significant Threshold of 1.OE-05 and establish the AOT for the configuration based on that time. The action required by the TS must be taken if the Potentially Risk-significant Threshold is exceeded. The CRMP would require the plant to initiate action to manage risk levels that are at or above the Non-Risk-significant threshold (1.OE-06). Because of the low risk significance of a number of components in the Technical Specifications, the process includes a "backstop" maximum AOT of 30 days.

Compliance with Design and Licensing Basis STPNOC is proposing a risk-informed method for determining configuration based AOTs in lieu of Technical Specification LCOs.

The proposal does not include new plant design features, new operating parameters, new operating configurations, new design analyses, or new analytical assumptions. No new accidents are postulated and the mitigation for existing design-basis accidents is unchanged.

Table 2 describes basis for each of the requested changes and depicts the calculated times required to accrue risk to a 1.0E-5 incremental core damage probability (ICDP) threshold for the affected systems assuming no additional modeled systems are concurrently unavailable.

For single items, these times are longer than the AOTs in the existing Technical Specifications. The longer calculated times are a result of the robust design and redundancy typical of nuclear plants, coupled with the low likelihood of design-basis initiating events.

Table 2 demonstrates that the proposed changes can be managed to meet the acceptance criteria of RG 1.182.

Description of Changes and Safety Evaluation NOC-AE-04001666 Page 8 STPNOC will continue to manage its maintenance practices to maintain good material condition of plant components. STPNOC will not unnecessarily extend out-of-service times such that equipment availability and reliability are adversely affected or in conflict with Maintenance Rule requirements. Since 1996, STPNOC has been able to routinely quantify risk from maintenance configurations. In that time, STP's maintenance history has consistently kept configuration risk in a band with an ICDP < 1.0E-06. The recent Standby Diesel Generator 22 extended outage resulted in an ICDP of about 1.2E-06 when the installation of temporary non-safety diesel generators is credited in the analysis. STP equipment reliability and availability requirements will still meet licensing and design-basis requirements established by regulations such as 10CFR50.63, "Loss of all alternating current power", and 10CFR50.65, "Requirements for monitoring the effectiveness of maintenance at nuclear power plants."

The 30-day AOT backstop limit established in TS 3.13.1 provides further assurance that there is no significant challenge to the design and licensing basis from the longer AOTs.

Based on the assessment above, the extended AOT will not affect design-basis assumptions for equipment availability and STPNOC concludes the proposed change does not change the design and licensing basis for STP.

Defense-in-Depth Following the guidance provided in Regulatory Guide (RG) 1.77, the impact of the proposed Technical Specification change on the defense-in-depth is addressed below. Based on the following discussion, STPNOC has concluded that the proposed change meets the defense-in-depth principle.

A reasonablebalance among prevention of core damage,prevention of containmient failure,and consequence mitigation is preserved, i.e., the proposedchange in a TS has not significantly changed the balance among these principlesof prevention and mitigation, to the extent that such balance is needed to meet the acceptance criteriaof the specific design-basisaccidents and transients,consistent with 10 CFR 50.36. TS change requests should considerwhether the anticipatedoperationalchanges associatedwith a TS change could introduce new accidents or transientsor could increase the likelihood of an accident or transient (as is required by 10 CFR 50.92).

The proposed change represents a more robust technical approach that preserves a reasonable balance among prevention of core damage, prevention of containment failure, and consequence mitigation. STPNOC is proposing no changes to the design of the plant or any operating parameter. No new operating configurations are being proposed. The design-basis is not changed by the proposed changes to the Technical Specifications.

The effect of the change when it is implemented will be that the CRMP will allow AOTs to vary based on the risk significance of the given plant configuration (i.e. the amount of equipment removed from service at any given time). In cases where there are multiple components inoperable in more than one train, the calculated risk-informed AOT for the

Description of Changes and Safety Evaluation NOC-AE-04001666 Page 9 combination may be less than currently prescribed in the Technical Specifications. In many cases, the calculated AOT for a single component will be greater than what the Technical Specifications currently allow.

As discussed above, STPNOC's CRMP has shown that STPNOC's risk monitoring practices are effective. As another compensatory measure, proposed TS 3.13.1 establishes a 30-day limit on the AOTs for those components whose calculated AOTs are particularly long (the "backstop").

Over-relianceon programmaticactivities to compensatefor weaknesses in plant design is avoided, e.g., use of high reliability estimates that areprimarilybased on optimistic program assumptions The proposed application of a plant-specific CRMP to determine AOTs uses plant-specific operating experience for component reliability and availability data. Thus, the allowances permitted by the CRMP are directly reflective of actual component performance in conjunction with component risk significance. In some cases the CRMP may use compensatory actions to reduce calculated risk in some configurations. These compensatory actions may be incorporated in procedures, work instructions, or other station media. The high degree of redundancy at STP reduces the reliance that might otherwise be placed on operator action or other programmatic activities.

STP's design includes three trains of Engineered Safety Feature (ESF) equipment, which is a robust design. Table I compares the defense-in-depth of STP's three-train design to the two-train design for a comparable Westinghouse PWR. Table 2 provides additional detail with respect to STP's accident mitigation capability with fewer than three trains available. The AOTs shown for STP with two of three trains out of service are roughly what would be expected to apply for a two-train plant with one of two trains out of service. The table clearly shows that significant margin is retained for either a three-train or a two-train design. The Table 2 values used to support the backstop are in most cases based on change in core damage frequency. With the exception of functions that directly affect containment capability (e.g. containment on-line purge), changes in large early release frequency are less significant than the associated change in core damage frequency.

The Standard Technical Specifications for Westinghouse plants are written for standard plants with two trains of Engineered Safety Feature (ESF) equipment. For such standard plant designs, the safety functions are degraded (loss of single failure protection) when a single train of an ESF function is inoperable, and there is a loss of safety function when two trains of an ESF function are inoperable. At STP, however, when only one of the three ESF trains is inoperable, there is more margin than for a two-train plant during conditions where one of two ESF trains is inoperable. STP does not experience a complete loss of safety function when two of three trains of an ESF function are inoperable. Because of the third ESF train, it is reasonable for the probabilistic risk assessment calculations for STP to justify relatively long AOTs when one of three trains

Description of Changes and Safety Evaluation NOC-AE-04001666 Page 10 is inoperable, and a reasonable AOT for conditions where two of three trains are inoperable.

STPNOC proposes to apply the CRMP to determine the appropriate AOTs based on quantifying the risk associated with the plant configuration. The advantage of the CRMP is that it quickly and accurately assesses the relative significance of a given configuration, including those that involve multiple components in a single train or more than one train of equipment. The use of the CRMP proposed in this submittal is an effective method to determine the safety implications associated with multiple inoperable components. In addition, the combined CRMP enables the operator to identify the most effective actions (i.e., return to service priority) to take to restore the plant to a safer (i.e., less risk-significant) configuration and how prompt the corrective or compensatory action should be.

STP has structured its application for Risk-Informed Technical Specifications to incorporate the three train design concepts described above. The first entry in Table 2 outlines a general philosophy of a typical two-train plant and a three-train plant with risk-informed Technical Specifications. The time allowed to be in a condition with less than three trains operable is based on a reasonable time to restore operability and the capability of the remaining operable equipment. The STP Probabilistic Safety Assessment (PSA) shows that the risks incurred by the proposed AOTs are acceptable and consistent with guidance contained in the EPRI PSA Application Guide.

System redundancy, independence, and diversity are maintainedcommensurate wvith the expectedfrequency and consequences of challenges to the system, e.g., there are no risk outliers. The following items should be considered.

Whether there are appropriaterestrictions in place to preclude simultaneous equipment outages that would erode the principlesof redundancy and diversity, Application of the CRMP determines the risk significance of plant configurations. It also permits the operator to identify the equipment that has the greatest effect on the existing configuration risk. With this information, the operator can manage the out-of-service duration and determine the consequences of removing additional equipment from service. The application of the CRMP approach places high value on key safety functions and works to ensure they remain a top priority over all plant conditions.

Whether compensatory actions to be taken when entering the modified AOTfor pre-planned maintenanceare identified, Application of the CRMP provides a structure to assist the operator in identifying effective compensatory actions for various plant maintenance configurations to maintain and manage acceptable risk levels.

Description of Changes and Safety Evaluation NOC-AE-04001666 Page 11

WVIzether voluntary removal of equipmentfrom service duringplant operation should not be scheduled when adverse weather conditions arepredicted or at times when the plant may be subjected to other abnormal conditions, and The CRMP is based on STP's Level 1 and 2 PRA, including external events; thus, the calculated values for configuration risk include the effect of adverse weather conditions on average. Consideration of existing weather effects on specific plant configurations is accounted for in the risk-informed programmatic application of the CRMP and in the station's Severe Weather procedure. STPNOC typically considers the potential effect of weather on planned maintenance of components that could potentially be challenged during severe weather, such as Standby Diesel Generators, Turbine Driven Auxiliary Feedwater pump, and Switchyard. Compensatory measures are also taken at STP for adverse weather conditions in accordance with plant procedures (e.g., freeze protection, storm warnings and watches).

lWhether the impact of the TS change on the safety finction should be taken into consideration. Forexample, what is the impact of a change in the AOTfor the lolv-pressuresafety injection system on the overall availabilityand reliability of the low-pressure injectionfiunction?

Application of the CRMP incorporates the impact of the extended AOT on the availability and reliability of the affected plant-level safety functions and associated equipment. The effects will be quantified and traceable on the key figures-of-merit such as core damage frequency and large early release frequency. Managing to the actions required in proposed TS 3.13.1 and the risk-informed configuration management program will assure that the effects are known, small, and manageable.

Also, the balance of availability and reliability will also be monitored and corrected in accordance with the station's compliance with the Maintenance Rule.

In an extension of the CRMP beyond Initiative 4B, STP proposes to allow application of the CRMP to an emergent condition where more than one channel of instrumentation actuation logic is inoperable. This would allow the CRMP to be applied in conditions that previously would have required entry into TS 3.0.3.

The proposed action is a logical application of a configuration risk management program. TS 3.0.3 was created to address conditions where the other TS had no prescribed action; i.e., where the plant was in an undefined operating configuration.

Application of the CRMP specifically addresses that situation by defining the risk associated with the configuration and facilitating the determination of the correct response. TS 3.0.3 prescribes only one action - shutdown. Shutdown might not be the most appropriate action and application of TS 3.13.1 and the CRMP provides the means for the operator to take a more effective and safer course of action.

Description of Changes and Safety Evaluation NOC-AE-04001666 Page 12 Safety Margin In accordancewith RG 1.177, with suzffcient safety margins:

Codes and standardsor theiralternativesapprovedforuse by the NRC are met.

Safety analysis acceptancecriteria in the Licensing Basis (e.g., FSAR, supporting analyses) are met, or proposed revisionsprovide sz.fficient margin to accountfor analysis and data uncertainty.

Use of the CRMP to determine AOT will not affect STPNOC's commitment to the codes and standards used in the design of STP. STPNOC is not proposing in this application to change any quality standard, material, or operating specification. Acceptance criteria for operability of equipment are not changed.

The design-basis analyses for STP remain applicable. Although STPNOC will be able to have design-basis equipment out of service longer than the current Technical Specifications allow, the actual expected increase in unavailability will be insignificant with respect to design-basis assumptions regarding accident mitigation. In addition, an increase in reliability to offset any increase in unavailability would be expected.

In support of its application for the license amendment extending the AOT for the Standby Diesel Generators (approved in Amendments 85 and 72), STP evaluated the capabilities of a single train of ESF equipment to mitigate design-basis accidents.

Because the governing event is a condition where only one train of ESF equipment is postulated to be available, the analyses and evaluations performed in support of Amendments 85 and 72 are relevant to the evaluations of the changes to the AOTs being proposed in the Risk-Informed Technical Specifications. The results of the deterministic evaluation done in support of those amendments show that with only one train of ESF equipment available, and allowing for some operator actions, STP can mitigate nearly all design-basis events. The design-basis event that could not be mitigated is not considered credible (i.e., design-basis LOCA).

Table 3 depicts the capability described above for STP to mitigate design-basis accidents with only one of the three ESF trains available, such as might be postulated if a design-basis accident and worst single failure were to occur with one entire train unavailable.

This is a very conservative assumption because it imposes single failure while the plant is in an ACTION statement. Were the single failure not considered, there would be no reduction in mitigation capability. The table shows that there is a substantial margin of safety.

Proposed TS 3.13.1 also helps protect the margin of safety by preventing operation for extended periods in a configuration where a single failure would cause the loss of function of a system required to mitigate a design-basis accident. Effective and timely maintenance practices will limit the time that any train of accident mitigation equipment is unavailable such that having even one train of ESF equipment out of service for 30

Description of Changes and Safety Evaluation NOC-AE-04001666 Page 13 days (assuming a system or component where that duration is permitted by the CRMP) is expected to rarely occur. In addition, compliance with Maintenance Rule requirements and availability and reliability standards from the Revised Reactor Oversight Program will limit the time any required equipment is out of service.

5. Regulatory Safety Analysis 5.1 No Significant Hazards Determination (Back to Table of Contents)

The following changes to the Technical Specifications are included in the proposed license amendment:

Proposed new TS 3.13.1 for AOTs to be determined by a risk-informed configuration risk management program and associated changes to the specific specifications that will applyTS 3.13.1

Proposed changes to certain ACTION statements in Instrumentation TS 3.3 to delete AOTs specific to the instrument and instead to apply the required ACTION for the actuated component or system

Proposed changes to certain ACTION statements in individual specifications to allow the application of the CRMP in accordance with the new TS 3.13.1.

In accordance with the criteria set forth in 10CFR50.92, the STP has evaluated these proposed Technical Specification changes and determined they do not represent a significant hazards consideration. The following is provided in support of this conclusion.

1. Does the proposed change to the Technical Specifications involve a significant increase in the probability or consequences of an accident previously evaluated?

The proposed changes to the Technical Specifications to add a new TS 3.13.1 and to change specific TS to apply the new TS 3.13.1 do not involve a significant increase in the probability of an accident previously evaluated because the changes involve no change to the plant or its modes of operation. In addition, the risk-informed configuration management program will be applied to effectively manage the availability of required systems, structures, and components to assure there is no significant increase in the probability of an accident. These proposed changes do not increase the consequences of an accident because the design-basis mitigation function of the affected systems is not changed and the risk-informed configuration management program will be applied to effectively manage the availability of systems, structures and components required to mitigate the consequences of an accident. The application of the risk-informed configuration management program is considered a substantial technological improvement over current methods.

Therefore, none of the proposed changes involve a significant increase in the probability or consequences of an accident previously evaluated.

-- : Description of Changes and Safety Evaluation NOC-AE-04001666 Page 14

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

None of the proposed changes involve a new mode of operation or design configuration. There are no new or different systems, structures, or components proposed by these changes. Therefore, there is no possibility of a new or different.

kind of accident.

3. Does the proposed change to the Technical Specifications involve a significant reduction to a margin of safety?

Proposed new TS 3.13.1 and the associated changes to the specifications that apply the new TS 3.13.1 implement a risk-informed configuration management program to assure that adequate margins of safety are maintained. Application of these new specifications and the configuration management program considers cumulative effects of multiple systems or components being out of service and does so more effectively than the current Technical Specifications. Therefore, application of these new specifications will not involve a significant reduction in a margin of safety.

Based on the evaluation above, none of the proposed changes involve a significant reduction in a margin of safety.

Description of Changes and Safety Evaluation NOC-AE-04001666 Page 15 5.2 Applicable Regulatory Criteria (Back to Table of Contents)

The proposed changes will revise the AOTs associated with selected specifications so that they will be managed in accordance with a risk-informed configuration risk management programinstead of having a prescriptive time in the specification. As discussed below, this change in format and AOT management still incorporates the elements required by 10CFR50.36 for Technical Specifications.

IOCFR50.36 requires that Technical Specifications contain limiting conditions for operation (LCOs). The changes proposed will retain the LCOs. The current LCOs associated with the specifications to be changed include ACTION statements that require shutdown if required conditions are not met in a specified time. 10CFR50.36 requires that: "When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met." STPNOC is proposing to change the specifications to allow for a risk-informed process for determining required remedial action. The mechanism for STPNOC's change is a new TS 3.13.1 that establishes a risk-informed configuration management program for determining required actions and AOTs, up to a 30-day limit.

Individual LCOs will indicate if TS 3.13.1 is applicable. Consequently, the provisions of 10CFR50.36 are met with the proposed TS 3.13.1.

STPNOC is not proposing changes that remove existing LCOs or which affect the 10CFR50.36 requirements for Safety Limits, Surveillance Requirements, Design Requirements, or Administrative Controls.

The proposed change complements recent changes to 10CFR50.65 requiring licensees to assess and manage risk associated with removing equipment from service for maintenance.

The risk-informed configuration management program used to determine the AOT of the Technical Specifications also meets the requirement of 10CFR50.65(a)(4) for performing a risk assessment for equipment removed from service for maintenance.

As discussed in the section below, STPNOC is not proposing to change the design or licensing basis for STP. Compliance with other design-basis regulations (e.g., 10CFR50.49, 10CFR50.46) or the General Design Criteria is not changed.

Based on the discussion above, STPNOC concludes that the proposed changes to the LCOs to eliminate the specified required ACTION times and replace them with application of TS 3.13.1 is in compliance with regulatory requirements.

Description of Changes and Safety Evaluation NOC-AE-04001666 Page 16 6.0 Environmental Assessment (Back to Table of Contents)

This proposed Technical Specification change has been evaluated against the criteria for and identification of licensing and regulatory actions requiring environmental assessment in accordance with 10CFR51.21. The proposed changes meet the criteria for categorical exclusion as provided for under 10CFR51.22 (c) (9). The following is a discussion of how the proposed Technical Specification change meets the criteria for categorical exclusion.

10CFR51.22 (c) (9). Although the proposed change involves changes to requirements with respect to the use of a facility component, (i) the proposed change involves no Significant Hazards Consideration (refer to the No Significant Hazards Consideration section of this Technical Specification Change Request),

(ii) there is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite since the proposed changes do not change the assumptions regarding generation of any radioactive effluents nor do they affect any of the permitted release paths, and (iii)there is no significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed change meets the eligibility criteria for categorical exclusion set forth in 10CFR51.22 (c)(9). Based on the aforementioned and pursuant to 10CFR51.22 (b),

no environmental assessment or environmental impact statement need be prepared in connection with issuance of an amendment to the Technical Specifications incorporating the proposed changes of this request.

Description of Changes and Safety Evaluation NOC-AE-03001466 Page 17 Table I General Case: Three-Train Design TS Requirements SystemJCondition, Standard Twoi- CurrentSTP Proposed iP Rlsk- Safet Evaluation C-,oments,

Train Specification 'Specification, Informed -

-- Specifications,: .. .

All Trains Operable Unlimited Unlimited Unlimited Two train and three train plants meet design-basis, Including single failure criterion.

1 Train Inoperable 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months (typ.) 7 days (typ.) As determined by the 2-train plant: no loss of safety Application of the CRMP CRMP function, but does not meet single recognizes the defense-in-depth failure criterion. capabilities and limitations and provides reasonable time and STP (3 trains): no loss of safety technical basis to take corrective function; meets single failure actions. CRMP also takes into criteria in most cases. account Integrated plant Impacts including unavailability of multiple systems, thereby performing the function of a Safety Function Determination Program.

2 Trains Inoperable T.S 3.0.3 or T.S. 3.0.3 or As determined by the 2-train Wlant: loss of safety Application of the CRMP equivalent equivalent (typ.) CRMP function. Application of CRMP recognizes the capabilities and recognizes plant level functional limitations and provides reasonable redundancy in safety systems and time to take corrective actions.

the low probability of an initiating CRMP also takes into account event requiring two trains for unavailability of multiple systems, mitigation. Some time to restore thereby performing the function of the Inoperable function is a Safety Function Determination appropriate based on the very low Program.

probability of an initiating event while in this configuration. Because STP typically has no action for 2 inoperable trains, TS STP (3 trains): loss of safety 3.0.3 applies and this extends function only for specific low Initiative 4B to cover Initiative 6 for probability events (see details these configurations.

below and Table 3). Retains safe shutdown capability for non-accident conditions. A risk-informed AOT is appropriate.

3 Trains Inoperable NA T.S. 3.0.3 or As determined by the Loss of safety function Some time to restore the equivalent CRMP Inoperable function is appropriate based on the very low probability of an initiating event while in this configuration. (RITS Initiative 6)

Attachment 1: Description of Changes and Safety Evaluation NOC-AE-0300 1466 Page 18 Table 2 Detailed Description of Changes and Basis

'; Specifcation - Old Action Requirem ent New Action Requirement Technical Dlscussion and Comments' Risk asis RITS Number ' : Calculated STP' Initiative

- AOT Before,

-Backstop ..

______________________ __________________________ base case)1' With the number of OPERABLE With the number of OPERABLE The reactor trip breaker motor control center >10 yrs. 4B, 6 3.3.1.20 channels one less than the channels less than the Minimum can be de-energized from the control room to 30 d

.3.1. Minimum Channels Channels OPERABLE requirement, assure reactor trip. TS 3.13.1 would allow (30 day RTBs OPERABLE requirement, be in within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months be Inat least HOT STP operators to take compensatory action, backstop) at least HOT STANDBY within STANDBY or apply the requirements such as determining that one of the channels Action 9 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ; however, one channel of Specification 3.13.1; however, one Isfunctional.

may be bypassed for up to 2 channel may be bypassed for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing hours for surveillance testing per per Specification 4.3.1.1, Specification 4.3.1.1, provided the provided the other channel Is other channel Is OPERABLE OPERABLE.

