NOC-AE-18003604, License Amendment Request to Revise Technical Specifications to Adopt TSTF-529, Clarify Use and Application Rules, Using the Consolidated Line Item Improvement Process

License Amendment Request to Revise Technical Specifications to Adopt TSTF-529, Clarify Use and Application Rules, Using the Consolidated Line Item Improvement Process

ML19126A309
Person / Time
Site:	South Texas
Issue date:	05/01/2019
From:	Connolly J South Texas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NOC-AE-18003604, STI: 34744980
Download: ML19126A309 (24)

Text

Nuclear Operating Company South Texas Project Electric Genei-atlng Station r0. Box 2 S? Wadsworth, Texas 77-fSJ May 1,2019 NOC-AE-18003604 10CFR 50.90 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 South Texas Project Units 1 and 2 Docket Nos. STN 50-498 and STN 50-499 License Amendment Request to Revise Technical Specifications to adopt TSTF-529, "Clarify Use and Application Rules J'Usinfl^^^^t^

Pursuant to 10 CFR 50.90, STP Nuclear Operating Company (STPNOC) hereby requests a license amendment to South Texas Project (STP) Renewed Operating Licenses NPF-76 and NPF-80 to revise Technical Specifications.

The proposed amendment would modify Technical Specifications in Section 3.0 and Section 4.0 regarding Limiting Conditions for Operation and Surveillance Requirements usage. These changes are consistent with NRC-approved Technical Specification Task Force (TSTF) Traveler TSTF-529, "Clarify Use and Application Rules."

The Enclosure to this letter provides a description and assessment of the proposed changes including technical and regulatory evaluations and a No Significant Hazards Consideration analysis. Marked-up and re-typed (clean) Technical Specification pages are provided in Attachments 1 and 2, respectively. Attachment 3 provides an existing Technical Specification Bases page marked to show the proposed changes for information only.

Approval of the proposed amendment is requested by January 1, 2020. STPNOC will implement the amendment within 90 days of the NRC approval date.

In accordance with 10 CFR 50.91 (b), STPNOC is notifying the State of Texas of this license amendment request by transmitting a copy of this letter and Enclosure to the designated State Official. The proposed amendment has been reviewed and approved by the STPNOC Plant Operations Review Committee and has undergone an independent organizational unit review.

There are no regulatory commitments in this amendment request.

If there are any questions or if additional information is needed, please contact Nic Boehmisch at (361) 972-8172 or me at (361) 972-7344.

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

Executed on T^d^ /, 9^ I J

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ally

' James Connolly Executive VP and CNO nb

Enclosure:

Evaluation of the Proposed Change STI:34744980

NOC-AE-18003604 Page 2 of 2 cc:

Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 1600 East Lamar Boulevard Arlington, TX 76011-4511 Glen Ed Miller Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint North (O9E01) 11555 Rockville Pike Rockville, MD 20852 NRC Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 289, Mail Code: MN116 Wadsworth, TX 77483

Enclosure NOC-AE-18003604 Page 1 of 4 ENCLOSURE Evaluation of the Proposed Change

Subject:

License Amendment Request to Revise Technical Specifications to adopt TSTF-529, Clarify Use and Application Rules, using the Consolidated Line Item Improvement Process

1.0 DESCRIPTION

2.0 ASSESSMENT 2.1 Applicability of Safety Evaluation 2.2 Variations

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Analysis 4.0 ENVIRONMENTAL EVALUATION ATTACHMENTS:

1. Technical Specification Page Markups

2. Retyped Technical Specification Pages

3. Technical Specification Bases Changes (for information only)

Enclosure NOC-AE-18003604 Page 2 of 4

1.0 DESCRIPTION

The proposed change revises Section 3.0, Limiting Conditions for Operation, and Section 4.0, Surveillance Requirements of the Technical Specifications to clarify the Technical Specification usage rules, as described below:

• Technical Specification 3.0.4.b is revised to clarify that Technical Specification 3.0.4.a, Technical Specification 3.0.4.b, and Technical Specification 3.0.4.c are independent options.

• Technical Specification 4.0.3 is revised to allow application of Technical Specification 4.0.3 when a Surveillance Requirement has not been previously performed and to clarify the application of Technical Specification 4.0.3.

2.0 ASSESSMENT 2.1 Applicability of Safety Evaluation STP Nuclear Operating Company (STPNOC) has reviewed the safety evaluation for TSTF-529 provided to the Technical Specification Task Force in a letter dated April 21, 2016. This review included a review of the NRC staffs evaluation, as well as the information provided in TSTF-529. STPNOC has concluded that the justifications presented in the TSTF-529 proposal and the safety evaluation prepared by the NRC staff are applicable to South Texas Project Units 1 and 2 and justify this amendment for the incorporation of the changes to the STP Technical Specifications.

