Text

Revised Broad Scope Risk-Informed Technical Specification Amendment Request
	ML061630315
Person / Time
Site:	South Texas
Issue date:	06/06/2006
From:	Rencurrel D; South Texas
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	NOC-AE-06002005, STI: 32001381
	Download: ML061630315 (126)
	v • d • e

Nuclear Operating Company South Tewi Projct Ek-ct* CencrathnS Station P0 &ow 289 JMfdlro~rthi Tewas77483 A June 6, 2006 NOC-AE-06002005 10CFR5 0.36 10CFR50.90 U. S. Nuclear Regulatory Commission Attention: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 South Texas Project Units 1 and 2 Docket Nos. STN 50-498, STN 50-499 Revised Broad Scope Risk-Informed Technical Specification Amendment Reqiuest

Reference:

1. Letter from T. J. Jordan to NRC Document Control Desk dated August 2, 2004, "Broad Scope Risk-Informed Technical Specification Amendment Request" (ML042190366, NOC-AE-0400 1666)

2. Letter from T. R. Tjader (NRC) to Biff Bradley (NEI) dated July 14, 2004, transmitting Requests for Additional Information on the Risk-Informed Technical Specification Initiative 4B submittals (MLO4 1820347)'1

3. Letter from T. R. Tjader (NRC) to Biff Bradley (NEI) dated May 31, 2005, transmitting Requests for Additional Information on the STP application in Reference 1 (MLO5 1570016) 2

4. Letter from M. A. McBurnett to NRC Document Control Desk dated February 10, 2006, "Response to NRC Requests for Additional Information on STPNOC Proposed Risk-Informed Technical Specifications" (ML060480439, NOC-AE-06001969)

5. Letter from M. A. McBurnett to NRC Document Control Desk dated April 26, 2006, "Response to NRC Requests for Additional Information on STPNOC Proposed Risk-Informed Technical Specifications" (NOC-AE-0600 1994)

The STP Nuclear Operating Company (STPNOC) submitted license amendment request for a broad scope risk-informned set of Technical Specification changes (Reference 1). This submittal is a revised license amendment request for the proposed risk-informned changes to the Technical Specifications (TS) 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, incorporate responses to NRC staff questions as documented in References 2, 3, 4, and 5, and incorporate the results of NRC - industry/STP discussions on the Electric Power Research This corrects the ADAMS accession number noted for this correspondence in the references in Reference 4.

2 This correspondence was incorrectly referenced in Reference 4 and Reference 5 as being dated June 3, 2005 with ADAMS accession number ML051510103.

STI:32001381

NOC-AE-06002005 Page 2 Institute (EPRI) Risk Managed Technical Specification (RMTS) Guidelines that are a substantial part of the basis for the STPNOC application.

The attached revision to the STPNOC license amendment request includes the following changes from the original application:

- It incorporates the resolution of NRC comments on the original STPNOC application and resolution of NRC comments on the industry's RMTS guidance.

- It removes discussion and details that are now adequately addressed in the RMTS Guidelines or which do not need to be repeated from Reference 1.

- It adds substantially more detail to Table 2 describing the changes to the individual Technical Specifications and the application of risk-infonned completion times to those specifications.

- It changes the Applicability of proposed TS 3.13.1 and 3.13.2 to MODE 1 and MODE 2.

- It deletes reactor trip breakers, pressurizer safety valves, feedwater isolation valves and feedwater isolation instrumentation from the scope of the application and incorporates other clarifying changes identified in responses to NRC questions.

- It adds Control Room Envelope HVAC (TS 3.7.7) to the scope of the application.

- TS 3.13.2 is added to require application of the Configuration Risk Management Program when multiple action statements are entered to which TS 3.13.1 may be applied. Action 3.8. 1.1.d is superseded by the new TS 3.13.2 and is deleted.

- It adds additional description to the Configuration Risk Management Program to reference the Risk Managed Technical Specification Guidelines.

- It revises proposed ACTION 19A to be based on the number of trains with less than the minimum channels operable instead of the number of channels being less than the minimum required number of channels.

- It revises the originally proposed action statement format for TS 3.5.1, 3.7.1.6, 3.8.2. 1, and 3.8.3.1 to have a separate action for more than one inoperable train/channel. This format change makes these TS consistent with the format of the other proposed applications of RMTS in the proposed amendment.

- It revises TS 3.7.1.2 to allow application of RMTS to one inoperable motor-driven auxiliary feedwater pump and to three inoperable trains of auxiliary feedwater.

- It incorporates updated page mark-ups that resulted from license amendments that have been approved since the submittal of Reference 3.

The application is resubmitted in its entirety.

The proposed amendment will not have an adverse impact on the health and safety of the public.

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.

NOC-AE-06002005 Page 3 describes the proposed changes and their technical and safety bases. is the markups of the affected Technical Specifications. discusses the STP PRA quality. describes a change to previous STP commitments to implement risk management actions based on exceeding a prescriptive outage time. Implementation of the risk management actions is to be based on exceeding or expecting to exceed a risk threshold consistent with the RMTS Guidelines. This change does not require prior NRC approval and is being implemented in the near future.

If you have any questions, please call Wayne Harrison at 361-972-7298 or me at 361-972-7867.

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

Executed onJQ 4)

Date David W. Rencurrel Vice President, Engineering Attachments:

1. Description of Changes and Safety Evaluation

2. Technical Specification Mark-up Pages

3. PRA Quality

4. Commitments

NOC-AE-06002005 Page 4 cc:

(paper copy) (electronic copy)

Regional Administrator, Region IV A. H. Gutterman, Esquire U. S. Nuclear Regulatory Commission Morgan, Lewis & Bockius LLP 611 Ryan Plaza Drive, Suite 400 Arlington, Texas 76011-8064 Mohan C. Thadani U. S. Nuclear Regulatory Commission Senior Resident Inspector Steve Winn U. S. Nuclear Regulatory Commission Christine Jacobs P. 0. Box 289, Mail Code: MN1 16 Michael A. Reed Wadsworth, TX 77483 NRG South Texas LP C. M. Canady J. J. Nesrsta City of Austin R. K. Temple Electric Utility Department E. Alarcon 721 Barton Springs Road City Public Service Austin, TX 78704 Richard A. Ratliff Jon C. Wood Bureau of Radiation Control Cox Smith Matthews Texas Department of State Health Services 1100 West 49th Street C. Kirksey Austin, TX 78756-3 189 City of Austin

NOC-AE-06002005 Description of Changes And Safety Evaluation Attachment 1

Description of Changes and Safety Evaluation NOC-AE-06002005 Page 1

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

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) to calculate a risk-informed completion time (RICT) based on the time required for the risk calculated for a plant configuration to attain a threshold. The risk thresholds, the process for calculating the configuration risk, and the requirements for PRA quality are described in the Electric Power Research Institute (EPRI) Risk Managed Technical Specification Guidelines (RMTS Guidelines). The RMTS Guidelines are incorporated by reference in the proposed STP Technical Specification changes. The STP CRMP is a procedurally controlled program utilized by STPNOC for the implementation of 10CFR5O.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-Informned Technical Specifications (RH'S) and for evaluation of RG 1.200.

This change proposes the establishment of a new specification, TS 3.13. 1, to determine risk-informned allowed outage time (AOT) which will be referred to as a RICT 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. Changes would be made to specific TS to reference TS 3.13.1 to allow for application of the CRMP to determine the AOT.

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 (i.e., a RICT) 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 determnine the RICT for the new configuration until no components are in ACTIONS beyond the frontstop time. Since the CRMP is the implementing process for IOCFR5O.65(a)(4), this achieves consistency between the regulations and the Technical Specifications.

In accordance with the RMTS Guidelines, 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) of 1.OE-06 as the first level threshold below which routine work controls are adequate with no requirement for specific risk management actions. At or above this threshold, the operator is required to initiate action to reduce or manage the risk in accordance with the CRMP. The

Description of Changes and Safety Evaluation NOC-AE-06002005 Page 2 TS RICT is established with a CDP of 1.OE-05 to define the limit for the AOTs for plant configurations. The RICT would be calculated as the time required for the cumulative risk associated with a plant configuration to cross the threshold. Should the RICT be exceeded, TS 3.13.1 would impose the TS requirements for action or completion time not met for the affected TS. The provisions of TS 3.0.2 are not affected by referencing TS 3.13.1 in TS in the scope of RMTS. If the affected SSC is restored before completion of a required shutdown or if the RICT is determnined prior to completion of a required shutdown, the shutdown need not be completed.

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 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 RICT can be calculated. The LCOs and ACTIONs to which this proposed specification applies would each be modified to reference TS 3.13. 1.

Approval of the changes proposed in this submittal will allow the plant to concentrate efforts on 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.OE3-05 CDP level.

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.

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

Description of Changes and Safety Evaluation NOC-AE-06002005 Page 3 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 functio acieed In accordance with RMTS Guideline ,MSwill notýbe appl~ied for con gurations where there is a complete loss of function. I~fa co Trrti-tenm+/-o5inoperable, it may still be considered to have PRA Functionality for calculation of a RICT if there is reasonable assurance that it can perform its required functions for events not affected by the degraded or non-conforming condition and if the condition can be quantified in the PRA. The EPRI RMTS Guidelines provide more detail on how PRA functionality may be applied for the determination of a RICT.

STP also proposes to add Technical Specification 3.13.2, which requires a risk-informed confirmation that the "front-stop" allowed outage times are acceptable for configurations where the ACTION statements for two or more Limiting Conditions for Operation (LCO) apply for equipment within the scope of the RMTS. This is a logical extension of the RMTS in that the associated risk thresholds should not be limited to conditions involving application of TS 3.13.1. This approach is also consistent with the intent of IOCFR5O.65(a)(4) for assessing risk.

2. Detailed Description of Proposed Changes Table 2 describes the proposed changes to the Technical Specifications. It includes the basis for each proposed change.

In Reference 5 of the cover letter, STPNOC committed to provide more specific responses to the NRC request for a comparison of the design basis functions and the functions modeled in the PRA (Question 8.b). STPNOC believes that sufficient detail has been added to Table 2 to address this question.

The risk basis column provides the calculated RICT 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 RICT without the application of the proposed 30-day backstop. The AOTs in this column represent "base case" and are calculated using the I OE-05 threshold. When "inoperable" is used in this column, it means that the SSC is not capable of performing its intended function.

Application of the CRMP to those conditions where the functionality requirements defined in the RMTS Guidelines are met could result in a longer AOT. The AOTs in Table 2 were determined using information from the Revision 4 of the PRA model. The train-related AOT asymmetry will be less pronounced for the AOTs calculated using Revision 5 of the PRA, which is currently being finalized. The AOTs in Table 2 provide useful insight into the available margin. To determine AOTs for actual plant configurations, STPNOC will use the

Description of Changes and Safety Evaluation NOC-AE-06002005 Page 4 PRA or the RICT Calculator (RICTCal), which is an extensive database of over 20,000 pre-calculated maintenance states.

3. Background

STPNOC is proposing in this application to implement a risk-informed process for determining AOTs for STP Technical Specifications. The risk-informned process involves the application of the STP CRMP. The STP CRMP is also utilized by STPNOC for the implementation of 10CFR5O.65(a)(4) for the Maintenance Rule. The STPNOC application is based on the EPRI RMTS Guidelines.

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 completely incorporated 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 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 10CFR5O.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.

Description of Changes and Safety Evaluation NOC-AE-06002005 Page 5 Incremental [Conditional] Incremental [Conditional]

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

> IE-05 Configuration should not > 1E-06 normally be entered voluntarily IE-06 - IE-05 0 Assess non- 1E-07 - IE-06 quantifiable factors

Establish risk I management actions

<1IE-06 INormal work controls <1IE-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).

The thresholds shown in the table were adapted by the RMTS Guidelines for use in the determination of risk-informed completion times (RICT) for risk-managed TS.

Although STPNOC does not believe RG 1.174 and 1.177 are directly applicable to this submittal, the format addresses the principles of risk-informned decision-making set forth in those R~s. 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 determnining 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, 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 additional 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

Description of Changes and Safety Evaluation NOC-AE-06002005 Page 6 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.

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. The proposed change implements a mechanism to ensure changes from modeled core damage contributors are identified and monitored. Therefore, the proposed change itself does not significantly impact core damage frequency and is consistent with the Commission's Safety Goal Policy Statement. 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 performnance 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, RMTS Guidelines, and Maintenance Rule Program. 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.

Description of Changes and Safety Evaluation NOC-AE-06002005 Page 7

4. Technical Analysis STPNOC proposes to apply a risk-informed process to determine the AOT for a number of Technical Specifications. The risk-informned process would apply the CRMP to evaluate plant configurations and determine the time required for the risk to exceed a conditional core damage probability threshold of 1.OE-05 and establish a RICT for the configuration based on that time. The action required by the TS must be taken if the threshold is exceeded. The CRMP would require the plant to initiate action to manage risk levels that are at or above a conditional core damage probability threshold of 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 determnining 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 the basis for each of the requested changes and depicts the calculated times required to accrue risk to a 1.OE-05 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 criteria established in the RMTS Guidelines.

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.OE-06. The recent Standby Diesel Generator 22 extended outage resulted in an ICDP of about 1.213-06 when availability 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 IOCFR5O.63, "Loss of all alternating current power," and 10CFR5O.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 bases from the longer AOTs.

Description of Changes and Safety Evaluation NOC-AE-06002005 Page 8 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 bases for STP.

Defense-in-Depth Following the guidance provided in Regulatory Guide (RG) 1.177, the impact of the proposed Technical Specification change on the defense-in-depth philosophy is addressed below. Based on the following discussion, STPNOC has concluded that the proposed change meets the defense-in-depth philosophy.

A reasonable balance among prevention of core damage, prevention of containment failure, and consequence mitigation is preserved, i.e., the proposed change in a TS has not significantly changed the balance among these principles of 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 consider whether the anticipatedoperationalchanges associatedwith a T'S change could introduce new accidents or transients or could increase the likelihood of an accident or transient(as is required by 10 C'FR 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 RICT for the combination may be less than currently prescribed in the Technical Specifications. In most 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. In conformance with the EPRI RMTS Guidelines, 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-reliance on programmaticactivities to compensatefor weaknesses in plant design is avoided, e.g., use of high reliability estimates that are primarilybased onl optimistic program assumptions.

The proposed application of a plant-specific CRMIP 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

Description of Changes and Safety Evaluation NOC-AE-06002005 Page 9 may use compensatory actions to reduce calculated risk in some configurations. These compensatory actions may be incorporated into 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 1 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 ACTs 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 ACTs when one of three trains is inoperable, and a reasonable ACT for conditions where two of three trains are inoperable.

STPNCC proposes to apply the CRMP to determine the appropriate ACTs 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

Description of Changes and Safety Evaluation NOC-AE-06002005 Page 10 three trains operable is based on a reasonable time to restore operability and the capability of the remaining operable equipment. The STP PRA 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 with thle 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 principles of 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 AOT for pre-planned maintenance are 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. In accordance with the RMTS Guidelines, risk management actions are required for configurations that exceed or are expected to exceed the IE-06 threshold.

Whether voluntary removal of equipment from service during plant operation should not be scheduled when adverse weather conditions arepredicted or at times when the plant may be subjected to other abnonnalconditions, 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).

Description of Changes and Safety Evaluation NOC-AE-06002005 Page 11 Whether the impact of the TS change on the safety function should be taken into consideration.For example, what is the impact of a change in the AOTfor the lowv-pressure safety injection system on the overall availability and reliability of the lowv-pressure injectionfunction?

Application of the CRMP incorporates the impact of the RICT 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.

STP proposes to allow application of the CRMiP 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.

Safety Margin In accordance with RG 1. 177, with sufficient safety margins:

" Codes and standardsor their alternatives approvedfor use by the NRC are met.

" Safety analysis acceptancecriteria in the Licensing Basis (e.g., FSAR, supporting analyses) are met, or proposed revisions provide sufficient margin to accountfor analysis and data uncertainty.

Use of the CRMIP to determine a RICT 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

Description of Changes and Safety Evaluation NOC-AE-06002005 Page 12 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 ACTs being proposed in the Risk-Informned Technical Specifications. The results of the determninistic 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).

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 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.

Exceptions to the RMTS Guidelines STPNOC is taking no exceptions to the RMTS Guidelines.

The guidelines allow for application of RICTs for MODE 3 and MODE 4 when the steam generators are available for decay heat removal, provided the licensee justifies the applicability of the at-power PRA model in those modes. STPNOC has elected to limit the applicability to MODE 1 and MODE 2.

5. Regulatory Safety Analysis 5.1 No Significant Hazards Determination The following changes to the Technical Specifications are included in the proposed license amendment:

" Proposed new TS 3.13.1 for ACTs to be determined by a risk-informed configuration risk management program and associated changes to the specific specifications that allow application of TS 3.13.1

" Proposed new TS 3.13.2 to require evaluation of the "frontstop" allowed outage times for entry into two or more LCOs that permit the application of TS 3.13.1

Description of Changes and Safety Evaluation NOC-AE-06002005 Page 13

Proposed changes to certain ACTION statements in individual specifications to allow the application of the Configuration Risk Management Program in accordance with the new TS 3.13. 1.

Proposed change to the Configuration Risk Management Program in TS 6.8.3.k to reference the EPRI Risk-Managed Technical Specification Guidelines.

Proposed administrative structural and wording changes to the affected TS to facilitate incorporating the references to TS 3.13.2.

" Proposed accompanying administrative changes to the TS Index In accordance with the criteria set forth in 10CFR5O.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 TS 3.13.2 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.

Changing TS 6.8.3.k to reference the EPRI Risk-Managed Technical Specification Guidelines is an administrative change that establishes the industry standard as the STP licensing basis. Meeting the standard provides additional assurance that the risk management program properly manages the plant configuration risk. Consequently, it does not involve a significant increase in the probability or consequences of an accident previously evaluated.

Changes to the affected TS require some minor grammatical and structure changes to effectively incorporate the reference to TS 3.13.1. These changes are editorial and administrative and have no safety significance. The changes to the TS Index are administrative and have no technical or safety significance.

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-06002005 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 involves 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 TS 3.13.2 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.

Changing TS 6.8.31k to reference the EPRI Risk-Managed Technical Specification Guidelines is an administrative change that establishes the industry standard as the STh licensing basis. Meeting the standard provides additional assurance that the risk management program properly manages the plant configuration risk. Consequently, it does not involve a significant reduction in the margin of safety.

Changes to the affected TS require some minor grammatical and structure changes to effectively incorporate the reference to TS 3.13. 1. These changes are editorial and administrative and have no safety significance. The changes to the TS Index are administrative and have no technical or safety significance.

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

5.2 Applicable Regulatory Criteria 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 program instead of having a prescriptive time in the specification. As discussed below, this change in format and RICT management still incorporates the elements required by 10CFR5O.36 for Technical Specifications.

10CFR5O.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

Description of Changes and Safety Evaluation NOC-AE-06002005 Page 15 shutdown if required conditions are not met in a specified time. 10CFR5O.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 deter-mining 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 10CFR5O.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 10CF'R50.65 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 IOCFR5O.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, 10CFR5O.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.

6 Environmental Assessment 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 10CFR5 1.21. The proposed changes meet the criteria for categorical exclusion as provided for under 10CFR5 1.22 (c) (9). The following is a discussion of how the proposed Technical Specification change meets the criteria for categorical exclusion.

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

Description of Changes and Safety Evaluation NOC-AE-06002005 Page 16 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 10CFR5 1.22 (c)(9). Based on the aforementioned and pursuant to LOCFR51.22 (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-06002005 Page 17 Table 1 General Case: Three-Train Design TS Requirements System/Condition Standard Two- Current STP Proposed STP Risk- Safety Evaluation Comments' 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 (3trains): 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 plant: loss of safety Application of the CRMP equivalent equivalent (typ.) CRMP function. Application of CRMP recognizes the the defense-in-recognizes plant level functional depth capabilities and limitations redundancy in safety systems and and provides reasonable time to the low probability of an initiating take corrective actions. CRMP event requiring two trains for also takes into account mitigation. Some time to restore unavailability of multiple systems, the inoperable function is thereby performing the function of appropriate based on the very low a Safety Function Determination probability of an initiating event Program.

while in this configuration.

Because STP typically has no STP (3trains): loss of safety action for 2 inoperable trains, TS function only for specific low 3.0.3 applies and this extends probability events. Retains safe Initiative 4B to cover Initiative 6 for shutdown capability for non- these configurations.

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

~ ~

__________________ ~ ~ ~

________ ~ ~

___Z________ ~ ~ ~ ~

__________ ~ ~ ~ ~_ cofgrto.

c ..... ITS Initiative 6)

/_____________

Description of Changes and Safety Evaluation NOC-AE-06002005 Page 18 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement New Action Requirement Technical Discussion and Comments Risk Basis Number Caiculated STP AOT Before Backstop (base case)1 33 1.18 With the number of ACTION 9A is split Into 9A a for The SI Input from ESFAS ensures that ifa reactor TS 3.3.1.18, Si input from ESFAS:

OPERABLE channels one one inoperable channel and 9A b trip has not already been generated by the RTS, the Si input from less than the Minimum for more than one inoperable ESFAS automatic actuation logic will initiate a 485 days for one channel (train) of SSPS to be ESFAS Channels OPERABLE channel. reactor trip upon any signal that initiates Si. This Is inoperable/non-functional requirement, restore the a condition of acceptability for the LOCA. However, Action 9A inoperable channel to a. With the number of OPERABLE other transients and accidents take credit for(3dabcktpplis OPERABLE status within channels one less than the varying levels of ESF performance and rely upon (3dabcktpplis 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , or be inat least Minimum Channels OPERABLE rod insertion, except for the most reactive rod that is Ifoecanl(ri)siopabendtethrs HOT STANDBY within the requirement, within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months assumed to be fully withdrawn, to ensure reactor nfonefuchioannl,(ri)i noealn then nayi wl oth eri next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ; however, one restore the inoperable channel to shutdown. Therefore, a reactor trip IsInitiated every nofutialthnaRAnlyswllb channel may be bypassed OPERABLE status, or apply the time an SI signal Ispresent. required For example, for a channel that is for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for rqieetofScfcaoninoperable only for seismic reasons, a PRA analysis surveillance testing per 3.13.1, or be in at least HOT There are two channels for this function. With one perfrme toi dpemonicsitratehisk.

ascianted 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 ; channel inoperable, the other channel will be ascae ihti pcfcstain provided the other channel however, one channel may be available to perform the function There are also Frteratrti ucin h R oe is OPERABLE. bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for functionally redundant reactor trip signals (e.g. assmethatteafce reactor e r wRoueld breakntint surveillance testing per pressurizer pressure - low) bealigned toa the rfeemann OPEctrAL braesSwoul Specification 4.3.1.1, provided thebeaindtthrmiigOPRBES S other channel IsOPERABLE. With both channels inoperable, the proposed channel.

change retains the time limits consistent with TS b.With the number of OPERABLE 3.0.3 that would apply to current TS with more than channels more than one less than one Inoperable channel. However, the operators the Minimum Channels would be allowed to apply TS 3.13.1 ifthere isan OPERABLE requirement, within 1 adequate compensatory action or ifthe channel Is hour restore at least one still functional In accordance with the RMTS inoperable channel to OPERABLE Guidelines.

status or apply the requirements of Specification 3.13.1, 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

Description of Changes and Safety Evaluation NOC-AE-06002005 Page 19 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement New Action Requirement Technical Discussion and Comments Risk Basis Number Caiculated STP AOT Before Backstop (base case)l 3 3.121 Same as 9A above Same as 9A above The LCO requirement for the Automatic Trip Logic 3 3.1.21 - Same result as 3.3 1.18, SI Input ensures that means are provided to Interrupt the Automatic Trip power to aiiow the rods to fail into the reactor core. (30 day backstop applies) and Interlock The reactor trip signais generated by the RTS Logic Automatic Trip Logic cause the reactor trip breakers and associated bypass breakers to open and shut Action 9A down the reactor.