Description of Changes and Safety Evaluation NOC-AE-0300 1466 Page 19 Table 2 Detailed Description of Changes and Basis Specification Old Action Re~quirement -7..,,New Action Requirement ~ Technical Discussilon and Comments Risk Basis , RITS, Number 'Clulae T ntaie I -,'AOT Before:

_________ 1 . (base ca'se~tl2 With the number of OPERABLE ACTION 9A Is split into 9A.a for one There are two channels for these functions. 484 days for one 4B3, 6 3...8channels one less than the Inoperable channel and 9A.b for more With only one channel Inoperable, the other channel (train) of 3...8Minimum Channels than one Inoperable channel. channel will be available to perform the SSPS to be EASIIptfo thequinprabemchnnel rPEstRABE a. With the number of OPERABLE function. With both channels inoperable, the inoperable/non-estreth canelproposed ESFSInpeabe change retains the time limits functional to OPERABLE status within 24 channels one less than the Minimum consistent with TS 3.0.3 that would apply to (3dabckso 3.3.1.21 hours, or be in at least HOT Channels OPERABLE requirement, current TS with more than one inoperable (0dybcso Automatic Tfl STANDBY Within the next 6 within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months restore the inoperable channel. However, the operators would be applies) and Interlock' hours; however, one channel channel to OPERABLE status, or allowed to apply TS 3.13.1 if there is an If one channel Logic may be bypassed for up to 4 apply the requirements of Specification adequate compensatory action or if the (train) Is hours for surveillance testing 3.13.1, or be In at least HOT channel Is still functional (e.g. Inoperable only inoperable and Action 9A per Specification 4.3.1.1, STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ; for seismic considerations). the other Is non-provdedtheothe chnne Is however, one channel may be fntoate OPERovidEd.h tecanl bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months forPRanlsswl PEAE.surveillance testing per Specification PRA analyised will 4.3.1.1, provided the other channel Is bexarpequrd Fo OPERBLE.Inoperable only b.With the number of OPERABLE for seismic, a channels more than one less than the PRA analysis Minimum Channels OPERABLE can be requirement, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore at performed to least one inoperable channel to demonstrate the OPERABLE status or apply the risk associated requirements of Specification 3.13.1, with this event.

or be Inat least HOT STANDBY

_ ____ _____ ____ _____ ____ w ithin the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

Description of Changes and Safety Evaluation NOC-AE-03001466 Page 20 Table 2 Detailed Description of Changes and Basis Specification ; OldAcilon Requiremnent Ne Action Requirement Tec hnical Dslc us i n and Co e Risk Basis RITS Number .Caicuiated STP: Initiative AOT Before;,

-' - - -Backstop,

_ _ _ __ _ _ __ _ __ __ __ __ _ __ __ _ _ _ __ __ _ _ _ _ __ _ _ __ _ _ __ _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _ __ _ __ _ __ _ _ _ _ _ _ _ _ _a asb ecc ss e 1_ __ _ _ __

3.3.2.1.b -SI Automatic With the number of OPERABLE ACTION 14 is split Into 14.a for one Except for the actuation relays, there are two 3.3.2.1.b - Same 4B, 6 Actuation Logic channels one less than the inoperable channel and 14.b for more channels for each of these functions. With result as 3.3.2.1.c - SI Minimum Channels than one Inoperable channel. only one channel inoperable, the other 3.3.1.18, SI Input Actuation OPERABLE requirement, channel will be available to perform the (30 day backstop restore the inoperable channel a. With the number of OPERABLE function. Manual action is also available to applies)

Relays channels one less than the Minimum 3.3.2.2.b - CS to OPERABLE status within 24 perform the function. For one inoperable hours, or be in at least HOT Channels OPERABLE requirement, channel, the existing frontstop of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is Automatic within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months restore the inoperable Actuation Logic STANDBY within the next 6 adequate time to perform an assessment of 3.3.2.2b, hours and In COLD channel to OPERABLE status, or the condition and determine the appropriate apply the requirements of Specification 3.3.2.3.a.2, SHUTDOWN within the action and AOT. 3.3.2.3.c.1, no 3.3.2.2.c 3.13.1, or be In at least HOT CS Actuation following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months ; however, measurable one channel may be bypassed STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and For the actuation relays, there are three Relays In COLD SHUTDOWN within the channels, each associated with its ESF train. Impact on CDF for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for or LERF (30 day surveillance testing per following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months ; however, one Actuation of either of the two trains of 3.3.2.3.a.2 - channel may be bypassed for up to 4 actuation logic will actuate all three ESF backstop applies)

Containment Specification 4.3.2.1, provided the other channel is hours for surveillance testing per trains. STP can mitigate nearly all design-Phase A Specification 4.3.2.1, provided the basis accidents with a single ESF train.

Isolation OPERABLE. Same as other channel is OPERABLE.

Automatic With more than one channel inoperable, the 3.3.1.18 and Actuation Logic b. With the number of OPERABLE proposed time limits reflect the same 3.3.1.21 3.3.2.3.a.3 - channels more than one less than the allowance that application of TS 3.0.3 would Containment Minimum Channels OPERABLE provide for the existing TS. With both Phase A requirement, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore at channels Inoperable, application of TS 3.13.1 Isolation least one inoperable channel to will allow the operators to determine if there Is Actuation OPERABLE status or apply the a suitable compensatory action. Manual Relays requirements of Specification 3.13.1, action is generally timely for most accidents or be in at least HOT STANDBY that would require actuation of these 3.3.2.3.c.1 within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and In COLD functions Phase B SHUTDOWN within the following 30 Isolation hours Automatic Actuation Logic 3.3.2.3.c.2 Phase B Isolation Actuation Relays Action 14 h I I J. L

Description of Changes and Safety Evaluation NOC-AE-03001466 Page 21 Table 2 Detailed Description of Changes and Basis wAtequirement- Jehrl~l isu R'Risk Basis ' RiTS Old Action iNe

uSpecification; Action equirementTon and Comments Number. -,. - - - Calculated STP Initiative

.- . AOT Before

eBackstop

_ _ _ _ __ _ __ __ __ _ __ __ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ (b ase 6a se)i' CS on Existing Action (to be Action a.): b.With the number of OPERABLE The current requirement would be retained as 1 channel: 4B, 6 Con channels more than one less than Action a.and a new Action b. that applies TS Containment With the number of OPERABLE the Total Number of channels, 3.13.1 is added for conditions where more >10 yrs.

Total Number of Channels, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months apply the than one channel is inoperable. The 3.3.2.3.c.3 place the Inoperable channel In requirements of Specification 3.13.1 actuation logic for the subject functions is 2/4, Containment the bypassed condition within or be in at least HOT SHUTDOWN which allows a relatively high degree of (30 days Isolation Phase 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , or be in at least HOT within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . redundancy. Application of TS 3.13.1 would backstop) permit the use of compensatory actions such B on Containmt hST anB Within STANDBY in the HT athleast next 6 as placing an inoperable channel in trip. The Containment hours and at in least HOT proposed 1hour frontstop time for ACTION b.

Pressure Hi-3 SHUTDOWN within the is consistent with TS 3.0.3 that currently following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . One applies for this condition and is conservative Action 17 b. additional channel may be with respect to the safety significance.

(New Action) bypassed for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for surveillance testing per Specification 4.3.2.1.

Description of Changes and Safety Evaluation NOC-AE-03001466 Page 22 Table 2 Detailed Description of Changes and Basis Specification Oi Action Requirement New Action Requirement Technical Discussion and Comments-; Risk Basis , RITS ;

Number - - -I Calculated STP Initiative

,- * . : '!AOT Before,

- - aBackstop 3.3.2.1.a With the number of OPERABLE Split into ACTION 19.a and 19.b. Automatic initiation of these functions is the 1 channel: >10 4B, 6 SI Manual channels one less than the A.LE primary initiation process. Inaddition, SI and yrs.

Initiation Minimum Channels a.With the number of thPERABL CS can be manually aligned and started from OPERABLE requirement, channels one less than the Minimum the control room. The most critical systems 3.3.2.2.a restore the inoperable channel Channels OPERABLE requirement, for containment isolation are those that could (30 day CS Manual to OPERABLE status within 48 within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months restore the inoperable be open to the atmosphere, which is backstop)

Initiation hours or be in at least HOT channel to OPERABLE status or apply generally limited to the normally closed RCB STANDBY within the next 6 the requirements of Specification purge. For most design-basis events, manual 3.3.2.3.a.1 hours and in COLD 3.13.1,or be in at least HOT STANDBY alignment is adequate for mitigation. A 48 Containment SHUTDOWN within the within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD hour frontstop time for one Inoperable Isolation Phase following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . SHUTDOWN within the following 30 channel iscommensurate with the risk-A- manual hours. significance of the condition. A l hour Initiation b.With the number of OPERABLE frontstop for more than one inoperable channels more than one less than the channel isconsistent with TS 3.0.3 that would Action 19 Minimum Channels OPERABLE apply to the current TS.

requirement, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore the inoperable channel to OPERABLE status or apply the requirements of Specification 3.13.1, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and In COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

Switchover to With the number of OPERABLE With the number of OPERABLE 19A better reflects the one channeltrain 1channel: 246 NA Contaimen t channels one less than the channels one less than the Minimum configuration and logic of this instrumentation days (30 day ontanmenp Minimum Channels Channels OPERABLE requirement, than the proposed change to Action 19. 48 backstop) based 3S3u2m: OPERABLE requirement, within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months restore the inoperable hours is an adequate frontstop time to identify on switchover A.u.t.a restore the Inoperable channel channel to OPERABLE status or apply appropriate compensatory action and apply function in PRA Actuation Logic to OPERABLE status within 48 the requirements of Specification TS 3.13.1 and Actuation hours or be in at least HOT 3.13.1, or be in at least HOT STANDBY within the next 6 STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and Relays hours and in COLD in COLD SHUTDOWN within the 3.3.2.7.b SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

le Tlow level following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

Action 19 to new Action 19A

Description of Changes and Safety Evaluation NOC-AE-03001466 Page 23 Table 2 Detailed Description of Changes and Basis

t .

1

'; '_ '_.'_ :' "'_Oid Specifiction

~ ,'

~

Act;-ion ; .*

I _

. i' "-

' ", 'adomm-

' ,' j AOT Before*

aRiskc;Basis s.e')1 RiTS Loss of power ACTION 20: New ACTION 20A: These instruments do not have Installed The risk basis is 4B, 6 bypass capability, so only original ACTION bounded by the 3.3.2.8.a a. With the number of OPERABLE 20 b. is relevant. evaluation done With the number of OPERABLE channels one less than the Total for inoperable 4.16kV ESF channels one less than the Total There are four channels for each of the Bus Number of Channels, STARTUP standby diesel Number of Channels, STARTUP and/or POWER OPERATION may functions with a 2/4 actuation logic.

Undervoltage - generators in TS and/or POWER OPERATION proceed provided the following Consequently, the function remains capable Loss Of may proceed provided the 3.8.1.1.

conditions are satisfied: of actuation as long as there are at least two Voltage following conditions are operable channels.

satisfied: 1.The inoperable channel Is placed In the tripped condition within 72 The consequences of the function not being 3.3.2.8.b. a. For Functional Units with hours, and capable of actuating is that a single train of installed bypass test capability, emergency ESF power will not start in the 4.16kV ESF the inoperable channel may be event of a transient or accident that involves Bus Under placed in bypass, and must be 2.The Minimum Channels a loss of off-site power. The two remaining Voltage - placed in the tripped condition OPERABLE requirement is met; trains provide adequate mitigation capability.

Tolerable within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . however, the inoperable channel Degraded may be bypassed for up to 12 The one-hour AOT for more than one Voltage Note: A channel may be hours for surveillance testing of Inoperable channel Is consistent with Coincident With bypassed for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months other channels. application of the current TS, which requires Si for surveillance testing per the application of TS 3.0.3.

Specification 4.3.2.1, provided b. With the number of OPERABLE no more than one channel Is channels more than one less than the In bypass at any time. Total Number of Channels, within 1 3.3.2.8.c hour apply the requirements of 4.16 kV ESF b. For Functional Units with no Specification 3.13.1, or be in at least Bus Installed bypass test capability, HOT STANDBY within the next 6 Undervoltage - hours and be in at least HOT Sustained 1. The inoperable channel is SHUTDOWN within the following 6 Degraded placed in the tripped condition hours, and be in COLD SHUTDOWN within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , and within the subsequent 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Voltage ACTION 20 2. The Minimum Channels replaced with OPERABLE requirement is new ACTION met; however, the inoperable 20A channel may be bypassed for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for surveillance testing of other channels per Specification 4.3.2.1.

J J. I

Description of Changes and Safety Evaluation NOC-AE-03001466 Page 24 Table 2 Detailed Description of Changes and Basis Specification- Old Action Requirement New Action Requirement i Technical Dscussion and Comments ' RIsk Basis RITS Number. . Calculated STP; Initiative AOT Before..

Backstop

.__x _ - _

_ __ __ __ - _ - _ - _ - _ - _ ; _ (base case)1 3.3.2.4.b With the number of OPERABLE Split Action 22 Into 22.a. and 22.b. Steam line isolation has 2 channels, either of 3.3.2.4.b 4B, 6 channels one less than the which will Initiate the isolation function. With Steam Line MinimumsChaenels a. With the number of OPERABLE whichannel inoperable, the other channel is 1 channel: >10 Isolation OPERABLE requirement, channels one less than the Minimum available to initiate the function. With one yrs.

Automatic restore the Inoperable channel Channels OPERABLE requirement, channel inoperable, 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months provides time to Actuation Logic to OPERABLE status within 24 within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months restore the inoperable restore the channel or identify compensatory and Actuation hours, or be in at least HOT channel to OPERABLE status or apply action that will allow the operator to apply TS (30 day Relays STANDBY within the next 6 the requirements of specification 3.13.1. With both channels inoperable, the backstop) 3.3.2.6.b hours and in at least HOT 3.13.1, or be in at least HOT one hour action time isconsistent with the SHUTDOWN within the STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and requirements of TS 3.0.3 that currently Auxiliary following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ; however, one in at least HOT SHUTDOWN within applies and provides operators with an option 3.3.2.6.b Feedwater channel may be bypassed for the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ; however, one to Identify a compensatory action or1chne>0 Automatic up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance channel may be bypassed for up to 4 determine that a degraded channel may have 1channel>10 Actuation Logic testing per Specification 4.3.2.1 hours1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months for surveillance testing per sufficient functionality to extend the AOT. yrs.

provided the other channel is Specification 4.3.2.1 provided the (30 day

.c OPERABLE. other channel is OPERABLE. The AFW automatic actuation logic and backstop)

Auxiliary b. With the number of OPERABLE actuation relays are trainospecific and TS Feedwater channels more than one less than the 3.13.1 may be applied to provide AOTs that Actuation Minimum Channels OPERABLE are consistent with the AOT for the AFW 3.3.2.6.c Relays requirement, within one hour restore at train(s) made Inoperable by the Inoperable3.

Action 22 least one inoperable channel to days,.Train B 3 6 OPERABLE status or apply the days train B 736 requirements of specification 3.13.1, or days, train C 502 be in at least HOT STANDBY within 6 days hours and in at least HOT (30 day SHUTDOWN within the following 6 backstop) hours.

Description of Changes and Safety Evaluation NOC-AE-03001466 Page 25 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement ; ew Acton Require ment Technical Discssion and Comments : Risk Basis. RITS Number: - Calculated STP.' Initiative

. ': - . AOT Before

- - Backstop

_____ _________ ____ ____(b a se case )l _ _ _ _

3.3.2.5.a With the number of OPERABLE Split Action 25 into 25.a and 25.b. There are two channels for these functions. 1 channel: 30 4B, 6 Turbine Trip channels one less than the a. With the number of OPERABLE With only one channel inoperable, the other days (backstop) and FW MnmmCanlchnesoelsthnteMium channel will be available to perform the (omaual Isolation OPERABLE requirement, Channels OnEl than the Minimum function. With both channels inoperable, Ts Nmeasurable Automatic restore the inoperable channel Channels OPERABLE requirement, 3.13.1 will allow the operators to determine if impact on CDF)

Lgc to OPERABLE status within 24 wihn2 or etr h nprbe there is a suitable compensatory action to Actuation Logic hours, or be In at least HOT channel to OPERABLE status, or manage the risk.

and Actuation STANDBY within the next 6 apply the requirements of Specification Relays hours; however, one channel 3.13.1, or be in at least HOT A one-hour frontstop for more than one Action 25 may be bypassed for up to 4 STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ; inoperable channel is consistent with TS hours for surveillance testing however, one channel may be 3.0.3 that would apply to the current TS.

per Specification 4.3.2.1 bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for provided the other channel Is surveillance testing per Specification OPERABLE. 4.3.2.1 provided the other channelis OPERBLE.OPERABLE.

b. With the number of OPERABLE channels more than one less than the Minimum Channels OPERABLE requirement, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore at least one inoperable channel to OPERABLE status or apply the requirements of Specification 3.13.1, or be In at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

Description of Changes and Safety Evaluation NOC-AE-03001466 Page 26 Table 2 Detailed Description of Changes and Basis Specification -Old Action Requirement . New Action Requirement TeShnical Dicusson andComm n Rsk Basis .RT Number; . , . Caiculated. STP. *initiat've Backstop.

j

,1 ... . --

_ _ _ _ _ _ _ _ _ _ (base c ase )1. _ _ _

3.3.5.1 Reword Actions 2.a and 2.b to In Action 2, the Inoperability of the instrument >10 yrs. NA

a. With one less than the reference TS 3.13.1, and add new makes the associated equipment Inoperable Atmospheric Action 2.c for condition where more and the appropriate action is to enter the TS (30 day Steam Relief required number of backstop) than two channels are Inoperable. for that equipment. The proposed changes Valve OPERABLE channels, restore the Inoperable channel to to allow the application of TS 3.13.1 In Action Instrumentation a. With one less than the required 2 will permit operators to apply AOTs to the OPERABLE status within 7 Action 2 number of OPERABLE channels, actuating instrumentation that are consistent days; or be in at least HOT within 7 days restore the inoperable with the AOTs for the actuated AFW STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . channel to OPERABLE status or equipment.

apply the requirements of

b. With two less than the Specification 3.13.1; or be in at least HOT STANDBY within the next 6 required number of OPERABLE channels, restore at least three hours.

channels to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ; or be in at least b. With two less than the required HOT STANDBY within the next number of OPERABLE channels, 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months restore at least three channels to OPERABLE status or apply the requirements of Specification 3.13.1; or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

c. With more than two less than the required number of OPERABLE channels, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore at least two channels to OPERABLE status or apply the requirements of Specification 3.13.1; or be In at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

Description of Changes and Safety Evaluation NOC-AE-03001466 Page 27 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement - :: NewAction Requirement :- .Techncal Discussion and Comments', Ri Basis .; RITS.

Number Calculated STP iInitiative:

, .. .,. , ; .ore

-* ,. . Backstopc

- (asecase)1; 3.4.2.2 With one pressurizer Code With one or more pressurizer Code Pressurizer power-operated relief valves and 1 Inoperable 4B, 6 safety valve Inoperable, either safety valves inoperable, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months pressurizer spray also provide overpressure safety relief Pressuafzer restore the inoperable valve to either restore the inoperable valve(s) protection. PORVs would normally provide valve: >10 yrs.

Code Safety OPERABLE status within 1 to OPERABLE status or apply the relief such that Code safety valves would not Valves hour or be in at least HOT requirements of Specification 3.13.1, be expected to lift. The one-hour requirement (30 day STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in or be in at least HOT STANDBY is consistent with the current TS which would backstop) at least HOT SHUTDOWN within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in at least HOT require application of TS 3.0.3.

within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

3.4.4 With one PORV inoperable due With one PORV inoperable due to Application of TS 3.13.1 will allow an One Inoperable 4B Pressurizer to causes other than excessive causes other than excessive seat assessment of the functionality of the PORV PORV: 352 days PORVs and seat leakage, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months leakage, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months either restore and an assignment of an AOT that reflects Associated either restore the PORV to the PORV to OPERABLE status or the actual plant condition. The redundant (30 day Associated OPERABLE status or close the close the associated block valve and PORV is still operable to perform the required backstop)

Block Valves associated block valve and remove power from the block valve; safety functions. The pressurizer safety remove power from the block within the following 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months restore valves are still available for design-basis valve; restore the PORV to the PORV to OPERABLE status or overpressure relief.

Action b. OPERABLE status within the apply the requirements of Specification following 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be In HOT 3.13.1, or be In HOT STANDBY within STANDBY within the next 6 the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT hours and InHOT SHUTDOWN SHUTDOWN within the following 6 within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . hours.

3.4.4 With both PORVs inoperable With both PORVs inoperable due to Overpressure protection is still provided by Both PORVs 4B due to causes other than causes other than excessive seat the Code safety valves and pressurizer spray inoperable: 349 Pressunzer excessive seat leakage, within leakage, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months either restore at is still available for response to normal days PORVs and 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months either restore at least least one of the PORVs to OPERABLE pressure fluctuations. (30 day Associated one of the PORVs to status or close their associated block (ay Block Valves OPERABLE status or close valves and remove power from the backstop) their associated block valves block valves and apply the and remove power from the requirements of Specification 3.13.1, Action c. block valves and be in HOT or be in HOT STANDBY within the STANDBY within the next 6 next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and HOT SHUTDOWN hours and HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

Description of Changes and Safety Evaluation NOC-AE-03001466 Page 28 Table 2 Detailed Description of Changes and Basis Specif tion' Rdiequirement New Action Requirement Techni al Dlscusslon and Comments. Risk'Basis ' IRITS Number Calculated 'STP Initiative "AOT ;Before 2" I Backstop

__________ ___________________________ (ba'se case 1:1 3.4.4 With one block valve With one block valve inoperable, within The existing required action makes no >10 yrs. 4B Pressurizer Inoperable, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore the block valve to distinction regarding the degree of Presuridr restore the block valve to OPERABLE status or place its functionality of the block valve. A degraded (30 day PORVs and operable status or place its associated PORV in closed position; block valve may be able to perform its backstop)

Block Valves associated PORV in closed within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months restore the block valve expected function.

position; restore the block valve to OPERABLE status or apply the to operable status within 72 requirements of Specification 3.13.1; A minor administrative fonmat change is hours; otherwise, be in at least otherwise, be in at least HOT made to put OPERABLE in all capital letters.

Action d. HOT STANDBY within the next STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT in HOT SHUTDOWN within the SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

3.4.4 With both block valves With both block valves inoperable, The existing requirement for restoration of >10 yrs. 4B Pressurizer inoperable, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore the block valves operability within one hour is inadequate time (30 day PORVs and restore the block valves to to OPERABLE status or place the to take reasonable action. backstop)

Associated operable status or place the associated PORVs in the closed backstop)

Block Valves associated PORVs in the position; restore at least one block A minor administrative format change is closed position; restore at least valve to OPERABLE status within the made to put OPERABLE in all capital letters.

one block valve to OPERABLE next hour or apply the requirements of status within the next hour, Specification 3.13.1; otherwise, be in Action e. otherwise, be Inat least HOT at least HOT STANDBY within the next STANDBY within the next 6 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN hours and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

Description of Changes and Safety Evaluation NOC-AE-03001466 Page 29 Table 2 Detailed Description of Changes and Basis Specification Old Acilon Requiremen New Action ent " Tehncal Discus sion-and Comments ' '

iequire ;

Risk Basis '-RITS "Number Calculated' STP' Initiative, I ', ' -AOT Before

. - I -, -Backstop*

3.5.1 With one accumulator With one or more accumulators The accumulators would only be expected to 1 Inoperable 4B, 6 Safety Injection Inoperable, except as a result of Inoperable, except as a result of boron be used for the most unlikely accidents. An accumulator Stem o boron concentration outside the concentration outside the required assessment can be performed to determine 2700 days System required limits, restore the limits, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore the the significance of the condition and if Accumulators inoperable accumulator to Inoperable accumulator(s) to compensatory actions are necessary. The bU akt OPERABLE status within 24 OPERABLE status or apply the one-hour requirement is a conservative time ackstop) hours or be in at least HOT requirements of Specification 3.13.1, considering the low risk significance of these 2 Inoperable Action a. STANDBY within the next 6 or be in at least HOT STANDBY components and is consistent with TS 3.0.3 accumulators:

hours and reduce pressurizer within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and reduce which would apply for more than one 360 days pressure to less than 1000 psig pressurizer pressure to less than 1000 inoperable accumulator in the current TS. It within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . psig within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . Is more restrictive than the 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months currently (30 day permitted for one Inoperable accumulator, backstop) however, STPNOC would likely 'pre-assess" the inoperable accumulator In the CRMP.