2.2 Variations STPNOC is proposing the following variations from the Technical Specification changes described in TSTF-529 or the applicable parts of the NRC staffs safety evaluation dated April 21, 2016:

• Section 1.3 revision to clarify discovery - will not be incorporated, and

• Section 1.3 revision to discuss exceptions to starting the Completion Time at condition entry - will not be incorporated, The STP Technical Specifications Section 1.0 does not contain a definition for Completion Time or a related term.

These variations do not affect the applicability of TSTF-529 or the NRC staffs safety evaluation to the proposed license amendment.

The STP Technical Specifications utilize different numbering and titles than the Standard Technical Specifications on which TSTF-529 was based. Specifically, Surveillance Requirement 3.0.3 in TSTF-529 is numbered as Technical Specification 4.0.3 in STP Technical Specifications. This difference is administrative and does not affect the applicability of TSTF-529 to the STP Technical Specifications.

Enclosure NOC-AE-18003604 Page 3 of 4

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Analysis STP Nuclear Operating Company (STPNOC) requests adoption of TSTF-529, Clarify Use and Application Rules, that is an approved change to the standard technical specifications (STS),

into the STP Units 1 and 2 Technical Specifications. The proposed change revises Section 3.0 Limiting Conditions for Operation and Section 4.0 Surveillance Requirements of the Technical Specifications to clarify the use and application of the Technical Specification usage rules and revise the application of Technical Specification Surveillance Requirement (SR) 4.0.3.

An editorial change is made to Technical Specification Limiting Conditions for Operation (LCO) 3.0.4.b to clarify that Technical Specification LCO 3.0.4.a, Technical Specification LCO 3.0.4.b, Technical Specification LCO 3.0.4.c are independent options. Technical Specification SR 4.0.3 is revised to allow application of Technical Specification SR 4.0.3 when a surveillance requirement has not been previously performed.

STPNOC has evaluated whether or not a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

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

Response: No.

The proposed change to Technical Specification LCO 3.0.4 has no effect on the requirement for systems to be Operable and has no effect on the application of Technical Specification actions.

The proposed change to Technical Specification SR 4.0.3 states that the allowance may only be used when there is a reasonable expectation the surveillance will be met when performed.

Since the proposed change does not significantly affect system Operability, the proposed change will have no significant effect on the initiating events for accidents previously evaluated and will have no significant effect on the ability of the systems to mitigate accidents previously evaluated.

Therefore, it is concluded that this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

Response: No.

The proposed change to the Technical Specifications usage rules does not affect the design or function of any plant systems. The proposed change does not change the Operability requirements for plant systems or the actions taken when plant systems are not Operable.

Therefore, it is concluded that this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

Enclosure NOC-AE-18003604 Page 4 of 4

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The proposed change clarifies the application of Technical Specification LCO 3.0.4 and does not result in changes in plant operation. Technical Specification SR 4.0.3 is revised to allow application of Technical Specification SR 4.0.3 when a Surveillance Requirement has not been previously performed if there is reasonable expectation that the Surveillance Requirement will be met when performed. This expands the use of Technical Specification SR 4.0.3 while ensuring the affected system is capable of performing its safety function. As a result, plant safety is either improved or unaffected.

Therefore, it is concluded that this change does not involve a significant reduction in a margin of safety.

Based on the above, STPNOC concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

4.0 ENVIRONMENTAL EVALUATION The proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

Enclosure NOC-AE-18003604 Attachment 1 Attachment 1 Technical Specification Page Markups

3/4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS 3/4. 0 APPLICABILITY LIMITING CONDITION FOR OPERATION 3.0.1 Compliance with the Limiting Conditions for Operation contained in the succeeding specifications is required during the OPERATIONAL MODES or other conditions specified therein; except that upon failure to meet the Limiting Conditions for Operation, the associated ACTION requirements shall be met.

3.0.2 Noncompliance with a specification shall exist when the requirements of the Limiting Condition for Operation and associated ACTION requirements are not met within the specified time intervals. If the Limiting Condition for Operation is restored prior to expiration of the specified time intervals, completion of the ACTION requirements is not required.

3.0.3 When a Limiting Condition for Operation is not met, except as provided in the associated ACTION requirements, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> action shall be initiated to place the unit in a MODE in which the specification does not apply by placing it, as applicable, in:

a. At least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />,

b. At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and

c. At least COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Where corrective measures are completed that permit operation under the ACTION requirements, the action may be taken in accordance with the specified time limits as measured from the time of failure to meet the Limiting Condition for Operation. Exceptions to these requirements are stated in the individual specifications.