There are two channels for this function. With one channei Inoperable, the other channei wili be available to perform the function.

The PRA models the digitai iogic processing and generation digital output signais for the reactor trip switchgear that causes a reactor tnip. It also models the actuation of a reactor trip whenever urgent alarms exist for two SSPS logic trains or two actuation trains.

With both channels Inoperable, the proposed change retains the time limits consistent with TS 3 0.3 that would apply to current TS with more than one inoperable channel. However, the operators would be allowed to apply TS 3.13.1 ifthere is an adequate compensatory action or if the channel is still functional In accordance with the RMTS Guidelines.

3.3.2.1 b-SI With the number of ACTION 14 is split into 14.a for one The SI signal Isused to Initiate the functions listed Except for the pressurization and recirculation Automatic OPERABLE channels one inoperable channel and 14 b for below, function of the Control Room Envelope HVAC Actuation Logic less than the Minimum more than one inoperable channel. 0 Reactor Trip System System and the FHB HVAC Exhaust Subsystem, Channels OPERABLE the initiated functions are modeled Inthe PRA. The Action 14 requirement, restore the a. With the number of OPERABLE

Turbine Trip pressurization and recirculation function of the inoperable channel to channels one less than the 0 Feedwater Isolation Control Room Envelope HVAC System and the OPERABLE status within Minimum Channels OPERABLE

Auxiliary Feedwater System FHB HVAC Exhaust Subsystem have no effect on 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , or be inat least requirement, within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 0 SadyDelGnrtosCDF or LERF.

HOT STANDBY within the restore the inoperable channel to StnbDislGeros next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD OPERABLE status, or apply the 0 Component Cooling Water System The PRA conservatively assumes that failure of any SHUTDOWN within the requirements of Specification I________________I_______ function required to be actuated causes

Description of Changes and Safety Evaluation NOC-AE-06002005 Page 20 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement New Action Requirement -Technical Discussion and Comments Risk Basis Number Calculated STP AOT Before Backstop (base case)1 following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months ; 3.13.1, or be inat least HOT

Safety Injection System SSPS/ESFAS failure. The required functions are however, one channel may STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months specific to the initiating event. For general be bypassed for up to 4 and inCOLD SHUTDOWN within 0 Essential Cooling Water System transients, the actuation functions are: reactor trip; hours for surveillance the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months ; however, 0 Reactor Containment Fan Coolers auxiliary feedwater actuation; turbine trip and testing per Specification one channel may be bypassed for 0 Containment Isolation Phase A feedwater isolation. For LOCAs, including SGTR, 4.3.2.1, provided the other up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance the actuation functions are: Safety injection; the channel is OPERABLE. testing per Specification 4 3 2.1, 0 Containment Ventilation Isolation ESF load sequencer, and those functions required provided the other channel is

Control Room Envelope HVAC System for general transients. For steam line breaks, the OPERABLE. actuation functions are: steam line isolation, those

EAB Main Area HVAC System required for general transients, and; depending b.With the number of OPERABLE

FHB HVAC Exhaust Subsystem upon location, the safety injection and ESF load channels more than one less than 0 ESF Load Sequencers sequencer functions. For Loss of Offsite Power, the the Minimum Channels actuation functions are: the functions required for OPERABLE requirement, within 1 0 Essential Chilled Water System general transients, and the ESF load sequencer hour restore at least one 0 Electrical Penetration Space HVAC Inoperable channel to OPERABLE System Calculated RICT:

status or apply the requirements of Specification 3.13.1, or be in at There are two channels of SI automatic actuation. 3 32.1 b- Same result as 3 3 1.18, SI Input least HOT STANDBY within the With only one channel inoperable, the other channel next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD will be available to perform the function Manual (30 day backstop applies)

SHUTDOWN within the following action Isalso available to perform the function. For 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . one inoperable channel, the existing frontstop of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is adequate time to perform an assessment of the condition and determine the appropniate action and AOT.

With more than one channel inoperable, the proposed time limits reflect the same allowance that application of TS 3 0 3 would provide for the existing TS With both channels inoperable, application of TS 3.13.1 will allow the operators to determine ifthere is a suitable compensatory action or apply RMTS functionality criteria. ______________________

332.1 c -Si Same as Action 14 above Same as Action 14 above For the actuation relays, there are three channels, The PRA can be applied to model the failure of an Actuation each associated with its ESF train. Actuation of actuated ESF train or a function associated with the Relays either of the two trains of actuation logic will actuate ESF train.

all three ESF trains STP can mitigate nearly all Action 14 design-basis accidents with a single ESF train. Calculated RICT:

With more than one channel inoperable, the One inoperable train of ESF relays,

_____________________________________________ I proposed time limits reflect the same allowance that 1______________________

Description of Changes and Safety Evaluation NOC-AE-06002005 Page 21 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement New Action Requirement Technical Discussion and Comments Risk Basis Number Calculated STP AOT Before Backstop (base case)1 application of TS 3 0.3 would provide for the existing TS With both channels Inoperabie, Train A 256 days application of TS 3.13.1 will allow the operators to determine ifthere Isa suitable compensatory Train B 507 days action. Manual action is generally timely for most accidents that would require actuation of these Train C 460 days functions (30 day backstop applies)

Two inoperable trains of ESF relays:

Trains A and C are limiting 10 days The asymmetry inthe train contribution is largely due to the contribution of fires outside the control room. These fires primarily affect the B and C trains, leaving the A train for fire mitigation. Any unavailability of A train equipment is more significant than the corresponding B or C trains.

3 3.2.2.b - CS Same as Action 14 above Same as Action 14 above Containment Spray automatic actuation logic No measurable impact on CIJF or LERF Automatic actuates the Containment Spray System and Actuation Logic Containment Isolation - Phase B. (30 day backstop applies)

Action 14 There are two channels for this function. With only one channel inoperable, the other channel will be available to perform the function. Manual action is also available to perform the function. For one inoperable channel, the existing frontstop of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months isadequate time to perform an assessment of the condition and determine the appropriate action and AOT.

With more than one channel inoperable, the proposed time limits reflect the same allowance that application of TS 3 0 3 would provide for the existing TS. With both channels inoperable, application of TS 3 13.1 will allow the operators to determine ifthere is a suitable compensatory action Manual action is generally timely for most

____________ ________________________accidents

___________________ that wol reur actu- -ation of these

Description of Changes and Safety Evaluation NOC-AE-06002005 Page 22 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement New Action Requirement Technical Discussion and Comments Risk Basis Number Calculated STP AOT Before Backstop (base case)I functions 3 3.2 2 c Same as Action 14 above Same as Action 14 above For the actuation relays, there are three channels, No measurable impact on CDF or LEAF each associated with its ESF train Actuation of CS Actuation either of the two trains of actuation logic will actuate (30 day backstop applies)

Relays all three ESF trains. STP can mitigate nearly all design-basis accidents with a single ESF train Action 14 With more than one channel inoperable, the proposed time limits reflect the same allowance that application of TS 3.0.3 would provide for the existing TS With both channels inoperable, application of TS 3 13 1 will allow the operators to determine ifthere is a suitable compensatory action. Manual action is generally timely for most accidents that would require actuation of the containment spray function 3 3 2.3 a.2 - Same as Action 14 above Same as Action 14 above Containment Phase A Isolation closes the The systems associated with these containment containment isolation valves associated with the isolation valves are either closed systems Inside the Containment following functions- containment and have design pressures higher than Phase A the accident pressure inside containment or use Isolation 0 OVOS RCP Seal Water Injection small diameter piping that limits the size of any Automatic

CVCS Letdown and Charging potential containment leak path.

Acuto*oi RCP Seal Water Leakoff Calculated RICT:

Action 14 0 Containment Normal Sump Discharge 0 Containment Fire Protection No measurable impact on CDF or LEAF

Post Accident Sampling(3dabcktpplis

Pressurizer Relief Tank Makeup and Vent(3dabcktpplis

SIS Check Valve Test

Accumulator Nitrogen Supply

Containment Hydrogen Monitoring

Pressurizer andRCS sampling ______________________

Description of Changes and Safety Evaluation NOC-AE-06002005 Page 23 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement New Action Requirement Technical Discussion and Comments, Risk Basis Number Calculated STP AOT Before Backstop (base case)1-

" Personnel Air Lock Air Supply and Auto Leak Rate Monitoring

RHR Sampling

" Si Accumulator Sampling

Containment Instrument Air

RCDT Discharge and Vent There are two channels for this function With only one channel inoperable, the other channel will be available to perform the function. Manual action is also available to perform the function For one inoperable channel, the existing frontstop of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is adequate time to perform an assessment of the condition and determine the appropriate action and AOT.

With more than one channel inoperable, the proposed time limits reflect the same allowance that application of TS 3 0.3 would provide for the existing TS. With both channels Inoperable, application of TS 3.13.1 will allow the operators to determine if there isa suitable compensatory action or if the RMTS criteria for functionality may apply.

3323 a3- Same as Action 14 above Same as Action 14 above For the actuation relays, there are three channels, The systems associated with these containment Containment each associated with its ESF train Actuation of isolation valves are either closed systems inside the Phase A either of the two trains of actuation logic will actuate containment and have design pressures higher than Isolation all three ESF trains. the accident pressure inside containment or use Actuation small diameter piping that limits the size of any Relays With more than one channel inoperable, the potential containment leak path proposed time limits reflect the same allowance that Action 14 application of TS 3 0.3 would provide for the Calculated RICT:

existing TS. With both channels inoperable, application of TS 3 13.1 will allow the operators to No measurable impact on CDF or LERF determine ifthere is a suitable compensatory action or ifthe RMTS criteria for functionality may apply. (30 day backstop applies)

Description of Changes and Safety Evaluation NOC-AE-06002005 Page 24 Table 2 Detailed Description of Changes and Basis Specification 'Old Action Requirement New Action Requirement Technical Discussion and Comments Risk Basis Number Calculated STP AOT Before Backstop (base case)1 3.3.2.3 c.1 Same as Action 14 above Same as Action 14 above Containment Phase B isolation Isolates the CCW No measurable impact on CDF or LERF supply and return lines to the RCP thermal barriers Phase B on a HI-3 containment pressure signal. (30 day backstop applies)

Isolation Automatic There are two channels for this function. With only Actuation Logic one channel inoperable, the other channel will be available to perform the function. Manual action is Action 14 also available to perform the function. For one inoperable channel, the existing frontstop of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months isadequate time to perform an assessment of the condition and determine the appropriate action and AOT.

With more than one channel Inoperable, the proposed time limits reflect the same allowance that application of TS 3 0.3 would provide for the existing TS. With both channels Inoperable, application of TS 3 13.1 wfill allow the operators to determine ifthere is a suitable compensatory action or ifthe RMTS criteria for functionality may apply.

3 3 2 3 c.2 Same as Action 14 above Same as Action 14 above There are three channels of Phase B isolation No measurable impact on COF or LERF actuation relays, each associated with its ESF train Phase B Actuation of either of the two trains of actuation (30 day backstop applies)

Isolation logic will actuate all the actuation relay channels.

Actuation Relays The COW supply and return lines that are isolated by Phase B utilize two containment penetrations.

Action 14 One of the penetrations IsIsolated inside containment by a check valve, making the Phase B signal to the two parallel valves outside the containment a redundancy. The other penetration is configured with three Isolation valves inparallel inside the containment ("A" train, "B"train and a check valve),and two isolation valves In parallel outside the containment ("C" train and "D"train). _______________________

Description of Changes and Safety Evaluation NOC-AE-06002005 Page 25 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement New Action Requirement Technical Discussion and Comments Risk Basis Number Calculated STP AOT Before Backstop (base case)1 Creation ot a release path Inthe unlikely event of an accident requires a break in the COW piping system inside containment and faiiure of an isoiation valve inside containment and an isolation valve outside containment. The COW piping Isdesigned for pressure significantiy greater than the containment accident pressure and the iikeiihood of its failure is very small, Inaddition to the Phase B signal, the Isolation valves can be manually closed from the control room.

With more than one channel inoperable, the proposed time limits reflect the same allowance that application of TS 3 0 3 would provide for the existing TS and application of TS 3 13.1 will allow the operators to determine ifthere is a suitable compensatory action or if the RMTS criteria for functionality may apply.

I I U The PRA models the Containment Pressure 111.3 3 32.2.d With the number of Existing Action 17 to be 17.a: The Containment Pressure 111-3 signal actuates OPERABLE channels one containment spray and Containment Isolation actuation function.

CS on less than the Total Number With the number of OPERABLE Phase B.

Containment of Channels, place the channels one less than the Total (See 3 62.1, Containment Spray)

Pressure Hi-3 inoperable channel inthe Number of Channels, within 72 The current requirement would be retained as bypassed condition within hours place the inoperable channel Action a and a provision to apply TS 3.13.1 would Calculated RICT:

3 32.3c 3 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , or be inat least inthe bypassed condition or apply be added. Application of TS 3.13.1 could allow HOT STANDBY within the the requirements of TS 3.13.1, or application of PRA functionality to conditions where 1 channel Inoperable:

next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and inat least be inat least HOT STANDBY the channel is inoperable but still able to perform its Containment HOT SHUTDOWN within function insome conditions (e g , only inoperable in Isolation Phase within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and inat >10 yrs.

the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . One least HOT SHUTDOWN within the a seismic event) Insuch a condition, application of B on additional channel may be Containment following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . One additional TS 3 13 1 may be preferable to placing the channel bypassed for up to 12 channel may be bypassed for up to inbypass. (30 day backstop applies)

Pressure Hi-3 hours for surveillance 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for surveillance testing testing per Specification per Specification 4.3.2.1.

Action 17 4.3 2.1.

3322d NA Exstn Action to be Action a. Action b.that applies TS 3.13.1 is added for Calculated RiOT: 2 or more channels inoperable:

Existingconditions where more than one channel Is CS on INew Action b: inoperable. The actuation logic for the subject As an upper bound, assuming the Containment

____________ L___________________________ functions is2/4, which allows a relatively high____________________

Description of Changes and Safety Evaluation NOC-AE-06002005 Page 26 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement 'New Action Requirement Technical Discussion and Comments Risk Basis Number Calculated STP AOT Before Backstop (base case)1 Containment degree of redundancy. Application of TS 3.13.1 Pressure Hi-3 signal is unavailable, there is no Pressure Hi-3 With the number of OPERABLE would permit the use of compensatory actions such change inCDF or LERF.

channels more than one less than as placing an inoperable channel intrip for those 3.3.2.3 c 3 the Total Number of channels, functions that have that capability. The proposed (30 day backstop applies) within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months apply the one-hour frontstop time for ACTION b.isconsistent requirements of Specification with TS 3 0 3 that currently applies for this condition Containment 3.13 1 or be inat least HOT and is conservative with respect to the safety Isolation Phase STANDBY inthe next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and significance. Current TS allow for two inoperable B on in HOT SHUTDOWN within the channels for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for surveillance testing PressurmenHit following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months This action is To preserve this allowance, the requirements of PrssreHi3not required for the surveillance Action bdo not apply ifthe surveillance testing Acio 1 btesting provision of Action 17 a provision of Action 17 a is being applied.

(New Action) 3 3 2.1.a With the number of Split into ACTION 19.a and 19 b. There are two actuation channels associated with The PRA models the manual actuation of these OPERABLE channels one each of these functions, functions.

SI Manual less than the Minimum a. With the number of OPERABLE Initiation Channels OPERABLE channels one less than the Automatic initiation of these functions isthe primary Calculated RICT:

requirement, restore the Minimum Channels OPERABLE initiation process. In addition, SI and CS can be 3.3 2 2 a inoperable channel to requirement, within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months manually aligned and started from the control room. 1 channel: >1 0 yrs.

OPERABLE status within restore the Inoperable channel to There are two channels for manual actuation. The CS Manual 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or be inat least OPERABLE status or apply the most critfical systems for containment isolation are (30 day backstop applies)

Initiation HOT STANDBY within the requirements of Specification those that could be open to the atmosphere, which next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD 3.13.1 ,or be In at least HOT is generally limited to the normally closed ROB SHUTDOWN within the STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months purge. For most design-basis events, manual 3 3 2 3 a.1 following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months and in COLD SHUTDOWN within alignment is adequate for mitigation. A48 hour the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . frontstop time for one inoperable channel is Containment commensurate with the risk-significance of the Isolation Phase b With the number of OPERABLE condition.

A- Manual channels more than one less than Initiation the Minimum Channels A one-hour frontstop for more than one inoperable OPERABLE requirement, within 1 channel is consistent with TS 3 0 3 that would apply Action 19 hour restore at least one channel to to the current TS.

OPERABLE status or apply the requirements of Specification 3.13.1, 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 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-06002005 Page 27 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement New Action Requirement Technical Discussion and Comments Risk Basis Number Caiculated STP AOT Before Backstop (base case)1' Automatic With the number of a. With one train with the number of SI and CS will automatically switch over from taking The automatic switchover to containment sump Switchover to OPERABLE channels one OPERABLE channeis iess than suction from the RWST to taking suction from the function is modeied inthe recirculation SI common Containment less than the Minimum the Minimum Channels containment sump when the RWST low-low level is system model.

Sump: Channels OPERABLE OPERABLE requirement, within reached.

requirement, restore the 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months restore the inoperable Calculated RICT:

3 3 2.7 a Inoperable channel to channel to OPERABLE status or There isone channel for each of the three ESF OPERABLE status within apply the requirements of trains for both of these functions. A single 1channel: 246 days based on switchover function Automatic 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or be inat least Specification 3 13 1, or be in at inoperable channel effectively makes the in PRA Actuation Logic HOT STANDBY within the least HOT STANDBY within the associated train of CS and SI inoperable. The 48-and Actuation next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and inCOLD hour allowed outage time is not consistent with the (30 day backstop applies)

Relays SHUTDOWN within the SHUTDOWN within the following 7-day allowed outage time for a train of SI.

following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . Application of TS 3.13.1 will allow the requirements 3 327bto be consistent. There is substantial margin inthe 3..7bb With more than one train with the design since STP can mitigate nearly all design-number of OPERABLE channels basis accidents with a single ESF train.

RWST low-low less than the Minimum Channels leelOPERABLE requirement, within The wording of Actioni 9A better reflects the one 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore the channels for at channel/train and three train configuration and logic Action 19 to least two trains to OPERABLE of this instrumentation than the wording of Action new Action status or apply the requirements 19, which applies to functions with two actuation 19A of Specification 3.13.1, or be in channels. 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months isan adequate frontstop time to at least HOT STANDBY Within identify appropriate compensatory action and apply the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and In COLD TS 3.13.1.

SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . For conditions where more than one train Is inoperable, one hour is established to restore the channels for at least two of the three trains or to apply the requirements of TS 3.13.1. One hour is consistent with the allowed outage time of TS 3.0.3 that would apply to the current TS.

Containment ACTION 20. New Action 20A: The primary changes from original Action 20 are the Ifthe containment pressure Hi-i signal is Pressure Hi-i provision to apply TS 3.13.1 with one Inoperable INOPERABLE but functional for some conditions With the number of a. With the number of OPERABLE channel and a new Action c that applies With more (eg., seismic qualification) then the PRA can be 3 3 2.1.d OPERABLE channels one channels one less than the than one inoperable channel, used to determine a RICT. As an upper bound, less than the Total Number Total Number of Channels, assuming the Containment Pressure Hi-i signal is Loss of power of Channels, STARTUP STARTUP and/or POWER The Containment Pressure Hi-i actuation function unavailable (only the pressurizer pressure Low and/or POWER OPERATION may proceed is modeled inthe PRA. Consequently, an allowed signal is available for SI actuation)-

3OPERATION may proceed provided the following outage time can be calculated for its unavailability.

332 8a provided the following conditions are satisfied: The function provides mitigation for main steam line Calculated RICT: > 10 years conditions are satisfied-' breaks, feed line breaks and LOCA. The SI I______________I______

Description of Changes and Safety Evaluation NOC-AE-06002005 Page 28 Table 2 Detailed Description of Changes and Basis Specification OdAction Requirmn New Action Requirement TehiaicsinadComets Risk Basis Number TcnclDsuso n me Oldlcemened STP AOT Before Backstop' actuation for the MSLB provides the input to the 4.16 kV ESF a. For Functional Units For Functional Units with reactor trip This function has a bypass capability, (30 day backstop applies)

Bus with installed bypass test installed bypass test so ACTION 20.b need not be applied and its Undervoitage - capability, the inoperable capability, the inoperable requirements are not Included inthe proposed new For undervoltage/degraded voltage instrumentation, Loss Of channel may be placed in channel may be placed in inoperability of 3 or more channels of either function bypass, and must be bypass, and within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months action.

Voltage would be the same as one inoperable train of placed inthe tripped place the channel inthe emergency ESF power (i.e., an inoperable SDG).

condition within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . tripped condition or apply Current TS allow for two inoperable channels for up 3.3.2.8 b. the requirements of to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for surveillance testing. To preserve See 3 8.1.1,b for the associated RICT.

