View source for L-2023-011, Response to Requests for Additional Information (Rais) Regarding License Amendment Request 297, Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, Provide Risk Informed

{{Adams
| number = ML23052A112
| issue date = 02/21/2023
| title = Response to Requests for Additional Information (Rais) Regarding License Amendment Request 297, Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, Provide Risk Informed
| author name = Strand D
| author affiliation = NextEra Energy Point Beach, LLC
| addressee name = 
| addressee affiliation = NRC/NRR, NRC/Document Control Desk
| docket = 05000266, 05000301
| license number = 
| contact person = 
| case reference number = L-2023-011
| document type = Letter type:L, Response to Request for Additional Information (RAI)
| page count = 1
| project = 
| stage = Response to RAI
}}

=Text=
{{#Wiki_filter:NEXTera                                                                                              L-2023-011 ENERGY ~                                                                                           10 CFR 50.90
~                   BEACH February 21, 2023 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington DC 20555-0001 RE:      Point Beach Nuclear Plant, Units 1 and 2 Docket Nos. 50-266 and 50-301 Renewed Facility Operating Licenses DPR-24 and DPR-27 Response to Requests for Additional Information (RAls) Regarding License Amendment Request 297, Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, "Provide Risk Informed Extended Completion Times - RITSTF Initiative 4b"

==References:==
: 1.       NextEra Energy letter NRC 2022-0007, Point Beach Nuclear Plant, Units 1 and 2, License Amendment Request 297, Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, "Provide Risk Informed Extended Completion Times - RITSTF Initiative 4b", May 20, 2022 (ADAMS Accession No. ML22192A152)
: 2.        NRC letter to Florida Power & Light Company, Point Beach Nuclear Plant, Units 1 and 2 -
Regulatory Audit in Support of Review of the Application to Adopt Risk-Informed Extended Completion Times - RITSTF Initiative 4b, August 11, 2022 (ADAMS Accession No. Ml22216A203)
: 3.        NRC electronic memorandum dated December 20, 2022, Final RAI - Point Beach 1 & 2 - License Amendment Request Regarding TSTF-505 (ADAMS Accession No. ML22354A161)
: 4.        NextEra Energy letter NRC 2022-0007, Point Beach Nuclear Plant, Units 1 and 2, Response to Requests for Additional Information (RAls) Regarding License Amendment Request 297, Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, "Provide Risk Informed Extended Completion Times - RITSTF Initiative 4b", January 11 , 2023 (ADAMS Accession No. ML23011A280)
: 5.        NRC electronic memorandum dated January 31, 2022, Final RAI (Volume 2) - Point Beach 1 & 2 -
License Amendment Request Regarding TSTS-505 (EPID No. L-2022-LLA-0074)
In Reference 1, NextEra Energy Point Beach, LLC (NextEra) submitted license amendment request (LAR) 297 for Point Beach Nuclear Plant Units 1 and 2 (Point Beach) , respectively. The proposed license amendments would modify the Point Beach Technical Specifications (TS) to permit the use of Risk Informed Completion Times in accordance with TSTF-505, Revision 2, "Provide Risk-Informed Extend Completion Times - RITSTF Initiative 4b, (ADAMS Accession No. ML18183A493).
In Reference 2, the NRC notified NextEra of its intent to conduct a regulatory audit to gain understanding, verify information, or identify information requiring docketing to support a licensing or regulatory decision.
In Reference 4, NextEra responded to the NRC's request for additional information provided in Reference
: 3. In Reference 5, the NRC requested additional information deemed necessary to complete its review.
The enclosure to this letter provides NextEra's response to the request for additional information (RAI) of Reference 5. Attachment 1 to the enclosure provides a revised Table E1-1, List of Revised Required Actions to Corresponding PRA Functions, which aligns with the RAI responses in this letter and in

Point Beach Nuclear Plant, Units 1 and 2                                                       L-2023-011 Docket Nos. 50-266 and 50-301                                                                  Page 2 of 2 Reference 4. Attachment 2 provides a revised Table E1-3(1), Information to Support RPS Instrumentation Redundancy and Diversity. Attachment 3 provides a revised Table E1-3(2), Information to Support ESFAS Instrumentation Redundancy and Diversity. The revised Tables E1-3(1) and E1-3(2) are provided in response to information request item #14 of Reference 2 and were also made available for NRC viewing on the NextEra Online Reference Portal. The revised Tables E1-1, E1-3(1) and E1-3(2) supersede and replace the corresponding Tables E1-1, E1-3(1) and E1-3(2) of Reference 1.
The supplements included in this RAI response provide additional information that clarifies the application, do not expand the scope of the application as originally noticed, and should not change the NRC staffs original proposed no significant hazards consideration determination as published in the Federal Register.
This letter contains no new regulatory commitments.
Should you have any questions regarding this submission, please contact Mr. Kenneth Mack, Fleet Licensing Manager, at 561-904-3635.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on the    2) day of February 2023.
Sincerely,
~L,,- S~
ianne Strand General Manager, Regulatory Affairs cc:      USNRC Regional Administrator, Region Ill Project Manager, USNRC, Point Beach Nuclear Plant Resident Inspector, USNRC, Point Beach Nuclear Plant Public Service Commission of Wisconsin Attachments (3)
: 1.       Table E1-1, List of Revised Required Actions to Corresponding PRA Functions (revised)
: 2.       Table E1-3(1), Information to Support RPS Instrumentation Redundancy and Diversity (revised)
: 3.       Table E1-3(2), Information to Support ESFAS Instrumentation Redundancy and Diversity (revised)

Point Beach Nuclear Plant, Units 1 and 2                                                         L-2023-011 Docket Nos. 50-266 and 50-301                                                                      Enclosure Page 1 of 13 Response to Request for Additional Information (RAI)
License Amendment Request 297, Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, "Provide Risk Informed Extended Completion Times - RITSTF Initiative 4b" Containment and Plant Systems Branch (SCPB) Audit Questions SCPB-RAl-1 (Audit Question 25)
In Enclosure 1 of the LAR, Table E1-1 indicates for TS LCO Action 3.6.2.C that there are two emergency airlocks. Specifically, it lists one equipment hatch, one personnel airlock, and two emergency airlocks.
FSAR, Chapter 5 indicates 2 personnel airlocks (one of which is emergency). FSAR Figures 5.1-4 and 5.1-5 are unreadable in the FSAR available at the NRC.
a)   Provide clear copies of the figures made available in the audit.
b)   Discuss why the LAR differs from the FSAR and confirm and correct.
NextEra Response:
a) A controlled, readable copy of UFSAR Figure 5.1-5, "Containment Structure - Equipment Hatch" was made available for NRC viewing on the NextEra Online Reference Portal. Regarding UFSAR Figure 5.1-4, "Containment Structure - Personnel Lock", NextEra identified that the controlled drawing needed to be redrawn. The discovery was entered into the Point Beach corrective action program (CAP). UFSAR Figure 5.1-4 details the containment personnel lock annulus, bulkhead panels and equalizing valves. As an alternative, Point Beach controlled drawings D-2 JOB 18006_2 and D-3 JOB 18006_2, which combined provide similar detail of the containment personnel air locks, were made available for NRC viewing on the NextEra Online Reference Portal.
b) Table E1-1 of LAR Enclosure 1 required correction for TS LCO Action 3.6.2, Condition C. As specified in Point Beach FSAR Chapter 5.1.2.6, Penetrations, the Point Beach Unit 1 and 2 containments each include one equipment hatch and two personnel airlocks, one of which is for convenience access. The revised Table E1-1 is included as Attachment 1 to this RAI response.
The revised Table E1-1 supersedes and replaces the corresponding Table E1-1 of Reference 1 to this RAI response.
SCPB-RAl-2 (Audit Question 26)
In Enclosure 1 of the LAR, Section 3, the licensee provides justification for TS LCO 3.6.2, "Containment Air Locks." However, it does not address the following issue: TSTF-505 Revision 2, for WOG LCO 3.6.2.C.2 reads "C.2 Verify a door is closed in the affected air lock." whereas the LAR's proposed Point Beach LCO 3.6.2.C.2 reads "C.2 Verify a bulkhead door and associated equalizing valve are closed in the affected air lock."
Provide additional information to explain: (1) how the equalizing valves function in relation to the bulkhead doors; and (2) why the difference in wording exists between the LCO of TSTF-505, Revision 2, and the LCO proposed in the LAR.
NextEra Response:
The personnel air lock equalizing valves connect the personnel lock with the interior and exterior of the containment vessel. The safety function is to isolate containment from the environment during design basis accident conditions. The equalizing valves are not "valves" in the traditional sense but consist of