This specification is not applicable in MODE 5 or 6.

3.0.4 When a Limiting Condition of Operation is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time; or

b. After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; (exceptions to this Specification are stated in the individual Specifications);, or

c. When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

SOUTH TEXAS - UNITS 1 & 2 3/4 0-1 Unit 1 - Amendment No. 170 Unit 2 - Amendment No. 158

APPLICABILITY SURVEILLANCE REQUIREMENTS 4.0.1 Surveillance Requirements shall be met during the OPERATIONAL MODES or other conditions specified for individual Limiting Conditions for Operation unless otherwise stated in an individual Surveillance Requirement.

Failure to meet a Surveillance Requirement, whether such a failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the Limiting Conditions for Operation. Failure to perform a Surveillance within the specified surveillance interval shall be failure to meet the Limiting Conditions for Operation except as provided in Specification 4.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

4.0.2 Each Surveillance Requirement shall be performed within the specified surveillance interval with a maximum allowable extension not to exceed 25 percent of the specified surveillance interval.

4.0.3 If it is discovered that a Surveillance was not performed within its specified surveillance interval (including the allowed extension per Specification 4.0.2), then compliance with the requirement to declare the Limiting Condition for Operation not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified surveillance interval, whichever is greater.

This delay period is permitted to allow performance of the surveillance. The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.

If the Surveillance is not performed within the delay period, the Limiting Condition for Operation must immediately be declared not met, and the applicable Condition(s) must be entered. When the Surveillance is performed within the delay period and the Surveillance is not met, the Limiting Condition for Operation must immediately be declared not met and the applicable Condition(s) must be entered.

4.0.4 Entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the Surveillance Requirement(s) associated with the LCO have been met within their specified Frequency, except as provided by Specification 4.0.3. When an LCO is not met due to Surveillance Requirement(s) not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with Specification 3.0.4. This provision shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

4.0.5 Surveillance Requirements for inservice inspection and testing of ASME Code Class 1, 2, and 3 components shall be applicable as follows:

a. lnservice testing of ASME Code Class 1, 2, and 3 pumps and valves, and inservice inspection of ASME Code Class 1,2, and 3 components shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR Part 50, Section 50.55a(f) and Section 50.55a(g), except where specific written relief has been granted by the Commission pursuant to 10 CFR Part 50, Section 50.55a(f)(6)(i) or Section 50.55a(g)(6)(i), or where the component has been found to qualify for exemption from special treatment; SOUTH TEXAS - UNITS 1 & 2 3/4 0-3 Unit 1 - Amendment No. 95, 141 ,145, 170,173 Unit 2 - Amendment No. 82, 129 133, 158, 161

Enclosure NOC-AE-18003604 Attachment 2 Attachment 2 Retyped Technical Specification Pages

3/4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS 3/4. 0 APPLICABILITY LIMITING CONDITION FOR OPERATION 3.0.1 Compliance with the Limiting Conditions for Operation contained in the succeeding specifications is required during the OPERATIONAL MODES or other conditions specified therein; except that upon failure to meet the Limiting Conditions for Operation, the associated ACTION requirements shall be met.

3.0.2 Noncompliance with a specification shall exist when the requirements of the Limiting Condition for Operation and associated ACTION requirements are not met within the specified time intervals. If the Limiting Condition for Operation is restored prior to expiration of the specified time intervals, completion of the ACTION requirements is not required.

3.0.3 When a Limiting Condition for Operation is not met, except as provided in the associated ACTION requirements, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> action shall be initiated to place the unit in a MODE in which the specification does not apply by placing it, as applicable, in:

a. At least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />,

b. At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and

c. At least COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Where corrective measures are completed that permit operation under the ACTION requirements, the action may be taken in accordance with the specified time limits as measured from the time of failure to meet the Limiting Condition for Operation. Exceptions to these requirements are stated in the individual specifications.

This specification is not applicable in MODE 5 or 6.

3.0.4 When a Limiting Condition of Operation is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time; or

b. After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate (exceptions to this Specification are stated in the individual Specifications); or

c. When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

SOUTH TEXAS - UNITS 1 & 2 3/4 0-1 Unit 1 - Amendment No. 170 Unit 2 - Amendment No. 158

APPLICABILITY SURVEILLANCE REQUIREMENTS 4.0.1 Surveillance Requirements shall be met during the OPERATIONAL MODES or other conditions specified for individual Limiting Conditions for Operation unless otherwise stated in an individual Surveillance Requirement.