3.5.1 With the boron concentration of With the boron concentration of one or Accumulator boron concentration deviations Although boron 4B, 6 one accumulator outside the more accumulators outside the required are not likely to be significantly outside concentration Is Safety injection required limit, restore the boron limit, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore the boron required limits. Conservatism In the accident not specifically System concentration to within the concentration to within the required analysis provides reasonable assurance that modeled, the Accumulators required limits within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months limits or apply the requirements of the accumulators would still provide their evaluation for the or be In at least HOT Specification 3.13.1, or be in at least required function even with concentration availability of the STANDBY within the next 6 HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months outside the limits. The one-hour requirement is accumulator in Action b. hours and reduce pressurizer and reduce pressurizer pressure to less a conservative time considering the low risk ACTION a.

pressure to less than 1000 psig than 1000 psig within the following 6 significance of these components and Is applies for this within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . hours. consistent with TS 3.0.3 which would apply for condition.

more than one accumulator with boron concentration out of limit in the current TS. It is more restrictive than the 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months currently permitted for one accumulator with boron concentration out of limit; however, STPNOC would likely "pre-assess" the inoperable accumulator in the CRMP. -

Description of Changes and Safety Evaluation NOC-AE-03001466 Page 30 Table 2 Detailed Description of Changes and Basis Specification Old Action R Tme' echnica Discussi nd Comment R:Isk Basis .. TS Number Calcuiated, STP nitaive AOT Before~

- - - -Backsto 3.5.2 With less than the above With less than the above subsystems With 1 inoperable train of SI, there is no loss 1 Inoperable train 4B ECCS in subsystems OPERABLE, but OPERABLE, but with at least two High of safety function, and STP meets single Train A 190 MODES 1,2, & with at least two High Head Head Safety Injection pumps in an failure except for specific low probability days, train B 3 Safety Injection pumps in an OPERABLE status, two Low Head events. 2087 days, train OPERABLE status, two Low Safety Injection pumps and associated C 2205 days Head Safety Injection pumps RHR heat exchangers In an and associated RHR heat OPERABLE status, and sufficient flow Action a. exchangers In an OPERABLE paths to accommodate these (30 day status, and sufficient flow paths OPERABLE Safety Injection pumps backstop) to accommodate these and RHR heat exchangers,** within 7 OPERABLE Safety Injection days restore the inoperable pumps and RHR heat subsystem(s) to OPERABLE status or exchangers," restore the apply the requirements of Specification inoperable subsystem(s) to 3.13.1, or be in at least HOT OPERABLE status within 7 STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and days or be in at least HOT In HOT SHUTDOWN within the STANDBY within the next 6 following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

hours and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

Description of Changes and Safety Evaluation NOC-AE-0300 1466 Page 31 Table 2 Detailed Description of Changes and Basis Specification Requirement Ne

- cio eqrement Tecical Discussion and Comments Risk B sis RTS.

Numb:er ;Calculated STP; Initiative,

-AOT Befo're

-Backstop~.;

'base' ','as 3.5.2 Existing ACTION b. moved to New ACTION b. With 2 inoperable trains of SI there is 2 inoperable 41 6 ACTION c. generally not a loss of safety function, trains - 35 days 4B6 ECCS in With less than two of the required although STP cannot mitigate LBLOCA if the (30day backstop)

MODES 1,2, & subsystems OPERABLE, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months SI train is injecting into the broken RCS loop. 3 bl 3 restore at least one subsystem to Mitigation of SBLOCA with SI in the broken 3 Inoperhaue OPERABLE status and apply the loop requires operator action. Steam line requirements of Specification 3.13.1, or break mitigation is impaired, but DNB is not With more than Action b. be In at least HOT STANDBY within the expected to occur. Winore next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and In HOT SHUTDOWN exeteroacui neinoeral within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . With no operable trains, STP loses the SI train, the safety function; however, a risk-informed AOT 3.1 3.1 Is Is appropriate to accommodate specific proposed as a situations where the SI trains are degraded requirement but still functional and to allow for timely rather than an actions commensurate with the actual option. This significance of the condition. accounts for the The proposed 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months time limit is consistent potential risk-with the requirement of TS 3.0.3 which would significance of a apply to the current TS. configuration where the HHSI function could be affected.

3.5.2 No ACTION c. In the event the ECCS is actuated and Administrative change to accommodate new NA Admin.

EC in

.S injects water into the Reactor Coolant ACTION b. No change to the TS requirement.

MODES 1,2, & System, a Special Report shall be 3 submitted within 90 days describing the circumstances of the actuation and the total accumulated actuation cycles to date. The current value of the Action c. usage factor for each affected Safety Injection nozzle shall be provided in this Special Report whenever Its value exceeds 0.70.

Description of Changes and Safety Evaluation NOC-AE-0300 1466 Page 32 Table 2 Detailed Description of Changes and Basis Specification ldAcion Requirement New Actio Re quirement Technical Discussion and Comments. Risk Basis : RITS:

Number Calculated :STP, Initiative

- -. AOTBefore

`Backstop 3.5.5 With the RWST Inoperable, With the RWST Inoperable, Within 1 The proposed action allows the operator to 5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months (based' 4B3 restore the tank to OPERABLE hour restore the tank to OPERABLE make a determination based on the specific on RWST not status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or be in at status or apply the requirements of situation and the degree of degradation of the being available)

RWST least HOT STANDBY within 6 Specification 3.13.1, or be in at least RWST. A number of situations may make the hours and InCOLD HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in RWST Inoperable, but still functional (e.g.,

MODE 1,2,3 34 SHUTDOWN within the COLD SHUTDOWN within the boron concentration slightly low or an ASME following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . Code question).

3.5.6 With one RHR loop Inoperable, With one RHR loop Inoperable, Within The proposed action Is justified by the plant- 1 Inoperable 4B RRrestore the required loop to 7 days restore the required loop to specific function of RHR and the degree of RHR train:

RROPERABLE status within 7 OPERABLE status or apply the redundancy at STP. STP's RHR does not >10ys MODE 1,2, 3 days or be in at least HOT requirements of Specification 3.13.1, perform a SI function. It is required only for >0ys STANDBY within the next 6 or be in at least HOT STANDBY long-term cooling after shutdown or post-Action a hours and in HOT SHUTDOWN Within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT accident. In post-LOCA conditions, LHSI is within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . SHUTDOWN within the following 6 functionally redundant.

hours. (30 day backstop) 3.5.6 With two RHR loops inoperable, With two RHR loops inoperable, within The proposed action is justified by the piant- 2 inoperabieRHR 4B3 RRrestore at least two RHR loops 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months restore at least two RHR specific function of RHR and the degree of trains:

HRto OPERABLE status within 24 loops to OPERABLE status or apply redundancy at STP. STP's RHR does not 54dy MODE 1,2, 3 hours or be in at least HOT the requirements of Specification perform a SI function. It Is required only for 54dy STANDBY Within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in 3.13.1, or be in at least HOT long-term cooling after shutdown or post- (30 day Action b HOT SHUTDOWN within the STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and InHOT accident. In post-LOCA conditions, LHSI is backstop) following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . SHUTDOWN within the following 6 functionally redundant.

hours.

Description of Changes and Safety Evaluation NOC-AE-03001466 Page 33 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement . - New Action Requirement Technical Discussion and ComRmentsRisk Basis RITS Number' - . : . , ; ' Calculated STP Initiative

- AOT Before

~- - ; - -; ; ;; :; .- - Backstop

- -.

_____ _____ ___ (base case l 3.6.1.7 With the 18-inch supplementary With the 18-inch supplementary Pre-planned operator action can reasonably No impact on 4B

. containment purge supply containment purge supply and/or be credited to close these valves for most CDF. 65 days Containment and/or exhaust isolation exhaust isolation valve(s) open for accident conditions. based on change Ventilation valve(s) open for reasons other reasons other than given in in LERF and than given in Specification Specification 3.6.1.7.b. above, within 4 assuming the 3.6.1.7.b. above, close the hours close the open 18-inch valve(s) valve is open.

Action b open 18-inch valve(s) or isolate or isolate the penetration(s), or apply (30 day the penetration(s) within 4 the requirements of Specification (ay hours, otherwise be in at least 3.13.1, or be in at least HOT backstop)

HOT STANDBY within the next STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in COLD in COLD SHUTDOWN within the SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

3.6.1.7 With a containment purge With a containment purge supply 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months provides adequate time to perform Bounded by 4B Containment supply and/or exhaust isolation and/or exhaust isolation valve(s) an assessment to determine acceptable 3.6.1.7 Action b on valve(s) having a measured having a measured leakage rate in alternative action and time needed to address assessment.

Ventilation leakage rate In excess of the excess of the limits of Specifications an inoperable containment purge isolation (30 day limits of Specifications 4.6.1.7.2 4.6.1.7.2 and/or 4.6.1.7.3, within 24 valve. backstop) and/or 4.6.1.7.3, restore the hours restore the inoperable valve(s) p Action c inoperable valve(s) to to OPERABLE status or isolate the OPERABLE status or Isolate penetrations so that the measured the penetrations so that the leakage rate does not exceed the measured leakage rate does limits of Specifications 4.6.1.7.2 and/or not exceed the limits of 4.6.1.7.3 or apply the requirements of Specifications 4.6.1.7.2 and/or Specification 3.13.1; otherwise be In at 4.6.1.7.3 within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , least HOT STANDBY within the next 6 otherwise be in at least HOT hours and In COLD SHUTDOWN STANDBY within the next 6 within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

hours, and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

Description of Changes and Safety Evaluation NOC-AE-03001466 Page 34 Table 2 Detailed Description of Changes and Basis Specification Old Action Re quirement; New Action Requirement : Technical Discussion and Conments Risk Basis RITS um Calculated STP;.' Initiative

',AOT Before.:.

Backstop,.:

- '(base cise)i 3.6.2.1 With one Containment Spray With one Containment Spray System The Containment Spray System is comprised >10 yrs. 4B Containment System Inoperable, restore the inoperable, within 7 days restore the of 3 trains. 2 operable trains meet the SryInoperable Spray System to Inoperable Spray System to design-basis and 1 train is adequate to based on LERF SryOPERABLE status within 7 OPERABLE status or apply the performn the system function at a degraded (30-day (Note 2) days or be in at least HOT requirements of Specification 3.13.1, level. Reactor Containment Fan Coolers backstop)

STANDBY within the next 6 or be Inat least HOT STANDBY within provide functionally redundant containment hours; restore the Inoperable the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD heat removal capability. Compensatory The Containment Spray System to OPERABLE SHUTDOWN within the following 30 actions can be taken to reduce Iodine Spray System Is status within the next 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months hours. contribution to operator dose. Deletion of the not flsk-or be In COLD SHUTDOWN 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months provision between HOT STANDBY significant.

Within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . and COLD SHUTDOWN would normally be a more restrictive change, but the 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months Is no longer relevant with the application of TS

_ __ _ _ _ __ __ _ _ __ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ 3 .1 3 .1 .

3.6.2.1 The current TS have no action With more than one Containment Reactor Containment Fan Coolers provide >10 yrs. 4B. 6 Contanment for more than one train of CS Spray System inoperable, within 1 functionally redundant containment heat baeonLR Containmnt Inoperable and TS 3.0.3 would hour restore at least one Inoperable removal capability. Evaluations performed forbaeonLR Sryapply. Spray System to OPERABLE status or STP TS Amendments 85/72 determined that (30-day New Action b. apply the requirements of Specification a single train of RCFCs and Containment backstop) 3.13.1, or be in at least HOT Spray Is adequate for containment heat STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and removal and RCB pressure control In In COLD SHUTDOWN within the accident conditions. Compensatory actions following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . can be taken to reduce Iodine contribution to operator dose.

The proposed time limit of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is consistent with the time limit of TS 3.0.3 which would apply to the current TS for more

____________ ______________________ ___________________________than one inoperable train of CS.________

Description of Changes and Safety Evaluation NOC-AE-03001466 Page 35 Table 2 Detailed Description of Changes and Basis Specification OldAction equirement i R Tec nicalI iscslon and Comments Risk Basi RITS Conaimen neefecho ect required Reactor Containment Reactor Containment Fan Coolers of redundancy and Containment Spray is Reactor Fan Coofers Inoperable, restore inoperable, within 7 days restore the functionally redundant for heat removal. bsdo D Fan Contanment Coolers the Inoperable group to OPERABLE statusofwithin RCFC 7 inoperable OPERABLEgroup statusoforRCFC applytothe nLERF.feto (Note 2) days or be in at least HOT requirements of Specification 3.13.1, (30-day STANDBY within the next 6 or be in at least HOT STANDBY backstop) hours and In COLD within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the SHUTDOWN within the following 30

__ ___ __ following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . hours.

tOPRBEsau thn7 OPERABLE status or apply the cnevtv osdrn h o ik _

aktp 3.6.2.3 The current TS have no action With more than one group of the Three trains of RCFCs provide a high degree >10 yrs. 4B 6 for more than one group of above required Reactor Containment of redundancy and Containment Spray is Reactor RCFCs inoperable and TS 3.0.3 Fan Coolers Inoperable, within 1hour functionally redundant for heat removal.

Fan Coolers would apply. restore at least two groups of RCFC to The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months for a time Is (0ayt LRrontstop" New Action b. requirements of Specification 3.13.1, c r o in wy or be in at least HOT STANDBY significance of the system and degree of within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD redundancy. Evaluations performed for STP SHUTDOWN within the following 30 TS Amendments 85/72 determined that a hours. single train of RCFCs and Containment Spray m iis adequate for containment heat removal Fand RCB pressure control In accident conditions. The one hour Is consistent with TS 3.0.3 which the current TS would apply to more than one Inoperable group of RCFCs.

Description of Changes and Safety Evaluation NOC-AE-03001466 Page 36 Table 2 Detailed Description of Changes and Basis

.Specification '.Old Action Requirement New Action Requirement Tehia icsinandCm ikBssT Number, C alculated STP initiative AOT Before, Backstop 3.6.3 With one or more of the With one or more of the Isolation The proposed change to this specification >10 yrs. 4B isolation valve(s) inoperable, valve(s) inoperable, maintain at least adds ACTION d. to allow the application of Containment maintain at least one isolation one Isolation barrier' OPERABLE in Specification 3.13.1. The existing action time (30 day Isolation Valves barrier* OPERABLE in each each affected penetration that is open of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is not changed. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is backstop) affected penetration that is and within 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months s: sufficient time to perform a risk assessment (Added new open and: Application of TS ACTION d. and of the condition to determine if additional time 3.13.1 would changed a. Restore the inoperable a. Restore the Inoperable valve(s) to may be taken for corrective maintenance evaluate the existing valve(s) to OPERABLE OPERABLE status, or before closing the affected penetration. function of the ACTION d. to status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , or individual ACTION e.) b. Isolate each affected penetration valve(s) that are by use of at least one deactivated affected with

b. Isolate each affected automatic valve secured In the penetration within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months isolation position, or check valve respect to the by use of at least one with flow through the valve functionality of deactivated automatic valve secured**, or their associated secured in the isolation system.

position, or check valve with flow through the valve c. Isolate each affected penetration secured", or by use of at least one closed manual valve or blind flange, or

c. Isolate each affected penetration within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months d. Apply the requirements of by use of at least one Specification 3.13.1 closed manual valve or blind flange, or Or

d. Be in at least HOT Be in at least HOT STANDBY within STANDBY within the next 6 the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD hours and in COLD SHUTDOWN within the following 30 SHUTDOWN within the hours.

following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

I I J.

Description of Changes and Safety Evaluation NOC-AE-0300 1466 Page 37 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement New Action Requirement Technical Discussion and Comments - Risk Basis RITS Number - -Calculated -. STP Initiative

'AOT Before

-,Backstop --

____ ___

baie cage ii

3.7.1.2 b. With the turbine-driven b. With the turbine-driven auxiliary STP's design Is highly redundant with 3 1 inoperable 4B auxiliary feedwater pump feedwater pump inoperable, or with motor-driven AFW pumps and 1 turbine- train:

Auxiliary inoperable, or with any two any two auxiliary feedwater pumps driven AFW pump. TDAFW: 340 Feedwater auxiliary feedwater pumps Inoperable, within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months restore the Proposed change to Action b. permits the days inoperable, restore the affected affected auxiliary feedwater pump(s) to Pplica o tion 1 ues the days Action b. auxiliary feedwater pump(s) to OPERABLE status or apply the application of TS 3.13.1 and uses the existing MDAFW: 502 Atob. OPERABLE status within 72 requirements of Specification 3.13.1. 72 hou actonsevtime. the rexsting 72thou days hours. The provisions of The provisions of Specification 3.0.4 AOT Is conservative with respect to the Specification 3.0.4 are not are not applicable for entry Into Mode redundancy in the STP design. Additional (0day applicable for entry into Mode 3 3 for the turbine-driven pump. Justification Is provided inletter dated backstop) aplcbefretyItthe turbine-driven oe33for pump.- December 3, 2001 (NOC-AE-01 001 196) that for the turbine-drivenspump. Is the basis for the existing AFW AOTs. 2 inoperable MDAFW: 7.5 3.7.1.3 With the AFST inoperable, With the AFST Inoperable, within 4 Application of TS 3.13.1 Is appropriate. The 1 1/2 hours 4B within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months restore the AFST hours restore the AFST to OPERABLE cause for the Inoperability of the AFWST (assumes the Auxiliary to OPERABLE status or be in at status or apply the requirements of might be such that it would be unsafe to AFST is Feedwater least HOT STANDBY within the Specification 3.13.1, or be in at least shutdown to a condition where the tank was unavailable; Storage Tank next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT HOT STANDBY within the next 6 required. More likely, the tank would be however, SHUTDOWN within the hours and in HOT SHUTDOWN within degraded but functional or other shutdown is not following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . compensatory actions could be implemented appropriate nor (e.g., tank fill options) such that an extended required by the AOT would be justified. TS with no AFW available to remove decay heat. (See TS 3.7.1 .2.d) 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for tank level

Description of Changes and Safety Evaluation NOC-AE-03001466 Page 38 Table 2 Detailed Description of Changes and Basis Specification OidAction Requiremnt New Action Re uirement Technical Discussion and'Comments;;;- Risk Biss ;: RITS Number* Calulate'd STP Initiative

- AOT Before'

- ;. Bc.kstop (base case __ _

3.7.1.5 MODE 1: Change APPLICABILITY from MODE The APPLICABILITY is revised to apply only 1 inoperable 4B, 6

. . . 1 2 and 3 to "MSIVs open in MODE to open MSIVs In MODE 1, 2, and 3. This MSIV: >10 yrs.

Main Steam With one MSIV Inoperable but 1:2. n "cag sesnilyamnsrtv ic h Isolation Valves open, POWER OPERATION 1 2 and 3 current Action only appinistrative since the 2 inoperable may continue provided the The terminology "but open" Is deleted from MSIV: 410 days inoperable valve is restored to With a MSIV inoperable, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Action 1 because it becomes redundant. This (30 day OPERABLE status within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months ; otherwise be in HOT close or restore the inoperable valve to has no safety implications because the backstop)

STANDBY within the next 6 OPERABLE status, or apply the MSIVs are performing their design function if hours and in HOT SHUTDOWN requirements of Specification 3.13.1; they are closed.

within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . otherwise be in HOT STANDBY within The distinction between MODE 1 and the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT MODEs 2 and 3 is deleted because the MODES 2 and 3 SHUTDOWN Within the following 6 revised action Includes a provision to close With one MSIV inoperable, hours. the valve and there is no difference In the subsequent operation in MODE Note: Separate condition entry is end-state MODE if TS 3.13.1 is not applied.

2 or 3 may proceed provided permitted for each MSIV. The addition of the note for separate the Isolation valve is maintained condition entry for each inoperable MSIV closed. Otherwise, be in HOT allows more than one Inoperable MSIV and is STANDBY within the next 6 better wording In this TS than 'with one or hours and in HOT SHUTDOWN more..." used elsewhere.

within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is a conservative time to determine the risk significance of the condition. The assessment may determine that although a MSIV Is not operable under all aspects of the TS definition, it is still functional and additional time can be taken to restore it to operability. 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is consistent with the current TS requirement to apply TS 3.0.3 for more than one inoperable MSIV.

Description of Changes and Safety Evaluation NOC-AE-03001466 Page 39 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement New Action R equirement:- Technical Discussion and or ments. - isk Basis. -RITS Number -, :. - ; Ca cul initiat-v

. AOT Before',

-;. :- ;s;:.

(baso -

3.7.1.6 With one less than the required With one less than the required 7 days is adequate time to determine 1Inoperable SG 4B

. atmospheric steam relief valves atmospheric steam relief valves alternative action and AOT. Additional AOT PORV: >790 Atmospheric OPERABLE, restore the OPERABLE, within 7 days restore the will probably be justifiable based on the days Steam Relief required atmospheric steam required atmospheric steam relief expected availability of the condenser and (30 day Valves relief valves to OPERABLE valves to OPERABLE status or apply associated steam dumps. backstop) status within 7 days; or be In at the requirements of Specification A minor editorial correction was made to least HOT STANDBY with the 3.13.1 or be in at least HOT correct "as to to Action a. next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and In HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and correc i o "witin".

SHUTDOWN within the in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and place the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and place the required RCS/RHR loops in required RCS/RHR loops in operation operation for decay heat for decay heat removal.

removal.

3.7.1.6 With two less than the required With two or more less than the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Is a conservative time to determine 2 inoperable SG 4B, 6 A atmospheric relief valves required atmospheric relief valves alternative action and AOT. Additional AOT PORVs: 83 days Atmospheric OPERABLE, restore at least OPERABLE, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore at is likely to be justifiable based on the Steam Relief three atmospheric relief valves least three atmospheric relief valves to expected availability of the condenser and (30 day Valves to OPERABLE status within 72 OPERABLE status or apply the associated steam dumps. The 1-hour limit Is backstop) hours or be in at least HOT requirements of Specification 3.13.1 or consistent with the limit of TS 3.0.3 which STANDBY with the next 6 be In at least HOT STANDBY within current TS would require with more than 2 Action b. hours and in HOT SHUTDOWN the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT less than the required number of operable within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and SHUTDOWN within the following 6 valves.

place the required RCS/RHR hours and place the required A minor editorial correction was made to loops in operation for decay RCS/RHR loops In operation for decay correct "witho to "within".

_______ ______ heat rem oval, heat removal.__ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

Description of Changes and Safety Evaluation NOC-AE-03001466 Page 40 Table 2 Detailed Description of Changes and Basis Specification -' Old Action Requirement-' New Actiln equirement i Technical iscussIon and Comm nts RIsIBasis -l RS:

Nube 7: '-Calculated,STP :Initiatlve,

-AOTBefore':

-___ __ -;_ _ -- _: _ _ - _ _. _ - _ - _; _ _ (base case)1 3.7.1.7 MODES 1 and 2: Change APPLICABILITY from MODE The APPLICABILITY Is revised to apply only One FWIV: >10 4B Main 1, 2, and 3 to 'MFIVs open in MODE 1, to open MFIVs in MODE 1, 2, and 3. This yrs.(30 day Feedwater With one MFIV inoperable but 2, and 3" change Is essentially administrative since the Backstop)

Isolation Valves open, operation may continue theInoperable Valveis With Inoperab ithin Iahoniur current Action only applies to open MFIVs.