Point Beach Nuclear Plant, Units 1 and 2                                                             L-2023-011 Docket Nos. 50-266 and 50-301                                                                          Enclosure Page 2of13 a disc plate that seals against a base plate with a dual 0-ring seal. The disk slides along extension bars by a lever and cam linkage working through a pivot plate attached to the ends of the extension bars.
The lever is connected to the existing linkage arm driven by the door operating mechanism. Test ports are provided in the adapter flange for leak testing the 0-ring seals on one face and the flange gasket on the other.
The difference in wording between Point Beach LCO 3.6.2, and LCO 3.6.2, ACTION C.2, of TSTF-505, Revision 2, is one of nomenclature since the "bulkhead" is the actual air lock door. However, the term "bulkhead" in Point Beach LCO 3.6.2, ACTION C.2, serves to underscore that the integrity of each airlock pressure boundary relies on the closure of both the bulkhead door and the associated equalizing valve. Of note is that Bases section 3.6.2 of NUREG 1431, Revision 4 (ADAMS Accession No. ML 121 OOA228), does not discuss air lock equalizing valves as part of the containment air lock pressure boundary and thereby it is not expected that the distinction would be addressed in LCO 3.6.2 of NU REG 1431, Revision 4 (ADAMS Accession No. ML12100A222), upon which LCO 3.6.2, ACTION C.2, of TSTF-505, Revision 2, is based. The plant-specific variation is acceptable since, consistent with LCO 3.6.2, ACTION C.2, of TSTF-505, Revision 2, Point Beach LCO 3.6.2, ACTION C.2, assures the integrity of at least one air lock pressure boundary when in Condition C, "One or more containment air locks inoperable for reasons other than Conditions A or B".
The difference in wording between Point Beach LCO 3.6.2, and LCO 3.6.2, ACTION C.2, of TSTF-505, Revision 2, is a plant-specific variation that was inadvertently omitted from and is in addition to the evaluations provided in Attachment 5, Evaluation of Plant-Specific Variations, of Reference 1.
Electrical Engineering Branch (EEEB) Audit Questions In Table E1-1 of Enclosure 1 of the LAR, the licensee lists each TS Required Action Condition proposed for the Point Beach RICT Program and documents information regarding the associated SSCs credited in plant safety analyses, the analogous PRA functions, and the results of the comparison. Questions EEEB-RAl-1 thru EEEBRAl-7 pertain to the information presented in Table E1-1.
EEEB-RAl-1 (Audit Question 27)
For each LCO proposed under TS 3.8, "Electrical Power Systems," clarify if Table E1-1 is written on a per unit basis for "SSC Function(s)" (Column 3), and "PRA Success Criteria" (Column 6), given that sharing of electrical systems is found in UFSAR.
NextEra Response:
Table E1-1 for TS 3.8, "Electrical Power Systems, required revision to clarify that Column 3, "SSC Function(s)", Column 5, "Design Success Criteria" and Column 6, "PRA Success Criteria" apply on a per unit basis. Specifically, for TS 3.8, Column 3 was revised to identify the SSCs associated with the LCO Condition on a per unit basis. Similarly, for TS 3.8, Columns 5 and 6 were revised to specify the minimum SSCs required to fulfill the safety function on a per unit basis. The revised Table E1-1 is included as Attachment 1 to this RAI response. The revised Table E1-1 supersedes and replaces the corresponding Table E1-1 of Reference 1.
EEEB-RAl-2 (Audit Question 28)
The licensee stated that the "SSC Function(s)" (Column 3) for TS 3.8.1, Conditions A, B, C, D, and Fis "Power onsite safeguards buses from offsite and onsite transmission networks to support normal, safe shutdown and accident mitigation conditions." Clarify why Column 3 is inconsistent with UFSAR by not listing four Class 1E 4.16 kV electrical buses since there are two of them per unit if this table addresses both Units 1 and 2.

Point Beach Nuclear Plant, Units 1 and 2                                                        L-2023-011 Docket Nos. 50-266 and 50-301                                                                     Enclosure Page 3of13 NextEra Response:
Table E1-1 for TS 3.8, "Electrical Power Systems", required revision to clarify that Column 3, "SSC Function(s)" applies on a per unit basis. The revision resolves the inconsistency with the UFSAR regarding the number of Class 1E 4.16 kV electrical buses for one versus both Point Beach nuclear units. The revision to Column 3 for TS 3.8.1, Conditions A, B, C, D, and F are listed below and were incorporated into the revised Table E-1.1, which is included as Attachment 1 to this RAI response. The revised Table E1-1 supersedes and replaces the corresponding Table E1-1 of Reference 1.
Required Action Condition           SSC Description          Function(s)
TS 3.8.1 Power Condition A Class 1E Associated unit 4.16 kV 345/13.8 kV (X03) safeguards transformer inoperable.
buses from OR offsite Gas turbine not in operation transmission when utilizing opposite unit's networks 345/13.8 kV (X03) transformer Power Class 1E TS 3.8.1 4.16 kV Condition 8 safeguards Associated unit's 13.8/4.16 kV buses from (X04) transformer offsite inoperable transmission networks Power Class 1E TS 3.8.1 4.16 kV Condition C safeguards Associated unit's required buses from offsite power source to buses offsite A05 and A06 inoperable.
transmission OR networks and Required offsite power source on site to buses 1A05 and 2A06 emergency inoperable power sources Power Class 1E 4.16 kV TS 3.8.1 safeguards Condition D buses from One or more required offsite offsite power source(s) to one transmission or more required Class 1E networks and 4.16 kV bus(es) on site inoperable emergency power sources

Point Beach Nuclear Plant, Units 1 and 2                                                           L-2023-011 Docket Nos. 50-266 and 50-301                                                                        Enclosure Page 4of13 Power Class 1E TS 3.8.1 4.16 kV Condition F safeguards One or more required buses from offsite power source to one or offsite more Class 1E 4.16 kV transmission safeguards bus(es) inoperable networks and AND Standby emergency on site power inoperable to redundant emergency equipment power sources EEEB-RAl-3 (Audit Question 29, rev 1) -TS LCO 3.8.1, Conditions A and B Explain why Columns 2 and 3 are inconsistent with LCO for SSCs specifically covered by the LCO (not addressing high voltage (HV) station auxiliary transformers X03s or low voltage (LV) station auxiliary transformers X04s) in associated unit for respective LCO condition.
NextEra Response:
Table E1-1 for TS 3.8, "Electrical Power Systems", required revision to specify the SSCs covered by TS 3.8.1, Conditions A and B. The revision reflects the availability of the offsite power sources to power 4.16 kV Class 1E safeguards busses, A05 and A06. Specifically, the changes below were incorporated into Table E.1-1 for consistency with TS 3.8.1, Conditions A and B. The revised Table E1-1 is included as Attachment 1 to this RAI response. The revised Table E1-1 supersedes and replaces the corresponding Table E1-1 of Reference 1.
Required Action SSC Condition                   Applicable SSCs Function(s)
Description TS 3.8.1 Condition A             Two circuits between the         Power Associated unit          offsite transmission network    Class 1E 345/13.8 kV (X03)          via the 345/13.8 kV (X03)        4.16 kV transformer inoperable.          transformers and the        safeguards OR                      13.8/4.16 kV (X04)       buses from Gas turbine not in operation        transformers, and the         offsite when utilizing opposite unit's   associated unit's 4.16 kV    transmission 345/13.8 kV (X03)         Class 1E safeguards buses)      networks transformer.
Two circuits between the         Power offsite transmission network    Class 1E TS 3.8.1 via the 345/13.8 kV (X03)        4.16 kV Condition B transformers and the        safeguards Associated unit's 13.8/4.16 13.8/4.16 kV (X04)       buses from kV (X04) transformer transformers, and the         offsite inoperable associated unit's 4.16 kV    transmission Class 1E safeguards buses       networks EEEB-RAl-4 (Audit Question 30, rev 1) -TS LCO 3.8.1, Conditions A and B Explain why Column 6 is inconsistent with LCO by not listing minimum SSCs of those listed in Column 3 (e.g., either opposite unit's HV (X03) or LV station auxiliary transformer (X04), respectively, for Condition A or B) to achieve safe shut down for a design basis accident (OBA) in opposite unit.