Failure to meet a Surveillance Requirement, whether such a failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the Limiting Conditions for Operation. Failure to perform a Surveillance within the specified surveillance interval shall be failure to meet the Limiting Conditions for Operation except as provided in Specification 4.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

4.0.2 Each Surveillance Requirement shall be performed within the specified surveillance interval with a maximum allowable extension not to exceed 25 percent of the specified surveillance interval.

4.0.3 If it is discovered that a Surveillance was not performed within its specified surveillance interval (including the allowed extension per Specification 4.0.2), then compliance with the requirement to declare the Limiting Condition for Operation not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified surveillance interval, whichever is greater.

This delay period is permitted to allow performance of the surveillance. The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.

If the Surveillance is not performed within the delay period, the Limiting Condition for Operation must immediately be declared not met, and the applicable Condition(s) must be entered. When the Surveillance is performed within the delay period and the Surveillance is not met, the Limiting Condition for Operation must immediately be declared not met and the applicable Condition(s) must be entered.

4.0.4 Entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the Surveillance Requirement(s) associated with the LCO have been met within their specified Frequency, except as provided by Specification 4.0.3. When an LCO is not met due to Surveillance Requirement(s) not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with Specification 3.0.4. This provision shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

4.0.5 Surveillance Requirements for inservice inspection and testing of ASME Code Class 1, 2, and 3 components shall be applicable as follows:

a. lnservice testing of ASME Code Class 1, 2, and 3 pumps and valves, and inservice inspection of ASME Code Class 1,2, and 3 components shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR Part 50, Section 50.55a(f) and Section 50.55a(g), except where specific written relief has been granted by the Commission pursuant to 10 CFR Part 50, Section 50.55a(f)(6)(i) or Section 50.55a(g)(6)(i), or where the component has been found to qualify for exemption from special treatment; SOUTH TEXAS - UNITS 1 & 2 3/4 0-3 Unit 1 - Amendment No. 95, 141 ,145, 170,173 Unit 2 - Amendment No. 82, 129 133, 158, 161

Enclosure NOC-AE-18003604 Attachment 3 Attachment 3 Technical Specification Bases Changes (for information only)

3/4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS 3.4.0 APPLICABILITY BASES Specification 3.0.1 through 3.0.5 establish the general requirements applicable to Limiting Conditions for Operation. These requirements are based on the requirements for Limiting Conditions for Operation stated in the Code of Federal Regulations, 10 CFR 50.36(c)(2):

"Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility. 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 specification until the condition can be met."

Specification 3.01 establishes the Applicability statement within each individual specification as the requirement for when (i.e., in which OPERATIONAL MODES or other specified conditions) conformance to the Limiting Conditions for Operation is required for safe operation of the facility.

The ACTION requirements establish those remedial measures that must be taken within specified time limits when the requirements of a Limiting Condition for Operation are not met.

There are two basic types of ACTION requirements. The first specifies the remedial measures that permit continued operation of the facility which is not further restricted by the time limits of the ACTION requirements. In this case, conformance to the ACTION requirements provides an acceptable level of safety for unlimited continued operation as long as the ACTION requirements continue to be met. The second type of ACTION requirement specifies a time limit in which conformance to the conditions of the Limiting Condition for Operation must be met. This time limit is the allowable outage time to restore an inoperable system or component to OPERABLE status or for restoring parameters within specified limits. If these actions are not completed within the allowable outage time limits, a shutdown is required to place the facility in a MODE or condition in which the specification no longer applies. it is not intended that the shutdown ACTION requirements be used as an operational convenience which permits (routine) voluntary removal of a system(s) or component(s) from service in lieu of other alternatives that would not result in redundant systems or components being inoperable.

The specified time limits of the ACTION requirements are applicable from the point in time it is identified that a Limiting Condition for Operation is not met; unless otherwise specified. The time limits of the ACTION requirements are also applicable when a system or component is removed from service for surveillance testing or investigation of operational problems. Individual specifications may include a specified time limit for the completion of a Surveillance Requirement when equipment is removed from service. In this case, the allowable outage time SOUTH TEXAS - UNITS 1 & 2 B 3/4 0-1 Unit 1 - Amendment No. 4

3.4.0 APPLICABILITY BASES (Continued) limits of the ACTION requirements are applicable when this limit expires if the surveillance has not been completed. When a shutdown is required to comply with ACTION requirements, the plant may have entered a MODE in which a new specification becomes applicable. In this case, the time limits of the ACTION requirements would apply from the point in time that the new specification becomes applicable if the requirements of the Limiting Condition for Operation are not met.