Note: Achannel may be Specification 3.13.1. this allowance, the requirements of Action b do not 4.16 kV ESF bypassed for up to 12 apply ifthe surveillance testing provision of Action Bus Under hours for surveillance Note. Achannel may be 20 a is being applied Voltage - testing per Specification bypassed for up to 12 Tolerable 4 32.1, provided no more hours for surveillance The degraded voltage and undervoltage Degraded than one channel is in testing per Specification instruments do not have installed bypass capability, Voltage bypass at any time. 4.3 2.1, provided no more so only original ACTION 20 b is relevant.

Coincident than one channel is in With SI b.For Functional Units with bypass at any time.

There are four channels per ESF train for each of no installed bypass test the functions with a 2/4 actuation logic.

3.3.2.8 c capability, For Functional Units with no Consequently, the function remains capable of installed bypass test capability, actuation as long as there are at least two operable 4.16 kV ESF 1. The inoperable channel channels.

Bus Isplaced inthe tripped 1.Within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months place the Undervoltage - condition within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , inoperable channel inthe The consequences of the function not being Sustained and tripped condition or apply the requirements of Specification capable of actuating is that a single train of Degraded emergency ESF power will not start inthe event of Voltage 2. The Minimum Channels 3.13 1, and a transient or accident that involves a loss of off-site OPERABLE requirement is power. The two remaining trains provide adequate New Action met; however, the 2.The Minimum Channels mitigation capability.

20A inoperable channel may be OPERABLE requirement is bypassed for up to 12 met; however, the inoperable hours for surveillance channel may be bypassed for The one-hour AOT for more than one inoperable testing of other channels up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for channel Isconsistent with application of the current per Specification 4 32.1. surveillance testing of other TS, which requires the application of TS 3 0 3 channels per Specification 432.1.

b. With the number of OPERABLE channels more than one less than the Total Number of 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 for functions with three channels and restore

Description of Changes and Safety Evaluation NOC-AE-06002005 Page 29 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement New Action Requirement Technical Discussion- and Comments -Risk Basis Number Calc ulated STP AOT Before Backstop (base case)l at least 3 channets to OPERABLE status for functions that have four channels, or apply the requirements of Specification 3 13 1; 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 be inat 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 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . This action is not required for the surveillance testing provision in the note to Action 20A a.

3 3 2.4 b With the number of Split Action 22 into 22 a and 22 b Steam line isolation has 2 channels, either of which Calculated RIOT:

OPERABLE channels one will Initiate the isolation function. With one channel Steam Line less than the Minimum a.With the number of OPERABLE inoperable, the other channel isavailable to initiate 3.3.2.4.b Isolation Channels OPERABLE channels one less than the the function. With one channel inoperable, 24 Automatic requirement, restore the Minimum Channels OPERABLE hours provides time to restore the channel orIchne:>0ys Actuation Logic inoperable channel to requirement, within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Identify compensatory action that will allow the 1chne:10ys and Actuation OPERABLE status within restore the inoperable channel to operator to apply TS 3.13.1. With both channels (3dabcktpplis Relays 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , or be In at least OPERABLE status or apply the inoperable, the one hour action time isconsistent (3dabcktpplis HOT STANDBY within the requirements of specification with the requirements of TS 3 0.3 that currently 3.3.2.6 b next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in at least 3.13.1, or be inat least HOT applies and provides operators with an option to 3.3.2.6 b HOT SHUTDOWN within STANDBY within the next 6 identify a compensatory action or determine that a Axlay the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ; hours and Inat least HOT degraded channel may have sufficient functionality 1 channel >1 0 yrs.

Auxiliatr however, one channel may SHUTDOWN within the following to extend the AOT.

Fedatr be bypassed for up to 4 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ; however, one channel (30 day backstop applies)

Automatic hours for surveillance may be bypassed for up to 4 The AFW automatic actuation logic and actuation Actuation Logic testing per Specification hours for surveillance testing per relays are train-specific and TS 3.13.1 may be 3 326 c 4 3 2.1 provided the other Specification 4.3 2.1 provided applied to provide AOTs that are consistent with the 3 32 6c channel is OPERABLE, the other channel isOPERABLE. AOT for the AFW train(s) made inoperable by the Train A39 4 days, train B 736 days, train C 502 Auxiliary bWtthnubroOPRBE Inoperable actuation days.

Fewtrchannels more than one less Train A Actuation Relays fail AFW Trains A and D, Actuation than the Minimum Channels The other actuation relay trains fail only the Relays OPERABLE requirement, within associated AFW train. Train C isdifferent than one hour restore at least one Train B because of the two Loss of DC Bus Action 22 channel to OPERABLE status for Initiators (Bus A and Bus B). The AFW B train

____________________ ________________results___show__an__eesultcshowantefectonstheLossCf DC susAA

Description of Changes and Safety Evaluation NOC-AE-06002005 Page 30 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement New Action Requirement Technical Discussion and Comments Risk Bas Is Number Calculated STP AOT Before Backstop (base case)1 functions with two channels or while the AFW C train results show an effect on the restore at least two channels to Loss of DC Bus A and B. The calculation did not OPERABLE status for functions credit operator action to manually start the AFW with three channels, or apply the pumps.

requirements of specification 3.13.1: or be In at least HOT (30 day backstop applies)

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 .

3 3 51 a. With one less than the Reword Actions 2 a and 2 b to In Action 2, the inoperability of the instrument The PRA models the function of these valves to required number of reference TS 3.13 1, and add new makes the associated equipment inoperable and dissipate RCS heat when the main condenser is not Atmospheric OPERABLE channels, Action 2 c for condition where the appropriate action is to enter the TS for that available. See the discussion for TS 3.7.1.6 for Steam Relief restore the inoperable more than two channels are equipment. The proposed changes to allow the additional information on the PRA modeling of these Valve channel to OPERABLE inoperable, application of TS 3.13.1 in Action 2 will permit valves.

Instrumentation status within 7 days; or be operators to apply AOTs to the actuating in at least HOT STANDBY instrumentation that are consistent with the AOTs Calculated RICT >1 0 yrs.

Action 2 within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , for the actuated equipment.

a. With one less than the required (30 day backstop applies) number of OPERABLE channels, within 7 days restore the inoperable b.With two less than the channel to OPERABLE status or See the assessment for TS 3.7.1.6. for the design required number of apply the requirements of functions of the valves.

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

Description of Changes and Safety Evaluation NOC-AE-06002005 Page 31 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement New Action Requirement Technical Discussion and Comments Risk Basis Number Calculated STP AOT Before Backstop (base case)1 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 inat least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

3 44 With one PORV inoperable With one PORV inoperable due to The PORVs function to relieve RCS pressure during The PRA models the pressurizer PORVs for Feed due to causes other than causes other than excessive seat design transients up to and including the design and Bleed, RCS pressure response to loss of load Pressurizer excessive seat leakage, leakage, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months either step load decrease with steam dump. Operation of events, RCS depressurization inresponse to a PORVs and within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months either restore restore the PORV to OPERABLE the PORVs minimizes the undesirable opening of steam generator tube rupture, and response to Associated the PORV to OPERABLE status or close the associated block the pressurizer safety valves. ATWS overpressure events, If a PORV is blocked Block Valves status or close the valve and remove power from the due to leakage, that PORV is unavailable for ATW~S associated block valve and block valve; within the following 72 The operability of the PORVs and block valves is response inthe PRA. Ifa PORV Isunavailable for Action b. remove power from the hours restore the PORV to based on their being capable of performing the any other reason, the PRA assumes that the PORV block valve; restore the OPERABLE status or apply the following functions: Isfailed. Unavailability of either PORV guarantees PORV to OPERABLE requirements of Specification -failure of the feed and bleed function modeled inthe status within the following 3.13.1, or be In HOT STANDBY PRA.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in HOT within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT 0 Manual control of the PORVs to control STANDBY within the next 6 SHUTDOWN within the following 6 RCS pressure for plant shutdown and for Calculated RIOT:

hours and inHOT hours, response to the steam generator tube SHUTDOWN within the rupture accident. One inoperable PORV: 355 days following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

0 Maintaining the integrity of the reactor (30 day backstop applies) coolant pressure boundary. Excessive leakage past the PORV could impair the ability to detect unidentified RCS pressure boundary leakage and the ability to effectively control excessive PORV leakage with the block valves isgoverned by this TS.

Application of TS 3.13.1 will allow an assessment of the functionality of the PORV and an assignment of a RIOT that reflects the actual plant condition. The redundant PORV is still operable to perform the

__________________________________________________________ 1 required safety functions. The pressurizer safety I_______________________

Description of Changes and Safety Evaluation NOC-AE-06002005 Page 32 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement New Action Requirement Technical Discussion and Comments Risk Basis II I I I

Number Calculated STP AOT Before Backstop, (base case)1 valves are still available for design-basis overpressure relief.

3 4.4 With both PORVs With both PORVs inoperable due Overpressure protection Isstill provided by the Calculated RIOT:

inoperable due to causes to causes other than excessive Code safety valves and pressurizer spray is still Pressurizer other than excessive seat seat leakage, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months apply available for response to normal pressure Both PORVs inoperable: 343 days PORVs and leakage, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months the requirements of Specification fluctuations Associated either restore at least one 3.13.1, or restore at least one of (30 day backstop applies)

Block Valves of the PORVs to the PORVs to OPERABLE status OPERABLE status or close or close their associated block Tesih ifrnei h ITfroeo w block valves and remove power from the Theslih diffperence inlettheR maCT foroneriutor of Atoc.

Actonc. valvesassociated their and remove power block valves, and be in HOTprsuie PORVs inpeableurefet thesmeall conthribtiono from the block valves and STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months presuie r PaRd faluetosenrisote.ta be in HOT STANDBY and HOT SHUTDOWN within thefedadbe.

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

HOT 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 block valve With one block valve inoperable, The existing required action makes no distinction INOPERABLE and Open 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 regarding the degree of functionality of the block Pressurizer restore the block valve to valve to OPERABLE status or valve.ý A degraded block valve may be able to >1 0 yrs.

PORVs and operable status or place its place its associated PORV in perform its expected function.

Associated associated PORV inclosed closed position; within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months (30 day backstop applies)

Block Valves position; restore the block restore the block valve to valve to operable status OPERABLE status or apply the INOPERABLE and Closed within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ; otherwise, requirements of Specification be in at least HOT 3.13.1; otherwise, be In at least STANDBY within the next HOT STANDBY within the next 6 Same as PORV Action3 4.4 Action b.

Atod.

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

A minor administrative format change is made to put OPERABLE in all capital letters.

Description of Changes and Safety Evaluation NOC-AE-06002005 Page 33 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement New Action Requirement Technical Discussion and Comments Risk Basis Number Calculated STP AOT Before Backstop (base case)l 3.4.4 With both block valves With both block valves inoperable, The existing time limit for restoration of operability is INOPERABLE and Open 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 inadequate to take reasonable action. Application Pressurizer restore the block valves to valves to OPERABLE status or of TS 3.13.1 provides an appropriate altemnative that >10 yrs.

PORVs and operable status or place place the associated PORVs inthe is commensurate with the risk-significance of the Associated the associated PORVs In closed position; restore at least configuration. (30 day backstop applies)

Block Valves the closed position; one block valve to OPERABLE restore at least one block status within the next hour or applyINPRBEadCoe valve to OPERABLE status the requirements of SpecificationINPRBEadCoe within the next hour; 3.13.1; otherwise, be in at least Atoe. otherwise, be inat least HOT STANDBY within the next 6 Same as PORV Action3.4.4 Action c.

Actone. HOT STANDBY within the hours and inHOT SHUTDOWN next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT 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 . Aminor administrative format change is made to put OPERABLE inall capital letters.

3 5.1 With one accumulator With one accumulator Inoperable, The accumulators function to assure that a The PRA assumes that two of the three Inoperable, except as a except as a result of boron sufficient volume of borated water will be accumulators are required for success Inmitigation Safety Injection result of boron concentration outside the required immediately forced into the reactor core through of a large break and one of three accumulators is System concentration outside the limits, within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months restore the three RCS cold legs Inthe event the RCS pressure needed for mitigation of a medium break. The Accumulators required limits, restore the inoperable accumulator to falls below the pressure of the accumulators. The accumulators have little risk-significance due to the Inoperable accumulator to OPERABLE status or apply the surge of water Into the core provides the Initial very low frequency of an initiating event that would Action a. OPERABLE status within requirements of Specification cooling mechanism inthe event of a large RCS pipe require them to function..

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or be inat least 3.13.1, or be inat least HOT rupture. The accident analysis assumes the HOT STANDBY within the STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months injection of two accumulators, since the volume of Calculated RIOT:

next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and reduce and reduce pressurizer pressure to one accumulator Isassumed to go out the break in pressurizer pressure to less than 1000 psig within the the RCS and not reach the core. 1 Inoperable accumulator: 2700 days less than 1000 psig within 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 . The accumulators would only be expected to be (30 day backstop applies) used for the most unlikely accidents. An assessment can be performed to determine the significance of the condition and ifcompensatory actions are necessary.

Description of Changes and Safety Evaluation NOC-AiE-06002005 Page 34 Table 2 Detailed Description of Changes and Basis Specification old Action Requirement New Action Requirement Technical Discussion and Comments' Risk Basis' Number Caiculated STP AOT Before Backstop (base case)l 3.5.1 New ACTION With more than one accumulator The one-hour requirement isa conservative time 2 inoperable accumulators: 360 days inoperable, except as a result of considering the low risk significance of these Safety Injection boron concentration outside the components and is consistent with TS 3 0.3 which (30 day backstop applies)

System required limits, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore would apply for more than one inoperable Accumulators at least two accumulators to accumulator inthe current TS OPERABLE status or apply the Action b. requirements of Specification 3.13.1, 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 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 3.5.1 (Previously ACTION b) With the boron concentration of one Accumulator boron concentration deviations are not 1 inoperable accumulator: 2700 days accumulator outside the required likely to be significantly outside required limits.

Safety Injection With the boron limit, within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months restore the Conservatism inthe accident analysis provides (30 day backstop applies)

System concentration of one boron concentration to within the reasonable assurance that the accumulators would Accumulators accumulator outside the required limits or apply the still provide their required function even with required limit, restore the requirements of Specification concentration outside the limits However, boron boron concentration to 3.13.1, or be in at least HOT concentration isnot specifically modeled in the PRA, within the required limits STANDBY Within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and STP would consider an accumulator with boron Acioc within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be In at and reduce pressurizer pressure to outside its limit to be non-functional.

c Actin least HOT STANDBY less than 1000 psig within the within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

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 .

3 5.1 New ACTION With the boron concentrations of The one-hour requirement Isa conservative time 2 inoperable accumulators: 360 days more than one accumulator outside considering the low risk significance of these Safety Injection the required limit, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months components and isconsistent with TS 3.0.3 which (30 day backstop applies)

System restore the boron concentration of would apply for more than one accumulator with Accumulators at least two accumulators to within boron concentration out of limit inthe current TS.

the required limits or apply the Action d requirements of Specification 3.13.1, 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 reduce pressurizer pressure to

Description of Changes and Safety Evaluation NOC-AE-06002005 Page 35 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement New Action Requirement Technical Discussion and Comments Risk Basis Number Caiculated STP AOT Before Backstop (base case)I less than 1000 psig within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

3.5.2 With less than the above With less than the above The OPERABILITY of three independent ECCS The PRA success criteria requires Injection from at subsystems OPERABLE, subsystems OPERABLE, but with at subsystems ensures that sufficient emergency core least one train of ECOS. However, for core cooling, EGOS in but with at least two High least two High Head Safety Injection cooling capability will be available In the event of a the design basis acceptance criteria are the criteria MODES 1,2,& Head Safety Injection pumps in an OPERABLE status, LOCA assuming the loss of one subsystem through of 10CFR50.46 while PRA acceptance criteria are 3pumps in an OPERABLE two Low Head Safety Injection any single failure consideration. Each subsystem is based on no core damage (core exit thermocouple with thecore accumulators capable ofinsupplying operating conjunction sufficient cooling to limit temperature less than 12000F).

status, two Low Head pumps and associated RHR heat Action a. Safety Injection pumps and exchangers in an OPERABLE the peak cladding temperatures within acceptable associated RHR heat status, and sufficient flow paths to limits for all postulated break sizes One EGOS is The difference in the calculated RIOT below is due exchangers in an accommodate these OPERABLE assumed to discharge completely through the to fires outside the control room These fires OPERABLE status, and Safety Injection pumps and RHR postulated break in the RCS loop. Thus, three trains primarily affect the B and C trains, leaving the A sufficient flow paths to heat exchangers,** within 7 days are required to satisfy the single failure criterion train for fire mitigation. Any unavailability of A train accommodate these restore the Inoperable subsystem(s) equipment is more significant then the OPERABLE Safety to OPERABLE status or apply the With 1 Inoperable train of SI, there is no loss of corresponding B or C trains.

Injection pumps and RHR requirements of Specification safety function, and STP meets single failure except heat exchangers,** restore 3.13.1, or be inat least HOT for specific low probability events. Calculated RIOT:

the inoperable STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months subsystem(s) to and In HOT SHUTDOWN within the 1 inoperable train OPERABLE status within 7 following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

days or be in at least HOT STANDBY within the next Train A 190 days, 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the Train B 2087 days, following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

Train C 2205 days (30 day backstop applies) 3.5 2 Existing ACTION b. moved New ACTION b. With two inoperable trains of Si there is generally not 2 inoperable trains - 35 days to ACTION c. a loss of safety function, although STP cannot EGOS in With less than two of the required mitigate LBLOOA If the SI train is Injecting Into the (30 day backstop applies)

MODES 1,2, & subsystems OPERABLE, within 1 broken RCS loop. Mitigation of SBLOOA with SI in 3 hour restore at least two the broken loop requires operator action. Steam line 3 inoperable trains 5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months subsystems to OPERABLE status break mitigation is impaired, but DNB Is not expected or apply the requirements of to occur. (Application of the RMTS Guidelines requires the Specification 3.13.1, or be in atdeemntoththeLOadATNarntmt

__________I least HOT STANDBY within the I___________ IWith no operable trains and no functionality, STP deeI nto htteLOadATO r o e

Description of Changes and Safety Evaluation NOC-AE-06002005 Page 36 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement New Action Requirement Technical Discussion and Comments, Risk Basis Number Caiculated STP AOT Before Backstop (base case)l next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and inHOT loses the SI safety function; however, a RIOT is based on exceeding the 1E.03/yr. GOOF criterion).

Action b. SHUTDOWN within the following 6 appropriate to accommodate specific situations hours. where the SI trains are degraded but still functional and to allow for timely actions commensurate with the actual significance of the condition.

The proposed one-hour time limit isconsistent with the requirement of TS 3.0.3 which would apply to the current TS.

3 52 No AGTION c. In the event the EGGS is actuated Administrative change to accommodate new NA and Injects water into the Reactor AGTION b No change to the TS requirement.

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

3.5.5 With the RWST inoperable, With the RWST inoperable, within 1 The OPERABILITY of the refueling water storage The PRA does not model the boratlon function restore the tank to hour restore the tank to tank (RWST) as part of the EGGS ensures that a associated with the RWST.

RWST OPERABLE status within 1 OPERABLE status or apply the sufficient supply of borated water Isavailable for hour or be inat least HOT requirements of Specification injection by the EGOS inthe event of a LOGA or a Galculated RIOT:

MODE 1,2,3,4 STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 3.13.1, or be in at least HOT steamrline break. The limits on RWST minimum and inGOLD SHUTDOWN STANDBY wiithin 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in volume and boron concentration ensure that: (1) 5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months (based on RWST not being functional) within the following 30 GOLD SHUTDOWN within the sufficient water is available within containment to hours. following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . permit recirculation cooling flow to the core, (2)the reactor will remain subcritical inthe cold condition (Application of the RMTS Guidelines for the risk following LOGA, and (3)the reactor will remain associated with a non-functional RWST requires the subritcaseamin folownga brak ndthee wlldetermination that the LGO and ACTION are not met subcritical foilloigau tariebeken.heewl based on exceeding the I E-03/yr. GOOF criterion).

The maximum allowable value for the RWST boron concentration forms the basis for determining the time (post-LOGA) at which operator action is required to switch over the EGGS to hot leg

_________________________recirculation in order to avoid precipitation of the I______________________

Description of Changes and Safety Evaluation NOC-AE-06002005 Page 37 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement New Action Requirement Technical Discussion and Comments Risk Basis Number Calcuiated STP AOT Before Backstop (base case)l soluble boron.

The limits on contained water volume and boron concentration of the RWST also ensure a pH value of between 7.5 and 10.0 for the solution recirculated Within containment after a LOCA.

The proposed application of TS 3 13.1 allows the operator to make a determination based on the specific situation and the degree of degradation of the RWST. A number of situations may make the RWST inoperable, but still functional in accordance with the RMTS Guidelines.

4 4- 4 3.5.6 With one RHR loop With one RHR loop inoperable, The OPERABILITY of the RHR system ensures The PRA models the RHR function to provide long inoperable, restore the within 7 days restore the required adequate heat removal capabilities for Long-Term term decay heat removal from the reactor core RHR required loop to loop to OPERABLE status or apply Core Cooling In the event of a small-break loss-of - during the Si recirculation phase of a small break or OPERABLE status within 7 the requirements of Specification coolant accident (LOCA), an isolatable LOCA, or a large break LOCA and to remove core decay heat days or be in at least HOT 3.13.1, or be in at least HOT secondary break in MODES 1, 2, and 3. The limits and sensible heat from the reactor core and RCS to MODE 1, 2, 3 on the OPERABILITY of the RHR system ensure achieve and maintain cold shutdown after the STANDBY within the next STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 6 hours and In HOT and in HOT SHUTDOWN within the that at least one RHR loop is available for cooling following events: feedwater line break, secondary Action a SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . including single active failure criteria. steam line break, and SGTR following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

The proposed action is justified by the plant-specific Calculated RICT:

function of RHR and the degree of redundancy at STP. STP's RHR does not perform a SI function, It 1 inoperable RHR train:

is required only for long-term cooling after shutdown or post-accident. In post-LOCA conditions, LHSI is >10 yrs.

functionally redundant.