Point Beach Nuclear Plant, Units 1 and 2                                                         L-2023-011 Docket Nos. 50-266 and 50-301                                                                      Enclosure Page 5of13 NextEra Response:
Table E1-1 for TS 3.8, "Electrical Power Systems", Column 5, "Design Success Criteria" and Column 6, "PRA Success Criteria" required revision to specify the minimum SSCs required to fulfill the safety function for TS 3.8.1, Conditions A and B. The revised success criteria require one circuit between the offsite transmission network and an affected unit's safeguard bus via automatic alignment with the opposite unit's X03 transformer for the condition of an inoperable X03 transformer and manual alignment with the opposite unit's X04 transformer for the condition of an inoperable X04 transformer.
Specifically, the changes below were incorporated into Columns 5 and 6 of Table E-1.1 for TS 3.8.1, Conditions A and B. The revised Table E1-1 is included as Attachment 1 to this RAI response. The revised Table E1-1 supersedes and replaces the corresponding Table E1-1 of Reference 1.
Required Action Condition          Design Success     PRASuccess Description                   Criteria          Criteria TS 3.8.1                   One circuit Condition A              between the offsite Associated unit          transmission network 345/13.8 kV (X03)           via a 345/13.8 kV transformer inoperable.        (X03) transformer Same OR                  and a 13.8/4.16kV Gas turbine not in operation      (X04) transformer, when utilizing opposite unit's   and an associated 345/13.8 kV (X03)          unit's 4.16 kV Class transformer.             1E safeguards bus One circuit between the offsite transmission network TS 3.8.1 via a 345/13.8 kV Condition B (X03) transformer Associated unit's 13.8/4.16                             Same and a 13.8/4.16kV kV (X04) transformer (X04) transformer, inoperable and an associated unit's 4.16 kV Class 1E safeguards bus EEEB-RAl-5 (Audit Question 31, rev 1)-TS LCO 3.8.1, Conditions C and D Explain why Columns 2 and 3 are inconsistent with respective LCO in that (a) HV station auxiliary transformers X03s supplying buses A05 and A06 are not shown for TS LCO 3.8.1, Condition C and (b) also for LCO 3.8.1, Condition D including EDGs based on TS Bases (page 473).
NextEra Response:
Table E1-1 for TS 3.8, "Electrical Power Systems", required revision to specify the SSCs covered by TS 3.8.1, Conditions C and D. The revision reflects the availability of the offsite power sources, including from the opposite unit, and the onsite emergency power sources to power 4.16 kV Class 1E safeguards busses, A05 and A06. Specifically, the changes below were incorporated into Table E.1-1 for consistency with TS 3.8.1, Conditions C and D. The revised Table E1-1 is included as Attachment 1 to this RAI response. The revised Table E1-1 supersedes and replaces the corresponding Table E1-1 of Reference 1.

Point Beach Nuclear Plant, Units 1 and 2                                                          L-2023-011 Docket Nos. 50-266 and 50-301                                                                       Enclosure Page 6of13 Required Action SSC Condition                 Applicable SSCs Function(s)
Description Two circuits between the offsite TS 3.8.1                                                 Power transmission network via the Condition C                                               Class 1E 345/13.8 kV (X03) transformers Associated unit's                                            4.16 kV and the 13.8/4.16kV (X04) required offsite power                                       safeguards transformers, and the associated source to buses A05                                          buses from unit's 4.16 kV Class 1E safeguards and A06 inoperable.                                             offsite buses OR                                               transmission AND Required offsite                                        networks and Two onsite emergency power power source to                                               on site sources capable of supplying the buses 1A05 and                                            emergency associated unit's 4.16 kV Class 1E 2A06 inoperable                                         power sources safeguards buses)
Two circuits between the offsite Power transmission network via the Class 1E TS 3.8.1         345/13.8 kV (X03) transformers 4.16 kV Condition D            and the 13.8/4.16kV (X04) safeguards One or more required    transformers, and the associated buses from offsite power     unit's 4.16 kV Class 1E safeguards offsite source(s) to one or                 buses transmission more required Class                   AND networks and 1E 4.16 kV bus( es)      Two onsite emergency power on site inoperable        sources capable of supplying the emergency associated unit's 4.16 kV Class 1E power sources safeguards buses EEEB-RAl-6 (Audit Question 32, rev 1) - TS LCO 3.8.1, Conditions C and D Explain why Column 6 is inconsistent by not listing minimum required SSCs for respective LCO (a) like one unit's HV station auxiliary transformer (X03) supplying a singular bus A05 or A06 for TS LCO 3.8.1, Condition C and one unit's HV station auxiliary transformer (X03), or one EDG supplying that unit's bus A05 or A06 for TS LCO 3.8.1, Condition D.
NextEra Response:
Table E1-1 for TS 3.8, "Electrical Power Systems", Column 5, "Design Success Criteria" and Column 6, "PRA Success Criteria" required revision to specify the minimum SSCs required to fulfill the safety function for TS 3.8.1, Conditions C and D. For the condition of the associated unit's offsite power source circuit inoperable, the revised success criteria require one circuit between the offsite transmission network and an associated unit's Class 1E 4.16 kV safeguards bus, A05 or A06, which can be satisfied by aligning the opposite unit's offsite power source circuit. For the condition of both offsite power source circuits unavailable, the revised success criteria require an onsite emergency power source capable of supplying an associated unit's Class 1E4.16 kV safeguards bus, A05 or A06.
Specifically, the changes below were incorporated into Columns 5 and 6 of Table E-1.1 for TS 3.8.1, Conditions C and D. The revised Table E1-1 is included as Attachment 1 to this RAI response. The revised Table E1-1 supersedes and replaces the corresponding Table E1-1 of Reference 1.

Point Beach Nuclear Plant, Units 1 and 2                                                           L-2023-011 Docket Nos. 50-266 and 50-301                                                                        Enclosure Page 7of13 Required Action Design Success         PRA Success Condition Criteria              Criteria Description One circuit between the offsite transmission network via a 345/13.8 kV TS 3.8.1          (X03) transformer Condition C          and a 13.8/4.16kV Associated unit's required    (X04) transformer, offsite power source to     and an associated buses A05 and A06       unit's 4.16 kV Class Same inoperable.         1E safeguards bus OR                       OR Required offsite power          One onsite source to buses 1A05 and      emergency power 2A06 inoperable         source capable of supplying an associated unit's 4.16 kV Class 1E safeguards bus One circuit between the offsite transmission network via a 345/13.8 kV (X03) transformer and a 13.8/4.16kV TS 3.8.1 (X04) transformer, Condition D and an associated One or more required unit's 4.16 kV Class offsite power source(s) to                                Same 1E safeguards bus one or more required OR Class 1E 4.16 kV bus( es)
One onsite inoperable emergency power source capable of supplying an associated unit's 4.16 kV Class 1E safeguards bus EEEB-RAl-7 (Audit Question 33, rev 1) -TS LCO 3.8.1, Condition F Explain why Column 6 is inconsistent with LCO by not listing minimum required SSCs one unit's HV station auxiliary transformer OR one EOG as supplying that unit's bus A05 or A06 as minimum SSCs for TS LCO 3.8.1, Condition F.
NextEra Response:
Table E1-1 for TS 3.8, "Electrical Power Systems", Column 5, "Design Success Criteria" and Column 6, "PRA Success Criteria" required revision to specify the minimum SSCs required to fulfill the safety function for TS 3.8.1, Condition F. For the condition of an inoperable offsite power source in conjunction with an inoperable onsite emergency power source, the revised success criteria require one circuit between the offsite transmission network and an associated unit's Class 1E 4.16 kV safeguards bus, A05 or A06, which can be satisfied by aligning the opposite unit's offsite power circuit. For the condition of both offsite power source circuits unavailable to the associated unit in conjunction with an inoperable onsite emergency power source, the revised success criteria require one onsite emergency power

Point Beach Nuclear Plant, Units 1 and 2                                                        L-2023-011 Docket Nos. 50-266 and 50-301                                                                     Enclosure Page 8of13 source capable of supplying an associated unit's Class 1E 4.16 kV safeguards bus (A05 or A06), which can be satisfied by aligning the opposite unit's onsite emergency power source associated with the affected safeguards bus. Specifically, the changes below were incorporated into Columns 5 and 6 of Table E-1.1 for TS 3.8.1, Condition F. The revised Table E1-1 is included as Attachment 1 to this RAI response. The revised Table E1-1 supersedes and replaces the corresponding Table E1-1 of Reference 1.
Required Action Design Success         PRA Success Condition Criteria             Criteria Description One circuit between the offsite transmission network via a 345/13.8 kV TS 3.8.1            (X03) transformer Condition F           and a 13.8/4.16kV One or more required       (X04) transformer, offsite power source to     and an associated one or more Class 1E       unit's 4.16 kV Class Same 4.16 kV safeguards        1E safeguards bus bus(es) inoperable                OR AND Standby emergency             One onsite power inoperable to       emergency power redundant equipment         source capable of supplying an associated unit's 4.16 kV Class 1E safeguards bus EEEB-RAl-8 (Audit Question 34, rev 1) -TS LCO 3.8.4, Condition A Explain why Column 6 does not list minimum required SSCs in agreement with LCO in terms of subsystems (See TS Bases on page 504, 3rd full paragraph, 1st sentence about term "subsystem" and usage at Point Beach) and indicate if swing battery and battery chargers should be captured here.
NextEra Response:
Table E1-1 for TS 3.8, "Electrical Power Systems", Column 2, "Applicable SSC's", Column 5, "Design Success Criteria" and Column 6, "PRA Success Criteria" required revision to specify the applicable and the minimum SSCs required to fulfill the safety function for TS 3.8.4, Condition A. The DC electrical power system consists of four main distribution buses configured as two redundant electrical 125 VDC trains, with each distribution bus powered by a battery charger and backed up by a station battery.
Thereby, the applicable SSCs for TS 3.8.4, Condition A, are four 125 VDC electrical subsystems each consisting of a battery charger backed by a station battery powering the associated DC distribution bus.
The revised success criteria require two 125 VDC electrical subsystems of the same electrical train, each consisting of a battery charger backed by a station battery powering the associated DC distribution bus. Just as the normally aligned batteries and battery chargers, the swing battery and charger are sized to provide 100% of required DC power, and thereby, the swing battery and charger need not be explicitly captured in the success criteria. Specifically, the changes below were incorporated into Columns 5 and 6 of Table E-1.1 for TS 3.8.4, Condition A The revised Table E1-1 is included as Attachment 1 to this RAI response. The revised Table E1-1 supersedes and replaces the corresponding Table E1-1 of Reference 1.