Specification 3.0.2 establishes that noncompliance with a specification exists when the requirements of the Limiting Condition for Operation are not met and the associated ACTION requirements have not been implemented within the specified time interval. The purpose of this specification is to clarify that (1) implementation of the ACTION requirements within the specified time interval constitutes compliance with a specification and (2) completion of the remedial measures of the ACTION requirements is not required when compliance with a Limiting Condition for Operation is restored within the time interval specified in the associated ACTION requirements.

Specification 3.0.3 establishes the shutdown ACTION requirements that must be implemented when a Limiting Condition for Operation is not met and the condition is not specifically addressed by the associated ACTION requirements. The purpose of this specification is to delineate the time limits for placing the unit in a safe shutdown MODE when plant operation cannot be maintained within the limits for safe operation defined by the Limiting Conditions for Operation and its ACTION requirements. It is not intended to be used as an operational convenience which permits (routine) voluntary removal of redundant systems or components from service in lieu of other alternatives that would not result in redundant systems or components being inoperable. One hour is allowed to prepare for an orderly shutdown before initiating a change in plant operation. This time permits the operator to coordinate the reduction in electrical generation with the load dispatcher to ensure the stability and availability of the electrical grid. The time limits specified to reach enter lower MODES of operation permit the shutdown to proceed in a controlled and orderly manner that is well within the specified maximum cooldown rate and within the cooldown capabilities of the facility assuming only the minimum required equipment is OPERABLE. This reduces thermal stresses on components of the primary coolant system and the potential for a plant upset that could challenge safety systems under conditions for which this specification applies.

If remedial measures permitting limited continued operation of the facility under the provisions of the ACTION requirements are completed, the shutdown may be terminated. The time limits of the ACTION requirements are applicable from the point in time there was a failure to meet a Limiting Condition for Operation. Therefore, the shutdown may be terminated if the ACTION requirements have been met or, the Limiting Condition for Operation is no longer applicable, or the time limits of the ACTION requirements have not expired, thus providing an allowance for the completion of the required SOUTH TEXAS - UNITS 1 & 2 B 3/4 0-2

3.4.0 APPLICABILITY BASES (Continued)

The time limits of Specification 3.0.3 allow 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> for the plant to be in the COLD SHUTDOWN MODE when a shutdown is required during the POWER MODE of operation. If the plant is in a lower MODE of operation when a shutdown is required, the time limit for reaching entering the next lower MODE of operation applies. However, if a lower MODE of operation is reached entered in less time than allowed, the total allowable time to reach enter COLD SHUTDOWN, or other applicable MODE, is not reduced. For example, if HOT STANDBY is reached entered in 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, the time allowed to reach enter HOT SHUTDOWN is the next 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br /> because the total time to reach enter HOT SHUTDOWN is not reduced from the allowable limit of 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />. Therefore, if remedial measures are completed that would permit a return to POWER operation, a penalty is not incurred by having to reach enter a lower MODE of operation in less than the total time allowed.

The same principle applies with regard to the allowable outage time limits of the ACTION requirements, if compliance with the ACTION requirements for one specification results in entry into a MODE or condition of operation for another specification in which the requirements of the Limiting Condition for Operation are not met. If the new specification becomes applicable in less time than specified, the difference may be added to the allowable outage time limits of the second specification. However, the allowable outage time limits of ACTION requirements for a higher MODE of operation may not be used to extend the allowable outage time that is applicable when a Limiting Condition for Operation is not met in a lower MODE of operation.

The shutdown requirements of Specification 3.0.3 do not apply in MODES 5 and 6, because the ACTION requirements of individual specifications define the remedial measures to be taken.

Specification 3.0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability when an LCO is not met. It allows placing the unit in a MODE or other specified condition stated in that Applicability (e.g., the Applicability desired to be entered) when unit conditions are such that the requirements of the LCO would not be met, in accordance with either Specification 3.0.4.a, 3.0.4.b, or 3.0.4.c.

Specification 3.0.4.a allows entry into a MODE or other specified condition in the Applicability with the LCO not met when the associated ACTIONS to be entered permit continued operation following entry into in the MODE or other specified condition in the Applicability will permit continued operation within the MODE or other specified condition for an unlimited period of time.

Compliance with ACTIONS that permit continued operation of the unit for an unlimited period of time in a MODE or other specified condition provides an acceptable level of safety for continued operation. This is without regard to the status of the unit before or after the MODE change.

Insert A Therefore, in such cases, entry into a MODE or other specified condition in the Applicability may be made in accordance with the provisions of the ACTIONS and the ACTIONS followed after entry into the Applicability.

Specification 3.0.4.b allows entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate.