(30 day backstop applies) 3 56 With two RHR loops With two RHR loops Inoperable, The application of TS 3.13.1 is justified by the plant- Calculated RICT:

inoperable, restore at least within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months restore at least two specific function of RHR and the degree of RHR two RHR loops to RHR loops to OPERABLE status or redundancy at STP. STP's RHR does not perform a 2 inoperable RHR trains:

OPERABLE status within apply the requirements of Si function. It Is required only for long-term cooling MODE 1, 2, 3 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or be in at least Specification 3.13.1, or be in at after shutdown or post-accident. In post-LOCA 524 days HOT STANDBY within 6 least HOT STANDBY within 6 conditions, LHSi is functionally redundant.

hours and in HOT hours and in HOT SHUTDOWN(3dabcktpplis Action b SHUTDOWN within the within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .(3dabcktpplis 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-06002005 Page 38 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement New Action Requirement Technical Discussion and Comments Risk Basis Number Calculated STP AOT Before Backstop (base case)1 3 6.1.7 With the 18-Inch With the 18-inch supplementary The design function associated With the isolation The isolation valves have no impact on CDF.

supplementary containment purge supply and/or valves for the containment normal purge and Containment containment purge supply exhaust Isolation valve(s) open for containment supplemental purge is to close and Calculated RICT:

Ventilation and/or exhaust isolation reasons other than given in remain closed in an accident. The normal purge valve(s) open for reasons Specification 3 6.1 7.b. above, isolation valves are required to be sealed closed 65 days based on change inLERF and assuming other than given in within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months close the open 18- during normal operations. the valve is open.

Specification 3 6.1.7 b. inch valve(s) or Isolate the Action b above, close the inch valve(s) open 18-or isolate the penetration(s),

requirements oforSpecification apply the Pre-planned credited to close theseaction operator valvescan for reasonably be most accident (30 day backstop applies) penetration(s) within 4 3 13.1, or be inat least HOT conditions.

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

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

36.1.7 With a containment purge With a containment purge supply Application of TS 3.13.1 within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months provides Bounded by 3.6.1.7 Action bassessment.

supply and/or exhaust and/or exhaust isolation valve(s) adequate time to perform an assessment to Containment isolation valve(s) having a having a measured leakage rate in determine acceptable altemnative action and time (30 day backstop applies)

Ventilation measured leakage rate in excess of the limits of needed to address an inoperable containment excess of the limits of Specifications 4 6 1.7.2 and/or purge isolation valve.

Specifications 4.6.1.7.2 4 6.1.7.3, within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months restore and/or 4.6.1.7.3, restore the inoperable valve(s) to c

Actin the Inoperable valve(s) to OPERABLE status or isolate the Actin c OPERABLE status or penetrations so that the measured isolate the penetrations so leakage rate does not exceed the that the measured leakage limits of Specifications 4 6.1.7.2 rate does not exceed the and/or 4 6.1.7.3 or apply the limits of Specifications requirements of Specification 4 6.1.7.2 and/or 46.1.7.3 3.13.1; otherwise be inat least within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , otherwise HOT STANDBY within the next 6 be inat least HOT hours and InCOLD SHUTDOWN STANDBY within the next within the foilowing 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

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-06002005 Page 39 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement New Action Requirement Technical Discussion and Comments Risk Basis Number Calculated STP AOT Before Backstop (base case)1 3 62.1 With one Containment With one Containment Spray The OPERABILITY of the Containment Spray Containment Spray action leveis have no Spray System inoperable, System inoperable, within 7 days System ensures that containment depressurization dependency on core damage frequency and are Containment restore the inoperable restore the inoperable Spray and cooling capability will be available Inthe event based on contributions to large early release Spray Spray System to System to OPERABLE status or of a LOCA or steam line break. Containment Spray frequency.

OPERABLE status within 7 apply the requirements of System also provides a mechanism for removing days or be inat least HOT Specification 3 13.1, or be Inat iodine from the containment atmosphere. Calculated RICT:

STANDBY within the next least HOT STANDBY within the 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ; restore the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and inCOLD The Containment Spray System is comprised of 3 >1 0 yrs. based on LERF inoperable Spray System SHUTDOWN within the following trains. 2 operable trains meet the design-basis and to OPERABLE status 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . 1 train isadequate to perform the system function at (30 day backstop applies) within the next 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or a degraded level. Reactor Containment Fan be inCOLD SHUTDOWN Coolers provide functionally redundant containment within the following 30 heat removal capability. Compensatory actions can The Containment Spray System Isnot risk-hours. be taken to reduce Iodine contribution to operator sgiiat dose. Deletion of the 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months provision between HOT STANDBY 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 Isno longer relevant with the application of TS 3 13.1.

36.2.1 The current TS have no With more than one Containment Reactor Containment Fan Coolers provide Calculated RICT:

action for more than one Spray System inoperable, within 1 functionally redundant containment heat removal Containment train of CS inoperable and hour restore at least two Spray capability. Evaluations performed for STP TS >10 yrs based on LERF Spray TS 3 0.3 would apply. Systems to OPERABLE status or Amendments 85172 determined that a single train of apply the requirements of RCFCs and Containment Spray is adequate for (30 day backstop applies)

New Action b Specification 3.13.1, or be in at containment heat removal and RCB pressure least HOT STANDBY within the control in accident conditions. Compensatory next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and inCOLD actions can be taken to reduce Iodine contribution SHUTDOWN within the following to operator dose.

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

The proposed time limit of one hour to apply TS 3.13.1 isconsistent 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-06002005 Page 40 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement New Action Requirement Technical Discussion and Comments Risk Basis Number Calculated STP AOT Before Backstop (base case)1 3.6 23 With one group of the With one group of the above The OPERABILITY of the Containment Cooling The PRA models the RCFC functions to ventilate above required Reactor required Reactor Containment Fan System ensures that. (1)the containment air and cool the main area reactor containment building Reactor Containment Fan Coolers Coolers inoperable, within 7 days temperature will be maintained within limits during and to maintain containment pressure within design Containment Inoperable, restore the restore the inoperable group of normal operation, and (2)adequate heat removal limits during accident conditions Fan Coolers inoperable group of RCFC ROFC to OPERABLE status or capacity Isavailable when operated inconjunction to OPERABLE status apply the requirements of with the Containment Spray Systems during post Reactor Containment Fan Cooler action levels have Action a. within 7 days or be inat Specification 3.13.1, or be inat LOCA conditions. STPEGS has three groups of no significant effect on core damage frequency or to least HOT STANDDY least HOT STANDBY within the Reactor Containment Fan Coolers (RCFCs) with large early release frequency.

within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and InCOLD two fans in each group (total of six fans). Five fans inCOLD SHUTDOWN SHUTDOWN within the following are adequate to satisfy the safety requirements Calculated RICT:

within the following 30 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months , including single failure.

husApplication of TS 3 13.1 isacceptable for >10 yrs based on CDF and LERF.

calculating an extension of the allowed outage time for the RCFO function. Three trains of RCFCs (30 day backstop applies) provide a high degree of redundancy and Containment Spray isfunctionally redundant for heat removal.

3.6.2.3 The current TS have no With more than one group of the Three trains of RCFCs provide a high degree of Calculated RIOT:

action for more than one above required Reactor redundancy and Containment Spray is functionally Reactor group of RCFCs inoperable Containment Fan Coolers redundant for heat removal. >10 yrs. Based on ODF and LERF Containment and TS 3.0.3 would apply. inoperable, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore at Fan Coolers least two groups of ROFO to The one-hour "frontstop" time is conservative (30 day backstop applies)

OPERABLE status or apply the considering the low risk-significance of the system New Action b. requirements of Specification and degree of redundancy. Evaluations performed 3.13.1, or be in at least HOT for STP TS Amendments 85/72 determined that a STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months single train of RCFCs and Containment Spray is and inCOLD SHUTDOWN within adequate for containment heat removal and ROB the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . pressure control inaccident conditions. The one hour Isconsistent with TS 3 0 3 which the current TS would apply to more than one inoperable group of ROF~s.

Description of Changes and Safety Evaluation NOC-AE-06002005 Page 41 Table 2 Detailed Description of Changes and Basis Specification Old AcinRequirement New Action Requirement TcnalDiscussion and Comments Risk Basis Number Actio TechicalCalculated STP AOT Before Backstop (base case~I 3.6.3 With one or more of the With one or more of the isolation The OPERABILITY of the containment isolation Calculated RICT:

isolation valve(s) valve(s) Inoperable, maintain at valves ensures that the containment atmosphere inoperable, maintain at least one isolation barrier* will be isolated from the outside environment Inthe >10 yrs.

Containment least one isolation barnier*

Isolation OPERABLE in each affected event of a release of radioactive material to the OPERABLE ineach penetration that is open and within containment atmosphere or pressurization of the Valves affected penetration that (30 day backstop applies) is open and 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months s: containment and is consistent with the requirements (Added new of General Design Criteria 54 through 57 of Application of TS 3 13.1 would evaluate the function ACTION d.and a. Restore the inoperable Appendix A to 10 CFR Part 50. Containment

a. Restore the inoperable isolation within the time limits specified for those of the individual valve(s) that are affected with changed valve(s) to valve(s) to OPERABLE respect to the functionality of their associated existing status, or Isolation valves designed to close automatically system.

OPERABLE status ensures that the release of radioactive material to ACTION d.to within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , or the environment will be consistent with the ACTION e.) b. Isolate each affected penetration by use of at least assumptions used inthe analyses for a LOCA.

b. Isolate each affected one deactivated automatic penetration within 24 valve secured inthe isolation hours by use of at The proposed change to this specification adds least one deactivated position, or check valve with ACTION d.to allow the application of Specification automatic valve flow through the valve 3.13.1. The existing action time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months isnot secured inthe isolation secured-, or changed 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months issufficient time to perform a position, or check risk assessment of the condition to determine if valve with flow through c. Isolate each affected additional time may be taken for corrective the valve secured-, or penetration by use of at least maintenance before closing the affected one closed manual valve or penetration. Ifthe RICT is not determined Within 24

c. Isolate each affected blind flange, or hours, one of the other actions must be taken.'

penetration Within 24 However, Ifthe penetration is closed per ACTION b hours by use of at d Apply the requirements of or c and a RICT is calculated after the 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months least one closed Specification 3.13.1 expires, the penetration may be opened in manual valve or blind accordance with TS 3 13.1.

flange, or 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

d. Be inat least HOT and inCOLD SHUTDOWN within STANDBY within the the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

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 .

I I a I

Description of Changes and Safety Evaluation NOC-AE-06002005 Page 42 Table 2 Detailed Description of Changes and Basis Specificat -Ion Old'Action Requirement New Action Requirement Technical Discussion and Comments Risk Basis Number Caiculated STP AOT Before Backstop (base case)1-3.7.1.2 With one motor-driven With one motor-driven auxiliary Even though the 28-day AOT Isalready comparable Calculated RICT:

auxiliary feedwater pump feedwater pump inoperable, within to the RMTS 30-day backstop, this action is Auxiliary Inoperable, restore the 28 days restore the pump to Included Inthe scope to enable the application of 502 days Feedwater pump to OPERABLE OPERABLE status or apply the TS 3.13 2 requirements for entry into multiple action status within 28 days. requirements of Specification statements. (30 day backstop applies) 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 The *action not met" requirement for ACTION a. is and in HOT SHUTDOWN within the relocated from ACTION c to ACTION a,which is Action a. following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , consistent with STP's TS format. This isan administrative change to facilitate incorporating TS 3.13.1 inthe other ACTIONs for this TS 3.7.1 2 With the turbine-driven With the turbine-driven auxiliary STP's design is highly redundant with 3 motor- The PRA models the AFW function during auxiliary feedwater pump feedwater pump inoperable, or with driven AFW pumps and 1turbine-driiven AFW emergency operation to supply feedwater to steam Auxiliary inoperable, or With any two any two auxiliary feedwater pumps pump Each auxiliary feedwater pump iscapable of generators to remove reactor core decay heat in Feedwater auxiliary feedwater pumps inoperable, within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months restore delivering feedwater to the entrance of the steam case of: 1)loss of normal feedwater supply; 2) inoperable, restore the the affected auxiliary feedwater generators with sufficient capacity to ensure that feedline rupture event; 3)other transients; 4)main affected auxiliary pump(s) to OPERABLE status or adequate feedwater flow Isavailable to remove steam line break; 5)SG tube rupture; 6)small feedwater pump(s) to apply the requirements of decay heat and reduce the Reactor Coolant System LOCAs; 7)as required for ATWS mitigation; or 8).

OPERABLE status within Specification 3.13.1, or be inat temperature to less than 350OF when the Residual the function to prevent the pressurizer from going Action b. 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . MODE 3 may be least HOT STANDBY within the Heat Removal System may be placed into water-solid.

entered with an Inoperable next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and inHOT operation. One train of AFW feeding an intact turbine-driven auxiliary SHUTDOWN within the following 6 steam generator is sufficient for post-accident Calculated RICT:

feedwater pump for the hours. MODE 3 may be entered decay heat removal. STP's safety analyses show purposes of performing with an inoperable turbine-driiven that three trains of AFW feeding three steam 1 inoperable train:

Surveillance Requirement auxiliary feedwater pump for the generators are required for sufficient RCS cooling to 4.7.1 2.1 a.2. purposes of performing prevent the pressurizer from going water solid ina MDAFW A or C: 700 days Surveillance Requirement loss of normal feedwater (LONF) assuming failure 4.7.1 2.1 a 2. of Train A ESF actuation to start Train A AFW and Train DAFW and with credit for operator action to MDAFW B: 1200 days manually start one of the failed AFW trains from the control room. TDAFW: 380 days Proposed change to Action b.permits the (30 day backstop applies) application of TS 3 13 1 and uses the existing 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months action time. The existing 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months AOT is 2 inoperable MDAFW: 7.9 days conservative with respect to the redundancy Inthe STP design. Additional justification Isprovided in 1 inoperable MDAFW and inoperable TDAFW: 42 5 letter dated December 3, 2001 (NOC-AE- days. (30 day backstop applies) 01001196) that is the basis for the existing AFW AOTs.

Description of Changes and Safety Evaluation NOC-AE-06002005 Page 43 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement New Action Requirement Technical Discussion and Com ments Risk Basis Number

Calculated STP, AOT Before Backstop (base case)1 Similar to the change for ACTION a, the change to ACTION b Includes an administrative change to relocate to ACTION b the "action not met" requirements for ACTION b from ACTION c.

3.7.1.2 With three auxiliary With three auxiliary feedwater As noted above, one train of AFW feeding an intact Three inoperable AFW pumps will exceed the feedwater pumps pumps inoperable, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months steam generator is sufficient for post-accident RMTS 1E-03 CDF limit if the pumps are not Auxiliary inoperable, or if the apply the requirements of decay heat removal For conditions where one or functional.

Feedwater required action and Specification 3 13 1, or be In at more of the inoperable pumps are functional, TS associated allowed least HOT STANDBY within the 3 13.1 could be applied to calculate an appropriate outage time for a) or b) is next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT AOT.

not met, be in at least SHUTDOWN within the following 6 HOT STANDBY within hours.

Action c. 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 .

37.1.3 With the AFST Inoperable, With the AFST inoperable, within 4 The OPERABILITY of the auxiliary feedwater The PRA models the AFW function to provide a within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months restore the hours restore the AFST to storage tank with the minimum water volume sufficient Inventory of water to allow the AFWS to Auxiliary AFST to OPERABLE OPERABLE status or apply the ensures that sufficient water Is available to maintain perform its function.

Feedwater status or be in at least requirements of Specification the RCS at HOT STANDBY conditions for 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Storage Tank HOT STANDBY within the 3.13. 1, or be in at least HOT with steam discharge to the atmosphere concurrent Calculated RICT:

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 with a MFWLB and failure of the AFW flow SHUTDOWN within the and in HOT SHUTDOWN within the controller followed by a cooldown to 350OF at 250F Exceeds the RMTS 1E-03 CDF limit 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 , per hour.

1 1/2 hours (assumes the AEST is unavailable; Application of TS 3.13 1 is appropriate. The cause however, shutdown is neither appropriate nor for the inoperability of the AFWST might be such required by the TS with no AFW available to that it would be unsafe to shutdown to a condition remove decay heat. (See TS 3.7.1 2 d) where the tank was required. More likely, the tank would be degraded but functional or other 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for tank level compensatory actions could be Implemented (e g, tank fill options) such that a RICT would be justified.

3.7.1.5 MODE 1: Change APPLICABILITY from The OPERABILITY of the main steam line Isolation The PRA models the function of the MSIVs to close MODE 1, 2, and 3 to 'MSiVs open valves ensures that no more than one steam to isolate containment Main Steam With one MSIV inoperable in MODE 1, 2, and 3" generator will blow down in the event of a steam Isolation but open, POWER line rupture. This restriction is required to: (1) Calculated RICT:

Valves OPERATION may continue With one MSIV inoperable, within 4 minimize the positive reactivity effects of the

___________provided the inoperable hours close or restore the Reactor Coolant System cooldown associated with

Description of Changes and Safety Evaluation NOC-AE-06002005 Page 44 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement New Action Requirement Technical Discussion and Comments Risk Basis Number Calcuiated STP AOT Before Backstop (base case)1 valve is restored to Inoperable vaive to OPERABLE the blowdown, and (2)limit the pressure nise within 1ioeal SV 0ys OPERABLE status within 4 status, or apply the requirements of containment inthe event the steam line rupture 1inprbeMI:10ys hours: otherwise be in Specification 3.13 1; otherwise be occurs within containment. The OPERABILITY of HOT STANDBY within the in HOT STANDBY within the next 6 the main steam isolation valves within the closure (30 day backstop applies) next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT hours and In HOT SHUTDOWN times of the Surveillance Requirements are SHUTDOWN within the within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , consistent with the assumptions used in the safety following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . analyses MODES 2 and 3 The APPLICABILITY is revised to apply only to open MSIVs inMODE 1, 2, and 3 This change is With one MSIV Inoperable, essentially administrative since the current Action subsequent operation in only applies to open MSIVs. The terminology "but MODE 2 or 3 may proceed open" isdeleted from Action 1 because itbecomes provided the Isolation valve redundant. This has no safety implications because is maintained closed, the MSIVs are performing their design function if Otherwise, be in HOT they are closed STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and In HOT The distinction between MODE 1 and MOD Es 2 SHUTDOWN within the and 3 is deleted because the revised action following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . includes a provision to close the valve and there is no difference Inthe end-state MODE if TS 3.13.1 is not applied.

3.7.1.5 No ACTION b. With more than one MSIV One hour Is a conservative time to determine the 2 inoperable MSiVs' 410 days inoperable, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months close or risk significance of the condition with more than one Main Steam restore at least three valve(s) to inoperable MSIV. The assessment may determine (30 day backstop applies)

Isolation OPERABLE status, or apply the that although a MSIV is not operable under all Valves requirements of Specification aspects of the TS definition, itis still functional and 3.13 1; otherwise be inHOT additional time can be taken to restore itto STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months operability. One hour isconsistent with the current and in HOT SHUTDOWN within the TS requirement to apply TS 3 0 3 for more than one following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . inoperable MS IV.

3.7.1.6 With one less than the With one less than the required The atmospheric steam relief valves are required The PRA models the function of these valves to required atmospheric atmospheric steam relief valves for decay heat removal and safe cooldown in dissipate RCS heat when the main condenser is not Atmospheric steam relief valves OPERABLE, within 7 days restore accordance with Branch Technical Position RSB 5- available.

Steam Relief OPERABLE, restore the the required atmospheric steam 1. In the safety analyses, operation of the Tevlefnto httePAceisdpnso Valves required atmospheric relief valves to OPERABLE status atmospheric steam relief valves is assumed in the vntalvneefnct.Ionthat th PRA ale ceitsdepedsing steam relief valves to or apply the requirements of accident analyses for mitigation of small break frtheintatglvesofnctiongenreralntePRA ishlooing

Description of Changes and Safety Evaluation NOC-AE-06002005 Page 45 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement New Action Requirement Technical Discussion and Comments Risk Basis Number Calcuiated STP AOT Before Backstop (base case)1 OPERABLE status within 7 Specification 3 13.1 or be in at LOCA, feedwater line break, loss of normai plant conditions The primary function isto control days; or be inat least HOT least HOT STANDBY within the feedwater and loss-of-offsite power. reactor decay heat, which post trip isan automatic STANDBY with the next 6 next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and inHOT function. For some initiating events, the valves are Action a. hours and in HOT SHUTDOWN Within the following 6 The atmospheric steam relief valve manual controls asked to perform a cooldown function in response SHUTDOWN within the hours and place the required must be OPERABLE InModes 1, 2,3, and 4 (Mode to operator control input. The model can adjust for following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and place RCS/RHR loops inoperation for 4 when steam generators are being used for decay the situation where automatic actuation works, but the required RCS/RHR decay heat removal heat removal) to allow operator action needed for manual does not by failing the associated valve for loops inoperation for decay heat removal and safe cooldown in cooldown purposes.

decay heat removal accordance with Branch Technical Position RSB 5- Calculated RICT:

1.

The atmospheric steam relief valve automatic 1 inoperable SG PORV: >790 days controls must be OPERABLE with a nominal setpoint of 1225 psig inModes 1and 2 because the (30 day backstop applies) safety analysis assumes automatic operation of the atmospheric steam relief valves with a nominal setpoint of 1225 psig with uncertainties for mitigation of the small break LOCA. Inorder to support startup and shutdown activities (including post-refueling low power physics testing), the atmospheric steam relief valves may be operated in manual and open InMode 2 to maintain the secondary side pressure at or below an indicated steam generator pressure of 1225 psig.

7 days Isadequate time to determine altemnative action and AOT. A RIOT will probably be justifiable based on the expected availability of the condenser and associated steam dumps.

Description of Changes and Safety Evaluation NOC-AE-06002005 Page 46 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement New Action Requirement Technical Discussion and Comments Risk Basis Number Calculated STP AOT Before Backstop

- (base case)1 37.1 6 With two less than the With two less than the required A RICT is likely to be justifiable based on the Calculated RICT:

required atmospheric relief atmospheric relief valves expected availability of the condenser and Atmospheric valves OPERABLE, OPERABLE, within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months associated steam dumps. 2 Inoperable SG PORVs: 83 days Steam Relief restore at least three restore at least three atmospheric Valves atmospheric relief valves to relief valves to OPERABLE status (30 day backstop applies)

OPERABLE status within or apply the requirements of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in at least Specification 3.13 1 or be in at HOT STANDBY with the least HOT STANDBY within the Action b next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the SHUTDOWN within the following 6 following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and place hours and place the required the required RCS/RHR RCS/RHR loops in operation for loops in operation for decay heat removal.

decay heat removal.

3.7.1.6 NA (New ACTION) With more than two less than the One hour is a conservative time to determine Calculated RICT:

required atmospheric relief valves altemnative action and AOT. A RICT is likely to be Atmospheric OPERABLE, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore justifiable based on the expected availability of the 3 inoperable SG PORVs: 12 days Steam Relief at least two atmospheric relief condenser and associated steam dumps. The 1-Valves valves to OPERABLE status or hour limit is consistent with the limit of TS 3 0.3 apply the requirements of which current TS would require with more than 2 Specification 3.13.1 or be In at less than the required number of operable valves.

least HOT STANDBY within the Actin c.next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and In HOT Actin c.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.