Point Beach Nuclear Plant, Units 1 and 2                                                         L-2023-011 Docket Nos. 50-266 and 50-301                                                                      Enclosure Page 9of13 Required Action Design Success          PRASuccess Condition             Applicable SSCs Criteria             Criteria Description Two 125 voe Four 125 voe electrical subsystems electrical subsystems of the same electrical TS 3.8.4            each consisting of a train, each consisting Condition A              battery charger of a battery charger         Same One DC electrical power      backed by a station backed by a station subsystem inoperable       battery powering the battery powering the associated DC associated DC distribution bus distribution bus EEEB-RAl-9 (Audit Question 35, rev 1) -TS LCO 3.8.7, Condition A Explain why Column 6 does not list minimum number of inverters per channel per unit required for DBA and UFSAR Section 8.6.2 and TS Bases (page 520, 2nd paragraph, last 5 sentences).
NextEra Response:
Table E1-1 for TS 3.8, "Electrical Power Systems", Column 2, "Applicable SSC's", Column 5, "Design Success Criteria" and Column 6, "PRA Success Criteria" required revision to specify the applicable and the minimum SSCs required to fulfill the safety function for TS 3.8.7, Condition A. The 120 VAC instrument system consists of four 120 VAC instrument channels (red, white, blue, and yellow) configured as two redundant 120 VAC electrical trains. Each are allocated four buses of which two are dedicated to Unit 1 and two dedicated to Unit 2. Each of the four channels are equipped with three inverters of which one is dedicated to Unit 1, one dedicated to Unit 2, and a third, swing inverter which can be aligned to replace either Unit 1 or Unit 2 inverters with full capability. Thereby, the applicable SSCs for TS 3.8.7, Condition A, are four 120 VAC instrument channels each equipped with a 120 VAC instrument inverter powering its two 120 VAC electrical buses. Since the four 120 VAC instrument channels are configured as two redundant 120 VAC electrical trains, the revised design and PRA success criteria for TS 3.8. 7, Condition A, are two 120 VAC instrument channels of the same electrical train, each equipped with a 120 VAC instrument inverter powering two 120 VAC electrical buses.
Specifically, the changes below were incorporated into Columns 2, 5 and 6 of Table E-1.1 for TS 3.8.7, Condition A. The revised Table E1-1 is included as Attachment 1 to this RAI response. The revised Table E1-1 supersedes and replaces the corresponding Table E1-1 of Reference 1.
Required Action Design Success         PRASuccess Condition              Applicable SSCs Criteria             Criteria Description Two 120 VAC Four 120 VAC instrument channels instrument channels TS 3.8.7                                  of the same electrical each equipped with a Condition A                                 train, each equipped 120 VAC instrument                                   Same One required inverter                               with a 120 VAC inverter powering two inoperable                                   instrument inverter 120 VAC electrical powering two 120 buses VAC electrical buses Instrumentation & Controls Branch (EICB) Audit Questions EICB-RAl-1 (Audit Question 36)
In Enclosure 1 of the LAR, Table E1-3(1 ), indicates the following:

Point Beach Nuclear Plant, Units 1 and 2                                                                  L-2023-011 Docket Nos. 50-266 and 50-301                                                                               Enclosure Page 10of13 RPS Function                       Functional Unit                Channels to Trip RCP breaker position - one loop                  FU10a 1 out of 1 per loop RCP breaker position - 2 loops                   FU10b Underfrequency Bus A01, A02                      FU12                      1 out of 1 per bus a)  Explain why it is not a loss of function to support the application of risk-informed completion time.
b)  Provide reference location in the UFSAR and RPS Design Basis Document (or in other available documentation) supporting the coincidence logic presented in the LAR.
NextEra Response:
In response to information request item #14 of the NRC's audit plan (Reference 2), Table E1-3(1),
Information to Support RPS Instrumentation Redundancy and Diversity, and Table E1-3(2), Information to Support ESFAS Instrumentation Redundancy and Diversity, were revised to identify for each design basis accident and transient, at least one diverse means of achieving the primary RPS trip or ESFAS actuation function(s) credited in plant safety analyses. Table E1-3(1) was also revised to correct the coincidence logic for FU10a, FU10b and FU12, as described below. The revised Table E1-3(1) and Table E1-3(2) are included as Attachments 2 and 3 to this RAI response, respectively, and were also made available for NRC viewing on the NextEra Online Reference Portal. The revised Table E1-3(1) and Table E1-3(2) supersede and replace the corresponding Table E1-3(1) and Table E1-3(2) of Reference 1.
a)   For Functional Units (FU) 10a, FU10b and FU12, Table E1-3(1) required correction for the coincidence trip logic column "Channels to Trip". The correct coincidence logic for these RPS functions is listed below and was incorporated into Table E1-3(1). The revised Table E1-3(1) is provided as Attachment 2 of this RAI response. The revised Table E1-3(1) supersedes and replaces the corresponding Table E1-3(1) of Reference 1.
RPS Function                        Functional Unit               Channels to Trip 1-out-of-2 per loop RCP breaker position - one loop                  FU10a 1-out-of-2 per loop RCP breaker position - 2 loops                   FU10b taken twice 1 out of 2 per bus Underfrequency Bus A01, A02                     FU12 taken twice For FU10a, "RCP Breaker Position - One Loop'', when above the P-8 permissive (-35% RTP), a reactor trip occurs upon one of the two RCP breaker relays sensing an open RCP breaker condition on either RCP. Should an FU10a channel become inoperable, the redundant FU10a channel is available to fulfill the coincidence trip logic for the affected RCP loop. Thereby, the loss of one FU1 Oa channel on either or both RCP loops is not a loss of function.
For FU10b, "RCP Breaker Position - 2 Loops", when above the P-7 permissive (-10% RTP) but below P-8 permissive, a reactor trip occurs upon one of the two RCP breaker relays sensing an open RCP breaker condition on both RCP loops. Should an FU10b channel become inoperable, it's redundant FU 1Ob channel is available to fulfill the coincidence trip logic for the affected RCP loop. Thereby, the loss of one FU10b channel on either or both RCP loops is not a loss of function.
During an audit meeting held on November 22, 2022, the NRC staff asked whether the RCP breakers are equipped with redundant relays (i.e., channels) to the RPS system, as inferred above by the '1 out of 2 per loop' trip logic associated with RPS trip functions FU1 Oa (RCP breaker position
        - one loop) and FU10b (RCP breaker position - 2 loops). The table below is derived from Point

Point Beach Nuclear Plant, Units 1 and 2                                                         L-2023-011 Docket Nos. 50-266 and 50-301                                                                      Enclosure Page 11of13 Beach Units 1 and 2 instrumentation & control (l&C) procedures ICP 02.029, Reactor Protection System Logic - RCP Breaker Position (RCP Loss of Power) - TADOT, which verify each train A and train B relay energize with the associated RCP breaker closed and de-energize with the RCP breaker racked-in and open. As can be seen, each RCP breaker is equipped with two, redundant matrix relays, and as such, loss of one relay does not create a loss of function. For an inoperable RCP-A-XA or RCP-A-XB relay on the 'A" RCP-breaker (or an inoperable RCP-B-XA or RCP-B-XB relay on the 'B' RCP breaker) TS 3.3.1, ACTION M would be entered for the loss of a single FU1 Oa channel when above the P-8 permissive, or ACTION N would be entered for the loss of a single FU10b channel when above P-7 but below P-8. The above discussion similarly applies to the Unit 2 'A' and 'B' RCPs. Of note is that neither ACTION M nor N address the condition of both relays associated with a single RCP breaker being inoperable, which would require LCO 3.0.3 entry for this loss of function condition. l&C procedures ICP 02.029 for Point Beach Units 1 and 2 were made available for NRC viewing on the NextEra Online Reference Portal.
RCP              Train        Pump Breaker        Contacts        Matrix Relay No.
A                                 3-4              RCP-A-XA 1P-1A                             1A52-04 B                                 7-8              RCP-A-XB A                                 3-4              RCP-B-XA 1P-1 B                            1A52-14 B                                 7-8              RCP-B-XB A                                 3-4              RCP-A-XA 2P-1A                             2A52-24 B                                 7-8              RCP-A-XB A                                 3-4              RCP-B-XA 2P-1B                             2A52-29 B                                 7-8              RCP-B-XB For FU12, "Underfrequency Bus A01, A02", when above the P-7 permissive, both RCP breakers are tripped (open) upon one of the two underfrequency relays sensing an underfrequency condition on both 4160 V buses A01 and A02. Should an FU12 channel become inoperable, its redundant FU12 channel is available to fulfill the coincidence trip logic for the affected A01 or A02 bus.
Thereby, the loss of one FU12 channel on either or both A01 and A02 buses is not a loss of function.
b)  The following Point Beach drawings detailing the RPS trip logic for FU10a, FU10b and FU12 were made available for NRC viewing on the NextEra Online Reference Portal:
* 883D195, Sheet 4, Rev. 23, 4160 V Bus Scheme Logic
* 883D195, Sheet 15, Rev. 10, RC Trip Signal Logic
* 883D195, Sheet. 1, Rev. 14, Logic Diagram Index and Symbols In addition, Point Beach design basis document (DBD) 27, Reactor Protection System, was made available for NRC viewing on the NextEra Online Reference Portal.
EICB-RAl-2 (Audit Question 37)
In Attachment 2a of the LAR, the licensee proposes that the COMPLETION TIME for TS 3.3.1, "Reactor Protection System (RPS) Instrumentation," CONDITION U change to "48 hours OR In accordance with the Risk Informed Completion Time Program." CONDITION U applies to Functional Unit (FU) 19, "Reactor Trip Breaker Undervoltage and Shunt." In Enclosure 1 of the LAR, Table E1-3(1) does not include information for FU19.
a)   Why is FU19 not included in the Table E1-3(1)?
b) What is the coincidence logic for FU19?