SOUTH TEXAS - UNITS 1 & 2 B 3/4 0-3 Unit 1 - Amendment No. 05-1034-3 Unit 2 - Amendment No. 05-1034-3

Insert A For example, Technical Specification 3.0.4.a may be used when the ACTION to be entered states that an inoperable instrument channel must be placed in the trip condition within the allowed outage time. Transition into a MODE or other specified condition in the Applicability may be made in accordance with Technical Specification 3.0.4 and the channel is subsequently placed in the tripped condition within the allowed outage time, which begins when the Applicability is entered. If the instrument channel cannot be placed in the tripped condition and ACTIONS allow the OPERABLE train to be placed in operation, use of Technical Specification 3.0.4.a is acceptable because the subsequent ACTIONS to be entered following entry into the MODE include ACTIONS (place the OPERABLE train in operation) that permit safe plant operation for an unlimited period of time in the MODE or other specified condition to be entered.

3/4.0 APPLICABILITY BASES (Continued)

For this reason, Specification 3.0.4.c is typically applied to Specifications which describe values and parameters and may be applied to other Specifications based on NRC plant-specific approval.

The provisions of Specification 3.0.4 should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability.

The provisions of Specification 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS. In addition, the provisions of Specification 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that result from any unit shutdown. In this context, a unit shutdown is defined as a change in MODE or other specified condition in the Applicability associated with transitioning from MODE 1 to MODE 2, MODE 2 to MODE 3, MODE 3 to MODE 4, and MODE 4 to MODE 5.

Upon entry into a MODE or other specified condition in the Applicability with the LCO not met, Specifications 3.0.1 and 3.0.2 require entry into the applicable LCO and ACTIONS until the Condition is resolved, until the LCO is met, or until the unit is not within the Applicability of the Technical Specification.

Surveillances do not have to be performed on the associated inoperable equipment (or on variables outside the specified limits), as permitted by Specification 4.0.1. Therefore, utilizing Specification 3.0.4 is not a violation of Specification 4.0.1 or 4.0.4 for any Surveillances that have not been performed on inoperable equipment. However, Surveillance Requirements must be met to ensure OPERABILITY prior to declaring the associated equipment OPERABLE (or variable within limits) and restoring compliance with the affected LCO.

Specification 3.0.5 delineates the applicability of each specification to Unit 1 and Unit 2 operation.

Specification 3.0.6 establishes the allowance for restoring equipment to service under administrative controls when it has been removed from service or declared inoperable to comply with ACTIONS.

The sole purpose of this Specification is to provide an exception to LCO 3.0.2 (e.g., to not comply with the applicable Required Action(s)) to allow the performance of surveillance requirements to demonstrate:

a. The OPERABILITY of the equipment being returned to service; or

b. The OPERABILITY of other equipment.

The administrative controls ensure the time the equipment is returned to service in conflict with the requirements of the ACTIONS is limited to the time absolutely necessary to perform the allowed surveillance requirements. This Specification does not provide time to perform any other preventive or corrective maintenance. Technical Specification 3.0.6 should not be used in lieu of other practicable alternatives that comply with ACTIONS and that do not require changing the MODE or other specified conditions in the Applicability in order to demonstrate equipment is OPERABLE. Technical Specification 3.0.6 is not intended to be used repeatedly.

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An example of demonstrating equipment is OPERABLE with the ACTIONS not met is opening a manual valve that was closed to comply with ACTIONS to isolate a flowpath with excessive Reactor Coolant System (RCS) Pressure Isolation Valve (PIV) leakage in order to perform testing to demonstrate that RCS PIV leakage is now within limit.

Examples of demonstrating equipment OPERABILITY include instances in which it is necessary to take an inoperable channel or trip system out of a tripped condition that was directed by an ACTION, if there is no ACTIONS Note for this purpose. An example of verifying OPERABILITY of equipment removed from service is taking a tripped channel out of the tripped condition to permit the logic to function and indicate the appropriate response during performance of required testing on the inoperable channel.

An example of demonstrating the OPERABILITY of the equipment being returned to service is reopening a containment isolation valve that has been closed to comply with Required Actions and must be reopened to perform the surveillance requirements.

SOUTH TEXAS - UNITS 1 & 2 B 3/4 0-5a Unit 1 - Amendment No. 05-1034-3 Unit 2 - Amendment No. 05-1034-3

3.4.0 APPLICABILITY BASES (Continued)

An example Examples of demonstrating the OPERABILITY of other equipment is are taking an inoperable channel or trip system out of the tripped condition 1) to prevent the trip function from occurring during the performance of a surveillance requirement on another channel in the other trip system. A similar example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition, or 2) to permit the logic to function and indicate the appropriate response during the performance of a surveillance requirement on another channel in the same trip system.