The terminology 'but open" Is deleted from Two FWIVs:

provided the Inoperable vaive is With a MFIV inoperable within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months the Action because It becomes redundant. 410 days restored to OPERABLE status close or restore the inoperable valve to This has no safety implications because the (3da within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months ; otherwise be in OPERABLE status or apply the MFIVs are performing their design function if backstop)

HOT STANDBY within the next requirements of Specification 3.13.1; they are closed.baktp 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . otherwise be In HOT STANDBY within Three FWIVs:

the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT There are adequate compensatory actions 295 days MODE 3: SHUTDOWN within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . available for inoperable MFIVs to permit successful application of TS 3.13.1, including (30 day With one MFIV inoperable, Note: Separate condition entry Is the redundant function provided by the feed Backstop) subsequent operation In MODE pmted for each MFIV. regulating valves. These compensatory Four FWIVs:

3 may proceed provided the permitted actions are already recognized in NUREG- 295 days Isolation valve is maintained 1431.

closed. Otherwise, be in HOT The proposed action time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is (30 day SHUTDOWN within the next 6 conservative and consistent with the time that Backstop) hours. would be required by current TS application of TS 3.0.3 for more than one inoperable MFIV.

The addition of the note for separate condition entry for each Inoperable MFIV allows more than one inoperable MFIV and Is better wording In this TS than 'with one or more..." used elsewhere.

The addition of the action to be in HOT SHUTDOWN in the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to the MODE 1 and 2 action allows the MODE 3 action to be combined so that there Is a single action.

Description of Changes and Safety Evaluation NOC-AE-03001466 Page 41 Table 2 Detailed Description of Changes and Basis Specifcation ld Action Requirement New Action Requirement DTechnical iscussion and Comments . Risk Basis :RITS Number; Calculated STP Initiative

, . . , . . AOT Before Backstop

___ ______ ___ ___ ___ __ (base case)1:'

3.7.3 With only two component a. With only two component cooling CCW has a high degree of redundancy. With 1 Inoperable train 4B cooling water loops water loops OPERABLE, within 7 one inoperable train, the system generally still of CCW:

Component OPERABLE, restore at least days restore at least three loops to meets the single failure criteria with only Cooling Water three loops to OPERABLE OPERABLE status or apply the modest degradation. The 7-day frontstop >10 yrs.

status within 7 days or be in at requirements of Specification time Is not representative of the safety least HOT STANDBY within the 3.13.1, or be in at least HOT significance of one train of CCW being next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months inoperable. (30 day SHUTDOWN within the and in COLD SHUTDOWN within backstop) following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . Proposed as Action a. because of proposed

_____________~ new Action b. below._ _ _ _ _ _ _ _

3.7.3 The current TS do not have an b. With two or more component Evaluations performed for STP Amendments 2 Inoperable 4B, 6 Component action for more than one cooling water loops inoperable, 85/72 showed that a single train of CCW is trains of CCW:

Cooling Water inoperable train of CCW. TS within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore at least two adequate for safe shutdown and accident 3.0.3 would apply. loops to OPERABLE status or mitigation with only modest degradation in 278 days Proposed new apply the requirements of capability.

Action b. Specification 3.13.1, or be in at least HOT STANDBY within the The one-hour time is conservative and next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD consistent with TS 3.0.3 which would be SHUTDOWN within the following required by current TS for more than one 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . inoperable train of CCW.

3.7.4 With only two essential cooling a. With only two essential cooling With a single train of ECW inoperable there is 1 inoperable train 4B water loops OPERABLE, water loops OPERABLE, within 7 no loss of safety function, and the plant of ECW Essen ial restore at least three loops to days restore at least three loops to generally meets single failure for most 99 days Cooling Water OPERABLE status within 7 OPERABLE status or apply the probable design-basis events.

days or be in at least HOT requirements of Specification . (30 da STANDBY within the next 6 3.13.1, or be in at least HOT Proposed as Action a. because of proposed backsto hours and in COLD STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months new Action b. below, p)

SHUTDOWN within the and in COLD SHUTDOWN within following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

Description of Changes and Safety Evaluation NOC-AE-0300 1466 Page 42 Table 2 Detailed Description of Changes and Basis Specification ld Action Requirement Ne"w Action Requirement Technical Discuss on and Comments Risk RITS Number Calculated STP Initiative

- . AOT Before

- & - Backstop

'__________________ _ "(base case)'

3.7.4 The current TS do not have an With two or more essential cooling With two inoperable ECW trains, the plant 2 Inoperable 4B, 6 Essential action for more than one water loops inoperable, withini hour retains its capability to mitigate a design- trains of ECW:

CoolnWat inoperable train of ECW. TS restore at least two loops to basis accident.

Cooling Water 3.0.3 would apply. OPERABLE status or apply the 102 hours0.00118 days 0.0283 hours 1.686508e-4 weeks 3.8811e-5 months Proposed new requirements of Specification 3.13.1, The one-hour time is conservative and Action b. or be in at least HOT STANDBY consistent with TS 3.0.3 which would be within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD required by current TS for more than one SHUTDOWN within the following 30 inoperable train of ECW.

hours.

3.7.14 With only two Essential a. With only two Essential Chilled With a single train of EChW inoperable there 1 inoperable train 4B

. Chilled Water System Water System loops OPERABLE, is no loss of safety function, and the plant of EChW:

Essential loops OPERABLE, restore within 7 days restore at least three generally meets single failure for most Chilled Water three loops to OPERABLE loops to OPERABLE status or probable design-basis events. >2900 days status within 7 days or be apply the requirements of (30 d In at least HOT STANDBY Specification 3.13.1, or be In at Proposed as Action a. because of proposed ay within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and least HOT STANDBY within the new Action b. below, In COLD SHUTDOWN next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD within the following 30 SHUTDOWN within the following hours. 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

3.7.14 The current TS do not have an b. With two or more Essential Chilled With two Inoperable EChW trains, the plant 2 Inoperable 4B, 6 action for more than one Water System loops Inoperable, retains its capability to mitigate a design- trains of EChW:

Essential Inoperable train of EChW. TS within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore at least two basis accident. 36 days Chilled Water 3.0.3 would apply. loops to OPERABLE status or The one-hour time is conservative and New Action b. apply the requirements ofcossetwhTS303hihoudb 0da Specification 3.13.1, or be in at consist with ent TSh3.0.3nwhich be backstoy)

(n3 least HOT STANDBY within the required by current TS for more than one p next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD inoperable train of EChW.

SHUTDOWN within the following All three trains of 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . EChW inoperable:

74 hours8.564815e-4 days 0.0206 hours 1.223545e-4 weeks 2.8157e-5 months

Description of Changes and Safety Evaluation NOC-AE-03001466 Page 43 Table 2 Detailed Description of Changes and Basis Specification; Old Action Requirement New Action Requirement N Technicil Discussion and Comments Is Bais RITS Number ' - t STP Initiative ATBefore',

r 'Backstop

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ (b ase' case)1 _ _ _ _

3.8.1.1 With one offsite circuit of the With one offsite circuit of the above- STP's switchyard Is served by 8 incoming Assuming loss of 4B A.C. Sources above-required A.C. electrical required A.C. electrical power sources lines. Three transformers are available to the 13.8kV bus Opeoratin power sources inoperable, inoperable, demonstrate the each unit to power the 13.8 KV buses that supply to a safety Operating demonstrate the OPERABILITY OPERABILITY of the remaining A.C. supply the 4.16 KV emergency buses. There bus, 1460 days of the remaining A.C. sources sources by performing Surveillance are 3 trains of ESF power, only one of which to 1E-05 by performing Surveillance Requirement 4.8.1.1.1.a within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is required to achieve and maintain safe Action a. Requirement 4.8.1.1.1 .a within and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months shutdown. This is a very reliable and (30 day 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least once per 8 thereafter. Within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months restore the redundant power supply system. 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is backstop) hours thereafter. Restore the offsite circuit to OPERABLE status or adequate to determine an alternate action or offsite circuit to OPERABLE apply the requirements of Specification justify addition time to restore the condition.

status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in 3.13.1, or be in at least HOT at least HOT SHUTDOWN SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in and in COLD SHUTDOWN within the COLD SHUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Description of Changes and Safety Evaluation NOC-AE-03001466 Page 44 Table 2 Detailed Description of Changes and Basis Specdic tion Old Action Requi en ew Atio entTehnicl I Discussion and Comments Ris Bsis ; iTS Number :litiLti; C

- AOT Before

' ": . Backstop -

- ,-(base case) :

3.8.1.1 With a standby diesel generator With a standby diesel generator With one inoperable Standby Diesel 1 SDG 4B

. inoperable, demonstrate the Inoperable, demonstrate the Generator (SDG), STP has no loss of safety inoperable:

Action b OPERABILITY of the above- OPERABILITY of the above-required function and generally meets the single 168 days required A.C. offsite sources by A.C. offsite sources by performing failure criteria.

performing Surveillance Surveillance Requirement 4.8.1.1.1.a (30 day Requirement 4.8.1.1.1 .a within within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least once per 8 backstop) 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least once per 8 hours thereafter. If the standby diesel hours thereafter. If the standby generator became Inoperable due to diesel generator became any cause other than an inoperable inoperable due to any cause support system, an Independently other than an inoperable testable component, or preplanned support system, an preventive maintenance or testing, Independently testable demonstrate the OPERABILITY of the component, or preplanned remaining OPERABLE standby diesel preventive maintenance or generators by performing Surveillance testing, demonstrate the Requirement 4.8.1.1 .2.a.2) for each OPERABILITY of the remaining such standby diesel generator OPERABLE standby diesel separately within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , unless it can generators by performing be demonstrated there is no common Surveillance Requirement mode failure for the remaining diesel 4.8.1.1.2.a.2) for each such generator(s). Within 14 days restore standby diesel generator the inoperable standby diesel separately within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , generator to OPERABLE status or unless it can be demonstrated apply the requirements of Specification there is no common mode 3.13.1, or be In at least HOT failure for the remaining diesel SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months generator(s). Restore the and in COLD SHUTDOWN within the inoperable standby diesel following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . (12) generator to OPERABLE status within 14 days or be In at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .1(

2 _

Description of Changes and Safety Evaluation NOC-AE-03001466 Page 45 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement,, New Actilon Requirement. - Technical Discussion and Comments . Risk Basis RITS Number :.: - . Calclated STP Initiative

- -, , ;-. . - i . - i,- . . -,Backsto 3.8.1.1 With one offsite circuit of the above- With one offsite circuit of the above- Deletion of the requirement to restore at least 1 Inoperable off- 4B required A.C. electrical power required A.C. electrical power sources two offsite circuits to OPERABLE status site circuit: 158 Action c sources and one standby diesel and one standby diesel generator within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months and three standby diesel days generator inoperable, demonstrate Inoperable, demonstrate the generators to OPERABLE status within 14 the OPERABILITY of the remaining OPERABILITY of the remaining A.C. days from the time of Initial loss is not a (30 day A.C. sources by performingbaktp Specification 4.8.1.1.1a. within 1 sources by performing Specification change because proper application of the TS backstop) hour and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 4.8.1.1.1 a. within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least would require this.

thereafter, and if the standby diesel once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter; and if the generator became Inoperable due standby diesel generator became to any cause other than an inoperable due to any cause other Inoperable support system, an than an inoperable support system, an independenney testable component, independently testable component, or maintenance or testing, preplanned preventive maintenance or demonstrate the OPERABILITY of testing, demonstrate the the remaining OPERABLE standby OPERABILITY of the remaining diesel generators by performing OPERABLE standby diesel Surveillance Requirement generator(s) by performing 4.8.1.1.2a.2) within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , unless Surveillance Requirement it can be demonstrated there Isno 4.8.1.1 .2a.2) within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , unless it common mode failure for the remaining diesel generator(s); can be demonstrated there is no restore at least one of the common mode failure for the inoperable sources to OPERABLE remaining diesel generators; within 12 status within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months or be in at hours restore at least one of the least HOT STANDBY within the Inoperable sources to OPERABLE next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD status or apply the requirements of SHUTDOWN within the following 30 Specification 3.13.1, or be in at least hours. Restore at least two offsite HOT STANDBY within the next 6 circuits to OPERABLE status with in hours and In COLD SHUTDOWN 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months and three standby diesel hin in 30HUTDOWN generators to OPERABLE status wihnteflong3hur.12 within 14 days from the time of Initial loss or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . (12)

Description of Changes and Safety Evaluation NOC-AE-03001466 Page 46 Table 2 Detailed Description of Changes and Basis Specification Old Action n Requirement : Technical Discussion and Comments Risk Basis RITS Numbe-r ,- -Calculated STP '; Initiative New Action Reqree - .. ' ' .,Backstop" 4 4 _ ____ _____ ____ _____ ____ _____ ____ (b ase case)1 _ __ __

3.8.1.1 With one standby diesel With one standby diesel generator 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is adequate time to determine the 184 hours0.00213 days 0.0511 hours 3.042328e-4 weeks 7.0012e-5 months 4B generator inoperable in addition inoperable in addition to ACTION b. or risk significance of the configuration. If there Action d. to ACTION b. or c. above, verify c. above, within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months apply the are inoperable cross-train components, the that: requirements of Specification 3.13.1, AOT should depend on the risk significance or be In at least HOT STANDBY of the specific configuration. For instance, an

1. All required systems, within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and In COLD inoperable cross-train accumulator or reactor subsystems, trains, SHUTDOWN within the following 30 containment fan cooler would be of low components, and hours. significance and additional time can be devices that depend on justified if necessary.

the'remaining OPERABLE diesel generator as a source of emergency power are also OPERABLE, and

2. When In MODE 1, 2, or 3, the steam-driven auxiliary feedwater pump is OPERABLE.

If these conditions are not satisfied within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . L & J.

Description of Changes and Safety Evaluation NOC-AE-03001466 Page 47 Table 2 Detailed Description of Changes and Basis Specification OldAction Requlement New Actionrement emeni Technical Discussion and Comments ,,, Risk Basis RITS NumberI ; - ', . Calculated STP, initiative tAOT Before'

-Backstop'"l

'~"base case 1 3.8.1.1 With two of the above required With two of the above required offsite In this configuration, STP still has at least one Train A 198 4B offsite A.C. circuits inoperable, A.C. circuits inoperable, within 24 ESF bus powered from off-site power. 24 days, train B 772 Action e. restore at least one of the hours restore at least one of the hours Is adequate time to determine the days, train C 918 inoperable offsite sources to inoperable offsite sources to appropriate action and allowable time to days. (30 day OPERABLE status within 24 OPERABLE status or apply the restore the inoperable off-site power. This is backstop) hours or be in at least HOT requirements of Specification 3.13.1, not an expected configuration. Were it to STANDBY within the next 6 or be In at least HOT STANDBY occur, grid stability might be a factor and a hours. With only one offsite within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . plant shutdown could exacerbate the source restored, restore at least degraded condition. TS 3.13.1 provides an two offsite circuits to appropriate mechanism to respond to the OPERABLE status within 72 condition.

hours from time of initial loss or be In at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

Description of Changes and Safety Evaluation NOC-AE-0300 1466 Page 48 Table 2 Detailed Description of Changes and Basis Seiiain .'Old Action Reurmn:New Action Requirement' Technicai Discussion~and Commrents,-' Risk Basis' RITS initatve Number, Caiculated: STP .

1AOT Before:' ,

- Backstop

_ __ _ _ __ _ __ _ _ __ __ _ __ __ _ _ __ _ __ _ _ __ _ __ _ _ _ _ _ _ _ _ _ _ _(b ase ca se jl 3.8.1.1 With two or three of the above With two or three of the above required With 2 Inoperable SDGs, STP does not lose 2 SDGs 4B Acinfrequired standby diesel standby diesel generators inoperable, the safety function and can meet almost all its inoperable:

Acinfgenerators inoperable, demonstrate the OPERABILITY of two design bases. 184 hours0.00213 days 0.0511 hours 3.042328e-4 weeks 7.0012e-5 months demonstrate the OPERABILITY offsite A.C. circuits by performing the Deleting the requirement to restore at least of two offslte A.C. circuits by requirements of Specification the tnb islgnrtr oAll three SDGs performing the requirements of 4.8.1.1.1 a.within 1hour and at least thEReesAnByE lseauithn1 geeatostromte inprb:

Specification 4.8.1.1.1 a.within once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter; within 12 oPERitaBlE lstus wihnIas from timeesine noper ab6leur 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least once per 8 hours restore at least one standby ofpInictia lossI nthaS chneqsines prpeh3ihur hours thereafter, restore at diesel generator to OPERABLE status anepplicationofitheu reqiresthisd itS least one standby diesel and apply the requirements ofinertaonwhuttbigsaed generator to OPERABLE status Specification 3.13.1, or be in at least within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months and at least two HOT STANDBY within the next 6 standby diesel generators to hours and in COLD SHUTDOWN OPERABLE status within 24 within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . (12) hours or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . Restore at least three standby diesel generators to OPERABLE status within 14 days from time of Initial loss or be Inat least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and In COLD SHUTDOWN within the

_______ ______ follow ing 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . (12)__ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

Description of Changes and Safety Evaluation NOC-AE-03001466 Page 49 Table 2 Detailed Description of Changes and Basis Specification Old Acilon Requirement New Action Requirement_- Technical Discussion and Comments Risk Basis RITS.

Number Calcuiated. STP initiative

AOT, Before,'

. ...... 'Backst op

_ _ __ __ _ __ _ _ __ __ _ _ _ _ __ _ __ _ _ _ _ _ _ _ _ __ _ _ _ ba se 6ase ll _ _ _ _

3.8.2.1 a. With one of the required With less than the required battery STP has 4 battery banks, each with two full 1 inoperable 4B, 6 battery banks inoperable, banks or battery chargers capacity chargers. The chargers are even battery bank: 140 D.C. Sources restore the Inoperable OPERABLE, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore less risk-significant due to their redundancy. days (Train D battery bank to OPERABLE the inoperable battery bank or The proposed 1hour time limit Isconsistent 1042 days) status Within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months or be battery charger, or apply the wt S303wihwudb eurdb h 3 a in at least HOT STANDBY requirements of Specification with TS 3.0.3 which would be required by the (30 day within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and 3.13.1, or be in at least HOT current TS for more than one inoperable backstop) in COLD SHUTDOWN STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months battery bank.

within the following 30 and in COLD SHUTDOWN within hours. the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

b. With no battery chargers for a channel OPERABLE, restore at least one battery charger to OPERABLE status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months or be in at least HOT STANDBY

within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

3.8.3.1 With one of the required trains With the required trains of A.C. ESF 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is a conservative time to assess the 1 inoperable AC 4B, 6 of A.C. ESF busses not fully busses not fully energized, within 1 configuration and determine the appropriate ESF bus: Train A Onsite Power energized, reenergize the train hour reenergize the train or apply the action and AOT. The time is consistent with 22 days, train B Distribution within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months or be In at least requirements of Specification 3.13.1, TS 3.0.3 which would currently apply for 58 days, train C Operating HOT STANDBY within the next or be in at least HOT STANDBY conditions with more than one required bus 79 days.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and In COLD within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD not fully energized. Extending the time further SHUTDOWN within the SHUTDOWN within the following 30 can be justified due to the redundancy of the Loss of a single Action a. following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . hours. ESF power. STP does not lose the safety does not result in function unless all three trains of ESF power a plant trip. Only are ost.one of three available trains would be affected.

Description of Changes and Safety Evaluation NOC-AE-03001466 Page 50 Table 2 Detailed Description of Changes and Basis Specification lActon Requirement - New Action Requirement Technical Discussion and Comments :. Risk Basis; - RITS Number - - Calculated STP Initiativ

-, . ,AOT Before':

-Balcksitop

_____________________ :: ____________________ -( f - se casell_ _

3.8.3.1 With one A.C. vital distribution With one or more A.C. vital distribution 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is a conservative time for an 1 Inoperable 4B, 6

. panel either not energized from panel(s) either not energized from its assessment to determine an appropriate AOT inverter: 278 Action b. its associated Inverter, or with associated Inverter, or with the inverter for the configuration. It isconsistent with TS days the inverter not connected to its not connected to its associated D.C. 3.0.3 which would currently apply if more than associated D.C. bus: (1) bus: (1)within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months reenergize the one vital distribution panel was not properly (30kdaty reenergize the A.C. distribution A.C. distribution panel(s) or apply the energized. The redundancy of the STP ackstop) panel within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months or be in at requirements of Specification 3.13.1, electrical power systems will provide 2 Inoperable least HOT STANDBY within the or be in at least HOT STANDBY adequate justification for extending the time inverters: 16 next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD beyond 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . Additional assessments days SHUTDOWN within the SHUTDOWN within the following 30 may be performed to determine the time following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months ; and (2) hours; and (2)within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months needed to re-energize the panel(s) from the reenergize the A.C. vital reenergize the A.C. vital distribution associated Inverter. The panels can also be 1 inoperable bus:

distribution panel from its panel(s) from its associated Inverter powered from an alternate 1E diesel backed 208 days associated Inverter connected connected to its associated D.C. bus bus.

to its associated D.C. bus within or apply the requirements of (30 day 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or be in at least HOT Specification 3.13.1, or be in at least backstop)

STANDBY within the next 6 HOT STANDBY within the next 6 2 inoperable hours and in COLD hours and in COLD SHUTDOWN buses: 8 days SHUTDOWN within the within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

3.8.3.1 With one D.C. bus not With one or more D.C. bus(es) not STP has 4 battery banks, each with two full Currently loss of 4B

. energized from its associated energized from Its associated battery capacity chargers. STP can lose up to two Bus A or B Action c. battery bank, reenergize the bank, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months reenergize the battery banks without jeopardizing a safety results in a plant D.C. bus from its associated D.C. bus(es) from its associated function. trip. Loss of Bus battery bank within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months or battery bank or apply the requirements C- 95 days, Bus be in at least HOT STANDBY of Specification 3.13.1, or be in at 1hour is consistent with the time requirement D 343 days.

within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in least HOT STANDBY within the next 6 of TS 3.0.3 which would currently apply with COLD SHUTDOWN within the hours and InCOLD SHUTDOWN more than one bus not energized from its following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . associated battery bank.

3.13.1 Did not exist Defines the actions to take at changing As described for the individual applications As described for 4B risk levels of the plant configuration the individual

-applications

Description of Changes and Safety Evaluation NOC-AE-0300 1466 Page 51 Table 2 Detailed Description of Changes and Basis

-'Specification~ -Old Action Requirement,'~: .N~iewrAction Reqiuilremenitl r ~Technic'al Discussion and Commen 'ts Risk Basis: RITS

~Number , t alculated STP1' Initiative.

- . Backstop,

____ ______ ____ ___(b ase case ll BASES Section added to explain these new The Bases are provided for Information and 4B 3.13.1 specifications the Into final version the NRC willofbeSTP's copy sent TS for incorporation after approval

___ ____ ___ ___ ____ ____ ___ ____ ____ ___ of the proposed am endm ent._ _ _ _ _ _ _ _

1. Base case is number of hours to exceed the CRMP Potentially Risk-significant Threshold for core damage probability (1E-05) assuming no other systems are inoperable. The Base Case Action Level where compensatory action must be initiated is 1E-06, or 10%of the time allowed to the 1E-05 Base Case. Note that the proposed backstop,time will establish the AOT for conditions where the CRMP calculated time exceeds 30 days.

2. Containment Spray and Reactor Containment Fan Cooler action levels have no dependency on core damage frequency and are based on contributions to large early release frequency.

3. This table may include actions from proposed TS changes that are not yet approved. Differences will be reconciled when STPNOC submits the actual license amendment request. Information from proposed changes is included to provide a more accurate representation of what STPNOC expects the risk-informed application to include.