3 7.3 With only two component With only two component cooling The OPERABILITY of the Component Cooling The PRA models the design basis heat removal cooling water loops water loops OPERABLE, within 7 Water System ensures that sufficient cooling functions of the CCW system.

Component OPERABLE, restore at days restore at least three loops to capacity is available for continued operation of Cooling Water least three loops to OPERABLE status or apply the safety-related equipment during normal and Calculated RICT:

OPERABLE status within 7 requirements of Specification accident conditions, It provides post-accident heat Action a days or be in at least HOT 3.13 1, or be in at least HOT removal for ECCS, RHR, and reactor containment 1 inoperable train of CCW:

STANDBY within the next STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months fan coolers 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD and in COLD SHUTDOWN within SHUTDOWN within the the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . CCW has a high degree of redundancy. With one >10 yrs.

following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . inoperable train, the system generally still meets the

Description of Changes and Safety Evaluation NOC-AE-06002005 Page 47 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement New Action Requirement Technical Discussion and Comments Risk Basis' Number Calculated STP AOT Belore Backstop (base case)1 single failure criteria with only modest degradation.

The 7-day frontstop time is not representative of the (30 day backstop applies) safety significance of one train of COW being inoperable.

Proposed as Action a. because of proposed new Action b.below.

3.7.3 The current TS do not With two or more component Evaluations performed for STP Amendments 85172 Calculated RIOT:

have an action for more cooling water loops inoperable, showed that a single train of COW is adequate for Component than one inoperable train within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore at least two safe shutdown and accident mitigation with only 2 inoperable trains of COW.

Cooling Water of COW. TS 3 0.3 would loops to OPERABLE status or modest degradation incapability.

apply. apply the requirements of 278 days Proposed new Specification 3.13.1, or be inat The one-hour time is conservative and consistent Action b least HOT STANDBY within the with TS 30.3 which would be required by current (30 day backstop applies) next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and InCOLD TS for more than one inoperable train of COW.

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

3.7.4 With only two essential With only two essential cooling The OPERABILITY of the Essential Cooling Water The PRA models the SOW function to provide cooling water loops water loops OPERABLE, within 7 (ECW) System ensures that sufficient cooling sufficient flow thru the supply and retumn headers to Essential OPERABLE, restore at days restore at least three ioops to capacity isavailable for continued operation of meet design basis accident and normal operating, Cooling Water least three loops to OPERABLE status or apply the safety-related equipment during normal and requirements and to provide cooling water thru heat OPERABLE status within 7 requirements of Specification accident conditions. The EOW self-cleaning exchangers of standby diesel generators and their Action a days or be inat least HOT 3.13.1, or be inat least HOT strainer must be in service and functional inorder support systems (design basis accident and normal STANDBY within the next STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for the respective ECW train to be OPERABLE, In operating conditions) 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and InCOLD and InCOLD SHUTDOWN within an accident or loss of offsite power, the SOW SHUTDOWN within the the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months , system transfers heat from the COW system and Calculated RIOT:

following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . the standby diesel generators to the ultimate heat sink. 1 inoperable train of SOW From a design basis perspective, SOW is comprised of three 50% trains. However, with a 99 days single train of ECW inoperable there is no loss of safety function, and the plant generally meets single (30 day backstop applies) failure for most probable design-basis events.

Proposed as Action a. because of proposed new Action b.below

Description of Changes and Safety Evaluation NOC-AE-06002005 Page 48 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement New Action Requirement Technical Discussion and Comments Risk Basis Number Calculated STP AOT Before Backstop (base case)1 3.7.4 The current TS do not have With two or more essential cooiing With two inoperable ECW trains, the piant retains its Caicuiated RiOT:

an action for more than water ioops inoperable, withinil capabiiity to mitigate a design-basis accident Essential one Inoperable train of hour restore at ieast two loops to 2 inoperable trains of ECW:

Cooling Water ECW. TS 3.0.3 would OPERABLE status or apply the The one-hour time Isconservative and consistent apply. requirements of Specification with TS 3 0 3 which would be required by current 102 hours0.00118 days 0.0283 hours 1.686508e-4 weeks 3.8811e-5 months Proposed new 3.13 1, or be inat least HOT TS for more than one inoperable train of ECW.

Actin b.STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Actin b.and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months 3 7.7 With one Control Room With one Control Room Makeup The Control Room Makeup and Filtration System The PRA models the cooling function associated Makeup and Cleanup and Cleanup Filtration System is comprised of three 50 percent redundant with this system as a potential plant initiating event.

Control Room Filtration System inoperable, within 7 days restore systems (trains) that share a common intake However, the pressurization and filtration function of Makeup and inoperable, restore the the inoperable system to plenum and exhaust plenum Each systemn/train is this system is not modeled in the PRA. The CR Cleanup inoperable system to OPERABLE status or apply the comprised of a makeup fan, a makeup filtration dose mitigation design basis function of the system Filtration OPERABLE status within requirements of Specification unit, a cleanup filtration unit, a cleanup fan, a is not relevant to either core damage frequency or 7 days or be Inat least 3.13.1, or be inat least HOT control room air handling unit, a supply fan, a large early release frequency and does not factor the next 6within hours retumn fan, and associated ductwork and dampers. into the calculation of an allowed outage time.

AcinaHOT Action athe STANDBY within next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in and InCOLDwithin STANDBY SHUTDOWN Two of the three 50% design capacity trains are COLD SHUTDOWN the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . required to be operable during the following modes Cluae IT 30ofthe following within operation, shutdown, hot standby, normal Cluae IT withn 30operation, th folowin postulated accident condition, and loss hours. of offsite power. One inoperable train:

The OPERABILITY of the Control Room Makeup 5500 days and Cleanup Filtration System ensures that. (1)the ambient air temperature does not exceed the (30 day backstop applies) allowable temperature for continuous duty rating for the equipment and Instrumentation cooled by this system, and (2)the control room will remain habitable for operations personnel during and following all credible accident conditions. The OPERABILITY of this system inconjunction with control room design provisions isbased on limiting the radiation exposure to personnel occupying the control room to 5 reins or less whole body, or its equivalent This limitation is consistent with the requirements of General Design Criterion 19 of Appendix A,10 CFR Part 50.

The effects of Inoperable heating ventilation and

_____________-J _______________ air conditioning I____________ (HVAC) functions of this system is I

Description of Changes and Safety Evaluation NOC-AE-06002005 Page 49 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement New Action Requirement Technical Discussion and Comments Risk Basis Number Calcuiated STP AOT Before Backstop (base case)1 addressed In the effects of an inoperable train of Essential Chilled Water (TS 3.7.14). Therefore, an allowance to apply TS 3.13.1 is needed for consistency with TS 3.7.14.

3.7.7 With two Control Room With two Control Room Makeup Same as above Calculated RICT:

Makeup and Cleanup and Cleanup Filtration Systems Control Room Filtration Systems inoperable, within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months restore Two inoperable trains, 61 hours7.060185e-4 days 0.0169 hours 1.008598e-4 weeks 2.32105e-5 months Makeup and inoperable, restore at at least two systems to Cleanup least two systems to OPERABLE status or apply the Exceeds the RMTS IE-03 COP limit if the trains are Filtration OPERABLE status within requirements of Specification not functional for longer than 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 72 hours or be in at least 3 13.1,. or be in at least HOT bHOT Acio STANDBY within STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Actin bthe next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in and In COLD SHUTDOWN within COLD SHUTDOWN the 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 .

37.7 With three Control Room With three Control Room Makeup The action requires actions to preclude a fuel Three Inoperable trains:

Makeup and Cleanup and Cleanup Filtration Systems handling accident in the spent fuel pool. With three Control Room Filtration Systems inoperable, suspend all operations inoperable trains, the allowed outage time Is 12 Exceeds the RMTS 1E-03 CDF limit if the trains are Makeup and inoperable, suspend all involving movement of spent fuel, hours. This accommodates maintenance or testing not functional for longer than 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Cleanup operations involving and crane operation with loads activities that require opening or entry into the Filtration movement of spent fuel, over the spent fuel pool, and within common plenums. This time is reasonable to and crane operation with 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months restore at least one diagnose, plan, and possibly repair problems with Action c loads over the spent fuel system to OPERABLE status or the boundary or the ventilation system. This is pool, and restore at least apply the requirements of acceptable based on the low probability of a design one system to Specification 3 13.1, or be in at basis event In that brief allowed outage time and OPERABLE status within least HOT STANDBY within the because administrative controls impose 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months or be in at least next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD compensatory actions that reduce the already small HOT STANDBY within SHUTDOWN within the following risk associated With being in the ACTION.

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

COLD SHUTDOWN The RMTS Guidelines would allow extension of the within the following 30 allowed outage time for emergent conditions where hours. there Is PRA functionality that meets the criteria in the guidelines.

Description of Changes and Safety Evaluation NOC-AE-06002005 Page 50 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement New Action Requirement, Technical Discussion and Comments Risk Basis Number Calcuiated STP AOT Before Backstop (base case)1 3.7.14 With oniy two With oniy two Essential Chilied The OPERABILITY of the Essential Chilled Water The PRA models the EChW system functions to Essential Chilled Water System ioops OPERABLE, System ensures that sufficient cooling capacity is provide cooling for the design basis functions.

Essential Water System loops Within 7 days restore at ieast three available for continued operation of safety-reiated Chilled Water OPERABLE, restore ioops to OPERABLE status or equipment duriing normal and accident conditions. Calculated RICT:

three loops to apply the requirements of The EChW system supports the area cooling for Action a OPERABLE status Specification 3.13.1, or be inat safety-related equipment inthe1inprbetano hW within 7 days or be in least HOT STANDBY within the Mechanical/Electrical Auxiliary Building and the 1inprbetanoEhW at least HOT next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD Fuel Handling Building The redundant cooling >90dy STANDBY within the SHUTDOWN within the following capacity of this system, assuming a single failure, is 290dy next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . consistent with the assumptions used Inthe safety (3dabcktpplis COLD SHUTDOWN analyses.(3dabcktpplis within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . From a design basis perspective, the EChW system is comprised of three 50% trains. With a single train of EChW inoperable there is no loss of safety function, and the plant generally meets single failure for most probable design-basis events.

Proposed as Action a. because of proposed new Action b.below.

3.7.14 The current TS do not With two or more Essential Chilled With two inoperable EChW trains, the plant retains 2 Inoperable trains of EChW:

have an action for more Water System loops inoperable, its capability to mitigate a design-basis accident.

Essential than one inoperable train within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore at least two 36 days Chilled Water of EChW. TS 3 0 3 would loops to OPERABLE status or With three inoperable EChW trains, the function is apply. apply the requirements of lost unless the PRA functionality provisions from the (30 day backstop applies)

New Action b. Specification 3.13.1, or be inat RMTS Guidelines can be applied.

least HOT STANDBY within the Altretan fEh nprbe next6 adhors inCOLDThe one-hour time Isconservative and consistent SHUTDOWN within the following with TS 3 0 3 which would be required by current 7 or eceste1E0/rlmtadT 30 ous.TS for more than one inoperable train of EChW. required action is not met as well as being a loss of function where RMTS may not be applied).

3 8.1.1 With one offsite circuit of With one offsite circuit of the The initial conditions of DBA and transient analyses The PRA models the offsite power design basis the above-required A C. above-required A C. electrical inthe FSAR, Chapter 6 and Chapter 15, assume functions including-A C.Sources electrical power sources power sources inoperable, ESF systems are OPERABLE. The AC electrical Operating inoperable, demonstrate demonstrate the OPERABILITY of power sources are designed to provide sufficient *Receive normal electrical power from the 25 the OPERABILITY of the the remaining A.C. sources by capacity, capability, redundancy, and reliability to KVAC main and auxiliary transformers system remaining A.C. sources by performing Surveillance ensure the availability of necessary power to ESF through the 25/1 3.8 KVAC Unit Auxiliary

__________ I performing Surveillance IRequirement 4 8.1.1.1 .a within 1 systems so that the fuel, Reactor Coolant System ______________________

Description of Changes and Safety Evaluation NOC-AE-06002005 Page 51 Table 2 Detailed Description of Changes and Basis Specification Number Old Action Requirement ICalculated New Action Requirement Technical Discussion and Comments Risk Basis STP ACT Before Backstop (base case)1 Requirement 48 1.1.1 a hour and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months (RCS), and containment design limits are not Transformers.

Action a within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at ieast thereafter. Within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months restore exceeded.

once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months the offsite circuit to OPERABLE " Receive altemnate electrical power from the 345 thereafter. Restore the status or apply the requirements of The OPERABILITY of the AC electrical power KVAC switchyard through the 345/13.8 KVAC offsite circuit to Specification 3.13.1, or be inat sources is consistent with the Initial assumptions of Standby Transformers.

OPERABLE status within least HOT SHUTDOWN within the the Accident analyses and is based upon meeting 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be inat least next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and inCOLD the design basis of the unit. In Modes 1, 2, 3,and 4 " Distribute 13 8 KVAC electrical power through the HOT SHUTDOWN within SHUTDOWN within the following this results inmaintaining at least two trains of the switchgear auxiliary and standby busses.

the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . onsite or one train of the offsite AC sources COLD SHUTDOWN within OPERABLE during Accident conditions inthe event " Control the supply of 13.8 KVAC electrical power the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . of: to components inthe Class 1E 4 16 KVAC distribution system

a. An assumed loss of all offsite power or all onsite AC power;, and Calculated RICT,

b. Aworst case single failure Assuming loss of the 13 8kV bus supply to a safety bus, 1460 days to 1E-05 A single train onsite AC source can effectively mitigate all but the most severe events with (30 day backstop applies) operator action insome cases. The events that cannot be mitigated by a single train onsite AC source are highly unlikely.

STP's switchyard Isserved by 8 incoming lines.

Three transformers are available to each unit to power the 13 8 KV buses that supply the 4.16 KV emergency buses. There are 3 trains of ESF power, only one of which isrequired to achieve and maintain safe shutdown. This is a very reliable and redundant power supply system. 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is adequate to determine an altemnate action or justify addition time to restore the condition.

STPNOC provided a detailed description of the application of RMTS to this action in response to NRC's request for additional information. See letter dated April 26, 2006 (ML a &

Description of Changes and Safety Evaluation NOC-AE-06002005 Page 52 Table 2 Detailed Description of Changes and Basis Specification OlJ cto Requireen N.ew AtoReurmnt TechnicalDsuio and Comments Risk Basis Number I-Dsuso OldAcion.1Calculated STP AOT Before Backstop I (base case)1 3.8.1.1 With a standby diesel With a standby diesel generator STP has three independent Standby Diesel The PRA models the SDG functions to generator inoperable, Inoperable, demonstrate the Generators (SDG) each associated with its ESF automatically start, load, and power their associated Action b demonstrate the OPERABILITY of the above- train, ESF systems while maintaining required voltage OPERABILITY of the required A.C. offsite sources by and frequency. The model Includes the load above-required A.C. offsite performing Surveillance In the event of a loss of preferred power, the ESF sequencer functions to strip loads and sequence on sources by performing Requirement 4.8.1.1.1 a within 1 electrical loads are automatically connected to the the required ESF systems. Dependency on Surveillance Requirement hour and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months SDGs insufficient time to provide for safe reactor required support systems is modeled (e.g.,

4 8.1. 1.1.a within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months thereafter. Ifthe standby diesel shutdown and to mitigate the consequences of a combustion air, fuel oil, overspeed protection).

and at least once per 8 generator became inoperable due Design Basis Accident (DBA) such as a loss of hours thereafter, Ifthe to any cause other than an coolant accident (LOCA). Calculated RICT:

standby diesel generator inoperable support system, an became inoperable due to independently testable component, Ratings for Train A,Train B and Train C DGs satisfy 1 SDG inoperable-any cause other than an or preplanned preventive the requirements of Regulatory Guide 1.108. The inoperable support system, maintenance or testing, continuous service rating of each DG is5500 kW 168 days an independently testable demonstrate the OPERABILITY of with 10% overload permissible for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months in component, or preplanned the remaining OPERABLE standby any 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period.

preventive maintenance or diesel generators by performing (30 day backstop applies) testing, demonstrate the Surveillance Requirement With one inoperable SDG, STP has no loss of OPERABILITY of the 4 8.1.1.2.a 2) for each such safety function and generally meets the single remaining OPERABLE standby diesel generator standby diesel generators separately within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , unless it failure criteria.

by performing Surveillance can be demonstrated there isno Requirement 4 8.1.1.2 a.2) common mode failure for the for each such standby remaining diesel generator(s).

diesel generator separately Within 14 days restore the within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , unless it Inoperable standby diesel can be demonstrated there generator to OPERABLE status or is no common mode failure apply the requirements of for the remaining diesel Specification 3.13.1, or be inat generator(s). Restore the least HOT SHUTDOWN within the inoperable standby diesel next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and inCOLD generator to OPERABLE SHUTDOWN within the following status within 14 days or be 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . (12) 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 inCOLD SHUTDOWN within 1 121the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . (

_______________ a

Description of Changes and Safety Evaluation NOC-AE-06002005 Page 53 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement New Action Requirement Technical Discussion and Comments Risk Basis I ~Calculated STP AOT Before Backstop

'(base case)1 3.8.1.1 With one offstte circuit of With one offsite circuit of the The design basis and redundancy of these systems The PRA model includes the offsite power and SDG the above-required A.C. above-required A.C. electrical isdescribed above. design functions as described above.

Action c electrical power sources power sources and one standby and one standby diesel diesel generator inoperable, Deletion of the requirement to restore at least two The PRA credits the operation of either station generator Inoperabie, demonstrate the OPERABILITY of offsite circuits to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months auxiliary transformer for supplying power to the demonstrate the the remaining A.C. sources by and three standby diesel generators to OPERABLE units ESF buses. Some examples where this may OPERABILITY of the performing Specification 4 8 1.1 Ia. status within 14 days from the time of initial loss is be challenged.

remaining A C.sources by within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least once per an administrative change only because proper performing Specification 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter, and ifthe application of the TS would require this. 1) Unit 1,DGA out of service, and station auxiliary 4 8.1.1.1la. within I hour standby diesel generator became transformer 1 fails, diesels B and C start and at least once per 8 inoperable due to any cause other automatically, the Abnormal Procedure for loss hours thereafter; and ifthe than an inoperable support system, of power to ESE bus would be used to restore standby diesel generator an independently testable power from Unit 2's station auxiliary became inoperable due to component, or preplanned transformer. After restoration, the PRA would any cause other than an preventive maintenance or testing, say the plant is restored to normal. Additional inoperable support system, demonstrate the OPERABILITY of equipment failures (eg, DG B or DG C)would an independently testable the remaining OPERABLE standby complicate the recovery, but no initiating event component, or prepianned diesel generator(s) by performing should occur. The RICT isthe same as the base preventive maintenance or Surveillance Requirement case DG.

testing, demonstrate the 4 8.1.1.2a 2)within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , unless OPERABILITY of the it can be demonstrated there is no 2) Unit 1 DGB out of service and the Unit Auxiliary remaining OPERABLE common mode failure for the, Transformer fails. Unit 1trips, DGA starts standby diesel generators remaining diesel generators; within automatically, ESF busses B and C are by performing Surveillance 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months restore at least one of the unaffected. RICT is not applicable until the plant Requirement 4 8 1.1.2a 2) inoperable sources to OPERABLE is stabilized.

within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , unless it status or apply the requirements of can be demonstrated there Specification 3 13.1, or be inat is no common mode failure least HOT STANDBY within the for the remaining diesel next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and inCOLD generator(s); restore at SHUTDOWN within the following least one of the inoperable 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . (12) sources to OPERABLE status within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 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 inCOLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . Restore at least two offsite circuits to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months and three standby diesel aenerators to

Description of Changes and Safety Evaluation NOC-AE-06002005 Page 54 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement New Action Requirement Technical Discussion and Com'ments - Risk Basis Number Calcuiated STIP AOT Before Backstop (base case)1 OPERABLE status within 14 days from the time of Initila loss or bo 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 1 12 the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . ( )

3 8.1.1 With one standby diesel Action d is deleted. Action d essentially tested for a loss of function that TS 3.13.2 has broader applicability than TS generator inoperable in could result from simultaneous inoperability of a 3 8.1 .i.d since it is not limited to conditions where a Action d. addition to ACTION b. or c. SDG and cross-train equipment that depends on SDG is affected, but will require a risk assessment above, verify that: one of the other diesels whenever the ACTION statements for two or more separate actions in the scope of TS 3 13 1 are

1. All required systems, As described above, STP does not lose safety entered.

subsystems, trains, function with the loss of two ESF trains.

components, and devices that depend on Proposed new TS 3.13 2 will replace TS 3 8.1.1 d 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 .

Description of Changes and Safety Evaluation NOC-AE-06002005 Page 55 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement New Action Requirement Technical Discussion and Comments Risk Basis Number Calculated STP ACT Before Backstop (base case)1 3811 With two of the above With two of the above required ACTION e establishes a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months required Calculated RICT: 1748 days required offsite A C. offsite A C.circuits inoperable, completion time iftwo required circuits between the Action e. circuits inoperable, restore within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months restore at least one off-site transmission network and the on-site Class Loss of both Standby Transformer feeds to ESF at least one of the of the Inoperable offsite sources to 1E distribution system are inoperable. busses B and Cwas evaluated. In this inoperable offsite sources OPERABLE status or apply the configuration, Train A will be supplied from the Unit to OPERABLE status requirements of Specification Two required circuits would be considered Auxiliary Transformer and Train B an Train C will be within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or be inat 3.13.1, or be in at least HOT inoperable if any of the following conditions are met: powered from their associated SDGs. Loss of the least HOT STANDBY STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . Standby Transformer should not result in a reactor within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . " Loss of two 13 8 kV Standby Bus to 4.16 kV ESF trip. This configuration is an example of the first With only one offsite Bus lines (per Note i to TS 3 8.1 1) bullet inthe Technical Discussion and Comments source restored, restore at column least two offsite circuits to OPERABLE status within " Loss of a 13 8kVStandby Bus to 4.16kV ESF Bus line while ina configuration where ACTION a The operator response to this condition would be to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months from time of initial align the Train B and Train C ESF busses to the loss or be in at least HOT applies Unit Auxiliary Transformer and secure the SDGs.

STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and inCOLD " A condition where two or more properly aligned and energized ESF busses are determined not to (30 day backstop applies)

SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . be in conformance with the design basis such that they are inoperable TS Note 1 (cited above) does not reflect STP's three-train design. With the loss of two 13.8 kW Standby bus to 4.16 kV ESF lines, STP still has one 13.8 kV Standby to 4.16 kV ESF connection.

STPNOC believes any condition where entry into ACTION e is required would be the result of an emergent condition.

The first two conditions would result ineither a de-energized ESF bus or one or more ESF busses powered from their associated 50G. Ifthe condition involves a loss of the UAT, the SDG will pick up the ESF loads; however, the reactor will trip on reactor coolant pump (RCP) undervoltage/underfrequency or RCS low flow because the reactor coolant pumps will lose power and coast down. Loss of the Standby Transformer should not result In a reactor trip.

a & a

Description of Changes and Safety Evaluation NOC-AE-06002005 Page 56 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement New Action Requirement Technical Discussion and Comments Risk Basis Number Calculated STP AOT Before Backstop (base case)1 Ifthe condition isthe result of a loss of offsite power (LOOP) or partial LOOP, the operators will be taking action to establish stable plant conditions from the transient as a priority before any consideration of applying TS 3.13 i to extend the completion time. One of those actions will most likely be securing the SDG and energizing the ESF bus from a preferred source, at which time the configuration will be the same as the condition addressed by ACTION a. ACTION e also imposes a 72-hour completion time, consistent with ACTION a.

STPNOC proposes to delete the 72-hour portion of ACTION e as an administrative change that eliminates the potential for being inACTION a and ACTION e at the same time.

STPNOC proposes to allow application of TS 3.13.1 to TS 38.1.1 e 3.8.1.1 With two or three of the With two or three of the above With 2 inoperable SDGs, STP does not lose the Calculated RIOT:

above required standby required standby diesel generators safety function and can meet almost all of its design Action f diesel generators inoperable, demonstrate the bases. 2 SDGs inoperable.

inoperable, demonstrate OPERABILITY of two offsite A C.

the OPERABILITY of two circuits by performing the Deleting the requirement to restore at least three 185 hours0.00214 days 0.0514 hours 3.058862e-4 weeks 7.03925e-5 months offsite A.C. circuits by requirements of Specification standby diesel generators to OPERABLE status performing the 4.8. 1.1.1 a. within 1hour and at within 14 days from time of Initial loss is an AltreS~ nprbe requirements of least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter; administrative change since proper application of AltreS~ nprbe Specification 4.8.1.1.1a. within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months restore at least one the TS requires this Interpretation without it being 3 or within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least standby diesel generator to stated 3 or once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months OPERABLE status or apply the thereafter; restore at least requirements of Specification one standby diesel 3.13.1, or be inat least HOT generator to OPERABLE STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months and at and in COLD SHUTDOWN within least two standby diesel the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . (12) generators to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 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 ____________________________________________

Description of Changes and Safety Evaluation NOC-AE-06002005 Page 57 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement New Action Requirement Technicai Discussion and Comments Risk Basis Number-Caicuiated STP AOT Before Backstop (base case)l inCOLD SHUTDOWN within the foliowing 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . Restore at ieast three standby diesei generators to OPERABLE status within 14 days 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 inCOLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . (12) 3 82.1 New note to accommodate Specification 3 13.1 may not be Since the batteries provide the power for the field NA implementation of RMTS entered for batteries or chargers flashing for the emergency diesel generator, an D C.Sources when the batteries are the sole emergent condition where a train of batteries is source of available power to their carrying the associated DC bus with no power to NOTE DC bus. Ifthe batteries discharge either of the battery chargers could Indicate an in-for more than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months as the sole progress loss of off-site power transient inwhich the source of power to their DC bus emergency diesel generator for the affected ESF while Specification 3.13.1 is being train did not start or Isnot available. STPNOC does applied and no alternate source of not believe itis appropriate to apply TS 3.13.1 to power is available, the extend the allowed outage time during an ongoing Specification 3.13.1 LCO shall be emergent transient condition. Discharge of the considered not met battery banks supporting the Channel 11and Channel IVDC loads will not result in a plant trip or transient; however, STPNOC would not normally permit continuous discharge of a battery inan emergent condition (provided power to one of the chargers is available) or plan a work activity that involved an extended discharge of a battery bank.

Discharge of the battery banks supporting Channel I and Channel Ill will not result inan immediate plant trip, however, a plant trip on low steam generator level will result after a loss of DC power as the Feedwater Isolation Valve hydraulic control system pressure bleeds off and the valves close. The evolution of the event provides the operators with an opportunity to anticipate this trip and it can be avoided with timely local operator action It Isnot STPNOC's Intent to use TS 3.13 i to extend the

_____________________________ ______________________allowed outageimefo cofiurtions where the ______________________

Description of Changes and Safety Evaluation NOC-AE-06002005 Page 58 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement New Action Requirement Technical Discussion and Comments Risk Basis, Number Calculated STP AOT Before Backstop (base case)1 battery bank is the sole source of power available for the ioads on the DC bus.

382.1 With one of the required With one of the required battery The Initial conditions of Design Basis Accident The PRA models the normal Class I E 125V DC battery banks inoperable, banks Inoperable, within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months (DBA) and transient anaiyses in the FSAR, assume busses supplied from one of two battery chargers D.C. Sources restore the inoperable restore the inoperable battery bank that Engineered Safety Feature (ESF) systems are with power from their associated ESF motor control battery bank to to OPERABLE status or apply the OPERABLE, centers. The associated battery bank provides the Action a OPERABLE status within requirements of Specification backup.

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months or be in at least 3.13.1, or be in at least HOT The DC electrical power system provides normal HOT STANDBY within STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and emergency DC electrical power for the SDGs, Calculated RIOT:

the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in and in COLD SHUTDOWN within emergency auxiliaries, and control and switching COLD SHUTDOWN the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months during all MODES of operation. The OPERABILITY 1 inoperable battery bank, 140 days (Train D 1040 within the following 30 of the DC sources is consistent with the initial days) hours. assumptions of the accident analyses and is based upon meeting the design basis of the unit. This (30 day backstop applies)

Includes maintaining the DC sources OPERABLE during accident conditions in the event ofan assumed loss of all offsite AC power or all onsite AC power and a worst-case single failure.

STP has 4 battery banks. Channel I s associated With Train A ESF. Channel IllIs associated with Train D (Train A ESF power). Channel Ill is associated with Train B ESF. Channel IV is associated with Train C ESF. Each battery bank has two full capacity chargers.

The DC bus could be energized through its associated batteries with its associated charger powered from an altemnate source or from a temporary charger. With inoperable batteries, the DC bus can be energized through an operable charger or a temporary charger. TS 3.13.1 would allow appropriate consideration of these altemnatives in determining an allowed outage time. In addition, the RMTS Guidelines allow a determination of functionality not available in the current TS.

3.8 2.1 New action With more than one of the required Same as above Two inoperable battery banks:

________________________battery banks inoperable, within 1 1_____________________ 1______________________

Description of Changes and Safety Evaluation NOC-AE-06002005 Page 59 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement New Action Requirement Technical Discussion and Comments Risk Basis Number Caiculated STP AOT Before Backstop (base case)l hour restore at least three battery D C. Sources banks to OPERABLE status or The proposed 1-hour time limit Is consistent with TS 6 days apply the requirements of 3 0.3 which would be required by the current TS for Action b Specification 3.13 1 or be in at more than one inoperable battery bank. Three inoperable battery banks:

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 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months , exceeds the RMTS I1E-03 CDF limit SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . Four Inoperable battery banks:

3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months , exceeds the RMTS 1E-03 CDF limit 38 2.1 (Previously ACTION b) With one channel with no battery Application of TS 3.13.1 to a stable configuration, One battery bank with no operable charger: same chargers OPERABLE, within 2 as required by the note described above, may be as above for an inoperable battery bank.

D C. Sources With no battery chargers hours restore at least one battery justified by the RMTS risk evaluation Examples of for a channel charger to OPERABLE status or this are situations where the chargers are Action c OPERABLE, restore at apply the requirements of inoperable but meet the RMVTS requirements for least one battery charger Specification 3.13.1, or be in at PRA functionality or pro-planned maintenance to OPERABLE status least HOT STANDBY within the activities where temporary chargers are used and within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , or be in at next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and In COLD their capability can be quantified in the PRA.

least HOT STANDBY SHUTDOWN within the following within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 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 82.1 New action With more than one channel with Same as above. Two battery banks with no operable charger:

no battery chargers for a channel D C. Sources OPERABLE, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore The proposed 1-hour time limit is consistent with TS Three battery banks with no operable charger:

at least one battery charger to 3 0.3 which would be required by the current TS for Action d OPERABLE status on at least three more than one Inoperable battery bank Four battery banks with no operable charger:

channels or apply the requirements of Specification 3.13.1, or be in atAlthsaeateevutinfrheIorbe least HOT STANDBY within the Albh aea h vlationy foatennoerbl next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and In COLD bteybns SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months With one of the required trains of The initial conditions of Design Basis Accident The PRA models the design basis functions for the 3 8 31

___________trains With one of the required of A C. ESF busses IA C. ESE busses not fully T DBA) and transient analyses In the FSAR assume I_______________I_______

Description of Changes and Safety Evaluation NOC-AE-06002005 Page 60 Table 2 Detailed Description of Changes and Basis Numbr

__________ I ICalculated IJ ~(base STP AOT Before Backstop case)1 not fully energized, energized, within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ESF systems are OPERABLE. The AC ,DC, and onsite power distribution system.

Onsite Power reenergize the train within reenergize the train or apply the AC vital bus electricai power distribution systems Distribution 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months or be in at ieast requirements of Specification are designed to provide sufficient capacity, 1 inoperable AC ESF bus: Train A 22 days, Train B HOT STANDBY within the 3 13.1, or be in at ieast HOT capability, redundancy, and reliabiiity to ensure the 58 days, Train C 79 days.

Operating 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 avaiiability of necessary power to ESF systems so SHUTDOWN within the and In COLD SHUTDOWN within that the fuel, Reactor Coolant System, and (30 day backstop applies for Train B and Train C) 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 containment design limits are not exceeded.

The difference In the RICTs for the ESF trains is Action a. This includes maintaining power distribution due to fires outside the control room. These fires systems OPERABLE during accident conditions in primarily affect the B and C trains, leaving the A the event of an assumed loss of all offsite power or train for fire mitigation. Any unavailability of A train all onsite AC electrical power and a worst case equipment is more significant then the single failure. corresponding B or C trains.

OPERABLE AC electrical power distribution Loss of a single AC ESF bus does not result in a subsystems require the associated buses, load plant trip. Only one of three available trains would centers, motor control centers, and distribution be affected.

panels to be energized to their proper voltages.

OPERABLE DC electrical power distribution subsystems require the associated buses and The RICT for Section 3 8 2.1 would apply if the bounding assumption is made that the loss of the ESF bus results in the loss of the associated battery distribution panels to be energized to their proper chargers.

voltage from either the associated battery or charger. OPERABLE vital bus electrical power distribution subsystems require the associated buses to be energized to their proper voltage from the associated inverter connected to the DC bus.

The inverters are the preferred source of power for the AC vital buses because of the stability and reliability they achieve. The function of the inverter is to provide AC electrical power to the vital buses.

Conditions may arise where ACTION a is entered because a 'downstream" bus (e.g. one half of the double ended 480-volt load center) has been do-energized by a fault or needs to be de-energized to perform maintenance. Because of available design redundancy, the eight hour completion time of ACTION a Is unnecessarily restrictive and application of TS 3.13 1 is appropriate. STPNOC provided additional detail on the application of I. a

Description of Changes and Safety Evaluation NOC-AE-06002005 Page 61 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement New Action Requirement Technical Discussion and Comments Risk Basis Number Calculated STP AOT Before Backstop (base case)1 RMTS to TS 3 8 3.1 ina letter dated April 26, 2006 responding to NRC request for additional information.

3.8.3.1 New ACTION b With more than one of the required One hour is a conservative time to assess the The RIOT for Section 3 8 2.1 would apply if the trains of A.C. ESF busses not fully configuration and determine the appropniate action bounding assumption is made that the loss of the Onsite Power energized, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months reenergize and AOT. The time is consistent with TS 3.0.3 ESF bus results in the loss of the associated battery Distribution at least two trains or apply the which would currently apply for conditions with more chargers requirements of Specification than one required bus not fully energized Operating 3.13.1, or be In at least HOT Extending the time further can be justified due to STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months the redundancy of the ESF power. STP does not and in COLD SHUTDOWN within lose the safety function unless all three trains of Action b the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . ESF power are lost.

3.8.3.1 (Previously ACTION b) With one A C.vital distribution These completion times may be extended with the Inoperable inverter backed up by non-regulated With one A.C. vital panel either not energized from application of TS 3 13 1. There is sufficient transformer~

Onste ditriutin owe pneleiter ot its associated inverter, or with redundancy to enable STPNOC to manage the DniePoe istribution energizedtfromnit the inverter not connected to its configuration risk when ACTION b applies. The Calculated RICT:

Disribtio enrgied romitsassociated D.C. bus: (1) within 2 STPNOC letter dated April 26, 2006 responded to associated inverter, or with hours reenergize the A C. NRC request for additional information on Oeaig toe itsvsscited D.C. bus:cte distribution panels or apply the application of RMTS to electrical TS and includes 278 days (1) reenergciaethed A.C. bu: requirements of Specification additional discussion on application to TS 3 83.1. (3dabcktpplis distribution panel within 2 3.13.1Y oribein athleastHO Action c. hours or be in at least HOT husTNB withintheD nexTDO6 STANDBY within the next within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months ; and 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD (2)within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months reenergize SHUTDOWN within the the A C. vital distribution panel following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months ; and (2) from its associated inverter reenergize the A C. vital connected to its associated D C.

distribution panel from its bus or apply the requirements of associated inverter Specification 3.13 1, or be in at connected to its associated least HOT STANDBY within the D.C. bus within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD be In at least HOT SHUTDOWN within the following STANDBY within the next 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

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 31 New ACTION With more than one A.C. vital One hour is a conservative time for an assessment Calculated RIOT:

________ _____________distribution panel either not to determine an appropriate RIOT for the I______________________

Description of Changes and Safety Evaluation NOC-AE-06002005 Page 62 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement New Action Requirement Technical Discussion and Comments Risk Basis Number Calculated STP AOT Before Backstop (base case)l energized from its associated configuration It Isconsistent with TS 3 0 3 which Action d. Inverter, or with the inverter not wouid currently apply if more than one vital 2 Inoperable Inverters: 16 days connected to its associated 0 C distribution panel was not properly energized. The bus: (1) within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months reenergize at redundancy of the STP eiectrical power systems will 1 inoperable bus: 208 days least five A C. distribution panels or provide adequate justification for extending the time apply the requirements of beyond two hours Additional assessments may be (30 day backstop applies)

Specification 3.13.1, or be in at performed to determine the time needed to re-least HOT STANDBY within the energize the panel(s) from the associated inverter. 2 Inoperable buses- 8 days next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD The panels can also be powered from an altemnate SHUTDOWN within the following 1E diesel backed bus 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months , and (2)within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months reenergize at least five A C. vital distribution panels from their associated inverters connected to their associated D.C. bus 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 .

38 3.1 (Previously ACTION c) With one D C. bus not energized Power to the DC bus can also be provided by either Currently loss of Bus A or B results In a plant trip.

from its associated battery bank, of its associated chargers The two-hour allowed Action e With one D C bus not within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months reenergize the D C. outage time Is not consistent with the redundancy Calculated RIOT:

energized from its bus from its associated battery available from the other DC channels and the low associated battery bank, bank or apply the requirements of likelihood of a LOOP. This action should be BsC-9 as u 4 as reenergize the D.C. bus Specification 3.13.1, or be in at consistent with the action for TS 3 82.1 for batteries Bs09 as u 4 as from its associated battery least HOT STANDBY within the and chargers. Consequently, it is appropriate to be (3dabcktpplis bank within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months or be next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD able to apply TS 3.13.1 to extend the two-hour (3dabcktpplis in at least HOT STANDBY SHUTDOWN within the following allowed outage time for either an emergent within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months condition or a planned maintenance evolution for in COLD SHUTDOWN which the corrective action requires the battery within the following 30 bank to be disconnected from the DC bus.

hours.

3 8 31 New ACTION With more than one D.C. bus not One hour Is consistent with the time requirement of Two DC busses not energized from the associated energized from its associated TS 3 0 3 which would currently apply with more battery bank, Bus A or B, plant trip Action f. battery bank, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months than one bus not energized from its associated

_____________________reenergize at least three D.C. ____________________________________________

Description of Changes and Safety Evaluation NOC-AE-06002005 Page 63 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement New Action Requirement Technical Discussion and Comments Risk Basis Number Caiculated STP AOT Before Backstop, (base case)1 buses from thetr associated battery battery bank TreD ussnteegzdfo h banks or apply the requirements of TreD ussnteegzdfo h Specification 3.13.1, or be inat It is appropriate to be able to apply TS 3.13.1 to associated battery bank-ieast HOT STANDBY within the extend the allowed outage time for either an next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and inCOLD emergent condition or a planned maintenance Plant trip SHUTDOWN within the following evolution for which the corrective action requires the 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months battery bank to be disconnected from the DC bus Four DC busses not energized from the associated Application of the proposed note inTS 3 8 2.1 battery bank:

prevents applying RMTS when the batteries are the sole source of power to their DC bus Plant trip 3.13.1 Did not exist Defines the actions to take at As discussed inthe preceding sections, the As described for the individual applications.

changing risk levels of the plant associated Bases pages, and the EPRI RMTS configuration Guidelines.

3.132 Did not exist Requires confirmation of the Applies the same risk thresholds as TS 3 13 1 for NA acceptability of the allowed outage consistent risk-management approach The basis time ifACTIONs are entered for is descriibed inthe preceding sections, the separate LOOs inthe scope of TS associated Bases, and the RMTS Guidelines.

3.13.1.

Admin TS k. Configuration Risk k. Configuration Risk Management The CRMP description in the TS 6.8.3 NA 6.8.3 k. Management Program Prociaram (CRMP). Administrative section will establish the risk (CRMP) management technical standard by reference to the A program to assess changes in EPRI RMTS Deletion of the specific list of core damage frequency and requirements is acceptable because the referenced cumulative core damage probability EPRI document includes the requirements.

A program to assess resulting from applicable plant changes in core damage configurations The program shall frequency and cumulative be Inaccordance with Section 2 of core damage probability the EPRI Risk-Managed Technical resulting from applicable Specifications (RMTS) Guidelines, plant configurations. The Rev. [

program should include the following, 1)training of personnel; 2)procedures for identifying plant

_________cofguaios te_______I______configurations,________________ _________________the______

Description of Changes and Safety Evaluation NOC-AE-06002005 Page 64 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement New Action Requirement Technical Discussion and Comments Risk Basis Number Calculated STP AOT Before Backstop (base case)1 generation of risk profiles and the evaluation of risk against established thresholds; and

3) provisions for evaluating changes in risk resulting from unplanned maintenance activities.

BASES Did not exist Section added to explain these The Bases are provided for information and the final NA new specifications version will be sent for incorporation into the NRC 3.13.1 copy of STP's TS after approval of the proposed amendment.

3.13 2

1. Base case is number of hours to exceed the CRMP 1E-05 threshold for core damage probability, 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 ACT for conditions where the CRMP calculated time exceeds 30 days.

NOC-AE-06002005 Technical Specification Mark-Up Pages Attachment 2

LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS SECTION PAGE 3/4.12 RADIOLOGICAL ENVIRONMENTAL MONITORING........................... 3/4 12-1 3/4.1 2.1 MONITORING PROGRAM DELETED 3/4.12.2 LAND USE CENSUS DELETED 3/4.12.3 INTERLABORATORY COMPARISON PROGRAM DELETED 3/4.13 RISK MANAGEMENT ............................................................. 3/4 13-1 3/4.13.1 ALLOWED OUTAGE TIME DETERMINATIONS 3/4 13-1 3/4.13.2 ALLOWED OUTAGE TIME DETERMINATIONS FOR ACTION 3/4 13-2 STATEMENTS IN MULTIPLE LCOS SOUTH TEXAS -UNITS 1 & 2 xii Unit 1 - Amendment No. 47-Unit 2 - Amendment No. 3,6

Co 0 TABLE 3.3-1 (Continued) CHANGES INO M REACTOR TRIP SYSTEM INSTRUMENTATION CHANNELS MINIMUM TOTAL NO. CHANNELS FUNCTIONAL UNIT OF CHANNELS TO TRIP OPERABLE MODES ACTION Co)

18. Safety I njection I nput f rom ESFAS 2 1 2 1,2 9A

19. Reactor Trip System Interlocks

a. Intermediate Range Neutron Flux, P-6 2 1 2 8

b. Low Power Reactor Trips Block, P-7 C,,

P-10 Input 4 2 3 1 8 or P-13 Input 2 1 2 1 8

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

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

2. 2.

e. Power Range Neutron Flux, P-i10 4 2 3 1,2 8 CD CD

0. =3 f. Turbine Impulse Chamber Pressure, P-13 2 2 1 8 (D CD

20. Reactor Trip Breakers 2 2 1,2 9, 12 z0 z 3*, 4*, 5*

0 2 2 10 L. W, 0)

TABLE 3.3-1 (Continued) INO CHANGESI (n,

0 REACTOR TRIP SYSTEM INSTRUMENTATION C

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

z 21. Automatic Trip and 2 1 2 1,2 9A

--4 Interlock Logic 2 1 2 3*, 4*, 5* 10 01 C C 3 3 CD CD z0 z0 r\31" N) co

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 one less than the Minimum Channels OPERABLE requirement, be in at least HOT STANDBY within 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 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 - ia. With the number of OPERABLE channels one less than the Minimum Channels OPERABLE requirement, ;,Wthi 24- ho-uir's restore the inoperable channel to OPERABLE statusWW wii 2 4 oe, 'or -apply the requrmns9 SpVecificaio~n 3.13A1,oýr 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 the numiiber of OPERABLE chýainnels mor-e than o-n-e les-s-t'h-a-n't-he Minimum Channels OPERABLE requirement, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore at Ileast one inoperable channel to OPERABLE status or apply the Irequirements of Specification 3.13.1, or-be in at least HOT STANDJBY 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.4-36 Unit 2 - Amendment No.42-5

INO CHANGESI 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. 60, 116 Unit 2 - Amendment No. 39, 104

INSTRUMENTATION INO CHANGES 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. 50,-1-30, 145 Unit 2 - Amendment No. 3, 1-1-9, 133

Cl) 0 TABLE 3.3-3 r

ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION

-I x MINIMUM TOTAL NO. CHANNELS CHANN ELS APPLICABLE FUNCTIONAL UNIT OF CHANNELS TO TRIP OPERABLE MODES ACTION Cl)

1. Safety Injection (Reactor Trip, Feedwater Isolation, Control

-I' 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 00,

c. Actuation Relays 3 2 3 1,2,3, 4 14

d. Containment Pressure-- 3 2 2 1,2,34 High-i C C

e. Pressurizer Pressure--Low 4 2 3 1, 2, 3# 20

f. Compensated Steam Line 3/steam line 2/steam line 2/steam line 1, 2, 3# 20 3 3 Pressure-Low any steam line in each steam line 0 0 0

NO CHANGES Cl) 0 TABLE 3.3-3 (Continuedl r

ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION m

TOTAL NO. MINIMUM MINIMUM x/

OF CHANNELS CHANNELS APPLICABLE Cn FUNCTIONAL UNIT CHANNELS TO TRIP OPERABLE MODES ACTION z

=1i 2. Containment Spray Cl)

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

c. Actuation Relays 3 2 3 1,2,3,4 14 CA) d. Containment Pressure- 4 2 3 1,2,3 17 High -3 CA)

3. Containment Isolation C C a. Phase "A"Isolation

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

2) Automatic Actuation 2 1 2 1,2,3,4 14 (D (D Logic

3) Actuation Relays 3 2 3 1,2,3,4 14 (D CD 4) Safety Injection See Item 1. above for all Safety Injection initiating functions and requirements.

z0 z0

Cl)

INO CHANGESI 0 TABLE 3.3-3 (Continued)

M ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION x MINIMUM TOTAL NO. CHANNELS CHANNELS APPLICABLE FUNCTIONAL UNIT OF CHANNELS TO TRIP OPERABLE MODES ACTION Cn z 3. Containment Isolation CD (Continued)

b. Containment Ventilation Isolation

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.