The administrative controls in Technical Specification 3.0.6 apply in all cases to systems or components in Section 3 of the Technical Specifications, as long as the testing could not be conducted while complying with the ACTIONS. This includes the realignment or repositioning of redundant or alternate equipment or trains previously manipulated to comply with ACTIONS, as well as equipment removed from service or declared inoperable to comply with ACTIONS.

Specifications 4.0.1 through 4.0.6 establish the general requirements applicable to Surveillance Requirements. These requirements are based on the Surveillance Requirements stated in the Code of Federal Regulations, 10 CFR 50.36 (c) (3):

"Surveillance requirements are requirements relating to test, calibration, or inspection to ensure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions of operation will be met."

Specification 4.0.1 establishes the requirement that Surveillances must be performed during the OPERATIONAL MODES or other conditions for which the requirements of the Limiting Conditions for Operation apply unless otherwise stated in an individual Surveillance Requirement. The purpose of this Specification is to ensure that Surveillances are performed to verify the operational status of systems and components and that parameters are within specified limits to ensure safe operation of the facility when the plant is in a MODE or other specified condition for which the associated Limiting Conditions for Operation are applicable.

Systems and components are assumed to be OPERABLE, when the associated Surveillance Requirements (SRs) have been met. Nothing in this Specification, however, is to be construed as implying that systems or components are OPERABLE when:

a. The systems or components are known to be inoperable, although still meeting the SRs; or

b. The requirements of the Surveillance(s) are known not to be met between required Surveillance performances.

Surveillance Requirements do not have to be performed when the facility is in an OPERATIONAL MODE for which the requirements of the associated Limiting Condition for Operation do not apply unless otherwise specified. The Surveillance Requirements associated with a Special Test Exception are only applicable when the Special Test Exception is used as an allowable exception to the requirements of a specification.

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Surveillance Requirements do not have to be performed on inoperable equipment because the ACTION requirements define the remedial measures that apply. However, the Surveillance Requirements have to be met to demonstrate that inoperable equipment has been restored to OPERABLE status.

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3.4.0 APPLICABILITY BASES (Continued)

Specification 4.0.2 establishes the limit for which the specified time interval for Surveillance Requirements may be extended. It permits an allowable extension of the normal surveillance interval to facilitate surveillance scheduling and consideration of plant operating conditions that may not be suitable for conducting the surveillance; e.g., transient conditions or other ongoing surveillance or maintenance activities. It also provides flexibility to accommodate the length of a fuel cycle for surveillances performed at each refueling outage and are specified with a 18-month surveillance interval. It is not intended that this provision be used repeatedly as a convenience to extend surveillance intervals beyond that specified for surveillances not performed during refueling outages. The limitation of Specification 4.0.2 is based on engineering judgment and the recognition that the most probable result of any particular surveillance being performed is verification of conformance with the Surveillance Requirements. This provision is sufficient to ensure that reliability ensured through surveillance activities is not significantly degraded beyond that obtained from the specified surveillance interval.

Specification 4.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limits when a Surveillance has not been completed performed within the specified surveillance interval. A delay period of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified surveillance interval, whichever is greater, applies from the point in time that it is discovered that the Surveillance has not been performed in accordance with Specification 4.0.2, and not at the time that the specified surveillance interval was not met.

This delay period provides adequate time to complete perform Surveillances that have been missed. This delay period permits the completion performance of a Surveillance before complying with Action requirements or other remedial measures that might preclude completion performance of the Surveillance.

The basis for this delay period includes consideration of unit conditions, adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements.

A missed surveillance can occur in a number of ways. Surveillances may be overlooked as a result of an error in surveillance tracking or a failure to follow procedure. On the other hand, a procedural inadequacy may be discovered that calls into question the results of the last performance of the surveillance. While the surveillance may have been performed within the specified frequency, the procedural inadequacy caused the surveillance to be inadequate or incomplete. For example, past reviews of complex systems, such as the reactor protection system or the engineered safety features actuation system, have identified portions of circuits that have not been fully tested.

Similarly, response time test procedure reviews have identified components that have not been properly response time tested. These situations would result in the associated surveillance tests to be considered "missed." (TSTF-IG-06-01, Implementation Guidance for TSTF-358, Revision 6, "Missed Surveillance Requirements").

When a Surveillance with a surveillance interval based not on time intervals, but upon specified unit conditions, operating situations, or requirements of regulations (e.g., prior to entering MODE 1 after each fuel loading, or in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions, etc.) is discovered to not have been performed when specified, Specification 4.0.3 allows for the full delay period of up to the specified surveillance interval to perform the Surveillance.