Description of Changes and Safety Evaluation NOC-AE-03001466 Page 52 Table 3 STP Systems with Reduced Design-basis Capability in Single Train Operation System : FunctionhAffected Alternative'AAction Event Probabilityt Comments Safety Injection Cannot mitigate None (minimal cooling 1.91 E-1 0 One train in (LHSI and HHSI) LBLOCA if the SI train is from using hot leg maintenance outage injecting into the broken recirculation) Note: Accounts for a One train fails RCS loop 25% chance of injecting One train injects into the in broken loop. (Leak broken loop.

before break not credited.)

Safety Injection Steam line break None required 2.25E-8 DNB not expected to (HHSI) mitigation capability occur reduced Note: Accounts for a rupture either inside or outside containment.

Safety Injection Cannot mitigate Operator action per 1.75E-9 One train in (LHSI and HHSI) SBLOCA without EOPs to depressurize maintenance.

operator action if the SI Note: No credit taken for One train fails.

train is injecting into the operator action to One train of HHSI not broken RCS loop depressurize enough to match break flow Operator action is expected to be effective Residual Heat Cannot provide long Continue to inject using See Comments RHR is required Removal term cooling if only a LHSI until RHR is approximately 14 hours1.62037e-4 days 0.00389 hours 2.314815e-5 weeks 5.327e-6 months single ESF bus is restored. after event. Recovery of energized or if RHR is power to ESF bus is injecting into broken expected within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months loop Containment Spray Iodine removal during a Monitor TSC doses and 1.97E-8 LBLOCA or SBLOCA relocate to lower dose area Note: Assuming most probable event of SBLOCA

Description of Changes and Safety Evaluation NOC-AE-0300 1466 Page 53 Table 3 STP Systems with Reduced Design-basis Capability in Single Train Operation System Function:Affected -Alternative Action- Event Probabilityt-- Comments-;

Control Room Cannot maintain 1/8" Positive pressure is 7.64E-10 Envelope HVAC positive pressure expected to be maintained, so system Note: This is the is expected to be probability of a functional LBLOCA, failure of DG and LOOP while in the AOT.

Fuel Handling Cannot provide filter Provide alternate power 6.37E-1 1 Building HVAC path for recirculation supply from operable phase leakage if C train diesel Note: Due to design is only operable train dependencies probabilities are calculated based on trains A or B being operable Component Cooling CCW flow to RCFC's Manually isolate non- 5.75E-5 If train C is the operable Water and RHR Heat safety header to restore train, CCW flow Exchanger less than design flow. Note: Accounts for the approximates design design probability of train C flow. Effect of reduced isolating non-safety CCW flow is slight even

.____ _.__ ._.__._.._.._.__._.._._ flows without manual action.

t The event probability is the likelihood of an initiating event (i.e., Large Break LOCA) with a loss of offsite power and failure of a standby diesel generator given a diesel generator is unavailable for 21 days while another train is out of service. It conservatively does not include recovery factors or support system failures.

Tech Spec Mark-Up Pages NO CHANGES 3/4.3 INSTRUMENTATION 3/4.3.1 REACTOR TRIP SYSTEM INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.1 As a minimum, the Reactor Trip System instrumentation channels and interlocks of Table 3.3-1 shall be OPERABLE with RESPONSE TIMES as shown in Chapter 16 in the Updated Final Safety Analysis Report (UFSAR).

APPLICABILITY: As shown in Table 3.3-1.

ACTION:

As shown in Table 3.3-1.

SURVEILLANCE REQUIREMENTS 4.3.1.1 Each Reactor Trip System instrumentation channel and interlock and the automatic trip logic shall be demonstrated OPERABLE by the performance of the Reactor Trip System Instrumentation Surveillance Requirements specified in Table 4.3-1.

4.3.1.2 The REACTOR TRIP SYSTEM RESPONSE TIME of each Reactor trip function shall be demonstrated to be within its limit at least once per 18 months. Each verification shall include at least one train such that both trains are verified at least once per 36 months and one channel per function such that all channels are verified at least once every N times 18 months where N is the total number of redundant channels in a specific Reactor trip function as shown in the "Total No. of Channels" column of Table 3.3-1.

SOUTH TEXAS - UNITS 1 & 2 3/4 3-1 Unit 1 - Amendment No. 60, 130 Unit 2 - Amendment No. 39, 119

TABLE 3.3-1 INO CHANGES C',

0 REACTOR TRIP SYSTEM INSTRUMENTATION C

or

-O I MINIMUM TOTAL NO. CHANNELS TO CHANNELS APPLICABLE m FUNCTIONAL UNIT OF CHANNELS TRIP OPERABLE MODES ACTION X

1. Manual Reactor Trip 2 1 2 1,2 1 C 2 1 2 3*, 4*, 5* 10 z 2. Power Range, Neutron Flux

a. High Setpoint 4 2 3 1,2 2 C-- b. Low Setpoint 4 2 3 1###, 2 2

3. Power Range, Neutron Flux High Positive Rate 4 2 1,2 2 01)

4. Deleted 90

5. Intermediate Range, Neutron Flux 2 1 1###, 2 3

6. Source Range, Neutron Flux

a. Startup 2 1 2## 4

b. Shutdown 2 1 3* 4*, 5* 10

7. Extended Range, Neutron Flux 2 0 3,4, 5 5 I

C C 8. Overtemperature AT 4 2 1,2 6

9. Overpower AT 4 2 1,2 6

. 2.

10. Pressurizer Pressure -- Low 4 2 1 6 3 3 (D (D (Interlocked with P-7)

11. Pressurizer Pressure-High 4 2 1,2 6

12. Pressurizer Water Level--High 4 2 1 6 (Interlocked with P-7) 34L 3 L j

TABLE 3.3-1 (Continued) lINO CHANGESl CD 0 REACTOR TRIP SYSTEM INSTRUMENTATION C

MINIMUM

-1 TOTAL NO. CHANNELS CHANNELS APPLICABLE m

x FUNCTIONAL UNIT OF TO TRIP OPERABLE MODES ACTION En CHANNELS C

z 13. Reactor Coolant Flow--Low 210 a. Single Loop (Above P-8) 3/1 oop 2/loop in any 2/loop in 1 6 operating loop each operating loop

b. Two Loops (Above P-7 and 3/loop 2/loop in two 2/loop each 1 6 below P-8) operating loops operating Icoz loop

14. Steam Generator Water 4/stm. gen. 2/stm. gen. in 3/stm. gen. 1, 2 6 1 Level--Low-Low any operating each stm. gen. operating stm. gen.

C C c c 15. Undervoltage--Reactor 4-1/bus 2 3 1 6 Coolant I I Pumps (Interlocked with P-7) 9 :>

=3 =3

16. Underfrequency--Reactor 4-1 /bus 2 3 1 6 Coolant Pumps (Interlocked (9 DD3

=3 :3 with P-7)

17. Turbine Trip (Interlocked with z z 0 0 P-9) on !¢

& -4 a. Low Emergency Trip Fluid 3 2 2 1 6 Pressure en a)

b. Turbine Stop Valve Closure 4 2 3 1 6

C', NO CHANGES O

C:

TABLE 3.3-1 (Continued)

REACTOR TRIP SYSTEM INSTRUMENTATION x MINIMUM D TOTAL NO. CHANNELS CHANNELS APPLICABLE l FUNCTIONAL UNIT OF CHANNELS TO TRIP OPERABLE MODES ACTION c

g 18. Safety Injection Input from Cn ESFAS 2 1 2 1,2 9A 90 19. Reactor Trip System Interlocks

a. Intermediate Range Neutron Flux, P-6 2 1 2 2## 8 cO) b. Low Power Reactor Trips Block, P-7 co P-10 Input 4 2 3 1 8 or P-13 Input 2 1 2 1 8

c. Power Range Neutron c c Flux, P-8 4 2 3 1 8

d. Power Range Neutron Flux, P-9 4 2 3 1 8

> >, e. Power Range Neutron 3 3 Flux, P-10 4 2 3 1,2 8 CD CD a: Cf. Turbine Impulse Chamber 3 3 Pressure, P-13 2 1 2 1 8

' 20.ReactorTrip Breakers 2 1 2 1,2 9,12 zz 0 0 2 1 2 3*, 4* 5* 10 M co en 0)

TABLE 3.3-1 (Continued)

NO CHANGES REACTOR TRIP SYSTEM INSTRUMENTATION I MINIMUM TOTAL NO. CHANNELS CHANNELS APPLICABLE FUNCTIONAL UNIT OF TO TRIP OPERABLE MODES ACTION Cn CHANNELS

-q Co

21. Automatic Trip and 2 1 2 1,2 9A I Interlock Logic 2 1 2 3*, 4*, 5* 10 co C,,

C C I.. -64*

(DI (D I 3 3 22 (D CD

=1v 3-z0 0z M CA) en o)

TABLE 3.3-1 (Continued)

ACTION STATEMENTS (Continued)

ACTION 7 - (Not Used)

ACTION 8 - With less than the Minimum Number of Channels OPERABLE, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months determine by observation of the associated permissive annunciator window(s) that the interlock is in its required state for the existing plant condition, or apply Specification 3.0.3.

ACTION 9 - With the number of OPERABLE channels i less than the Minimum Channels OPERABLE requirement, within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months apply te uirementsofS icationf .13_.1or, be in at least HOT STANDBY within-6-hours; however, one channel may be bypassed for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing per Specification 4.3.1.1, provided the other channel is OPERABLE.

ACTION 9A - i With the number of OPERABLE channels one less than the Minimum Channels OPERABLE requirement, within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months restore the inoperable channel to OPERABLE status within2A h-iirs, ' r appl' the requrements of Specification 33.11, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ; however, one channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing per Specification 4.3.1.1, provided the other channel is OPERABLE.

b. -With theinumber of OPERABLE channels more than one less than the Minimum Channels OPERABLE requiremen't, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore at least one inoperable channel to OPERABLE status or apply the requirements of Specification_3.13.1, or -be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

ACTION 10- With the number of OPERABLE channels one less than the Minimum Channels OPERABLE requirement, restore the inoperable channel to OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or open the Reactor Trip System breakers within the next hour.

ACTION 11 - (Not Used)

ACTION 12 - With one of the diverse trip features (undervoltage or shunt trip attachment) inoperable, restore it to OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or declare the breaker inoperable and apply ACTION 9. The breaker shall not be bypassed while one of the diverse trip features is inoperable except for the time required for performing maintenance to restore the breaker to OPERABLE status.

SOUTH TEXAS - UNITS 1 & 2 3/4 3-8 Unit 1 - Amendment No.4k36 Unit 2 - Amendment No.425

NO CHANGES INSTRUMENTATION 3/4.3.2 ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.2 The Engineered Safety Features Actuation System (ESFAS) instrumentation channels and interlocks shown in Table 3.3-3 shall be OPERABLE with their Trip Setpoints set consistent with the values shown in the Trip Setpoint column of Table 3.3-4 and with RESPONSE TIMES as shown in Chapter 16 in the UFSAR.

APPLICABILITY: As shown in Table 3.3-3.

ACTION:

a. With an ESFAS Instrumentation or Interlock Trip Setpoint trip less conservative than the value shown in the Trip Setpoint column but more conservative than the value shown in the Allowable Value column of Table 3.3-4, adjust the Setpoint consistent with the Trip Setpoint value.

b. With an ESFAS Instrumentation or Interlock Trip Setpoint less conservative than the value shown in the Allowable Value column of Table 3.3-4, declare the channel inoperable and apply the applicable ACTION statement requirements of Table 3.3-3 until the channel is restored to OPERABLE status with its Setpoint adjusted consistent with the Trip Setpoint value.

c. With an ESFAS instrumentation channel or interlock inoperable, take the ACTION shown in Table 3.3-3.

SOUTH TEXAS - UNITS 1 & 2 3/4 3-16 Unit 1 - Amendment No. 0, 116 Unit 2 - Amendment No. 39, 104

NO CHANGES INSTRUMENTATION SURVEILLANCE REQUIREMENTS 4.3.2.1 Each ESFAS instrumentation channel and interlock and the automatic actuation logic and relays shall be demonstrated OPERABLE by performance of the ESFAS Instrumentation Surveillance Requirements specified in Table 4.3-2. I 4.3.2.2 The ENGINEERED SAFETY FEATURES RESPONSE TIME of each ESFAS function shall be verified to be within the limit at least once per 18 months. Each verification shall include at least one train so that:

a. Each logic train is verified at least once per 36 months,

b. Each actuation train is verified at least once per 54 months*, and

c. One channel per function so that all channels are verified at least once per N times 18 months where N is the total number of redundant channels in a specific ESFAS function as shown in the "Total No. of Channels" column of Table 3.3-3.

If an ESFAS instrumentation channel is inoperable due to response times exceeding the required limits, perform an engineering evaluation to determine if the test failure is a result of degradation of the actuation relays. If degradation of the actuation relays is determined to be the cause, increase the ENGINEERED SAFETY FEATURES RESPONSE TIME surveillance frequency such that all trains are tested at least once per 36 months.

SOUTH TEXAS - UNITS 1 & 2 3/4 3-17 Unit 1 - Amendment No. 60, 130, 145 Unit 2 - Amendment No. 39,119, 133

Cl I NO ,CHANGF;

_. ., l. I___ I 0 TABLE 3.3-3 l C

I ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION

-4 x

m MINIMUM x

TOTAL NO. CHANNELS CHANNELS APPLICABLE FUNCTIONAL UNIT OF CHANNELS TO TRIP OPERABLE MODES ACTION Cn CD 1. Safety Injection (Reactor Trip, Feedwater Isolation, Control

-o ri Room Emergency Ventilation, Start Standby Diesel Generators, Reactor Containment Fan Coolers, and Essential Cooling Water).

a. Manual Initiation 2 1 2 1,2, 3, 4 19

b. Automatic Actuation Logic 2 1 2 1, 2, 3, 4 14 co 0, c. Actuation Relays 3 2 3 1, 2,3, 4 14

d. Containment Pressure-- 3 2 2 1, 2, 3 4 20 High-1 C C

e. Pressurizer Pressure--Low 4 2 3 1,2, 3# 20 I I f. Compensated Steam Line 3/steam line 2/steam line 2/steam line 1,2, 3# 20 Pressure-Low any steam line in each steam line 3q 3 CD CD

= Z3 3 3 22L

0. .

l NO CHANGES 0 TABLE 3.3-3 (Continued)

C

--orI I ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION m

-n MINIMUM MINIMUM TOTAL NO. CHANNELS CHANNELS APPLICABLE FUNCTIONAL UNIT OF TO TRIP OPERABLE MODES ACTION C

z CHANNELS

-4 cn,

2. Containment Spray

a. Manual Initiation 2 1 with 2 1, 2,3,4 19 2 coincident switches

b. Automatic Actuation Logic 2 1 2 1, 2,3,4 14 co' c. Actuation Relays 3 2 3 1, 2, 3,4 14 0, d. Containment Pressure- 4 2 3 1, 2, 3 17 co co High -3

3. Containment Isolation C c

a. Phase "A" Isolation

( -L

1) Manual Initiation 2 1 2 1, 2, 3, 4 19 (D

a1 CD 3 2) Automatic Actuation 2 1 2 1,2, 3, 4 14 Logic

3) Actuation Relays 3 2 3 1,2,3,4 14 1- -*

4) Safety Injection See Item 1. above for all Safety Injection initiating functions and requirements.

z z 0 0

I NO CHANGES 0 TABLE 3.3-3 (Continued)

C c

I ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION x MINIMUM c TOTAL NO. CHANNELS CHANNELS APPLICABLE FUNCTIONAL UNIT OF CHANNELS TO TRIP OPERABLE MODES ACTION C

z 3. Containment Isolation H

-- I (Continued)

Q° b. Containment Ventilation Isolation CD, 1) Automatic Actuation Logic 2 1 2 1,2,3,4 18

2) Actuation Relays*** 3 2 3 1,2,3,4 18

3) Safety Injection See Item 1. above for all Safety Injection initiating functions and requirements.

ro

4) RCB Purge 2 1 2 1, 2, 3, 4, 5##, 18 CA) Radioactivity- High 6##

5) Containment Spray- See Item 2. above for Containment Spray manual initiating functions and requirements.

0 Manual Initiation

6) Phase "A" Isolation- See Item 3.a. above for Phase "A" Isolation manual initiating functions and Manual Isolation requirements.

c. Phase "B" Isolation 1)Automatic Actuation Logic 2 1 2 1,2,3,4 14

2) Actuation Relays 3 2 3 1, 2, 3, 4 14 C 3) Containment Pressure -- 4 2 3 1, 2, 3 17 High-3

'I. 4) Containment Spray-- See Item 2. above for Containment Spray manual initiating functions and requirements.

Manual Initiation 3CD d. RCP Seal Injection Isolation

1) Automatic Actuation Logic 1 I 1 1,2,3,4 16 M and Actuation Relays CD z

0

C' I MKinri-JAMit I 0 TABLE 3.3-3 (Continued) I iAiA."

C ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION m MINIMUM TOTAL NO. CHANNELS CHANNELS APPLICABLE (I FUNCTIONAL UNIT OF CHANNELS TO TRIP OPERABLE MODES ACTION C

z 3.d. RCP Seal Injection Isolation (Continued)

=1q C,

2) Charging Header 1 1 1 1,2,3,4 16 Pressure - Low Coincident with Phase See item 3.a. above for Phase "A" Isolation initiating functions and requirements "A" Isolation

4. Steam Line Isolation

a. Manual Initiation co 1) Individual 2/steam line 1/steam line 2/operating 1, 2,3 24 C,

steam line

2) System 2 1 2 1, 2,3 23

b. Automatic Actuation Logic 2 1 2 1, 2, 3 22 and Actuation Relays CC c. Steam Line Pressure - 3/steam line 2/steam line 2/ steam line 20 I Negative Rate--High any steam line in each I I steam line I

3 3 d. Containment Pressure - 3 2 2 1, 2, 3 20

= (D High-2 3 3 e. Compensated Steam Line 3/steam line 2/steam line 2/steam line 1, 2, 3# 20 I

a. Pressure- Low any steam line in each z z steam line 0 0 M cA) e~n 0)

NO CHANGES TABLE 3.3-3 (Continued)

(n 0 ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION a

-- I I MINIMUM

-f m TOTAL NO. CHANNELS CHANNELS APPLICABLE FUNCTIONAL UNIT OF TO TRIP OPERABLE MODES ACTION CHANNELS z 5. Turbine Trip and Feedwater Isolation in 5-0 a. Automatic Actuation 2 1 2 1, 2,3 25 C,)

Logic and Actuation Relays

b. Steam Generator Water 4/ stm. gen. 2/ stm. gen. in 3/stm. gen. in 1, 2,3 20 Level-- any each coC,, High-High (P-14) operating stm. operating co) gen. stm. gen.

c. Deleted

d. Deleted

e. Safety Injection See Item 1. for all Safety Injection initiating functions and requirements.

C: f. Tavg - Low coincident with 4 (1/loop) 2 3 1, 2,3 20 Reactor Trip (P-4)

(Feedwater Isolation Only)

=1 CD

-4.

z0

TABLE 3.3-3 (Continued) 0 ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION a8 I

--I MINIMUM TOTAL NO. CHANNELS CHANNELS APPLICABLE FUNC ,TIONAL UNIT OF CHANNELS TO TRIP OPERABLE IMODES ACTION

-4

6. Auxiliary Feedwater C

z

a. Manual Initiation 1/pump 1/pump 1/pump 1, 2, 3 26

b. Automatic Actuation Logic 2 1 2 1, 2, 3 22 90

c. Actuation Relays 3 2 3 1, 2, 3 22

d. Stm. Gen. Water Level --

Low-Low Start Motor- 4 stm. gen. 2 stm. gen. in 3/stm. gen. in 1, 2, 3 20 Driven Pumps and Turbine- any each stm. gen.

Driven Pump stm. gen.

CA) e. Safety Injection See Item 1. above for all Safety Injection initiating functions and requirements.

co co

f. Loss of Power See Item 8. below for all Loss of Power initiating functions and requirements.

(Motor Driven Pumps Only)

C C 7. Automatic Switchover to

. . Containment Sump****

a. Automatic Actuation Logic 3-1/train 1/train 1/train 1, 2, 3, 4 l 3I 3~ I and Actuation Relays

b. RWST Level -- Low-Low 3-1/train 1/train 1/train 1, 2, 3, 4 I a; a Coincident With: See Item 1. above for all Safety Injection initiating functions and requirements.

- 3 Safety Injection 3 ZR z z 0 0

0 I TABLE 3.3-3 (Continued) m ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION Wn MINIMUM TOTAL NO. CHANNELS CHANNELS APPLICABLE z FUNCTIONAL UNIT OF CHANNELS TO TRIP OPERABLE MODES ACTION 8n 8. Loss of Power M a. 4.16kVESFBusUnder- 4/bus 2/bus 3/bus 1,2,3,4 20A voltage-Loss of Voltage

b. 4.16 kV ESF Bus Under-voltage-Tolerable Degraded Voltage Coincident with SI 4/bus 2/bus 3/bus 1, 2, 3, 4 20O

c. 4. 16 kV ESF Bus Under-voltage - Sustained Degraded 4/bus 2/bus 3/bus 1,2, 3, 4 20A Voltage

9. Engineered Safety Features

a. Pressurizer Pressure, P-11 3 2 2 1,2,3 21

b. Low-Low Tayg, P-12 4 2 3 1,2,3 21

c. Reactor Trip, P-4 2 1 2 1, 2, 3 23 C

(D CD CD zp3

NO CHANGES C',

0 C

I TABLE 3.3-3 (Continued)

HI ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION m

C', MINIMUM TOTAL NO. CHANNELS CHANNELS APPLICABLE C: ACTION z FUNCTIONAL UNIT OF CHANNELS TO TRIP OPERABLE MODES C', 10. Control Room Ventilation

a. Manual Initiation 3 (1/train) 2 (1/train) 3 (1/train) All 27

b. Safety Injection See Item 1. above for all Safety Injection initiating functions and requirements.

c. Automatic Actuation Logic 3 2 3 All 27 and Actuation Relays

d. Control Room Intake Air 2 1 2 All 28 co Radioactivity - High

e. Loss of Power See Item 8. above for all Loss of Power initiating functions and requirements.

co it 6 11. FHB HVAC

a. Manual Initiation 3 (1/train) 2 (1/train) 3 (1/train) 1, 2, 3, 4 or with 29, 30 irradiated fuel in spent pool

b. Automatic Actuation Logic 3 2 3 1,2,3,4orwith 29, 30 and Actuation Relays irradiated fuel in spent pool

c. Safety Injection See Item 1. above for all Safety Injection initiating functions and requirements.

d. Spent Fuel Pool Exhaust 2 1 2 With irradiated fuel 30 Radioactivity - High in spent fuel pool

TABLE 3.3-3 (Continued)

TABLE NOTATIONS

- - Function is actuated by either actuation train A or actuation train B. Actuation train C is not used for this function.

- - - Automatic switchover to containment sump is accomplished for each train using the corresponding RWST level transmitter.

Trip function may be blocked in this MODE below the P-1 1 (Pressurizer Pressure Interlock) Setpoint.