Point Beach Nuclear Plant, Units 1 and 2                                                            L-2023-011 Docket Nos. 50-266 and 50-301                                                                         Enclosure Page 12 of 13 c)  If the coincidence logic is X-out-of-X (such as 1-out-of-1 or 2-out-of-2), why it is not a loss of function to support the application of risk-informed completion time?
d)  Provide reference location in the UFSAR and RPS Design Basis Document (or in other available documentation) supporting the trip logic for FU19.
NextEra Response:
a)    Table E1-3(1) of LAR Enclosure 1 identifies for each design basis accident and transient, at least one diverse means of achieving the primary RPS trip function(s) credited in plant safety analyses.
Table E1-3(1) specifies as one of the diverse means of achieving the primary RPS trip function, the ability to manually trip the reactor. Both the primary and diverse RPS trip functions specified in Table E1-3(1) rely on two operable logic trains of Reactor Trip Breakers (RTBs) each capable of de-energizing the associated RTB (or bypass) undervoltage coil upon receipt of an RPS signal and energizing open the associated RTB via a shunt trip device upon receipt of a manual trip signal.
Operability of both trip mechanisms on each RTB logic train ensures that no single trip mechanism failure will prevent opening any breaker on a valid RPS signal. Thereby, FU19, Reactor Trip Breaker Undervoltage and Shunt Trip Mechanisms, need not be explicitly listed in Table E1-3(1) since an operable FU19 is necessary to achieve both the primary and diverse means of achieving the specified RPS trip functions.
b)   The coincidence logic for FU19 is 1-out-of-2, meaning only one of the two FU19 channels are needed to achieve the reactor trip upon receipt of a valid RPS signal.
c)   With one FU19 channel inoperable, the redundant FU19 channel is capable of providing the reactor trip upon receipt of a valid RPS signal. Thereby, the loss of one FU19 channel does not result in a loss of function.
d)   The following Point Beach drawings detailing the RPS trip logic for FU10a, FU10b and FU12 were made available for NRC viewing on the NextEra Online Reference Portal:
* 883D195, Sheet 2, Rev. 9, Reactor Trip Signal Logic
* 883D195, Sheet. 1, Rev. 14, Logic Diagram Index and Symbols In addition, Point Beach DBD 27, Reactor Protection System, was uploaded to the NextEra Online Reference Portal for NRC viewing in response to item #14 of the NRC's audit document request (Reference 2).
During the audit meeting held on November 22, 2022, the NRC staff asked for the plant conditions warranting entry into FU18 versus FU19 entry. FU18 addresses the operability of the RTBs exclusive of individual trip mechanisms. Two RTBs are required to ensure no single random failure can disable the RPS trip capability. FU19 addresses the operability of the RTB undervoltage and shunt trip device mechanisms. Should an RTB become inoperable independent of the corresponding trip mechanisms, TS 3.3.1, Table 3.3-1, Condition Q would be entered for an inoperable FU18-required RTB. Should either the RTB undervoltage or shunt trip device mechanism become inoperable, TS 3.3.1, Table 3.3-1, Condition U, would be entered for an inoperable FU 19-required trip mechanism. However, it would not be necessary to also enter Condition U for an inoperable FU18-required RTB since the affected RTB remains capable of tripping the unit upon receipt of a valid RPS signal. Noteworthy in both scenarios is that the redundant RTB remains available and capable of performing its function upon a valid RPS signal, and thereby entry into FU 18, FU 19 or both does not constitute a loss of function.

==References:==

Point Beach Nuclear Plant, Units 1 and 2                                               L-2023-011 Docket Nos. 50-266 and 50-301                                                            Enclosure Page13of13
: 1.      NextEra Energy letter NRC 2022-0007, Point Beach Nuclear Plant, Units 1 and 2, License Amendment Request 297, Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, "Provide Risk Informed Extended Completion Times - RITSTF Initiative 4b", May 20, 2022 (ADAMS Accession No. ML22192A152)
: 2.      NRC letter to Florida Power & Light Company, Point Beach Nuclear Plant, Units 1 and 2 -
Regulatory Audit in Support of Review of the Application to Adopt Risk-Informed Extended Completion Times- RITSTF Initiative 4b, August 11, 2022 (ADAMS Accession No. Ml22216A203)

Point Beach Nuclear Plant, Units 1 and 2                                                                                             L-2023-011 Docket Nos. 50-266 and 50-301                                                                                                      Attachment 1 Page 1 of 12 Table E1 List of Revised Required Actions to Corresponding PRA Functions (revised)
Required Action SSC       PRA         Design Success      PRASuccess Condition              Applicable SSCs                                                                                       Comments Function(s)   Modeled           Criteria          Criteria Description TS 3.3.1, RPS Instrumentation (Table 3.3-1)
Condition B                                                                                                   The operator actions for failure to One Manual                                                                         1of2           Not Modeled actuate a manual reactor trip will be (FU1)               Reactor Trip Reactor Trip                                                      No          Manual Rx Trip         -See     used as a surrogate to conservatively Two Manual Rx Trip channels       Initiation channel inoperable                                                                  channels          comments   bound the risk increase associated with (Modes 1,2)                                                                                                   this function as permitted by NEI 06-09.
(FU2a)                                                2 of4          Not Modeled The condition of one of two inoperable Reactor Trip Four Power Range Neutron                       No      Power Range Neutron        -See     reactor trip breakers is used as a Initiation Flux High channels                                  Flux- High channels     comments   surrogate for this condition.
(FU2b)                                                2 of4          Not Modeled The condition of one of two inoperable Reactor Trip Four Power Range Neutron                       No      Power Range Neutron        -See     reactor trip breakers is used as a Initiation Flux Low channels                                    Flux- Low channels     comments   surrogate for this condition.
(FU5)                                                2 of4          Not Modeled The condition of one of two inoperable Reactor Trip Four Overtemperature Lff                      No       Overtemperature t:,.T     -See     reactor trip breakers is used as a Initiation channels                                             channels          comments   surrogate for this condition.
2 of 4         Not Modeled The condition of one of two inoperable Condition D                   (FU6)               Reactor Trip No           Overpower t:,.T       -See     reactor trip breakers is used as a One channel       Four Overpower!::,.T channels     Initiation channels          comments   surrogate for this condition.
inoperable (FU?b)                                                2 of3          Not Modeled The condition of one of two inoperable Reactor Trip Three Pressurizer Pressure -                    No      Pressurizer Pressure -     -See      reactor trip breakers is used as a Initiation High channels                                        High channels       comments   surrogate for this condition.
2 of 3 (FU13)                                                               Not Modeled The condition of one of two inoperable Reactor Trip             SG Water Level Low-Three SG Water Level Low-Low                     No                                 -See      reactor trip breakers is used as a Initiation             Low channels on any channels per SG                                                           comments    surrogate for this condition.
SG (FU14)                                        One SG Water Level Two SG Water Level Low;                               Low coincident w/ one   Not Modeled The condition of one of two inoperable Reactor Trip Coincident w/ Steam-Flow/                      No        Steam-Flow/ Feed-        -See      reactor trip breakers is used as a Initiation Feed-Flow Mismatch channels                                 Flow Mismatch        comments    surrogate for this condition.
perSG                                          channel on any SG