However, since there is not a time interval specified, the missed Surveillance should be performed at the first reasonable opportunity.

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3.4.0 APPLICABILITY BASES (Continued)

Insert B Specification 4.0.3 provides a time limit for, and allowances for the performance of, Surveillances that become applicable as a consequence of MODE changes imposed by Required Actions.

Failure to comply with specified surveillance interval for the Specification is expected to be an infrequent occurrence. Use of the delay period established by Surveillance Requirement 4.0.3 is a flexibility which is not intended to be used as an operational convenience repeatedly to extend Surveillance intervals. While up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the limit of the specified surveillance interval is provided to perform the missed Surveillance, it is expected that the missed Surveillance will be performed at the first reasonable opportunity. The determination of the first reasonable opportunity should include consideration of the impact on plant risk (from delaying the Surveillance as well as any plant configuration changes required or shutting the plant down to perform the Surveillance) and impact on any analysis assumptions, in addition to unit conditions, planning, availability of personnel, and the time required to perform the Surveillance. This risk impact should be managed through the program in place to implement 10 CFR 50.65(a)(4) and its implementation guidance, NRC Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." This Regulatory Guide addresses consideration of temporary and aggregate risk impacts, determination of risk management action thresholds, and risk management action up to and including plant shutdown.

The missed Surveillance should be treated as an emergent condition as discussed in the Regulatory Guide. The risk evaluation may use quantitative, qualitative, or blended methods. The degree of depth and rigor of the evaluation should be commensurate with the importance of the component. Missed Surveillances for important components should be analyzed quantitatively. If the results of the risk evaluation determine the risk increase is significant, this evaluation should be used to determine the safest course of action. All missed Surveillances will be placed in the licensee's Corrective Action Program.

If a Surveillance is not completed within the allowed delay period, then the equipment is considered inoperable or the variable is considered outside the specified limits and the entry into the ACTION requirements for the applicable Limiting Conditions for Operation begins immediately upon expiration of the delay period. If a Surveillance is failed within the delay period, then the equipment is inoperable, or the variable is outside the specified limits and entry into the ACTION requirements for the applicable Limiting Conditions for Operation begins immediately upon the failure of the Surveillance. Completion of the Surveillance within the delay period allowed by this Specification, or within the Allowed Outage Time of the applicable ACTIONS, restores compliance with Specification 4.0.1.

Specification 4.0.4 establishes the requirement that all applicable Surveillance Requirements (SRs) must be met before entry into a MODE or other specified condition in the Applicability.

This Specification ensures that system and component OPERABILITY requirements and variable limits are met before entry into MODES or other specified conditions in the Applicability for which these systems and components ensure safe operation of the unit. The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability.

A provision is included to allow entry into a MODE or other specified condition in the Applicability when an LCO is not met due to Surveillance not being met in accordance with Specification 3.0.4.

However, in certain circumstances, failing to meet an SR will not result in Specification 4.0.4 restricting a MODE change or other specified condition change. When a system, subsystem, SOUTH TEXAS - UNITS 1 & 2 B 3/4 0-8 Unit 1 - Amendment No. 11-11813-7 Unit 2 - Amendment No. 11-11813-7

Insert B Technical Specification 4.0.3 is only applicable if there is a reasonable expectation the associated equipment is OPERABLE or that variables are within limits, and it is expected that the Surveillance will be met when performed. Many factors should be considered, such as the period of time since the Surveillance was last performed, or whether the Surveillance, or a portion thereof, has ever been performed, and any other indications, tests, or activities that might support the expectation that the Surveillance will be met when performed. An example of the use of Technical Specification 4.0.3 would be a relay contact that was not tested as required in accordance with a particular Surveillance Requirement, but previous successful performances of the Surveillance Requirement included the relay contact; the adjacent, physically connected relay contacts were tested during the Surveillance Requirement performance; the subject relay contact has been tested by another Surveillance Requirement; or historical operation of the subject relay contact has been successful. It is not sufficient to infer the behavior of the associated equipment from the performance of similar equipment. The rigor of determining whether there is a reasonable expectation a Surveillance will be met when performed should increase based on the length of time since the last performance of the Surveillance. If the Surveillance has been performed recently, a review of the Surveillance history and equipment performance may be sufficient to support a reasonable expectation that the Surveillance will be met when performed. For Surveillances that have not been performed for a long period or that have never been performed, a rigorous evaluation based on objective evidence should provide a high degree of confidence that the equipment is OPERABLE. The evaluation should be documented in sufficient detail to allow a knowledgeable individual to understand the basis for the determination.