4) RCB Purge 2 1 2 1, 2, 3, 4,5##, 18 Radioactivity- High 03 5) Containment Spray- See Item 2. above for Containment Spray manual initiating functions and requirements.

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

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

3 Manual Initiation

d. RCP Seal Injection Isolation CD 1) Automatic Actuation Logic 1 1 1 1,2,3,4 16

3 and Actuation Relays CD z0

C,) NNO CHANGES 0 TABLE 3.3-3 (Continued)

ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION m

x MINIMUM C/) TOTAL NO. CHANNELS CHANNELS APPLICABLE FUNCTIONAL UNIT OF CHANNELS TO TRIP OPERABLE MODES ACTION z 3.d. RCP Seal Injection Isolation (Continued)

CD

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 C,,

.r~. a. Manual Initiation CA,

1) Individual 2/steam line 1/steam line 2/operating 1,2,3 24 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

c. Steam Line Pressure - 3/steam line 2/steam line 2/ steam line 20 I C Negative Rate--High any steam line in each steam line M..

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

e. Compensated Steam Line 3/steam line 2/steam line 2/steam line 1, 2, 3# 20 3 3 Pressure - Low any steam line in each zz steam line 0 0 ca M 0)

INO CHANGESI TABLE 3.3-3 (Continued)

Co 0 ,ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION r

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

z 5. Turbine Trip and Feedwater Isolation

__q C',

90

a. Automatic Actuation 2 1 2 1,2,3 25 Logic and Actuation Relays

b. Steam Generator Water 4l/stm. gen. 2/ stm. gen. in 3/stm. gen. in 1,2,3 20 Level-- any each High-High (P-14) operating stm. operating CA, 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 (i/loop) 2 3 1,2,3 20 Reactor Trip (P-4)

(Feedwater Isolation Only)

CD CD z0

TABLE 3.3-3 (Continued)

Cl) 0 ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION C

--I MINIMUM TOTAL NO. CHANNELS CHANNELS AP PLICABLE FUNC TIONAL UNIT OF CHANNELS TO TRIP OPERABLE MODES ACTION C/)

6. Auxiliary Feedwater z 1/pump

a. Manual Initiation 1/pump 1/pump 1,2,3 26 Cf) b. Automatic Actuation Logic 2 1 2 1,2,3 22

-A

c. Actuation Relays 3 2 3 1,2,3 22 90

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.

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

(Motor Driven Pumps Only)

C 7. Automatic Switchover to Containment Sump****

2. CD a. Automatic Actuation Logic 3-1/train 1/train 1/train 1,2,3,4 T99_A and Actuation Relays

b. RWST Level -- Low-Low 3-1 /train 1/train 1/train 1,2,3,4 19M (D

CD Coincident With: See Item 1.above for all Safety Injection initiating functions and requirements.

(D Safety Injection 0~

z0

C))

0

-I TABLE 3.3-3 (Continued)

--I m ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION x

cn MINIMUM TOTAL NO. CHANNELS CHANNELS APPLICABLE z FUNCTIONAL UNIT OF CHANNELS TO TRIP OPERABLE MODES ACTION Cl) 8. Loss of Power

a. 4.16 kV ESF Bus Under- 4/bus 2/bus 3/bus 1,2,3,4 i0A voltage-Loss of Voltage

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

c. 4. 16 kV ESF Bus Under-voltage - Sustained Degraded 4/bus 2/bus 3/bus 1, 2, 3,4 26A Voltage

9. Engineered Safety Features

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

b. Low-Low Tavg,RP12 4 2 3 1,2,3 21

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

CL (D

0

INO CHANGES I Cl) 0 TABLE 3.3-3 (Continued)

Cn ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION

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

10. Control Room Ventilation Nl)

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 CA) Radioactivity - High

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

CA,

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-i 1 (Pressurizer Pressure Interlock) Setpoint.

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

1. 1. Trip function automatically blocked above P-i 1 and may be blocked below P-i 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, Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months restore the inoperable channel to OPERABLE status Withiii:24 44ýw, bioapply the requirements ~of Sji-ifi6&_I6ii'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 ; 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.

it te umerofOPERABLE harlsmethnoelessi than the Mirinimumi bY 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-hours-and in COLD SHUTDOWN within the following 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 - a.With the number of OPERABLE channels one less than the Total Number of Channels, withini 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months place the inoperable channel in the bypassed condition 'or aipplysthe-r-equir-ements of TS 3.13:1 Wxithin 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.Wth nme fOPERfAB LE cha~nijesm6or~e tha~n one6i less-th-an t-h-e Tota-l Numrber of channells, 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 inat least HOT STANDBY In 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 This action Is not required for the surveillance testing provision of Action 17a.

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 SOUTH TEXAS - UNITS 1 & 2 3/4 3-26 Unit 1 - Amendment No. 4=60 Unit 2 - Amendment No. 4=50

NOTE:

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 "l: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. 46 Unit 2 - Amendment No. 4=69

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 19'- ab.With th&n6fiiiil7W6f OPERABLE _channels n leýIssttha-n the -Minimiuni'Chii-niel~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 t6he irequirements 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 -inCOLD.SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

b.- With the l__imiberof OPERABLE channiels mo~re tfhan one less thian the-MinimudmiCh-annels OPERABLE requirement, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore at least one channel to OPERABLE status oir 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 119A a. Withnetra~in wiiirith ~the numb6er of OPERABLE chainnels_ le6ssth-an 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 oir apply the requirements of Specification 3.13.1, 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 InCOLD- SHUTDOWN within the-following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .'

b. With mobreithan -one train with tenmrofOPERABLE channels 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 the channels for at least two trains to OPERABLE status or apply the requirements of Specification 3.13.1, or be Init least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and inCOLD SHUTDOWN within the following 30_hours.

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.

SOUTH TEXAS -UNITS 1 & 2 3/4 3-27 Unit 1 - Amendment No. 160 Unit 2 - Amendment No. 150 7,

ACTION 20A'- a)With~the766fimber of OPERABLE c6hanrlies one less than6the Total Number of Channels, STARTUP and/or POWER OPERATION may proceed provided the following conditions are satisfied:

'For Func~tiotnIl Units-withi installed bpstetcaily;the inopeirable channel 'may be placed in bypass, and within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months place the channel in the tripped condition or apply the requirements of Specification 3.13.1.'

N6t&iAch'itýfihe maiy6bebypasse6d foup12 hours _for surveill aniceite-sting per Specification 4.3.2.1, provided no more than onelchannel is in bypass at any time.

'ForýFniction-al UriitsWjitth no"installid bypiassteist ia-bility, j1 . Withiff72 Koursplac~e the IoralchnehIfthe tri~jed ii66diti6n plythe lior requirements of Specification 3.13.1, and 27-'T~i- MI ihiiihiiChtiiniie6ls7OPERABLE-f Y ilihimefntiit li6t,; h-o-w-e-ver, the i'n-o-pe-rable-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 14.3.2.1.'

With'thebr~fi'6F&OPERABLE chahniels ire -fthadnonele-ss than the Total Ndfimberof 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 for functions With three channels and restore at least 3 channels to OPERABLE status for functions that have four channels, 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 be In at least HOT SHUTDOWN within the followifig6 COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . This action is not requiredand Shours, theInsurveillance testing provision In the note to Action 20A.a.

forbe 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, i46t6riiho inb~oal, hnb t61OPERABL E gt~tuS, wvithin'24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months s restoe te Inoper6-able 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 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.

b. With th ime~fOPERABLE Ch-ri~Is mori-iýe than'o-n'e le-s-s thah. th-e Mini iniiff Channels OPERABLE requirement, within one hour restore at least one channel to OPERABLE status for functions with two'channels or restore at least two channels to OPERABLE status for functions with three channels, or apply the requirements of specification 3.13.1; or be in at least HOT STANDBY within -the-next 6 -hours and in at least HOTSHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

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. 160 Unit 2 - Amendment No. 150

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 - With the number of OPERABLE channels one less than the Minimum Channels OPERABLE requirement, 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 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 4.3.2.1 provided the other channel is OPERABLE.

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) inthe 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) inthe 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) inthe 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) inthe recirculation and makeup filtration mode.

c. With required ACTION 28a. or 28b. not met inMODE 1,2,3,or 4,immediately suspend movement of irradiated fuel assemblies and crane operations with loads over the spent fuel pool, AND be inMODE 3 in6 hours and in MODE 5 inthe 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 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 & 2 314 3-28 Unit 1 - Amendment No. 4.53 Unit 2 - Amendment No. 444-

INSTRUMENTATION IZN NO CHANGES E

3/4.3.5 ATMOSPHERIC STEAM RELIEF VALVE INSTRUMENTATION LIMITING CONDITION FOR OPERATION:

3.3.5.1 The atmospheric steam relief valve instrumentation shown inTable 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 +/-t7 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

(n 0

r

--I M I NO CHA TABLE 3.3-14 x

Co ATMOSPHERIC STEAM RELIEF VALVE INSTRUMENTATION z

Co 90 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 control channels (1/valve) do, M'

/

C C:

N, 3

CD (D 0.

2 (D CD z0 z0 0

N)

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 Tdays restore the inoperable channel to OPERABLE status

~I'f~ithh; da - 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 .

b. With two less than the required number of OPERABLE channels, within 72 hour-s restore at least three channels to OPERABLE status within-:2 ppyheruieents of Specif ication 3.13.1; or be in at h~~u~e~or least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

c. With mrthntwo less than the -require-dnumber o-f O-P-ERABLE

'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 OPPERABLE status or apply the requirements of Specification 1113.1;p_ok bein at least HOT STNB wihi tenext 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.1-48 Unit 2 - Amendment No.4-36

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; Wifivithin'th folIwiii6672hofiirs6 restore the PORV to OPERABLE status 6A9ithin the follov.'ing

2 hef br pplIy th6e-rrequi1re--m-en6t-s-of Speci6flic-ation 3.13.1, 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 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 h46F4 ppl "the rf6qudir'6m66ts_`of'l S~ ioIn-3.13'.1,_ or restore at least one of the PORVs to OPERABLE status or close their associated block valves and remove power from the block valves and 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 OPPERABILE status or place its associated PORV in closed position; Within- 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months restore the block valve to, OPERABLCE status W:itiin 722 hourfsor apply the requirments 6fSpe ificaion3.13.1; otherwise, be in at least HOT STANDBY within the next 6 ho~urs 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 OPERABLE status or place the associated PORVs in the closed position; restore at least one block valve to OPERABLE status within the next hour or apply the

'e-q-u-i-re--m-ent-so-f SpVe'cifi-c'atio-n 3-.13.1f; 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 .

SOUTH TEXAS - UNITS 1 & 2 3/4 4-10 Unit 1 - Amendment No. 55470 Unit 2 -Amendment No. 4.44=68

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 accumulator inoperable, except as a result of boron concentration outside the required limits, Withifi24*h&Lirs restore the inoperable accumulator to OPERABLE status Wtiri4,2-4 6r-46ti iipply the requiremeiti~o~f Spe6ification 3.13.1, or0 t 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 .

Ji? WtW-beta one c&iiut60ei~o able ,-xceptads -aresult'bf bbron concen6ft~atidii outside the required limits, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore at least two accumulators 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 reduce pressurizer pressure to less than 100-0_psig within-the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

6.' With the boron concentration of one accumulator outside the required limit, within -72 Ioiurs restore the boron concentration to within the required limits W:ithitY72,lhofr orapply the requirements of6 Spec-ific~ationh 3.1 3.1,"ojK 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 hour8.

d.- With-thie bb&rbn concenitrations-of mnor-ethint bn67e 6umulat6f -outside thed requfired limfit, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore the boron concentration of at least two accumulators to within the required limits 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 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 Ž!8800 gallons and *! 9100 gallons and nitrogen cover-pressure is Ž: 590 psig and *5 670 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 Ž!2700 ppmn and

<ý3000 ppmn 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. 51, 54, 59, 13 Unit 2 -Amendment No. 40, 43, 17,121

EMERGENCY CORE COOLING SYSTEMS 3/4.5.2 ECCS SUBSYSTEMS - IAVG~ GREATER THAN OR EQUAL TO 350OF 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, Wi ~thin 7 dayjs restore the inoperable subsystem(s) to OPERABLE status ýWithi4-7 days or applyjthe -requiremffentsof Speci1ficationi 3.1.~17brbe 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 less -thntiif'woof the reiqui red s~ubijFst6emigOPE RAB LE, within '1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore at least two subsystems to OPERABLE status or apply the requirements of Specification 3.13.1, or be in at least HOT STANDBY within the next 6,hours and in -HOT SHUTDOWN -within-thefollowing 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

c. Inthe 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.

Entry into MODE 3 is permitted 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 375 0F, 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. 41, -1704 Unit 2 -Amendment No. 4-39,1-58

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, vimhiin 1i hou'r restore the tank to OPERABLE status 64W6i or a*p'-py the _re-qutirements of Spcfcto .31 rbe 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. 54 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, wvithin 7 daji restore the required loop to OPERABLE status ýMhi 7,ay orpplfi'---*--

33.1., 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, withini 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months si restore at least two RHR loops to OPERABLE status withiin 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or hply the* eqiements of Specific~ation ,3.13-.11, 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 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 3/45-11 Unit 1 - Amendment No.659 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 inCOLD 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, Witlhin 4 fiou6ri close the open 18-inch valve(s) or isolate the penetration(s) i~ithin 4 i-hGor apply theMquirements of Specification 3.13.1, -o'r ethePwise 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 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, rWit-hin 2-4 -h-o-u'r-s 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 within 21ho h or apl h eqieet of _pecification 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 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, Withifi-7-day restore the inoperable Spray System to OPERABLE status ýWti4i ~7 daye or apply the rqquiiemenffts~of

$pecific~titln'f3.1 3.1 '-brl 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 ; F66t6&4h16 inoporablo Spray ýSyctorn6ýQFERA RLE ctat&~ithi 18 hobrE; 6- b6 and in COLD 4hTx SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

b. 'With' more thanone -i6Conta'inmentSpray Sy~tdrffifti6pe~able,-Within_1 K6Uir'res-tore at least two Spray Systems 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 ~iifd iii COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

SURVEILLANCE REQUIREMENTS 4.6.2.1 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. 4-56 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,

~,ithiln-7 da-y-s restore the inoperable group of RCEC to OPERABLE status 64hRýý-t

'days, or applIy. thie r-e'_'uAr"e'rri ents' -ofS pecif icat!ioun i3.13.1, o- be i n 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 SHU40TDOW N within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

b. Wftinithmr~e thian 'on'e group of the abo6ve r-eq'u-i're-d R-ea-cto-r -C-o-n-tain'-m-e-n-t F-a--n Coolers inoperable, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 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 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months s-an-d 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.

b. 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 3/46-16 Unit 1 - Amendment No. -4 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 With in 24'ho u-s-:

a. Restore the inoperable valve(s) to OPERABLE status wi4thin 221 hou r.6, or

b. Isolate each affected penetration ýWthin 241 hb4r 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 %:ithir'214 h66uic by use of at least one closed manual valve or blind flange, or

d. te reqiremnts o Speifcti-on 3.13.1 Aply 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 .

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 isperformed 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 "A"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 "B" Isolation test signal, each Phase "B" 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 Desigi Criteria 57 penetration)

SOUTH TEXAS - UNITS 1 & 2 3/4 6-17 Unit 1 - Amendment No. 59,-14 3 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:

ai. ___With one motor-driven auxiliary feedwater pump inoperable, withini28 la-y's restore the pump to OPERABLE status bri applythe req~udirements of

$PoiifiC~tion3.13.1 ti o be in at least HOT STANDBY withini 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 the turbine-driven auxiliary feedwater pump inoperable, or with any two auxiliary feedwater pumps inoperable, withihn-72 hours restore the affected auxiliary feedwater pump(s) to OPERABLE statusAwithin 72:ý hours or ap plyth a-t least HOT STANDBY withini or be.- nin lre'q-u'ir e-m__enis6'f SOec-ification -3.113._1,o 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 .

MODE 3 may be entered with an inoperable turbine-driven auxiliary feedwater pump for the purposes of performing Surveillance Requirement 4.7.1.2.1 .a.2.

c. With three auxiliary feedwater pumps inoperable, Within 1 h~o~u~r appl1y t~he yieuireiii6_fit~sof Specificationi 3.'13-.1, or #ifthorquirod -cinAnd-ascao utagoetimo for elo.o a) or b) is not mot, 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.

e. Specification 3.0.4.b is not applicable.

SOUTH TEXAS - UNITS 1 & 2 3/4 7-4 Unit 1 - Amendment No. .1-4 6,-1:70 Unit 2 -Amendment No. 13~4, 158

PLANT SYSTEMS AUXILIARY FEEDWATER STORAGE TANK LIMITING CONDITION FOR OPERATION 3.7.1.3 The auxiliary feedwater storage tank (AEST) 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 AEST inoperable, within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months restore the AEST to OPERABLE status '0rapply requiremenits o-ftSp-ec -iffic-a-tio-n 3.31,3A -or- be in at least HOT STAN DBY within the next the--lq 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: MIsopen in MODES 1, 2, and 3 ACTION:

a. With rG"4-9ra MSIV inoperable bu-pPOWAER OPERATION May cOntinU9pprvided within 4 houIrs ýIos-e-o-r-restore the inoperable valve is Festered to OPERABLE status, or applyjthe rquirements of Sppc-ificati-on '3.,13ý-lý.18t~ A h n- otherwise be in HOT STANDBY w~ith6in -t-h'e n'ext 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 ~more than- ori&MSIV in'operable, within 1 h6F6urdosie or re'sto-re at le'asti thfriee Valve(s) to OPERABLE status, or apply the requirements of Specification 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 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 4.7.1.5 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 4.0.4 are not applicable for entry into MODE 3.

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, W-withn 7 rd~ays restore the required a mospheric steam relief valves to OPERABLE status or

~pp yfthe reuirements of Specification 3. 314ti-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 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 less than the required atmospheric relief valves OPERABLE, 'Wiithi~n72 hours restore at least three atmospheric relief valves to OPERABLE status or apiply the requirements o~fSSpec'ifitin 33.11 ý thi 72 ur6 or be in at leastHO 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.

C. With *more- than twoles's_ tha n the 'requirE~datmos6ipheric relie*f v~alv~e's-OPERABLE,

'within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore at least two atmospheric relief valves to OPERAB'LIE "status pr 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 HOT SHUTDOWN within the follo-wing66" hours and place, the, required RCS/RHR loops in-r 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.

SRequired to be met for automatic controls only in MODES 1 and 2.

SOUTH TEXAS - UNITS 1 & 2 3/4 7-10 Unit 1 - Amendment No. .11-4,-167 Unit 2 -Amendment No. 102, -456

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, Within 7days restore at least three loops to OPERABLE status 'ithiii J. .p-appljtherqieet fStiiain312 bi,2 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 .

,least 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 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 4.7.3 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 "B" 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 & 2 314 7-12 Unit 1 - Amendment No. 4,5,91-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:

Ja.'With only two essential cooling water loops OPERABLE, wifihin 7daysg restore at least three loops to OPERABLE status ýithin4L-dayý ror aippljfirejequirements of Seiito .31 ro-r 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 folflowing 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

cooingwtrlosioealwihn orrsoea es 0.bVVit-hi-twio -o'rm-o-r'e -e-s-en'tiaI-'61 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 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 4.7.4 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. 126,-469 Unit 2 - Amendment No. 4-1-5

PLANT SYSTEMS 3/4.7.7 CONTROL ROOM MAKEUP AND CLEANUP FILTRATION SYSTEM LIMITING CONDITION FOR OPERATION 3.7.7 Three independent Control Room Makeup and Cleanup Filtration Systems shall be OPERABLE.

APPLICABILITY: All MODES.

ACTION:

MODES 1, 2, 3, and 4:

a. With one Control Room Makeup and Cleanup Filtration System inoperable, wvithiiin 7days restore the inoperable system to OPERABLE status with~iR7-days-orapp'jyjthejrquirements of Specification 3.131,6rbe 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 following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

b. With two Control Room Makeup and Cleanup Filtration Systems inoperable, Within 72 hou6ri restore at least two systems to OPERABLE status 2hoi 6ihnbr ýapply he reiq-uirements of Spe-cif icatio-n-3A13.1 , 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 following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

c. With three Control Room Makeup and Cleanup Filtration Systems inoperable, suspend all operations involving movement of spent fuel, and crane operation with loads over the spent fuel pool, and Withiln 12 hlo-urs restore at least one system to OPERABLE status .6t~hM42 hours_ or apply the, requirements of Specification 3.1.1, or'be in at least HOT STANDBY within thenex 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 .