Point Beach Nuclear Plant, Units 1 and 2                                                                                              L-2023-011 Docket Nos. 50-266 and 50-301                                                                                                       Attachment 1 Page 2 of 12 Table E1 List of Revised Required Actions to Corresponding PRA Functions (revised)
Required Action                                                                 Design Success      PRASuccess SSC       PRA Condition              Applicable SSCs                                                                                      Comments Function(s)   Modeled           Criteria          Criteria Description 1 of 2 Condition E                  (FU12)                                                               Not Modeled The condition of one of two inoperable Reactor Trip             Underfrequency Bus One channel     Two Underfrequency Bus A01,                       No                                 -See     reactor trip breakers is used as a Initiation               channels on both inoperable           A02 channels per bus                                                         comments   surrogate for this condition.
A01 and A02 (FU7a)                                                2 of4          Not Modeled The condition of one of two inoperable Reactor Trip Four Pressurizer Pressure -                    No      Pressurizer Pressure -     -See     reactor trip breakers is used as a Initiation Low channels                                         Low channels        comments   surroQate for this condition.
(FU8)                                               2 of 3         Not Modeled The condition of one of two inoperable Reactor Trip Three Pressurizer Water Level -                   No        Pressurizer Water        -See     reactor trip breakers is used as a Initiation High channels                                    Level - High channels    comments   surrogate for this condition.
Condition K One channel                                                                        2 of 3 (FU9b) inoperable                                                              Reactor Coolant Flow -  Not Modeled The condition of one of two inoperable Three Reactor Coolant Flow -    Reactor Trip No      Low channels on both       -See     reactor trip breakers is used as a Low (Two loops) channels per       Initiation RCS Loops when        comments   surrogate for this condition.
RCS Loop above P8 1of2 (FU11)                                                              Not Modeled The condition of one of two inoperable Reactor Trip               Undervoltage Bus Two Undervoltage Bus A01,                      No                                 -See     reactor trip breakers is used as a Initiation                  channels on A02 channels per electrical bus                                                    comments   surrogate for this condition.
A01 and A02 Condition L                                                                       2 of3 (FU9a)
One Reactor                                                               Reactor Coolant Flow -  Not Modeled The condition of one of two inoperable Three Reactor Coolant Flow -    Reactor Trip Coolant Flow-Low                                                     No       Low channels on any       -See     reactor trip breakers is used as a Low (Single Loop) channels per      Initiation (Single Loop)                                                             RCS Loop when below      comments   surrogate for this condition.
RCS Loop channel inoperable                                                                      P8 Condition M One Reactor                                                                 One RCP Breaker (FU10a)                                                              Not Modeled The condition of one of two inoperable Coolant Pump                                       Reactor Trip              Position channel on One RCP Breaker Position                      No                                 -See     reactor trip breakers is used as a Breaker Position                                       Initiation            any RCP when below (Single Loop) channel per RCP                                                     comments   surrogate for this condition.
(Single Loop)                                                                        P8 channel inoperable One RCP breaker Condition N                 (FU10b)                                                              Not Modeled The condition of one of two inoperable Reactor Trip              Position channel on One inoperable    One RCP breaker position (two                    No                                 -See     reactor trip breakers is used as a Initiation              both RCPs when channel          loops) channel per RCP                                                        comments    surrogate for this condition.
above P8

Point Beach Nuclear Plant, Units 1 and 2                                                                                              L-2023-011 Docket Nos. 50-266 and 50-301                                                                                                      Attachment 1 Page 3of12 Table E1 List of Revised Required Actions to Corresponding PRA Functions (revised)
Required Action SSC         PRA       Design Success      PRASuccess Condition             Applicable SSCs                                                               *criteria                Comments Function(s)     Modeled         Criteria Description 2 of2 (FU15a)                                                               Not Modeled The condition of one of two inoperable Reactor Trip              Turbine trip - Low Three Turbine trip - Low Auto-                     No                                -See    reactor trip breakers is used as a Condition 0                                          Initiation            Auto-Stop Oil Pressure Stop Oil Pressure channels                                                       comments   surrogate for this condition.
One turbine trip                                                                   channels channel                                                                          2 of 3 inoperable                  (FU15b)                                                               Not Modeled The condition of one of two inoperable Reactor Trip              Turbine trip - Stop Two Turbine trip - Stop Valve                      No                                -See    reactor trip breakers is used as a Initiation                 Valve Closure Closure channels                                                            comments   surrogate for this condition.
channels 1of2           Not Modeled The condition of one of two inoperable (FU16)               Reactor Trip Condition P                                                          No     SI input from ESFAS        -See    reactor trip breakers is used as a Two SI input from ESFAS trains      Initiation One train                                                                        trains          comments   surrogate for this condition.
inoperable                                                                         1of2           Not Modeled The condition of one of two inoperable (Modes 1,2)                   (FU21)               Reactor Trip No     Automatic Trip Logic       -See    reactor trip breakers is used as a Two Automatic Trip Logic trains     Initiation trains          comments   surrogate for this condition.
Condition Q Not Modeled This SSC is used as a surrogate for One RTB                    (FU18)               Reactor Trip                     1of2 No                                -See    other TS 3.3.1 RPS Instrumentation inoperable              Two RTB trains              Initiation                   RTB trains comments   Conditions.
(Modes 1,2)
Condition U (FU19)                                              One RTB One trip                                                                                        Not Modeled The condition of one of two inoperable One RTB Undervoltage and        Reactor Trip               Undervoltage and mechanism                                                           No                                -See    reactor trip breakers is used as a Shunt Trip Mechanism per RTB        Initiation            Shunt Trip Mechanism inoperable for one                                                                                     comments   surrogate for this condition.
train                                          on any RTB train RTB (Modes 1,2)
TS 3.3.2, ESFAS Instrumentation (Table 3.3-2)
The operator actions for failure to 1of2           Not Modeled manually actuate SI will be used as a (FU1a)              Safety Injection No        Manual Initiation       -See    surrogate to conservatively bound the Two Manual Initiation channels      Initiation Condition B                                                                        channels         comments   risk increase associated with this One channel                                                                                                    function as permitted bv NEI 06-09.
inoperable                                                                                                   The condition of manual SI function Containment                       1of2          Not Modeled (FU3a)                                                                           inoperable is used as a surrogate for Isolation       No        Manual Initiation       -See Two Manual Initiation channels                                                               this condition since an SI signal Initiation                   channels         comments aenerates a Cl sianal.

Point Beach Nuclear Plant, Units 1 and 2                                                                                                  L-2023-011 Docket Nos. 50-266 and 50-301                                                                                                           Attachment 1 Page 4 of 12 Table E1 List of Revised Required Actions to Corresponding PRA Functions (revised)
Required Action SSC         PRA       Design Success        PRASuccess Condition            Applicable SSCs                                                                                            Comments Function(s)     Modeled          Criteria           Criteria Description 1of2                        The failure of the automatic SI signals (FU1 b)
Automatic          Not Modeled will be used as a surrogate to Two Automatic             Safety Injection No      Actuation Logic and        -See     conservatively bound the risk increase Actuation Logic and Actuation        Initiation Actuation Relay trains     comments   associated with this function as Condition C               Relay trains channels                      oermitted bv NEI 06-09.
One train 1of2 inoperable.                (FU3b)                                                                               The condition of automatic SI function Containment                    Automatic          Not Modeled Two Automatic                                                                            inoperable is used as a surrogate for Isolation       No      Actuation Logic and        -See Actuation Logic and Actuation                                                                    this condition since an SI signal Initiation                    Actuation          comments Relay trains                                                                           generates a Cl signal.
Relay trains The condition of automatic SI function (FU1c)                                                   2 of 3          Not Modeled Safety Injection                                               inoperable is used as a surrogate for Three Containment Pressure -                          No    Containment Pressure         -See Initiation                                                  this condition since it is the same High channels                                          - High channels        comments function (SI initiation).
The condition of automatic SI function (FU1d)                                                   2 of 3          Not Modeled Safety Injection                                               inoperable is used as a surrogate for Three Pressurizer Pressure -                         No    Pressurizer Pressure -       -See Initiation                                                  this condition since it is the same Low channels                                            Low channels         comments function (SI initiation).
2 of 3                      The condition of automatic SI function (FU1e)                                                                   Not Modeled Safety Injection         Steam Line Pressure -                 inoperable is used as a surrogate for Three Steam Line Pressure -                         No                                 -See Initiation            Low channels per main                 this condition since it is the same Low channels per steam line                                                          comments steam line                    function (SI initiation).
Condition D                                                                                                      The failure of the model logic for steam One channel                  (FU4c)                 Steam Line                       2 of3           Not Modeled generator isolation will be used as a inoperable. Three Containment Pressure -         Isolation       No    Containment Pressure         -See     surrogate to conservatively bound the High, High channels             Initiation             - High, High channels     comments   risk increase associated with this function as permitted bv NEI 06-09.
(FU4d)                                           1 of 2 High Steam Two High Steam Flow                                        Flow channels Steam Line                                       Not Modeled The condition of steam generator channels; Coincident with SI                               coincident with SI and Isolation       No                                 -See      isolation function inoperable is used as and Coincident with three T avg -                            coincident with 2 of 3 Low, Low channels per RCS           Initiation                                      comments    a surrogate for this condition.
Tavg - Low, Low loop                                                 channels (FU4e)
Steam Line                                       Not Modeled The condition of steam generator Two High, High Steam Flow Isolation      No               1 of 2            -See      isolation function inoperable is used as channels per steam line; Initiation                                      comments    a surrogate for this condition.
Coincident with SI