1. During CORE ALTERATIONS or movement of irradiated fuel within containment.

1. 1. Trip function automatically blocked above P-11 and may be blocked below P-1 1 when Low Compensated Steamline Pressure Protection is not blocked.

ACTION STATEMENTS ACTION 14- a: With the number of OPERABLE channels one less than the Minimum Channels OPERABLE requirement, withiiin 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months restore the inoperable channel to OPERABLE status h Ripply.the requireme purs, _iofecificait -3..1,3.1T be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months ; however, one channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing per Specification 4.3.2.1, provided the other channel is OPERABLE.

-,hW itKthle'number of OPERABLE channels mnore than oneelsthan the Minimu m Channels OPERABLE'requirement, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore at least one inoperable iciiannel to OPERABLE status oreapply the requirements of Specification 3.13.1, or be In at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and In COLD SHUTDOWN within the followi-ng 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

ACTION 15- (Not Used)

ACTION 16- With the Charging Header Pressure channel inoperable:

a) Place the Charging Header Pressure channel in the tripped condition within one hour and b) Restore the Charging Header Pressure channel to operable status within 7 days or be in at least Hot Standby within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in Cold Shutdown within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

ACTION 17- With the number of OPERABLE channels one less than the Total Number of Channels, place the inoperable channel in the bypassed condition within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in at least HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . One additional channel may be bypassed for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for surveillance testing per Specification 4.3.2.1.

b tnumber of OPERABLE channels more than one less thanthieT6otal NumbeTrof 16ithe channels, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months apply the requirements of Specification 3.13.1 or be in at least HOT SHUTDOWNi within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months !

ACTION 18- a) With less than the Minimum Channels OPERABLE requirement for Automatic Actuation Logic or Actuation Relays, operation may continue provided the containment purge supply and exhaust valves are maintained closed.

b) MODE 1, 2, 3, 4, or 5":

1. With one less than the Minimum Channels OPERABLE requirement for RCB Purge Radioactivity-High, within 30 days restore the inoperable channel or maintain the containment purge supply and exhaust valves closed.

NOTE:

SOUTH TEXAS - UNITS 1 & 2 3/4 3-26 Unit 1 - Amendment No. 46O Unit 2 - Amendment No. 4=9

MODE 1, 2, 3, or 4: Supplementary containment purge supply and isolation valves may be open during the allowed outage time for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months at a time for required purge operation provided the valves are under administrative control.

MODE 5"': Supplementary or Normal containment purge supply and isolation valves may be open during the allowed outage time for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months at a time for required purge operation provided the valves are under administrative control.

SOUTH TEXAS - UNITS 1 & 2 3/4 3-26 Unit 1 - Amendment No. 460 Unit 2 - Amendment No. 460

TABLE 3.3-3 (Continued)

ACTION STATEMENTS (Continued)

2. With two less than the Minimum Channels OPERABLE requirement for RCB Purge Radioactivity-High, operation may continue provided the containment purge supply and exhaust valves are maintained closed.

c) MODE 6": With less than the Minimum Channels OPERABLE requirement for RCB Purge Radioactivity - High, apply the requirements of Technical Specification 3.9.9 for an inoperable Containment Ventilation Isolation System.

NOTE:

With one less than the Minimum Channels Operable requirement for RCB Purge Radioactivity-High, Supplementary or Normal containment purge supply and isolation valves may be open for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months at a time for required purge operation provided the valves are under administrative control.

ACTION I9 19 a. WithtlenuhbtFer of OPERABIEchannels ssth-arithe'Mifmu-mChan-nels OPERABLE Requirement, within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months restore the inoperable channel to OPERABLE status or apply the requirements'of Specification 3.13.1, 'or be in at least HOT STANDBYywithin the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months knd in COLD SHUTDOWN within the following 30 h6urs'

[. b it te umerofOPERABLE cha'iinnels-mo-reithianon-e lessthaFthbMinil um-iCKannili OPERABLE requirement, within 1 'hour restore theinoperable channel to OPERABLE sstatus or apply the requirements'of Specification 3;13.1, or be In at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

ACTION 1-9A With the number of OPERABLE channels one less than the Minimum Channels OPERABLE requirement, within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months restore the Inoperable channel to OPERABLE status or apply ttih iequirements of Specification 3.13.1, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and In COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

ACTION 20 - With the number of OPERABLE channels one less than the Total Number of Channels, STARTUP and/or POWER OPERATION may proceed provided the following conditions are satisfied:

a. For Functional Units with installed bypass test capability, the inoperable channel may be placed in bypass, and must be placed in the tripped condition within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

Note: A channel may be bypassed for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for surveillance testing per Specification 4.3.2.1, provided no more than one channel is in bypass at any time.

b. For Functional Units with no installed bypass test capability,

1. The inoperable channel is placed in the tripped condition within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , and

2. The Minimum Channels OPERABLE requirement is met; however, the inoperable channel may be bypassed for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for surveillance testing of other channels per Specification 4.3.2.1.

rACTION_2OaWith the numberof OPERABLE Ehannels one leissthiantheT6tial Number of Chaninels, STARTUP and/or POWER OPERATION may proceed provided the following conditions ie satisfied:

i.-The lInopeirable chtan-nel 'ls'pac-ed'lnfthe tri~pped co-nditl6on within 72 hiour~s,;an~d 2:Thie Minimum Channeli OPERABLE ieqiirement is met; however, the Inoperable channel ay'be bypassed frW pto12 h'ouwirs for surveillance testing of other channels!

SOUTH TEXAS - UNITS 1 & 2 3/4 3-27 Unit 1 - Amendment No.

Unit 2 - Amendment No.

b. With thi inumitbrf OPERABLE channieIi iiore than one less than thfeT6tal NuibierT6f Channels, withiri 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months apply the requirements of Specification 3.13.1,'or be In at'least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and be in at least HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and be In COLD SHUTDOWN within the subsequent 24,hours.

ACTION 21 - With less than the Minimum Number of Channels OPERABLE, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months determine by observation of the associated permissive annunciator window(s) that the interlock is in its required state for the existing plant condition, or apply Specification 3.0.3.

ACTION 22 - a. With the number of OPERABLE channels one less than the Minimum Channels OPERABLE requirement, Fee hanno lIhe OPERABLEB 1inoporable R atus, wltiiin24'hours restore the inoperable channel to OPERABLE status or apply the requirements of specification 3.1 3.1,orj be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in at least HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ; however, one channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing per Specification 4.3.2.1 provided the other channel is OPERABLE.

b1-With the nutber-of OPERABLE channels more than one less tha-nthteMiiiiiTm Channels OPERABLE requirement, within one hour restore at least one inoperable Channel to OPERABLE status or apply therequirements of specification 3.13.1, or be at least HOT STANDBYwithin the'next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and In 'atleast HOT.SHUTDOWN within'the followIng 6,hours7 ACTION 23 - With the number of OPERABLE channels one less than the Total Number of Channels, restore the inoperable channel to OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or be in at least HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in at least HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

SOUTH TEXAS - UNITS 1 & 2 3/4 3-27 Unit 1 - Amendment No.

Unit 2 - Amendment No.

TABLE 3.3-3 (Continued)

ACTION STATEMENTS (Continued)

ACTION 24 - With the number of OPERABLE channels one less than the Total Number of Channels, restore the inoperable channel to OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or declare the associated valve inoperable and take the ACTION required by Specification 3.7.1.5.

ACTION 25- a. With the number of OPERABLE channels one less than the Minimum Channels OPERABLE requirement, withinii24iWhours restore the inoperable channel to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , or bapply the requirements of Spec-iication 3.i.13 3.1 7rbe in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ; however, one channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing per Specification 4.3.2.1 provided the other channel is OPERABLE.

15-With the number ofOPERABLE channels more than one less than the Minilrnuiii Channels OPERABLE requirement, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore at least one inoperable tchannel to OPERABLE status or apply the requirements of Specificatlon 3.13., or be In at least HOT STANDBY withinthe next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

ACTION 26- With the number of channels OPERABLE less than the Minimum Channels OPERABLE requirement, declare the affected Auxiliary Feed Water Pump inoperable and take ACTION required by Specification 3.7.1.2.

ACTION 27- For an inoperable channel, declare its associated ventilation train inoperable and apply the actions of Specification 3.7.7.

ACTION 28- a. With the number of OPERABLE channels one less than the Minimum Channels OPERABLE requirement, within 7 days initiate and maintain operation of the Control Room Makeup and Cleanup Filtration System (at 100% capacity) in the recirculation and makeup filtration mode.

b. With the number of OPERABLE channels two less than the Minimum Channels OPERABLE requirement, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months initiate and maintain operation of the Control Room Makeup and Cleanup Filtration System (at 100% capacity) in the recirculation and makeup filtration mode, or immediately suspend CORE ALTERATIONS, movement of irradiated fuel assemblies and crane operations with loads over the spent fuel pool, AND within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months initiate and maintain operation of the Control Room Makeup and Cleanup Filtration System (at 100% capacity) in the recirculation and makeup filtration mode. CORE ALTERATIONS, movement of irradiated fuel assemblies, and crane operations with loads over the spent fuel pool are permitted during operation of the Control Room Makeup and Cleanup Filtration System (at 100% capacity) in the recirculation and makeup filtration mode.

c. With required ACTION 28a. or 28b. not met in MODE 1,2,3, or 4, immediately suspend movement of irradiated fuel assemblies and crane operations with loads over the spent fuel pool, AND be in MODE 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in MODE 5 in the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

d. With required ACTION 28a. or 28b. not met in MODE 5 or 6, immediately suspend CORE ALTERATIONS, movement of irradiated fuel assemblies, and crane operations with loads over the spent fuel pool.

ACTION 29 - For an inoperable channel, declare its associated ventilation train inoperable and apply the actions of Specification 3.7.8.

ACTION 30- With irradiated fuel in the spent fuel pool: With the number of OPERABLE channels less than the minimum Channels OPERABLE requirement, fuel movement within the spent fuel pool or SOUTH TEXAS - UNITS 1 & 2 3/4 3-28 Unit 1 - Amendment No. 453 Unit 2 - Amendment No. 441

crane operation with loads over the spent fuel pool may proceed provided the FHB exhaust air filtration system is in operation and discharging through at least one train of HEPA filters and charcoal adsorbers.

SOUTH TEXAS - UNITS 1 & 2 3/4 3-28 Unit 1 - Amendment No. 453 Unit 2 - Amendment No. 441

l NO CHANGES I INSTRUMENTATION 3/4.3.5 ATMOSPHERIC STEAM RELIEF VALVE INSTRUMENTATION LIMITING CONDITION FOR OPERATION:

3.3.5.1 The atmospheric steam relief valve instrumentation shown in Table 3.3-14 shall be OPERABLE.

APPLICABILITY: As shown in Table 3.3-14 ACTION: As shown in Table 3.3-14 SURVEILLANCE REQUIREMENTS:

4.3.5.1 Perform a CHANNEL CHECK on each atmospheric steam relief valve automatic actuation channel at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

4.3.5.2 Perform a CHANNEL CALIBRATION on each atmospheric steam relief valve automatic actuation channel at a nominal setpoint of 1225 psig + 7 psi at least once every 18 months.

4.3.5.3 Perform an ANALOG CHANNEL OPERATIONAL TEST on each atmospheric steam relief valve automatic actuation channel at a nominal setpoint of 1225 psig +/- 7 psi at least once every 18 months.

SOUTH TEXAS - UNITS 1 & 2 3/4 3-85 Unit 1 - Amendment No. 114 Unit 2 - Amendment No. 102

0 INO CHANGES

--I m TABLE 3.3-14 x

ATMOSPHERIC STEAM RELIEF VALVE INSTRUMENTATION C

z C'n REQUIRED NO. OF APPLICABLE FUNCTIONAL UNIT CHANNELS MODES ACTION Manual actuation control 4 1, 2, 3, 4* 1 channels (1 /valve)

Automatic actuation 4 1,2# 2 co, (1 /valve) control channels CD, co 0)

C C 3 -D

=3I =3I (D(CD 3 3 3

CD CD z z 0 0

_L O -

TABLE 3.3-14 (Continued)

TABLE NOTATIONS

When steam generators are being used for decay heat removal.

Atmospheric steam relief valve(s) may be in manual operation and open, or in automatic operation, to maintain secondary side pressure at or below an indicated I steam generator pressure of 1225 psig.

ACTION STATEMENTS ACTION 1 - With the number of OPERABLE channels less than the required number of channels, declare the affected valve(s) inoperable and apply Technical Specification 3.7.1.6.

ACTION 2 - a. With one less than the required number of OPERABLE channels, within 7 days restore the inoperable channel to OPERABLE status th!n Toy ror, apply th req ii i ficiation 3.13.1; or be in at least HOT STANDBY within'the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

b. With two less than the required number of OPERABLE channels,JitVn hours restore at least three channels to OPERABLE status within 7 4U-iFso of33.1; or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

'c.With moore than two less than-the rioll OPmbeF hannels, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore at least two channels to OPERABLE status or apply the requirements of Specification 3.13.1; or be in at least HOT STANDBY within'the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

SOUTH TEXAS - UNITS 1& 2 3/4 3-87 Unit 1 - Amendment No.448 Unit 2 - Amendment No.436

REACTOR COOLANT SYSTEM OPERATING LIMITING CONDITION FOR OPERATION 3.4.2.2 All pressurizer Code safety valves shall be OPERABLE with a lift setting' of 2485 psig i 2%.2 APPLICABILITY: MODES 1, 2, and 3.

ACTION:

With one 5iimor pressurizer Code safety valves inoperable, withn'i i either restore the inoperable valve(s) to OPERABLE status ,hiW hour ur apply the requiremeits of

!cifica1o 3.13, or be in at least HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in at least HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

SURVEILLANCE REQUIREMENTS 4.4.2.2 No additional requirements other than those required by Specification 4.0.5.

'The lift setting pressure shall correspond to ambient conditions of the valve at nominal operating temperature and pressure.

2 The as left lift setting shall be within +/-1% following valve testing.

SOUTH TEXAS-UNITS 1 & 2 3/4 4-8 Unit 1 - Amendment No. 59, :78 Unit 2 - Amendment No. 4,

REACTOR COOLANT SYSTEM 3/4.4.4 RELIEF VALVES LIMITING CONDITION FOR OPERATION 3.4.4 Both power-operated relief valves (PORVs) and their associated block valves shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

ACTION:

a. With one or both PORV(s) inoperable, because of excessive seat leakage, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months either restore the PORV(s) to OPERABLE status or close the associated block valve(s) with power maintained to the block valve(s); or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

b. With one PORV inoperable due to causes other than excessive seat leakage, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months either restore the PORV to OPERABLE status or close the associated block valve and remove power from the block valve; WifhiInthe following 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months restore the PORV to OPERABLE status Within th foli

,_2_ hours orapplythe requirents o Specfiai3 or be in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

c. With both PORVs inoperable due to causes other than excessive seat leakage, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months either restore at least one of the PORVs to OPERABLE status or close their associated block valves and remove power from the block valves and pl~~ythe ens; of 'SPeqf icitiW3913.1[ or be in HOT STANDBY within;'

the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

d. With one block valve inoperable, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore the block valve to OPERABCE status or place its associated PORV in closed positionjififiii72 hours restore the block valve to OPEtA,BLE status ;ithin72-hours p! apply the requireimentiof Specificatlon 3.13.1; otherwise, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

e. With both block valves inoperable, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore the block valves to iOPERABLE status or place the associated PORVs in the closed position; restore at least one block valve to OPERABLE status within the next hour, app!~l~ie rquiremetsf Speifiation 3.13.1; otherwise, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

f. The provisions of Specification 3.0.4 are not applicable SOUTH TEXAS - UNITS 1 & 2 3/4 4-10 Unit 1 -Amendment Nob-5 Unit 2 - Amendment No. 44

3/4.5 EMERGENCY CORE COOLING SYSTEMS 3/4.5.1 ACCUMULATORS LIMITING CONDITION FOR OPERATION 3.5.1 Each Safety Injection System accumulator shall be OPERABLE APPLICABILITY: MODES 1 and 2 MODE 3 with pressurizer pressure > 1000 psig ACTION:

a. With one br more accumulators inoperable, except as a result of boron concentration outside the required limits, Within Ihoiur restore the inoperable accumulator(s) to OPERABLE status withiiin2 hourAbr aporhe requirer tsfSpcifictiozi3T13§1 or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and reduce pressurizer pressure to less than 1000 psig within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

b. With the boron concentration of one Fiibre accumulators outside the required limit, Within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore the boron concentration to within the required limits Wi722 hjou_1 o pplythe se-meftt-of Specification 3.13.1,'3r, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and reduce pressurizer pressure to less than 1000 psig within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

SURVEILLANCE REQUIREMENTS 4.5.1.1 Each accumulator shall be demonstrated OPERABLE:

a. At least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months by:

1) Verifying the contained borated water volume is 2 8800 gallons and < 9100 gallons and nitrogen cover-pressure is 2 590 psig and < 670 psig, and

2) Verifying that each accumulator isolation valve is open.

b. At least once per 31 days and within 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months s* after each solution volume increase of greater than or equal to 1% of tank volume that is not the result of addition from the RWST by verifying the boron concentration of the accumulator solution is 2 2700 ppm and

< 3000 ppm and

c. At least once per 31 days when the RCS pressure is above 1000 psig by verifying that power to the isolation valve operator is removed.

The 6 hr. SR is only required to be performed for affected accumulators SOUTH TEXAS - UNITS 1 & 2 3/4 5-1 Unit 1 -Amendment No. 61, 64, 69, 135 Unit 2 - Amendment No. 10, 43, 47, 124

EMERGENCY CORE COOLING SYSTEMS 3/4.5.2 ECCS SUBSYSTEMS - TAVG GREATER THAN OR EQUAL TO 350'F LIMITING CONDITION FOR OPERATION 3.5.2 Three independent Emergency Core Cooling System (ECCS) subsystems shall be OPERABLE with each subsystem comprised of:

a. One OPERABLE High Head Safety Injection pump,

b. One OPERABLE Low Head Safety Injection pump,

c. One OPERABLE RHR heat exchanger, and

d. An OPERABLE flow path capable of taking suction from the refueling water storage tank on a Safety Injection signal and automatically transferring suction to the containment sump during the recirculation phase of operation through a High Head Safety Injection pump and into the Reactor Coolant System and through a Low Head Safety Injection pump and its respective RHR heat exchanger into the Reactor Coolant System.

APPLICABILITY: MODES 1, 2, and 3.*

ACTION:

a. With less than the above subsystems OPERABLE, but with at least two High Head Safety Injection pumps in an OPERABLE status, two Low Head Safety Injection pumps and associated RHR heat exchangers in an OPERABLE status, and sufficient flow paths to accommodate these OPERABLE Safety Injection pumps and RHR heat exchangers,** witfi 7days restore the inoperable subsystem(s) to OPERABLE status withn days or epply-herequirements of Specificati6-313.1Xo be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

U. _Wi th' les-s thfa~n-twoof th rqure ublisy-ste-m-sOPERABLE, withinf-1'Kour restore at least one subsystem to OPERABLE status and apply the iequirerments of Specification 3.13.1, or- be in at least HOT STANDBY Withifi

-the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in -HOISHUTDOWN within the following 6hours.

E. In the event the ECCS is actuated and injects water into the Reactor Coolant System, a Special Report shall be submitted within 90 days describing the circumstances of the actuation and the total accumulated actuation cycles to date.

The current value of the usage factor for each affected Safety Injection nozzle shall be provided in this Special Report whenever its value exceeds 0.70.

The provisions of Specifications 3.0.4 and 4.0.4 are not applicable for entry into MODE 3 for the Safety Injection pumps declared inoperable pursuant to Specification 4.5.3.1.2 provided that the Safety Injection pumps are restored to OPERABLE status within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months or prior to the temperature of one or more of the RCS cold legs exceeding 3750F, whichever comes first.

- Verify required pumps, heat exchangers and flow paths OPERABLE every 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months .

SOUTH TEXAS - UNITS 1 & 2 3/4 5-3 Unit 1 - Amendment No. 161-Unit 2 - Amendment No. 439

EMERGENCY CORE COOLING SYSTEMS 3/4.5.5 REFUELING WATER STORAGE TANK LIMITING CONDITION FOR OPERATION 3.5.5 The refueling water storage tank (RWST) shall be OPERABLE with:

a. A minimum contained borated water volume of 458,000 gallons, and

b. A boron concentration between 2800 ppm and 3000 ppm.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTION:

With the RWST inoperable withinIihour restore the tank to OPERABLE status Hihi or 5i y0threirem ents of Sp6cification3.13.1, or be in at least HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

SURVEILLANCE REQUIREMENTS 4.5.5 The RWST shall be demonstrated OPERABLE at least once per 7 days by:

a. Verifying the contained borated water volume in the tank, and

b. Verifying the boron concentration of the water.

SOUTH TEXAS - UNITS 1 & 2 3/4 5-10 Unit 1 - Amendment No. 64 Unit 2 - Amendment No. 43

EMERGENCY CORE COOLING SYSTEMS 3/4.5.6 RESIDUAL HEAT REMOVAL (RHR) SYSTEM LIMITING CONDITION FOR OPERATION 3.5.6 Three independent Residual Heat Removal (RHR) loops shall be OPERABLE with each loop comprised of:

a. One OPERABLE RHR pump,

b. One OPERABLE RHR heat exchanger, and

c. One OPERABLE flowpath capable of taking suction from its associated RCS hot leg and discharging to its associated RCS cold leg.*

APPLICABILITY: MODES 1, 2 and 3.

ACTION:

a. With one RHR loop inoperable, WitKiiT7dgays restore the required loop to OPERABLE status daysor then7 rem tf Specificion

.13.1 or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

b. With two RHR loops inoperable, itfiiW24 restore at least two RHR loops to OPERABLE status itin2 hrreuir ents of Specification-3.13.1,1orj be in at least HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

c. With three RHR loops inoperable, immediately initiate corrective action to restore at least one RHR loop to OPERABLE status as soon as possible.

SURVEILLANCE REQUIREMENTS 4.5.6.1 Each RHR loop shall be demonstrated OPERABLE on a STAGGERED TEST BASIS pursuant to the requirements of Specification 4.0.5.

4.5.6.2 At least once per 18 months by verifying automatic interlock action of the RHR system from the Reactor Coolant System to ensure that:

a. With a simulated or actual Reactor Coolant System pressure signal greater than or equal to 350 psig, the interlocks prevent the valves from being opened.

Valves MOV-0060 A, B, and C and MOV-0061 A, B, and C may have power removed to support the FHAR (Fire Hazard Analysis Report) assumptions.