MODES 5 and 6:

a. With one Control Room Makeup and Cleanup Filtration System inoperable, restore the inoperable system to OPERABLE status within 7 days or initiate and maintain operation of the remaining OPERABLE Control Room Makeup and Cleanup Filtration Systems in the recirculation and makeup air filtration mode, or suspend all operations involving CORE ALTERATIONS, operations involving positive reactivity additions that could result in loss of required SHUTDOWN MARGIN or required boron concentration, movement of spent fuel, and crane operation with loads over the spent fuel pool.

b. With more than one Control Room Makeup and Cleanup Filtration System inoperable, or with the OPERABLE Control Room Makeup and Cleanup Filtration Systems required to be inthe recirculation and makeup air filtration mode by ACTION a. not capable of being powered by an OPERABLE emergency power source, suspend all operations involving CORE ALTERATIONS, operations involving positive reactivity additions that could result in loss of required SHUTDOWN MARGIN or required boron concentration, movement of spent fuel, and crane operations with loads over the spent fuel pool.

SURVEILLANCE REQUIREMENTS 4.7.7 Each Control Room Makeup and Cleanup Filtration System shall be demonstrated OPERABLE:

a. At least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months by verifying that the control room air temperature is less than or equal to 780F;

b. At least once per 92 days on a STAGGERED TEST BASIS by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers of the makeup and cleanup air filter units and verifying that the system operates for at least 10 continuous hours with the makeup filter unit heaters operating; SOUTH TEXAS - UNITS 1 & 2 3/47-16 Unit 1 - Amendment No. 59, 425,4128 Unit 2 - Amendment No. 47,-1-3,4-1-1

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 loopsOPERABLE, w-ithin 7 days restore at least three loops to OPERABLE status wih~-ay~s qi applly the requirements of Speifiaton .131,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' S__H`UTfDObWN with in the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

b. Wfth'iwi o-r-'mio-re--Esse-n'tIall Chilled Water System loops inoperable, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore at least 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 and ini

'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. 7-2

3/4.8 ELECTRICAL POWER SYSTEMS 314.8.1 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 off site transmission network and the onsite Class 1E Distribution System(1 ), 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. With!iný 666 hors i6Tst&6 the off site circuit to O PERAB LE status ~'ti 2husor japp ly the ,re~qu irements of

Specification 3-.1 3'.1 ,'o&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 .

b. With a standby diesel generator inoperable, demonstrate the OPERABILITY of the above-required A.C. off site 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)._Within114 d~a'y~sres~tore the inoperable standbyý diesel geneqrator to OPERABLE status wiloiw14ýIays or apply the requirements of Spe~cificaitio-n 3.13.1, o 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, 14-8

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; w~ithi~ii 12 houir's restore at least one of the inoperable sources to OPERABLE status, :ithin 19 hiu or'apply the requremets f Sidfidion3.13.1-&o be in at least HOT STANDBY within the nex6horan in COLD SHUTDOWN w-ithin'the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . Ale"Stor a las toýofstoIruis PEALsttsith7horantho tnbdislgenerator-s to OPEIRABLEr staif4J'_Itlii S1days from the Vtime Of initial loss Or b3e in at least12HOT STANDBY withinth e 6ousadi COLD SHUTDONwti the following _30 hours. ( ) hnx6husadi that;A;ithin 2 hrcpply tho requirornentso peifiaton 3.13.1, or he in at lIat; HT STANDBY within the; next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and On COL-1D SHU TDOWNI within the following 30 hour3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

OPER ABLEr diesel generators as a source ofeegnypoWerare also OPERBEan

22. WfhoPr ijýIVODEý ,6 3,the st6_4n drive axlif6d'a pm is'OPERABLE9 Iýfthý 6'ito taifidwti 24b oi a o4~O STANDBY i~ithi6 thi4 Fie" hour andin OLD HUTOWN within the fleilowing 30 hour-s

e. With two of the above required offsite A.C. circuits inoperable, W~ithin 24 hiddri6 restore at least one of the inoperable offsite sources to OPERABLE status !ithin 21 hours2.430556e-4 days 0.00583 hours 3.472222e-5 weeks 7.9905e-6 months or apply the r-equiremenrts of Spe.~ificatiori 3.113.11ý, 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 oeneffsit6 sourerestored, resAto-reat 6s v' feti-it &PRBL'ttwti 2husfo ieo initial loss or beA in a-t leas_;t HOT S-TANIDBY within the-next 6,hours and inCOL=D SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

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 re uirements 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; ffJ R' at least one standby etr )OT diesel generator to OPERABLE status- 6ii42 or apply the requirements of Specification 3.13.1, or .4,06_6t two standoby4deslgeertrst OPERABLER ktý- mwithiin 21 hous -4; be in at least HOT STANDJBY w-i-thin the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD 'SHUTDOWN within the- f-o-llo-wing 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

Rectrs a l6~ tre o~oator to PERALE satuswithn'1 daf~o tiro6o stadbdisbl initial loss or be ina:t 16das-t 2)

HOT SADYitnthne 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUT-DOWN wti the) following 30 (1rs 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 I1125-volt Battery Bank El1Al11(Unit 1), E2A1 1 (Unit 2) and one of its two associated chargers,

b. Channel 11 125-volt Battery Bank El D1l1 (Unit 1), E2D1 1 (Unit 2)and one of its two associated full capacity chargers, C. Channel Ill 125-volt Battery Bank El 131 (Unit 1), E2B1311 (Unit 2) and one of its two associated full capacity chargers, and

d. Channel IV 125-volt Battery Bank El C1l1 (Unit 1), E2C1 1 (Unit 2) and one of its two associated chargers.

APPLICABILITY: MODES 1,2,3, and 4 ACTION:NOTE charg eriwhei:n t he6 liatter ie--aiirei the6 so-1 ACTION:Spei fi cat-ion63._1 3.11 mia-y not be666entred' foir batteri es or:1

~source of available power to their DC bus. If the batteries discharge for more than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months as the sole source of power to their DC bus while Specification 3.13.1 isbeing applied and no alternate

ýource of oower is available, the Soecification 3.13.1 LCO shall be considered not met.

a. With one of the required battery banks inoperable,!výithii6--ib2 6ur-s restore the inoperable battery bank to OPERABLE status'o-r apply the requirements of Specificatlon'3.1-31,vm'-ithin-2ihbwi4._ 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 inCOLD SH-UTD OWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

b.' With mnore t h an ne6 6f -the i'rec iired baittery ba~nks in6o~perable_,_i wifhin- 1 h our 6's t-6re--at Ilea st th ree battery banks 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 .

c. With one _channel 'withi no battery chargers f64 -a-ehaai 4i -OPERABLE, wvithini 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months restore at least one battery charger to OPERABLE status 4ith~in -he rapyterqieet of Specificitio-n 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

d. With mo-re than one channel wiith no0 batteiry charges ora hane OPERABLE, iithin _ho~u~r restore at least one battery charger to OPERABLE status on at least three channels or apply the requirements of Specification 3.13.1, or be inat least HOTSTANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and inCOLD SHUTDOWN with-in the following ý30,hours 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. 4473 Unit 2 - Amendment No. 62

ELECTRICAL POWER SYSTEMS ZINOCAGES 314.8.3 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. ESE Busses consisting of:

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

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

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

1) 4160-Volt ESF Bus # EIB (Unit 1), E2B3 (Unit 2), and

2) 480-Volt ESF Busses # El Bi and E11B2 (Unit 1), E2B31 and E2B32 (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 ESE Busses # EICI and EIC2 (Unit 1), E2CI and E2C2 (Unit 2) from respective load center transformers.

d. 120-Volt A.C. Vital Distribution Panels DP1 201 and DPOO1 energized from their associated inverters connected to D.C. Bus # EIAII* (Unit 1), E2AII* (Unit 2), .

e. 120-Volt A.C. Vital Distribution Pane! DPi 202 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 DP1 204 and DPOO2 energized from their associated inverters connected to D. C. Bus #El1C1l1 * (Unit 1), E2C1 1* (Unit 2),

h. 125-Volt D. C. Bus El Al 1 (Unit 1) E2A1 1 (Unit 2) energized from Battery Bank El All1 (Unit 1), E2A1 1 (Unit 2),

L. 125-Volt D. C. Bus El D1l1 (Unit 1) E2OD1 1 (Unit 2) energized from Battery Bank El Dl (Unit 1), E2Dl 1 (Unit 2),

j. 125-Volt D. C. Bus El Bi 1 (Unit 1) E2Bl1 1 (Unit 2) energized from Battery Bank El Bl (Unit 1), E21311 (Unit 2), and

k. 125-Volt D. C. Bus El C1l1 (Unit 1) E2C1 1 (Unit 2) energized from Battery Bank El Cl (Unit 1), E2Cl 1 (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 1,2A3 and 4.

ACTION:

a. With one of the required trains of A.C. ESF busses not fully ene -rgized, Wvith l6'8"hours reenergize the train orapiIthrejirementfi Spcfication_3.1 3.1, 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. W6ithmiieta n fterqie ~i~ .. EE uss~~ ul nrie;wti i Teenergize at least two trains 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 .

c. With one 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)"With1n 2-hours-r-een-r-giz-eth-eA.C.'distribiti6ni 2 hureor ppl ti e~iernntsof Specification 3.13.1, or be in at least HOT ka~e~.~thl 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 ; and (2) wvithin_24_hours reenergize the A.C. vital distribution panel(s) from its associated inverter connected to its associated D.C. bus Ofithin21 hor oriaipily the reqijuirem~ens of Specifica~ti6h_3.1 3.1, 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 .

d. "Withmoreiiýthan b'6-AC'Mitl distribution0pnanl @ith~eintti~erg6ized firou~tii itsbsioia-ted Inverter, or with the Inverter not connected to its associa1ted D.C. bus: (1)within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months reenergize at least five A.C. distribution panels or apply the requirements of Specification 3.113.1, 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 ; and (2)within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months reenergize at least five A.C. vital distribution panels from their associated inverter connected to their associated D.C. bus 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 .

e. With one D.C. bus not energized from its associated battery bank, Wvithin 2 hour6s reenergize the D.C.

bus from its associated battery bank ýith'R2-houý6 or ji~pply thei 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 .

f. With iore~i than 66DC bus-niot 'eneirgized fromm itt asoiated so battery bank, within 1 hbour-reenergize at least three D.C. buses from their associated battery banks 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 4.8.3.1 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: 1) MODE 1 and MODE 2, and

2) Conditions where a Loss of Function has not occurred ACTION:

a. Within the allowed outage time of the referencing specification determine that the configuration is acceptable for extension beyond the allowed outage time for the referencing specification, AND

b. Within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months determine that the configuration is acceptable for continued operation beyond the allowed outage time for the referencing specification whenever configuration changes occur that may affect plant risk as calculated in the CRMP, AND C. Restore the required inoperable subsystem or component to OPERABLE status within the acceptable allowed outage time extension or 30 days, whichever is shorter.

OR Take the ACTION(s) required in the referencing specification for required action or completion time not met.

SURVEILLANCE REQUIREMENTS 4.13.1 As required by the referencing specification SOUTH TEXAS - UNITS 1 & 2 3/4 13-1 Unit 1 - Amendment No.

Unit 2 -Amendment No.

3/4.13 RISK MANAGEMENT 3/4.13.2 ALLOWED OUTAGE TIME DETERMINATIONS FOR ACTION STATEMENTS IN MULTIPLE LOOs LIMITING CONDITION FOR OPERATION 3.13.2 When two or more ACTION statements to which Specification 3.13.1 may apply are entered, the allowed outage time shall not exceed the criteria of the Configuration Risk Management Program.

APPLICABILITY: 1) MODE 1 and MODE 2, and

2) Entry into two or more ACTION statements to which Specification 3.13.1 may be applied, and

3) Configurations where LCO 3.13.1 is not being applied ACTION: Determine the configuration is acceptable for the application of at least the specified allowed outage times for the affected components within the shorter of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months or the shortest affected allowed outage time. For configurations where the specified allowed outage time is longer than the calculated allowed outage time, restore one or more of the affected components to OPERABLE status within the calculated allowed outage time or take the ACTION(s) required in the referencing specification(s) for required action or completion time not met.

SOUTH TEXAS - UNITS 1 & 2 3/4 13-2 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, 10CFR5O.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 the incremental core damage probability threshold of 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 against extending baseline AOTs to the detriment of component or system availability.

TS 3.13.1 applies in the at-power MODEs 1 and 2 where the PRA model applies. If the MODE of applicability is exited, the risk-informed provisions of TS 3.13.1 may not be applied and the completion times for the subject TS shall apply from the time of the MODE change.

TS 3.13.1 .a establishes the conditions for performance of the risk assessment. The LOOs 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.

TS 3.13.1 applies separately to each ACTION for which TS 3.13.1 is entered. When TS 3.13.1 is entered from a referencing TS, it is entered at ACTION a, even if TS 3.13.1 is already being applied for another referencing TS; i.e., TS 3.13.1 is applied as an extension of the ACTION statement of the referencing TS. Although TS 3.13.1 may be applied to extend the allowed outage time for a referencing TS, except for the extension in the allowed outage time, the other requirements of the referencing TS continue to apply. For instance, if TS 3.13.1 is applied to extend the allowed outage time for Train A ECW (TS 3.7.4.a), the provisions of TS 3.7.4.b. will apply if another ECW train becomes inoperable.

TS 3.0.2 applies to the RMTS ACTION statement allowance to calculate a risk-informed completion time (RICT). If the component is restored or if a RICT is calculated in accordance with the ACTION before a required shutdown is completed, the shutdown need not be completed.

The requirement to continually determine the acceptability of the plant configuration means that once the subject LCO has exceeded the baseline AOT, the risk assessment must be reperformed to determine the need to adjust the required action and time limits for any affected TS component based on the risk associated with any CRMP component that subsequently becomes inoperable or non-functional. 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 1E-05 conditional core damage probability risk 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 1E-05 threshold, the calculated RIOT has been exceeded and the action required at the expiration of the LCO AOT must be taken.

Application of TS 3.13.1 will provide action for conditions where more than one train or channel of a function is inoperable. Unless otherwise permitted in the TS, TS 3.13.1 will not be applied for configurations where there is a complete loss of function (e.g., all three trains of ECW or all channels of an actuation logic that results in all trains of a function being non-functional).

If a component is determined to be inoperable, it may still be considered to have PRA Functionality for calculation of a RIOT if there is reasonable assurance that it can perform its required functions for events not affected by the degraded or non-conforming condition and if the condition can be quantified in the PRA. If these conditions are not met, the component will be assumed to be non-functional for calculating the RIOT; i.e., it will have no PRA Functionality.

Examples of where a component has PRA Functionality such that the condition could be quantified in the determination of an allowed outage time are listed below:

SSCs that don't meet seismic requirements but are otherwise capable of performing their design function.

" SSCs that are inoperable but secured in their safe position (e.g., a closed containment isolation valve).

" SSCs powered from a source other than their normal power source, provided the alternate power source is modeled in the PRA.

" An SSC with an inoperable automatic function if the manual actuation of the SSC is modeled in the PRA (e.g., a diesel generator with an inoperable sequencer). Actuation channels are associated with their actuated components or trains. Loss of actuation channels is not considered a Loss of Function unless no train of the actuated SSC function has PRA Functionality.

An SSC that is functional for mitigation of a set of events (e.g. steam generator tube rupture, small break LOCA) but is not functional for other events for which it is credited (e.g. large break LOCA or steam line break), providing the PRA model can quantify the risk for the calculation of a RIOT. An example of this type of condition is degradation of environmental qualification.

Reference 1 specifies the criteria for determining functionality.

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.

Bases for Technical Specification*3.13.2 Technical Specification 3.13.2 requires confirmation that the specified allowed outage times are acceptable when more than one ACTION is entered that allows the application of TS 3.13.1.

The allowed outage times for SSCs are often based on no other SSC being inoperable at the same time. Some configurations where the plant is in two or more LCO ACTION statements could potentially impose an unacceptable level of risk. This is particularly the case if the affected components are in different safety trains because the redundancy of accident mitigation capability could be adversely affected.

TS 3.13.2 applies only in MODE 1 and MODE 2 because those are the at-power modes best represented by the PRA.

TS 3.13.2 applies to the LOOs to which TS 3.13.1 can be applied because those are the SSCs that are modeled in the PRA and for which a quantified allowed outage time can be determined.

To prevent redundant or conflicting requirements, TS 3.13.2 does not apply when TS 3.13.1 is being applied to manage risk for configurations with components beyond their frontstop allowed outage times. Inthose situations, TS 3.13.1 already imposes the appropriate requirements for the assessment of configuration risk.

Reference:

1. EPRI Risk Managed Technical Specifications Guidelines

6.0 ADMINISTRATIVE CONTROLS 6.8 Procedures, Programs, and Manuals 6.8.3 .j (continued)

Peak calculated containment internal pressure for the design basis loss of coolant accident (LOCA), Pa is 41.2 psig.

The maximum allowable containment leakage rate, La, is 0.3 percent of containment air weight per day.

Leakage rate acceptance criteria are:

1) Containment overall leakage rate acceptance criterion is <1.0 La. During the first unit start-up following testing in accordance with this program, the leakage rate acceptance criteria are < 0.60 1, for the combined Type B and Type C tests, and <.75 La, as-left and < 1.0 La as-found for Type A tests.

2) Air lock testing acceptance criteria for the overall air lock leakage rate is <

0.05 1, when tested at > Pa.

The provisions of Surveillance Requirement 4.0.2 do not apply to the test frequencies specified in the Containment Leakage Rate Testing Program.

The provisions of Surveillance Requirement 4.0.3 apply to the Containment Leakage Rate Testing Program.

k. Configuration Risk Management Program (CRMP)

A program to assess changes in core damage frequency and cumulative core damage probability resulting from applicable plant configurations. The program shou~l shall be in accordance with Section 2 of the EPRI Risk-Managed Technical Specifications (RMTS) Guidelines, Rev. []include the following.:

1) Training of personnel evaluation of r-iský against established thresholds, and-

3) provisions for-evaluating, changes in risk resulting from unplanned maintenance activities, (continued)

SOUTH TEXAS - UNITS 1 & 2 6-10 Unit 1 - Amendment No.

Unit 2 - Amendment No.

NOC-AE-06002005 P-R-A Quality

PRA Quality NOC-AE-06002005 Attachment 3 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 inform-ation required by RG 1.200 will require a substantial effort. This submittal contains an outline with some preliminary information.

The remainder of the information wvill 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 which 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 include as a minimum performance data, procedures, and modifications. The reviews and updates are performed 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 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-1 5049-A and relaxed accumulator surveillance -requirements consistent with Westinghouse Improved Technical Specifications.

6. Amendment Nos. 143 & 13 1, dated September 17, 2002. The application allowed a one-time 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-03001 167).

These amendments eliminated the turbine missile design basis.

PRA Quality NOC-AE-06002005 Attachment 3

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 license 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 requiting 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 incorporated as appropriate into Revision 4 of the STP PRA.

The STP PRA Revision 4 model was the basis for the original 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. Revision 5 of the PRA will incorporate the Level 2 update and any changes from internal flooding. No issues have been identified from the flood reevaluation to date that affect the PRA.

STPNOC provided the detailed disposition of the peer review F&O in Reference 5 in the cover letter for this submittal.

RG 1.200 Required Informnation The information described below has been provided or is available to demonstrate that the parts of the STP PRA are of sufficient quality to support the analyses used in this application:

PRA Quality NOC-AE-06002005 Attachment 3

The process for maintenance, update, and control of the PRA meets the requirements in the EPRI Risk-Managed Technical Specification Guidelines. The procedures for the process are implemented and available for NRC review.

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. Incorporation of these changes into PRA will be performed in accordance with the requirements of the EPRI Risk-Managed Technical Specification Guidelines.

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. STPNOC provided the detailed disposition of the peer review F&O in Reference 5 in the cover letter for this submittal.

NOC-AE-06002005 Commitments

Commitments NOC-AE-06002005 Attachment 4 Page I In previous risk-informed Technical Specification submittals to extend the allowed outage time for the Standby Diesel Generators, Essential Cooling Water, Essential Chilled Water, and Auxiliary Feedwater System, STPNOC committed to implement a set of risk management actions when the allowed outage time extension is applied (i.e., when the duration of the work exceeds the originally licensed allowed outage time). For the SDG, ECW, and EChW, the risk management procedures require RMAs if the SSC will be inoperable for longer than the duration of the allowed outage time prior to approval of Amendment 85/72. For one inoperable MD AFW pump, the RMAs are required if the duration of the inoperable condition will exceed 14 days. These times are prescriptive and do not take into account the actual quantified risk of the plant configuration when the SSC is removed from service or becomes inoperable for an emergent condition.

STPNOC is revising the risk management procedures to base the RMA requirements on exceeding or expecting to exceed the RMAT in accordance with the RMTS Guidelines instead of the current prescriptive time requirements described above. This approach is consistent with the proposed license amendment and the change does not require prior NRC approval. STPNOC plans to implement the change in the near future.

Implementation of the Maintenance Rule (MR) as described in 10CFR5O.65(a)(4) requires an assessment of risk for maintenance and that the risk be managed. STPNOC has established a configuration risk management program (CRMP) to comply with the MR. Consistent with NUMARC 93-01, it establishes specific risk thresholds that require compensatory action if the configuration risk exceeds the threshold. The non-risk-significant threshold is established at an incremental core damage probability (ICDP) of IE-06. RMA is required for configurations where the risk exceeds that threshold.

The RMTS Guidelines applies the same ICDP threshold for RMA as the MR. The RMTS Guidelines also establish a incremental large early release probability (ILERP) threshold of lE-

07. The RMTS Guidelines specifically require RMAs for conditions that exceed the RMAT:

For plant configurations in which the RMAT either has been exceeded (emergent event) or is anticipated to be exceeded (either planned condition or emergent event), appropriate compensatory risk management actions shall be identified and implemented. For preplanned maintenance activities for which the RMAT is anticipated to be exceeded, RMAs shall be implemented at the earliest appropriate time.

Revising the STP procedures to apply thresholds consistent with the MR and the RMTS Guidelines will establish an internally consistent risk-informed process with one set of criteria that is firmly grounded in industry and regulatory precedent.

This revised action is tracked by Condition Report (CR) 06-6838.

NOC-AE-06002005, Revised Broad Scope Risk-Informed Technical Specification Amendment Request

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NOC-AE-06002005, Revised Broad Scope Risk-Informed Technical Specification Amendment Request

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