Point Beach Nuclear Plant, Units 1 and 2                                                                                             L-2023-011 Docket Nos. 50-266 and 50-301                                                                                                     Attachment 1 Page 5 of 12 Table E1 List of Revised Required Actions to Corresponding PRA Functions (revised)
Required Action SSC        PRA         Design Success       PRASuccess Condition           Applicable SSCs                                                                                          Comments Function(s)  Modeled            Criteria           Criteria Description High, High Steam Flow channels per steam line coincident with SI (FU5b)                Feedwater                       2 of3           Not Modeled The condition of steam generator Three SG Water Level - High      Isolation     No      SG Water Level - High       -See     isolation function inoperable is used as channels per SG            Initiation               channels per SG        comments   a surrogate for this condition.
The failure of the model logic for these 2 of3 (FU6b)                 Auxiliary                                      Not Modeled relays will be used as a surrogate to SG Water Level - Low, Three SG Water Level - Low,     Feedwater      No                                  -See     conservatively bound the risk increase Low channels on any Low channels per SG           Initiation                                      comments   associated with this function as SG permitted bv NEI 06-09.
Condition F                (FU4a)               Steam Line                                       Not Modeled The condition of steam generator One Manual Initiation One channel      One Manual Initiation channel    Isolation     No                                  -See     isolation function inoperable is used as channel per RCS loop inoperable             per RCS loop              Initiation                                      comments   a surrogate for this condition.
1of2 (FU4b)                Steam Line                                      Not Modeled The condition of steam generator Automatic Actuation Two Automatic Actuation Logic     Isolation     No                                  -See     isolation function inoperable is used as Logic and Actuation and Actuation Relay trains      Initiation                                      comments   a surrogate for this condition.
Relav trains 1of2 (FU5a)                                                                Not Modeled Condition G                                      Feedwater                Automatic Actuation                The condition of AFW initiation is used Two Automatic Actuation Logic                   No                                  -See One train                                       Isolation               Logic and Actuation                as a surrogate for this condition.
and Actuation Relay trains                                                      comments inoperable                                                                   Relay trains The failure of the model logic for these 1of2 (FU6a)                                                                Not Modeled relays will be used as a surrogate to Auxiliary               Automatic Actuation Two Automatic Actuation Logic                   No                                  -See     conservatively bound the risk increase Feedwater                Logic and Actuation and Actuation Relay trains                                                      comments    associated with this function as Relay trains permitted bv NEI 06-09.
The failure of the model logic for 1 of2 Condition H                (FU6d)                                                                Not Modeled  starting all four AFW pumps will be Auxiliary                Undervoltage Bus One channel     Two Undervoltage Bus A01 and                    No                                  -See      used as a surrogate to conservatively Feedwater                    channels on inoperable     A02 channels per electrical bus                                                   comments    bound the risk increase associated with A01 and A02 this function as permitted bv NEI 06-09.

Point Beach Nuclear Plant, Units 1 and 2                                                                                            L-2023-011 Docket Nos. 50-266 and 50-301                                                                                                     Attachment 1 Page 6 of 12 Table E1 List of Revised Required Actions to Corresponding PRA Functions (revised)
Required Action SSC        PRA        Design Success      PRASuccess Condition              Applicable SSCs                                                                                      Comments Function(s}    Modeled           Criteria         Criteria Description TS 3.4, Reactor C.oolant System TS 3.4.11 Condition B One PORV          Two Power Operated Relief     RCS pressure                       1 of2 Yes                               Same inoperable and not           Valves (PORVs)               control                      PO RVs capable of being manually cycled TS 3.4.11 Condition C                                                                  Associated Block Two PORV Block Valves         RCS integrity    Yes                               Same One block valve                                                                   Valve closure inoperable TS 3.5, Emergency Core Cooling System (ECCS}
1 of 2 SI pumps, and 1 of 2 RHR pumps Two ECCS trains each          Emergency TS 3.5.2      comprised of one SI pump, one    core cooling Condition A         RHR pump, one RHR heat          and post-              1 of 2 RHR pumps w/
Yes           suction from        Same One ECCS train        exchanger and associated     accident (long-inoperable       RWST and containment sump        term) core               containment sump, flowpaths                 cooling             supplying suction to 1 of 2 SI pumps for flowpath to RCS TS 3.6, Containment Systems TS 3.6.2 Condition C                                                                       One of two                  The failure of the model logic for One or more         One equipment hatch; ltwo                               containment air lock  Not Modeled containment penetrations will be used Containment containment air      personnel airlocks (one for                     No        doors closed with      -See     as a surrogate to conservatively bound integrity locks inoperable        emergency use)[MJ1J                                         acceptable       comments   the risk increase associated with this for reasons other                                                             containment leakage                function as permitted by NEI 06-09.
Condition A or B

Point Beach Nuclear Plant, Units 1 and 2                                                                                           L-2023-011 Docket Nos. 50-266 and 50-301                                                                                                    Attachment 1 Page 7 of 12 Table E1 List of Revised Required Actions to Corresponding PRA Functions (revised)
Required Action SSC        PRA       Design Success      PRA Success Condition            Applicable SSCs                                                                                      Comments Function(s)    Modeled          Criteria         Criteria Description TS 3.6.3 Condition A One or more penetration flow paths with one                                                                                                The failure of the model logic for containment                                                                       1 of2         Not Modeled containment penetrations will be used Two isolation valves on each     Containment isolation valve                                                     No      isolation valves per     -See     as a surrogate to conservatively bound containment penetration           integrity inoperable                                                                penetration isolate   comments   the risk increase associated with this (applicable to                                                                                               function as permitted by NEI 06-09.
penetration flow paths with two containment isolation valves)
TS 3.6.3 Condition C One or more penetration flow paths with one The failure of the model logic for containment                                                                        Each         Not Modeled containment penetrations will be used One isolation valve and one isolation valve                                    Containment closed system on each                         No       isolation valve per     -See     as a surrogate to conservatively bound inoperable                                         integrity containment penetration                                penetration isolates   comments   the risk increase associated with this (applicable to function as permitted by NEI 06-09.
penetration flow paths with one containment isolation valve and a closed system)
TS 3.7, Plant Systems TS 3.7.2 Condition A Two Main Steam Lines          Steam Line One Steam equipped with one Main Steam      Isolation from             MSIV on affected Generator                                                       Yes                              Same Isolation Valve (MSIV) and one   Faulted Steam              steam line isolates flowpath with one Non-Return Check Valve               Line or more inoperable valves in MODE 1

Point Beach Nuclear Plant, Units 1 and 2                                                                               L-2023-011 Docket Nos. 50-266 and 50-301                                                                                        Attachment 1 Page 8 of 12 Table E1 List of Revised Required Actions to Corresponding PRA Functions (revised)
Required Action SSC         PRA      Design Success      PRASuccess Condition            Applicable SSCs                                                                            Comments Function(s)    Modeled        Criteria         Criteria Description TS 3.7.4 Condition A                                        Facilitate Unit Two Atmospheric Dump Valves                                         1of2 One required ADV                                        cooldown to      Yes                            Same (ADVs)                                            ADV flowpaths flowpath                                      SOC conditions inoperable TS 3.7.5 Condition A Turbine driven AFW pump system inoperable due to   One turbine-driven AFW pump         Feedwater             One motor driven AFW one inoperable     and one motor-driven AFW         supply to SGs            pump supplies CST Yes                            Same steam supply,   pump and associated CST and         upon loss of                feedwater to OR Turbine driven          SW suction piping          main feedwater                  both SGs AFW pump system inoperable in MODE 3 following refueling TS 3.7.5 Condition B One turbine-driven AFW pump         Feedwater               One turbine driven OneAFWpump and one motor-driven AFW        supply to SGs            AFW pump supplies system inoperable                                                        Yes                            Same pump and associated CST and         upon loss of           CST feedwater to both in MODE 1, 2 or 3 SW suction piping          main feedwater                     SGs for reasons other than Condition A Two Component Cooling Water         Heat sink for (CCVI/) trains each consisting of     removing               1 CCW pump and TS 3.7.7 one CCW pump and one CCW           process and              1 CCW HX provide Condition A heat exchanger, and one        operating heat    Yes         heat sink to       Same One CC pump                                                                     safety related common CCW heat exchanger          from safety-inoperable                                          related                   equipment capable of aligning to either train                components