SOUTH TEXAS - UNITS 1 & 2 3/4 5-11 Unit 1 - Amendment No. 69 Unit 2 - Amendment No. 47

CONTAINMENT SYSTEMS CONTAINMENT VENTILATION SYSTEM LIMITING CONDITION FOR OPERATION 3.6.1.7 Each containment purge supply and exhaust isolation valve shall be OPERABLE and:

a. Each 48-inch containment shutdown purge supply and exhaust isolation valve shall be closed and sealed closed, and

b. The 18-inch supplementary containment purge supply and exhaust isolation valves shall be closed to the maximum extent practicable but may be open for supplementary purge system operation for pressure control, for ALARA and respirable air quality considerations for personnel entry and for surveillance tests that require the valves to be open.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTION:

a. With a 48-inch containment purge supply and/or exhaust isolation valve open or not sealed closed, close and/or seal close that valve or isolate the penetration(s) within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , otherwise be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

b. With the 18-inch supplementary containment purge supply and/or exhaust isolation valve(s) open for reasons other than given in Specification 3.6.1 .7.b.

above, within 4hou'rs close the open 18-inch valve(s) or isolate the penetration(s) W nthi'-4-hs, e rem 3.1 3.1,-or3 b m sobe in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

c. With a containment purge supply and/or exhaust isolation valve(s) having a measured leakage rate in excess of the limits of Specifications 4.6.1.7.2 and/or 4.6.1.7.3, iiii1n _4 hiioiu restore the inoperable valve(s) to OPERABLE status or isolate the penetrations so that the measured leakage rate does not exceed the limits of Specifications 4.6.1.7.2 and/or 4.6.1.7.3 i+/-~hk 4 or lfply trq irmnsof fi~cation 3. otherwise be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

SOUTH TEXAS - UNITS 1 & 2 3/4 6-12 Unit 1 -Amendment No.

Unit 2 - Amendment No.

CONTAINMENT SYSTEMS 3/4.6.2 DEPRESSURIZATION AND COOLING SYSTEMS CONTAINMENT SPRAY SYSTEM LIMITING CONDITION FOR OPERATION 3.6.2.1 Three independent Containment Spray Systems shall be OPERABLE with each Spray System capable of taking suction from the RWST and transferring suction to the containment sump.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTION:

a. With one Containment Spray System inoperable,within 7 daysrestore the inoperable Spray System to OPERABLE status Wthi7Jdays or apply the 'requirements of Specificitini3.13.71,o6r be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ;t inoporablo Spray SyRtimnitsOPERABLE f hours or be and in COLD SHUTDOWN within the following 8O.30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

b.TWithmioreithanone C6ntainme-ntSjray Shstiminoperablewithin1' hour restore at least one inoperable Spray System to OPERABLE status or apply the requirements'of Specification 3.13.1, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWNwithin the'following'30_hoursI SURVEILLANCE REQUIREMENTS 4.6.2.1 Each Containment Spray System shall be demonstrated OPERABLE:

a. At least once per 31 days by verifying that each valve (manual, power-operated, or automatic) in the flow path that is not locked, sealed, or otherwise secured in position, is in its correct position;

b. By verifying on a STAGGERED TEST BASIS, that on recirculation flow, each pump develops a differential pressure of greater than or equal to 283 psid when tested pursuant to Specification 4.0.5;

c. At least once per 18 months during shutdown, by:

1) Verifying that each automatic valve in the flow path actuates to its correct position on a Containment Pressure High 3 test signal, and

2) Verifying that each spray pump starts automatically on a Containment Pressure High 3 test signal coincident with a sequencer start signal.

d. By verifying each spray nozzle is unobstructed following maintenance activities that could result in spray nozzle blockage.

SOUTH TEXAS - UNITS 1 & 2 3/4 6-14 Unit 1 - Amendment No. 466 Unit 2 - Amendment No. 444

CONTAINMENT SYSTEMS CONTAINMENT COOLING SYSTEM LIMITING CONDITION FOR OPERATION 3.6.2.3 Three independent groups of Reactor Containment Fan Coolers (RCFC) shall be OPERABLE with a minimum of two units in two groups and one unit in the third group.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTION:

a. With one group of the above required Reactor Containment Fan Coolers inoperable, Wthiin 7daysrestore the inoperable group of RCFC to OPERABLE status within s or apply the requirements of Specification 3.13.1, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

b. With moirethan one grouip of the aibove required Reactor Containment Fan Coolers inoperable, within 1hour restore at least two groups of RCFC to OPERABLE status or apply the requirements of Specification 3.13.1, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

SURVEILLANCE REQUIREMENTS 4.6.2.3 Each group of Reactor Containment Fan Coolers shall be demonstrated OPERABLE:

a. At least once per 92 days by:

1) Starting each non-operating fan group from the control room, and verifying that each fan group operates for at least 15 minutes, and

2) Verifying a component cooling water flow rate of greater than or equal to 1800 gpm to each cooler.

a. At least once per 18 months by verifying that each fan group starts automatically on a Safety Injection test signal.

SOUTH TEXAS - UNITS 1 & 2 3/4 6-16 Unit 1 - Amendment No. -74 Unit 2 - Amendment No. 63

CONTAINMENT SYSTEMS 3/4.6.3 CONTAINMENT ISOLATION VALVES LIMITING CONDITION FOR OPERATION 3.6.3 The containment isolation valves shall be OPERABLE with isolation times less than or equal to the required isolation times.

APPLICABILITY: MODES 1, 2,3, and 4.

ACTION:

With one or more of the isolation valve(s) inoperable, maintain at least one isolation barrier* OPERABLE in each affected penetration that is open and WithiIW24 Ilursi:

a. Restore the inoperable valve(s) to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , or

b. Isolate each affected penetration iithin241ior by use of at least one deactivated automatic valve secured in the isolation position, or check valve with flow through the valve secured"*, or

c. Isolate each affected penetration WitinH 21 i by use of at least one closed manual valve or blind flange, or atone'p-pythte refirtieme~nts ~of Spec fica-fo6n 3.13._1 Or Be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

SURVEILLANCE REQUIREMENTS 4.6.3.1 The isolation valves shall be demonstrated OPERABLE prior to returning the valve to service after maintenance, repair or replacement work is performed on the valve or its associated actuator, control or power circuit by performance of a cycling test, and verification of isolation time.

4.6.3.2 Each isolation valve shall be demonstrated OPERABLE during the COLD SHUTDOWN or REFUELING MODE at least once per 18 months by:

a. Verifying that on a Phase "A" Isolation test signal, each Phase NAB isolation valve actuates to its isolation position;

b. Verifying that on a Containment Ventilation Isolation test signal, each purge and exhaust valve actuates to its isolation position; and

c. Verifying that on a Phase "BN Isolation test signal, each Phase NB" isolation valve actuates to its isolation position.

d. Verifying that on a Phase "A" Isolation test signal, coincident with a low charging header pressure signal, that each seal injection valve actuates to its isolation position.

4.6.3.3 The isolation time of each power-operated or automatic valve shall be determined to be within its limit when tested pursuant to Specification 4.0.5.

An isolation barrier may either be a closed system (i.e., General Design Criteria 57 penetrations) or an isolation valve.

- A check valve may not be used to isolate an affected penetration flow path in which more than one isolation valve is inoperable or in which the isolation barrier is a closed system with a single isolation valve (i.e., General Design Criteria 57 penetration)

SOUTH TEXAS - UNITS 1 & 2 3/4 6-17 Unit 1 -Amendment No. 69, 113 Unit 2 -Amendment No. 47, 101

PLANT SYSTEMS AUXILIARY FEEDWATER SYSTEM LIMITING CONDITION FOR OPERATION 3.7.1.2 Four independent steam generator auxiliary feedwater pumps and associated flow paths shall be OPERABLE with:

a. Three motor-driven auxiliary feedwater pumps, each capable of being powered from separate emergency busses, and

b. One steam turbine-driven auxiliary feedwater pump capable of being powered from an OPERABLE steam supply system.

APPLICABILITY: MODES 1, 2, and 3.

ACTION:

a. With one motor-driven auxiliary feedwater pump inoperable, restore the pump to OPERABLE status within 28 days.

b. With the turbine-driven auxiliary feedwater pump inoperable, or with any two auxiliary feedwater pumps inoperable, ihin 72 h1ours restore the affected auxiliary feedwater pump(s) to OPERABLE statusA, it, um br' aqppyljth requiremients

' of Spej cificatioin 3.1 . The provisions of Specification 3.0.4 are not applicable for entry into Mode 3 for the turbine-driven pump.

c. With three auxiliary feedwater pumps inoperable, or if the required action and associated allowed outage time for a) or b) is not met, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

d. With four auxiliary feedwater pumps inoperable, immediately initiate action to restore at least one auxiliary feedwater pump to OPERABLE status as soon as possible. LCO 3.0.3 and all other LCO actions requiring Mode changes are suspended until one of the four inoperable auxiliary feedwater pumps is restored to OPERABLE status.

SOUTH TEXAS - UNITS 1 & 2 3/4 7-4 Unit 1-Amendment No. 446 Unit 2 - Amendment No. 434

PLANT SYSTEMS AUXILIARY FEEDWATER STORAGE TANK LIMITING CONDITION FOR OPERATION 3.7.1.3 The auxiliary feedwater storage tank (AFST) shall be OPERABLE with a contained water volume of at least 485,000 gallons of water.

APPLICABILITY: MODES 1, 2, and 3.

ACTION:

With the AFST inoperable, within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months restore the AFST to OPERABLE status B yippir the~requireimits of S .131 o -'ificatio be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

SURVEILLANCE REQUIREMENTS 4.7.1.3 The AFST shall be demonstrated OPERABLE at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months by verifying the contained water volume is within its limits.

SOUTH TEXAS - UNITS 1 & 2 3/4 7-6 Unit 1 - Amendment No. 33 Unit 2 - Amendment No. 24

PLANT SYSTEMS MAIN STEAM LINE ISOLATION VALVES LIMITING CONDITION FOR OPERATION 3.7.1.5 Each main steam line isolation valve (MSIV) shall be OPERABLE.

APPLICABILITY: MSIVs open In MODES 1, 2, and 3 ACTION:

With H a MSIV inoperable u ponPOWER OPERATION may-continue proided withini hour close or restore the inoperable valve is restered to OPERABLE status, or apply the repquiFments of Sei ti; otherwise be in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

ote meach Miv SURVEILLANCE REQUIREMENTS 4.7.1.5 Each MSIV shall be demonstrated OPERABLE by verifying full closure within 5 seconds when tested pursuant to Specification 4.0.5. The provisions of Specification 4.U.4 are not applicable for entry into MuODE i.

SOUTH TEXAS - UNITS 1 &2 3/4 7-9 Unit 1 - Amendment No.

Unit 2 - Amendment No.

PLANT SYSTEMS ATMOSPHERIC STEAM RELIEF VALVES LIMITING CONDITION FOR OPERATION 3.7.1.6 At least four atmospheric steam relief valves shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4.*

ACTION:

a. With one less than the required atmospheric steam relief valves OPERABLE, Ith-ii7 i restore the required atmospheric steam relief valves to OPERABLE status C 4y the 7r qiliipficaton- .1 3.t or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and place the required RCS/RHR loops in operation for decay heat removal.

b. With two of more less than the required atmospheric relief valves OPERABLE, WIthini

>-hour restore at least three atmospheric relief valves to OPERABLE status within 72 hus Fppyth qirsm onsf SPecifct 331 O be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and place the required RCS/RHR loops in operation for decay heat removal.

SURVEILLANCE REQUIREMENTS 4.7.1.6 Each atmospheric relief valve shall be demonstrated OPERABLE prior to startup following any COLD SHUTDOWN of 30 days or longer or following any refueling shutdown, by verifying that all valves will open and close fully by operation of automatic and manual controls.

When steam generators are being used for decay heat removal.

SOUTH TEXAS - UNITS 1 & 2 3/4 7-10 Unit 1 - Amendment No. 444 Unit 2 - Amendment No. 402

PLANT SYSTEMS MAIN FEEDWATER SYSTEM LIMITING CONDITION FOR OPERATION 3.7.1.7 Each main feedwater isolation valve (MFIV) shall be OPERABLE.

APPLICABILITY: tilein MODES 1, 2, and 3.

ACTION:

MODES 1 and 2: With a ene MFIV inoperable witin., c lose or restore the valve to vperable ma" continue p roided tho inoporabl

'alvo is rostored to OPERABLE status Within-4-hous or apply the pequirements of !Secification2 3.13.1; otherwise be in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

Note: Separate condition entry is permitted for each MFIV.

MODE 3 _ With ono MFIV'inoV-perablo, b opnt oeration in MODE-3 mar" ro6nd proidod the iselatioR valve is mRaiRt nodcps. dQther:6 be in HOT SHUTDOWN within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

SURVEILLANCE REQUIREMENTS 4.7.1.7 Each MFIV shall be demonstrated OPERABLE by verifying full closure within 10 seconds when tested pursuant to Specification 4.0.5. The provisions of specification 4.0.4 are not applicable for entry into MODE 3.

SOUTH TEXAS - UNITS 1 & 2 3/4 7-1 Oa Unit 1 - Amendment No. 4-9 Unit 2 - Amendment No. 9

PLANT SYSTEMS 3/4.7.3 COMPONENT COOLING WATER SYSTEM LIMITING CONDITION FOR OPERATION 3.7.3 At least three independent component cooling water loops shall be OPERABLE.

APPLICABILITY: MODES 1, 2,3, and 4.

ACTION:

a. With only two component cooling water loops OPERABLE, WfitilE1day-s restore at least three loops to OPERABLE status or hquirements of Specifict*ionL3.13.1, ob be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

E.With two or more component cooling7wter loops inoerable,-within1fh least two loopsito OPERABLE status or apply the requirements of Specification 3.13.1, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the ifo'lowing'30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

SURVEILLANCE REQUIREMENTS 4.7.3 At least three component cooling water loops shall be demonstrated OPERABLE:

a. At least once per 31 days by verifying that each valve outside containment (manual, power-operated, or automatic) servicing safety-related equipment that is not locked, sealed, or otherwise secured in position is in its correct position; and

b. At least once per 18 months by verifying that:

1) Each automatic valve servicing safety-related equipment or isolating the non-nuclear safety portion of the system actuates to its correct position on a Safety Injection, Loss of Offsite Power, Containment Phase UB" Isolation, or Low Surge Tank test signal, as applicable (performed during shutdown);

2) Each Component Cooling Water System pump starts automatically on a Safety Injection or Loss of Offsite Power test signal (performed during shutdown); and

3) The surge tank level instrumentation which provides automatic isolation of portions of the system is demonstrated OPERABLE by performance of a CHANNEL CALIBRATION test.

c. By verifying that each valve inside containment (manual, power-operated, or automatic) servicing safety-related equipment that is not locked, sealed, or otherwise secured in position is in its correct position prior to entering MODE 4 following each COLD SHUTDOWN of greater than 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months if not performed within the previous 31 days.

SOUTH TEXAS - UNITS 1 & 2 3/4 7-12 Unit 1 - Amendment No. 4,69,91

- Unit 2 - Amendment No. 47,78

PLANT SYSTEMS 3/4.7.4 ESSENTIAL COOLING WATER SYSTEM LIMITING CONDITION FOR OPERATION 3.7.4 At least three independent essential cooling water loops shall be OPERABLE.

APPLICABILITY: MODES 1, 2,3, and 4.

ACTION:

a, With only two essential cooling water loops OPERABLE, Withiii-Tdays restore at least three loops to OPERABLE status Pi`hkin 7days apl the requirements of Specification 3.

or' be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

b. Withftwo -ormore essential cooling waer loops k~o iWfiviwithiii hiour restore' at1eia'st two loops to OPERABLE status or apply the requirements of Specification 3.13.1, or. be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months candiin COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

SURVEILLANCE REQUIREMENTS 4.7.4 At least three essential cooling water loops shall be demonstrated OPERABLE:

a. At least once per 31 days by verifying that each valve (manual, power-operated, or automatic) servicing safety-related equipment that is not locked, sealed, or otherwise secured in position is in its correct position;

b. At least once per 18 months during shutdown, by verifying that:

1) Each Essential Cooling Water automatic valve in the flow path that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal, and

2) Each Essential Cooling Water pump starts automatically on an actual or simulated signal.

SOUTH TEXAS - UNITS 1 & 2 3/4 7-13 Unit 1 - Amendment No. 42 Unit 2 - Amendment No. 445

PLANT SYSTEMS 3/4.7.14 ESSENTIAL CHILLED WATER SYSTEM LIMITING CONDITION FOR OPERATION 3.7.14 At least three independent Essential Chilled Water System loops shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTION:

a. With only two Essential Chilled Water System loops OPERABLE, withi-7 restoreat least three loops to OPERABLE status lI- L aorpplythe requirements of iecition 3.113.1, orJ be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

b. WEth, o or more Essential ChiiiWti -e loops inoperable, within hour restore at least two loops to OPERABLE status or apply the requir6ments of Specification 3.13.1, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and In COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months SURVEILLANCE REQUIREMENTS 4.7.14 The Essential Chilled Water System shall be demonstrated OPERABLE by:

a. Performance of surveillances as required by Specification 4.0.5, and

b. At least once per 18 months by demonstrating that the system starts automatically on a Safety Injection test signal.

SOUTH TEXAS - UNITS 1 & 2 3/4 7-33 Unit 1 - Amendment No. 85 Unit 2 - Amendment No. -2

3/4.8 ELECTRICAL POWER SYSTEMS 3/4.8.1 A.C. SOURCES OPERATING LIMITING CONDITION FOR OPERATION 3.8.1.1 As a minimum, the following A.C. electrical power sources shall be OPERABLE.

a. Two physically independent circuits between the offsite transmission network and the onsite Class 1E Distribution System('), and

b. Three separate and independent standby diesel generators, each with a separate fuel tank containing a minimum volume of 60,500 gallons of fuel, and an automatic load sequencer.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTION:

a. With one offsite circuit of the above-required A.C. electrical power sources inoperable, demonstrate the OPERABILITY of the remaining A.C. sources by performing Surveillance Requirement 4.8.1.1.1 .a within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter.Within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months iret6re the offsite circuit to OPERABLE status within iT or Fjpt- the requirements of

'Pecif iEafi n or be inat least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

b. With a standby diesel generator inoperable, demonstrate the OPERABILITY of the above-required A.C. offsite sources by performing Surveillance Requirement 4.8.1.1.1 .a within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter. If the standby diesel generator became inoperable due to any cause other than an inoperable support system, an independently testable component, or preplanned preventive maintenance or testing, demonstrate the OPERABILITY of the remaining OPERABLE standby diesel generators by performing Surveillance Requirement 4.8.1.1.2.a.2) for each such standby diesel generator separately within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , unless it can be demonstrated there is no common mode failure for the remaining diesel generator(s)._litfiin 14 days restoFr the inoperable standby diesel generator to OPERABLE status WhiR 4-daye or 'apply the requirements of Speificaion3.13.1 r be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .(12)

c. With one offsite circuit of the above-required A.C. electrical power sources and one standby diesel generator inoperable, demonstrate the OPERABILITY of the remaining A.C. sources by performing Specification 4.8.1.1.1 a. within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter; and if the standby diesel generator became inoperable due to any cause other than an inoperable support system, an independently testable component, or preplanned preventive SOUTH TEXAS - UNITS 1 & 2 3/4 8-1 Unit 1 - Amendment No. 85 Unit 2 - Amendment No. 72,-48

ELECTRICAL POWER SYSTEMS LIMITING CONDITION FOR OPERATION ACTION (Continued) maintenance or testing, demonstrate the OPERABILITY of the remaining OPERABLE standby diesel generator(s) by performing Surveillance Requirement 4.8.1.1.2a.2) within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , unless it can be demonstrated there is no common mode failure for the remaining diesel generators; wi l2hours restore at least one of the inoperable sources to OPERABLE status PiF in'T ii6s or applyte requierements of Specif icaion, 1 ,~oi be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . Restoro at least two 'offsite crc OPERABLE titHin7_hours and three ctandbA diosol gonorators to OPERABEI CtPatu within 3 o itial or be in at loast HOTSTANDBY ikithin the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD, SHU TDOWN within tho followin~g 30 hour3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months sYZ2

d. With one standby diesel generator inoperable in addition to ACTION b. or c. above, vify that ithinl 24-iours apply the re'quirements of Specification 3.13.1; or, beiiiFatleast HOTSTANDBY~withiri the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in'COLD SHUTDOWN within'the following,30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

lZl ^1 riliror 6wtorL iltms taincomp Or an~ th~lfi6tid 2ron rn tho romtntnrs OPERABLE die6el'gonerators as a sourco of morgoncy-powr aalso OPERABLE, and

2;Wo in MO-E t;3h,;~rvnAxFir odw riOERABLtE.

TA -itfiiMiDE

5~

If-those cond-itiND fNtivfiod withii2hous'boins S B and in COID SHUTDOWN within theonllowinrg 30 hour3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months s:

rours

e. With two of the above required offsite A.C. circuits inoperable, withini24i-'iui-s restore at least one of the inoperable offsite sources to OPERABLE status Witlii 7 1'24 urs or 'apply there uie-fent9f r

Specification 3.13.1, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . With only ono 6ffsio source rostorod, rostore at circuitOPERABLE status within 7" hours from tire of initial loss or be in at least HOLSTAND1Y3within tho noext6: hours and in COLD SHUTDOWN within the following .30hours:

f. With two or three of the above required standby diesel generators inoperable, demonstrate the OPERABILITY of two offsite A.C. circuits by performing the requirements of Specification 4.8.1.1.1 a.

within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter; w-iith2 hours restore at least one standby diesel generator to OPERABLE status Vland apply the requirements of Specification 3.13.1, or a two standby d ionnbratort6 OPERABIE , iFil ih be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

Restore at' least thretndby dil geeatorsOE A I sttu wPA ithin 11 days from time f initial loss or-bo i6 at0least HOT STANDBY within'thoinxt 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months s9a0d in COLD SHUTDOWN withi tho following 30 hour3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months sY' 2>

SOUTH TEXAS - UNITS 1 & 2 3/4 8-2 Unit 1 -Amendment No. 85 Unit 2 -Amendment No. 72, 148

ELECTRICAL POWER SYSTEMS 3/4.8.2 D.C. SOURCES OPERATING LIMITING CONDITION FOR OPERATION 3.8.2.1 As a minimum, the following D.C. electrical sources shall be OPERABLE:

a. Channel I 125-volt Battery Bank ElAl 1(Unit 1), E2A1 1 (Unit 2) and one of its two associated chargers,

b. Channel 11125-volt Battery Bank El Dl1 (Unit 1), E2Dl 1 (Unit 2) and one of its two associated full capacity chargers,

c. Channel III 125-volt Battery Bank El Bi 1 (Unit 1), E2B1 1 (Unit 2) and one of its two associated full capacity chargers, and

d. Channel IV 125-volt Battery Bank El C11 (Unit 1), E2C1 1 (Unit 2) and one of its two associated chargers.

APPLICABILITY: MODES 1, 2,3, and 4.

ACTION:

Wnithlessthan the required battery banks or battery chargers OPERABL:E, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore thi Inoperable battery bank or battery charger, or apply the requirements of Speclfication'3.13.1, or be In at least HOT STANDBY within the next 6,hours and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

btatu- within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months r bo in at loast HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD HUD O wi'thin thoIfo!IAwing 3n hourcw is. 'Wih~hater c ar Hr~noPERA~BLErsooa iE6;f l3batfiery go toi 12CRAR IsRtatus w.ithi hurs or in HOT STANDBYhwithin the next 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months andin

.rnO nLQ UTD withi;!h9!follwi.;ng .30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

SURVEILLANCE REQUIREMENTS 4.8.2.1 Each 125-volt battery bank and charger shall be demonstrated OPERABLE:

a. At least once per 7 days by verifying that:

1) The parameters in Table 4.8-2 meet the Category A limits, and

2) The total battery terminal voltage is greater than or equal to 129 volts on float charge.

SOUTH TEXAS - UNITS 1 & 2 3/4 8-10 Unit 1 - Amendment No. 4-3 Unit 2 - Amendment No. 2

ELECTRICAL POWER SYSTEMS NO CHANGES 3/4.8.3 ONSITE POWER DISTRIBUTION OPERATING LIMITING CONDITION FOR OPERATION 3.8.3.1 The following electrical busses shall be energized in the specified manner:

a. Train A A.C. ESF Busses consisting of:

1) 4160-Volt ESF Bus # EIA (Unit 1), E2A (Unit 2), and

2) 480-Volt ESF Busses # EIAI and EIA2 (Unit 1), E2AI and E2A2 (Unit 2) from respective load center transformers.

b. Train B A.C. ESF Busses consisting of:

1) 4160-Volt ESF Bus # EIB (Unit 1), E2B (Unit 2), and

2) 480-Volt ESF Busses # El B1 and EIB2 (Unit 1), E2BI and E2B2 (Unit 2) from respective load center transformers.

c. Train C A.C. ESF Busses consisting of:

1) 4160-Volt ESF Bus # EIC (Unit 1), E2C (Unit 2), and

2) 480-Volt ESF Busses # EICI and EIC2 (Unit 1), E2CI and E2C2 (Unit 2) from respective load center transformers.

d. 120-Volt A.C. Vital Distribution Panels DP1201 and DP001 energized from their associated inverters connected to D.C. Bus # EIAII* (Unit 1), E2AII* (Unit 2), .

e. 120-Volt A.C. Vital Distribution Panel DP1202 energized from its associated inverter connected to D.C. Bus # EIDII* (Unit 1), E2DII* .(Unit 2),

f. 120-Volt A.C. Vital Distribution Panel DP1203 energized from its associated inverter connected to D.C. Bus # EIBII* (Unit 1), E2BII* (Unit 2),

g. 120-Volt A. C. Vital Distribution Panels DP1204 and DPOO2 energized from their associated inverters connected to D. C. Bus #E1 Cl1 * (Unit 1), E2C1 1* (Unit 2),

h. 125-Volt D. C. Bus ElAl 1 (Unit 1) E2A1 1 (Unit 2) energized from Battery Bank ElAl1 (Unit 1), E2A11 (Unit 2),

i. 125-Volt D. C. Bus El Dl1 (Unit 1) E2OD1 1 (Unit 2) energized from Battery Bank El Dl1 (Unit 1), E2D1 1 (Unit 2),

j. 125-Volt D. C. Bus El B1 1 (Unit 1) E2B1 1 (Unit 2) energized from Battery Bank El B1 1 (Unit 1), E2B1 1 (Unit 2), and

k. 125-Volt D. C. Bus El Cl 1 (Unit 1) E2CI 1 (Unit 2) energized from Battery Bank ElCl1 (Unit 1), E2C11 (Unit 2).

The inverter(s) associated with one channel may be disconnected from its D.C. bus for up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months as necessary, for the purpose of performing an equalizing charge on its associated battery bank provided: (1)its vital distribution panels are energized, and (2)the vital distribution panels associated with the other battery banks are energized from their associated inverters and connected to their associated D.C. busses.

SOUTH TEXAS - UNITS 1 & 2 3/4 8-14 Unit 1 - Amendment No. 4 Unit 2 - Amendment No.

ELECTRICAL POWER SYSTEMS LIMITING CONDITION FOR OPERATION (Continued)

APPLICABILITY: MODES 1, 2,3, and 4.

ACTION:

a. With ow-of the required trains of A.C. ESF busses not fully energized, Wit honur reenergize the train within8 hour or 'apply therequirements _f Spficatlin'3.13.T,

i. be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

b. With one rmore A.C. vital distribution panel,() either not energized from its associated inverter, or with the inverter not connected to its associated D.C. bus(1) itfi I sii 'or applythe requirements of

pecification-3.13.1, or: be in'at least HOT-STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and iin

,OLD SHUTDOWN within the'following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months ;'.and (2) within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months reenergize the A.C. vital distribution panel(s) from its associated inverter connected to its associated D.C. bus w'ti T'hou or piyptheirequiremnents of or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

c. With one or more D.C. bus(is) not energized from its associated battery bank, ithin1 hour reenergize the D.C. busj(s) from its associated battery bank Wihin or ours rppeyequir'menits-6 Spe ificiati . ic be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

SURVEILLANCE REQUIREMENTS 4.8.3.1 The specified busses shall be determined energized in the required manner at least once per 7 days by verifying correct breaker alignment and indicated voltage on the busses.

SOUTH TEXAS - UNITS 1 & 2 3/4 8-15 Unit 1 -Amendment No.

Unit 2 - Amendment No.

3/4.13 RISK MANAGEMENT 3/4.13.1 ALLOWED OUTAGE TIME DETERMINATIONS LIMITING CONDITION FOR OPERATION 3.13.1 When referred to this specification, equipment that has been declared inoperable shall be evaluated for its impact on plant risk and allowed outage times determined accordingly.

APPLICABILITY: As required by the referencing specification(s)

ACTION:

Determine that the configuration is acceptable for extension of the allowed outage time beyond the allowed outage time for the referencing specification(s),

AND Determine that the configuration is acceptable for continued operation beyond the allowed outage time for the referencing specification(s) whenever configuration changes occur that may affect plant risk, AND Restore required inoperable subsystem, component to OPERABLE status within the acceptable allowed outage time extension or 30 days, whichever is shorter.

Note: The 30-day limitation may be applied individually to each specification for which Specification 3.13.1 has been entered.

OR Take the ACTION(s) required in the referencing specification(s) for required action or completion time not met SURVEILLANCE REQUIREMENTS 4.13.1 As required by the referencing specification(s)

SOUTH TEXAS - UNITS 1 & 2 3/4 13-1 Unit 1 - Amendment No.

Unit 2 - Amendment No.

Bases for Specification 3.13.1 Specification 3.13.1 establishes provisions for performing a risk assessment to determine required actions and allowed outage times for specifically identified specifications for structures, systems, and components. Application of the risk assessment is consistent with the requirements of the Maintenance Rule, 10CFR50.65(a)(4), to assess and manage the increase in risk that may result from maintenance activities. The process to manage the risk assesses the rate of accumulation of risk in plant configurations and determines the allowed outage time (AOT) by calculating the time required to cross a Potentially Risk-significant Threshold (1.OE-05).

Application of the risk assessment to manage allowed outage time in different plant configurations is complemented by the station's programs to monitor performance indicators for long-term availability of risk-significant components. The requirement to achieve acceptable long-term performance indicators provides a significant disincentive to the potential to regularly extend baseline AOTs to the detriment of availability.

TS 3.13.1.a establishes the conditions for performance of the risk assessment. The LCOs subject to the Configuration Risk Management Program (CRMP) specifically reference TS 3.13.1. The baseline AOT or required completion time specified in the LCO may be used to apply the TS 3.13.1 to determine an alternate AOT and compensatory actions.

The requirement to continuously determine the acceptabilityiof the plant means that once the subject LCO has exceeded the baseline AOT, the risk assessment must be reperformed as needed to determine the required action and time limits for any TS component that subsequently becomes inoperable. This requirement provides assurance that the configuration risk is adequately assessed. In a configuration with multiple LCOs not met, the risk assessment may determine that the AOT is shorter than what would be allowed by the baseline time in the affected LCOs. With more than one LCO not met, the baseline time for a subsequent inoperable TS component might also be a non-conservative time to perform a risk assessment to determine the appropriate required action and time. Consequently, the risk assessment process may also be applied to determine how much time is available to perform a risk assessment for subsequent inoperable TS components.

TS 3.13.1 is applied with the referencing specification and the ACTION required by the referencing specification must be taken if the configuration risk exceeds the Potentially Risk-significant Threshold. It recognizes that the plant is in an extended AOT that has a specified required action if the required action time is exceeded. In a configuration where the risk exceeds the Potentially Risk-significant Threshold, the calculated AOT has been exceeded and the action required at the expiration of LCO AOT must be taken. If more than one LCO is beyond its frontstop time, the LCO with the most limiting required action must be followed.

Application of TS 3.13.1 will provide for more than one train of a function to be inoperable.

However, pre-planned entry into configurations where there is a complete loss of function (e.g.,

all three trains of ECW or all channels of an actuation logic) is not permitted.

TS 3.13.1 establishes a backstop AOT of 30 days. This backstop AOT prevents allowing a component with little or no risk significance from being inoperable indefinitely and resulting in a defacto change to the design or licensing basis of the plant. The note allows the 30-day backstop to be applied individually to specifications for which TS 3.13.1 is being used.

Implementation Examples NOC-AE-03001466 Attachment 3 Implementation Examples

Implementation Examples NOC-AE-03001466 Attachment 3 Page 1 In addition to the CRMP, STPNOC also has a procedure that prescribes and governs compensatory actions to be implemented for the extended AOTs for the standby diesel generators and associated support systems and for the auxiliary feedwater system.

Implementation of the proposed risk informed Technical Specifications will introduce the ability to extend many more AOTs. As discussed in this application, the CRMP will be used to determine the AOT extension and to identify the need for any compensatory action. STPNOC plans to consolidate the requirements for identifying compensatory actions into a single procedure, the CRMP procedure. The CRMP generally will not prescribe the specific compensatory actions for each configuration. Those actions will be determined based on a case-by-case basis.

The CRMP procedure establishes the thresholds for compensatory action and is the implementing procedure for both the risk informed Technical Specifications and the Maintenance Rule (a)(4) risk assessment. Imposing a compensatory action for a given plant configuration will be independent of the source of the need for the action. For instance, if the 1.OE-06 threshold is crossed, even with all TS actions within their frontstop time, the CRMP will require the implementation of appropriate compensatory action.

The examples in this attachment depict how the risk-informed Technical Specifications and the CRMP would be applied. As discussed earlier, STPNOC's implementation of the risk-informed Technical Specifications will be based on the NEI Risk Managed Technical Specifications Guide.

A component can be functional for its purpose in the PRA but not meet the TS definition of OPERABLE. For the purpose of tracking the AOT, the TS ACTION is entered when it is determined that the affected component does not meet the TS definition of OPERABLE and may not be exited until either the component meets the TS definition of OPERABLE or the actions required by the TS have been performed.

Extended AOTs calculated in accordance with TS 3.13.1 may be based on the functionality of the affected component. For instance, a component may be declared inoperable if it is found not to meet seismic design requirements. However, the component is still functional and the AOT calculated for the component will account for the component being functional. The component would not be declared OPERABLE until the seismic design requirements were met.

If the component was not restored to OPERABLE status within the AOT calculated in accordance with TS 3.13.1 or the 30-day backstop (whichever is shorter), the LCO for the component would not be met and the plant would have to take the ACTION required.

A component is considered functional if it meets the procedural requirements shown below.

FUNCTIONAL: The structure, system, or component (SSC) is capable of performing its intended function for both normal and emergency operations. This definition applies to testing and maintenance activities in all MODES of operation.

1. Functional SSCs do not require automatic actuation or alignment if the function can be promptly restored either by an operator in the Control Room or by a dedicated operator

Implementation Examples NOC-AE-03001466 Attachment 3 Page 2 stationed locally for that purpose. Restoration actions must be contained in approved written instructions, must be uncomplicated and must not require diagnosis or repair.

Credit for a dedicated local operator can be taken only if positioned at the proper location throughout the duration of the activity.

2. Functional SSCs may not always meet all Technical Specification, Licensing or Design-basis assumptions. (The Technical Specification ACTION will apply if the SSC is functional but not OPERABLE. If TS 3.13.1 is referenced by the affected TS, TS 3.13.1 may be applied to determine the appropriate AOT. The TS AOT limit will apply until the SSC is OPERABLE.)

3. Functional SSCs do not require attendant fire detection or suppression.

4. Performance of maintenance activities may involve alterations to SSCs which affect functionality. Examples of such alterations include:

Installation of terminal jumpers

Lifting of electrical leads

Placing of temporary lead shielding on pipes or equipment Removal of barriers

Use of temporary blocks, bypasses, scaffolding or supports.

Removal of insulation.

5. An SSC should be considered functional if there is reasonable assurance that it can perform its intended risk function(s). Ifthis evaluation is later proven incorrect, the determination of non-functional time will be corrected accordingly.

6. An SSC aligned to its failure mode configuration per a clearance order or work order may be considered functional.

7. An SSC with an inoperable snubber may be considered functional. Engineering assistance may be required to determine the functionality of an SSC with an inoperable snubber.

8. During maintenance, an SSC can be declared functional when it is capable of performing its intended risk function(s) following the completion of restoration activities (i.e. clearance released, system lineup completed, filling/venting completed and other operational prerequisites met). If maintenance on an SSC does not involve major component disassembly, then the SSC can be declared functional following or during maintenance when the maintenance has reached a point where the on-duty Senior Reactor Operators consider the SSC ready for service or post-maintenance testing. If subsequent post-maintenance testing fails, then the determination of non-functional time will be corrected accordingly.

9. SSCs are considered functional during surveillance testing provided one of the following conditions is met:

The SSC will respond to its actuation signal (e.g. a containment isolation valve is functional during a valve operability test).

The surveillance procedure specifies the recovery actions required to return the SSC to its required safety condition (e.g.,AFW inservice test provides guidance for the operator to close the test line isolation valve in the event of an AFW actuation).

The surveillance test places the SSC in the conservative safety state (e.g. the bistable is tripped).

Implementation Examples NOC-AE-03001466 Attachment 3 Page 3 Example 1: Routine Train A work week with emergent Train B condition This example illustrates how the Technical Specifications would be applied for situation where a train of equipment is out of service for planned maintenance and a risk-significant component on a different train is found to be inoperable. Current TS for the condition below would require entry into TS 3.0.3 for the second inoperable HHSI train. This would subsequently require plant shutdown within a few hours unless STPNOC was granted enforcement discretion by the NRC.

Application of the proposed risk-informed TS would allow STP to determine the appropriate AOT for the condition where the second HHSI train was inoperable. The example demonstrates that there is adequate time for the plant to address the emergent condition without shutting down or requesting enforcement discretion.

Time Event Frontstop Calculated Risk Comment (hh:mm) AOT (/hr)

(time to reach 1E-05) 00:00 Begin Train A work HHSI (3.5.2.a): 7 days NA, planned 5.9E-09 Routine planned maintenance week (SDG, ECW, CCW (3.7..3.a): 7 days to remain CCW, HHSI) ECW (3.7.4.a): 7 days within SDG (3.8.1.1.b): 14 days frontstop AOT.

24:00 Train B HHSI found 3.5.2.b: 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to apply TS 24 days 1.7E-08 Emergent condition where CTS would to be inoperable 3.13.1 require TS 3.0.3 entry. RITS permits the station to address the condition with normal work controls.

36:00 Train B HHSI Exit TS 3.5.2.b and TS restored 3.13.1 applicability.

Back on the work week clock with 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months ela

Implementation Examples NOC-AE-03001466 Attachment 3 Page 4 Example 2: Emergent condition while in configuration where TS 3.13.1 is in use This example illustrates how the TS would be applied in a situation where a frontstop AOT has been extended by use of TS 3.13.1 and there is a subsequent emergent condition involving an inoperable risk-significant component. The recalculated AOT of 27 days when the TDAFW pump is found to be inoperable also accounts for the days that the ECW pump has been out of service.

Time Event Frontstop Calculated Risk Comment (hh:mm) AOT (/hr)

(time to reach 1E-05 00:00 ECW pump TS 3.7.4.a: 7 days 1 train of 4.5E-09 TS 3.13.1 requirements apply after 7 days.

replacement (Also makes associated ECW could The risk is calculated from the time the expected to last 10 SDG inoperable) be allowed ECW is taken out of service.

days. OOS up to the 30-day backstop 8 days Turbine-driven TS 3.7.1.2.b: 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 27 days 1.5E-08 Regardless of the frontstop time for the AFW found to be TS 3.8.1.1.d: 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months TDAFW pump, TS 3.13.1 applies because inoperable the ECW has gone beyond its frontstop.

TS 3.13.1 requires a determination of the acceptability of the configuration with the additional inoperable TDAFW.

Application of the CRMP would determine the configuration is acceptable.

9 days ECW pump is TS 3.7.1.2.b: 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months less > 30 days 1.5E-09 The condition that caused TS 3.13.1 to restored the 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months that have (backstop apply has been exited and there are no TS transpired. would apply) beyond their frontstop time. The frontstop AOT may be applied to the TDAFW.

Implementation Examples NOC-AE-03001466 Attachment 3 Page 5 Example 3: Same as Example 2, except that the emergent condition is restored first Time Event Frontstop Calculated Risk Comment (hh:mm) AOT (/hr)

(time to reach 1E-05) 00:00 ECW pump TS 3.7.4.a: 7 days 1 train of 4.5E-09 TS 3.13.1 requirements apply after 7 days.

replacement ECW could The risk is calculated from the time the expected to last 10 be allowed ECW is taken out of service days. OOS up to the 30-day backstop 8 days Turbine-driven TS 3.7.1.2.b: 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 27 days 1.5E-08 Regardless of the frontstop time for the AFW found to be TS 3.8.I1. Ld: 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months TDAFW pump, TS 3.13.1 applies because inoperable the ECW has gone beyond its frontstop.

TS 3.13.1 requires a determination of the acceptability of the configuration with the additional inoperable TDAFW.

Application of the CRMP would determine the configuration is acceptable.

9 days TD AFW restored NA > 30 days 4.5E-09 TS 3.13.1 still applies. TDAFW no longer contributes to risk calculation. A new completion time may be calculated.

PRA Quality NOC-AE-03001466 Attachment 4 PRA Quality

PRA Quality NOC-AE-03001466 Attachment 4 Page 1 As stated in the cover letter, STPNOC proposes that this application be used as a pilot for Regulatory Guide (RG) 1.200, "An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities".

STPNOC has determined that preparing and submitting the information required by RG 1.200 will require a substantial effort. This submittal contains an outline with some preliminary information.

The remainder of the information will be included in future submittals.

Description of the STP PRA The STP PRA is a full-scope Level 1 / 2 PRA that incorporates internal events, inclusive of fires/floods, and external events (seismic, fire, flood). STP's PRA features a seismic PRA, flood PRA (including spatial interactions analysis), human reliability analysis, and detailed common cause modeling. The model is quantified using the RISKMAN software code that has met station and industry software quality assurance requirements. The PRA is maintained and updated under a PRA configuration control program in accordance with station procedures.

Periodic reviews and updates, if necessary, for plant changes (includes as a minimum performance data, procedures, and modifications) by qualified personnel with independent reviews and approvals.

STPNOC has used the PRA for risk-informed insights and applications since the mid-1980s.

The NRC has previously reviewed the STP PRA in support of approving the following risk-informed licensing applications:

1. Amendment Nos. 59 & 47, dated February 17, 1994 (initial application made in 1990). The application extended the AOTs for 10 LCOs and the intervals for 3 surveillance tests.

2. Amendment Nos. 85 & 72, dated October 31, 1996. The application extended the AOT for the standby diesel generators and their associated support systems.

3. Amendment Nos. 125 & 113, dated September 26, 2000. The application relaxed LCO requirements for control room and fuel handling building HVAC.

4. Approval of Exemption to Special Treatment Requirements, dated August 3, 2001.

The application relaxed regulatory requirements for various degrees of special treatment provisions for safety related components (Option 2 Pilot).

5. Amendment Nos. 135 & 124, dated January 10, 2002. The application extended the AOT for ECCS Accumulators consistent with WCAP-15049-A and relaxed accumulator surveillance requirements consistent with Westinghouse Improved Technical Specifications.

6. Amendment Nos. 143 & 131, dated September 17, 2002. The application allowed a one extension of integrated leak rate test to 15 years.

7. Amendment Nos. 146 & 134, dated December 31, 2002. The application extended the AOT for auxiliary feedwater.

8. Amendment Nos. 158 and 146 dated December 2, 2003 (AE-NOC-03001167).

These amendments eliminate the turbine missile design basis.

PRA Quality NOC-AE-03001466 Attachment 4 Page 2

9. Amendment No. 149 for STP Unit 2 dated December 30, 2003. This amendment allows a one-time extension of the AOT for standby diesel generator SDG 22 to 113 days.

In addition to the risk-informed licensing applications above, STPNOC has used the STP PRA to provide additional insight to other licenses amendments and to respond to NRC questions.

The following references are evaluations of the STP PRA that have been performed by the NRC and others:

1. NRC SER related to the STP Probabilistic Safety Assessment, dated January 21, 1992, documented favorable conclusions with regard to the STP PRA, including its treatment of fire (done to support the review for Amendment Nos. 59 & 47, above).

2. 2002 Peer Review In April 2002, STP's PRA underwent an industry peer review performed in accordance with NEI-00-02, "Industry PRA Peer Review Process." All technical elements within the scope of the peer review were graded as sufficient to support application requiring the capabilities of a grade 2 (e.g., risk ranking applications).

Most of the elements were further graded as sufficient to support application requiring the capabilities defined for grade 3 (e.g., risk-informed applications supported by deterministic insights). The general assessment of the peer reviewers was that STP's PRA could effectively be used to support applications involving risk significance determinations supported by deterministic analyses once the items noted in the element summaries and Fact & Observations (F&O) sheets were addressed.

Using STP's Corrective Action program as a tracking mechanism, with two major exceptions, all F&O items identified by the peer team have been completed and are incorporated as appropriate into the latest revision of the STP PRA (Revision 4). The STP PRA Revision 4 model is the basis for this application of Risk-Informed Technical Specifications. The two major exceptions which are not included in the current PRA are Level 2 model update and reevaluation of internal flood modeling.

The Level 2 update is currently being performed with contractor assistance and will be complete by the end of 2004. The internal flood reevaluation is in progress and will be finished prior to the end of 2004. No issues have been identified from the flood reevaluation to date that affect the PRA.

RG 1.200 Required Information The information described below will be provided to demonstrate that the parts of the STP PRA are of sufficient quality to support the analyses used in this application 0 A description of the process for maintenance, update, and control of the PRA.

PRA Quality NOC-AE-03001466 Attachment 4 Page 3

Identification of changes to design or operational practices whose impacts have not been incorporated in the PRA model used to support the application, and either a justification of why this does not impact the results used or the results of a sensitivity study to demonstrate that the impact is not significant.

Documentation that the parts of the PRA required to produce the results used in the decision are performed consistently with the standard or peer review process as endorsed in the appendices to this regulatory guide, or a discussion of the impact of not meeting the standard or the criteria of the peer review process on the results and either a justification of why this does not impact the results used or the results of a sensitivity study that demonstrate that the impact is not significant.

A characterization of the assumptions and approximations that have a significant impact on the results used in the decision-making process. This characterization also includes the peer reviewers' assessment of those assumptions. These characterizations provide information that the NRC staff may find useful to support the assessment of whether the use of these assumptions and approximations is either appropriate for the application, or whether sensitivity studies performed to support the decision are appropriate.

A discussion of the resolution of the peer review comments that are applicable to the parts of the PRA required for the application. This may take the form of: (1) a discussion of how the PRA model has been changed, (2) a justification of why the particular issue raised does not impact the results used, or (3) the results of a sensitivity study that demonstrate that the impact is not significant.

NOC-AE-04001666, Broad-Scope Risk-Informed Technical Specification Amendment Request

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NOC-AE-04001666, Broad-Scope Risk-Informed Technical Specification Amendment Request

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