Point Beach Nuclear Plant, Units 1 and 2                                                                                L-2023-011 Docket Nos. 50-266 and 50-301                                                                                         Attachment 1 Page 9of12 Table E1 List of Revised Required Actions to Corresponding PRA Functions (revised)
Required Action SSC       PRA          Design Success      PRASuccess Condition              Applicable SSCs                                                                            Comments Function(s)   Modeled            Criteria         Criteria Description Two Component Cooling Water        Heat sink for TS 3.7.7     (CCW) trains each consisting of      removing                 1 CCW pump and Condition B      one CCW pump and one CCW          process and               1 CCW HX provide One required CC         heat exchanger, and one       operating heat   Yes            heat sink to        Same heat exchanger      common CCW heat exchanger         from safety-                  safety related inoperable        capable of aligning to either      related                     equipment train               components Heat sink for               2 SW pumps and TS 3.7.8 Six Service Water (SW) system        removing                 1 SW Ring Header Condition A pumps, one common ring         process and               provide heat sink to One SW pump header, non-essential flowpath   operating heat   Yes        CCW system and          Same inoperable AND isolation valves and associated    from safety-             essential loads; auto-Both units in SW intake piping             related               isolate non- essential Modes 1, 2, 3, or 4 components                      flowpaths Heat sink for               2 SW pumps and TS 3.7.8 Six Service Water (SW) system        removing                 1 SW Ring Header Condition C pumps, one common ring         process and               provide heat sink to SW ring header header, non-essential flowpath   operating heat   Yes         CCW system and         Same continuous                                        from safety-             essential loads; auto-isolation valves and associated flowpath SW intake piping              related             isolates non-essential interrupted components                      flowpaths TS 3.7.8 Condition D One or more Heat sink for               3 SW pumps and non-essential-SW-Six Service Water (SW) system       removing                 1 SW Ring Header load flowpath(s) pumps, one common ring         process and               provide heat sink to with one required                                                                  CCW system and         Same header, non-essential flowpath  operating heat   Yes automatic isolation isolation valves and associated   from safety-             essential loads; auto-valve inoperable.
SW intake piping              related             isolates non- essential AND Affected non-components                      flowpaths essential flowpath(s) not isolated

Point Beach Nuclear Plant, Units 1 and 2                                                                                L-2023-011 Docket Nos. 50-266 and 50-301                                                                                         Attachment 1 Page 10of12 Table E1 List of Revised Required Actions to Corresponding PRA Functions (revised)
Required Action SSC       PRA          Design Success      PRASuccess Condition              Applicable SSCs                                                                           Comments Function(s)  Modeled             Criteria         Criteria Description TS 3.8, Electrical Power Systems TS 3.8.1 Condition A Power                       One circuit Associated unit    Two circuits between the offsite     Class 1E                between the offsite 345/13.8 kV transmission network via the       4.16 kV               transmission network (X03)             345/13.8 kV (X03)           safeguards                via a 345/13.8 kV transformer          transformers and the          buses from                (X03) transformer inoperable. 13.8/4.16kV (X04) transformers,                   Yes                                Same offsite               and a 13.8/4.16kV OR         and the associated unit's 4.16   transmission            (X04) transformer, and Gas turbine not in   kV Class 1E safeguards buses        networks               an associated unit's operation when 4.16 kV Class 1E utilizing opposite safeguards bus unit's 345/13.8 kV (X03) transformer.
Power                      One circuit Two circuits between the offsite Class 1E                between the offsite transmission network via the TS 3.8.1                                           4.16 kV              transmission network 345/13.8 kV (X03)
Condition B                                         safeguards                via a 345/13.8 kV transformers and the Associated unit's                                      buses from                (X03) transformer 13.8/4.16kV (X04) transformers,                   Yes                                Same 13.8/4.16kV (X04)                                          offsite               and a 13.8/4.16kV and the associated unit's 4.16 transformer                                       transmission            (X04) transformer, and kV Class 1E safeguards buses inoperable                                         networks               an associated unit's 4.16 kV Class 1E safeguards bus TS 3.8.1     Two circuits between the offsite       Power                      One circuit Condition C       transmission network via the       Class 1E                between the offsite Associated unit's          345/13.8 kV (X03)              4.16 kV              transmission network required offsite       transformers and the           safeguards                via a 345/13.8 kV power source to    13.8/4.16kV (X04) transformers,     buses from               (X03) transformer buses A05 and       and the associated unit's 4.16       offsite               and a 13.8/4.16kV Yes                                Same A06 inoperable. kV Class 1E safeguards buses     transmission            (X04) transformer, and OR                      AND                 networks and               an associated unit's Required offsite     Two onsite emergency power           on site                4.16 kV Class 1E power source to      sources capable of supplying      emergency                   safeguards bus buses 1A05 and       the associated unit's 4.16 kV  power sources                        OR 2A06 inooerable       Class 1E safequards buses                              One onsite emerqencv

Point Beach Nuclear Plant, Units 1 and 2                                                                                L-2023-011 Docket Nos. 50-266 and 50-301                                                                                         Attachment 1 Page 11 of 12 Table E1 List of Revised Required Actions to Corresponding PRA Functions (revised)
Required Action SSC       PRA          Design Success      PRASuccess Condition              Applicable SSCs                                                                           Comments Function(s)  Modeled             Criteria         Criteria Description power source capable of supplying an associated unit's 4.16 kV Class 1E safeguards bus One circuit Two circuits between the offsite      Power                  between the offsite transmission network via the      Class 1E               transmission network TS 3.8.1            345/13.8 kV (X03)             4.16 kV                 via a 345/13.8 kV Condition D           transformers and the          safeguards                (X03) transformer One or more      13.8/4.16kV (X04) transformers,    buses from                and a 13.8/4.16kV required      and the associated unit's 4.16       offsite             (X04) transformer, and offsite power     kV Class 1E safeguards buses     transmission              an associated unit's Yes                                Same source(s) to one or               AND                 networks and                4.16 kV Class 1E more required     Two onsite emergency power           on site               safeguards bus, OR Class 1E 4.16 kV     sources capable of supplying     emergency              One onsite emergency bus( es)      the associated unit's 4.16 kV  power sources            power source capable inoperable        Class 1E safeguards buses                                   of supplying an associated unit's 4.16 kV Class 1E safeguards bus TS 3.8.1                                                                       One circuit Condition F                                           Power                  between the offsite Two circuits between the offsite One or more                                          Class 1E              transmission network transmission network via the       4.16 kV required                                                                  via a 345/13.8 kV 345/13.8 kV (X03) offsite power                                       safeguards                (X03) transformer transformers and the source to one or                                     buses from                and a 13.8/4.16kV 13.8/4.16kV (X04) transformers, more Class 1E                                          offsite             (X04) transformer, and and the associated unit's 4.16 4.16 kV                                       transmission    Yes       an associated unit's     Same kV Class 1E safeguards buses safeguards                                       networks and                4.16 kV Class 1 E AND bus(es) inoperable                                        on site                  safeguards bus Two onsite emergency power AND Standby                                         emergency                         OR sources capable of supplying emergency power                                     power sources            One onsite emergency the associated unit's 4.16 kV inoperable to                                                               power source capable Class 1E safeguards buses redundant                                                                    of supplying an equipment                                                                 associated unit's 4.16

Point Beach Nuclear Plant, Units 1 and 2                                                                                L-2023-011 Docket Nos. 50-266 and 50-301                                                                                         Attachment 1 Page 12of12 Table E1 List of Revised Required Actions to Corresponding PRA Functions (revised)
Required Action SSC        PRA          Design Success     PRA Success Condition             Applicable SSCs                                                                             Comments Function{s)    Modeled            Criteria        Criteria Description kV Class 1E safeguards bus Supply                     Two 125 VDC required DC             electrical subsystems TS 3.8.4          Four 125 VDC electrical          motive and             of the same electrical Condition A      subsystems each consisting of    control power             train, each consisting One DC electrical  a battery charger backed by a     to shut down     Yes       of a battery charger    Same power subsystem     station battery powering the       the reactor              backed by a station inoperable      associated DC distribution bus   and maintain it            battery powering the in a safe                  associated DC condition                  distribution bus Supply                     Two 120VAC Four 120 VAC instrument            120 VAC              instrument channels of TS 3.8.7       channels each equipped with a    battery-backed              the same electrical Condition A       120 VAC instrument inverter         power to               train, each equipped Yes                               Same One required         powering two 120 VAC         various safety-                with a 120 VAC inverter inoperable         electrical buses              related                 instrument inverter instrument            powering two 120 VAC racks                    electrical buses

Point Beach Nuclear Plant, Units 1 and 2                                                                                          L-2023-011 Docket Nos. 50-266 and 50-301                                                                                                   Attachment 2 Page 1 of 7 Table E1-3(1) - Information to Support RPS Instrumentation Redundancy and Diversity (revised)
FSAR            FSAR described         Functional                                Channels    Functional       Diverse Trip Primary Trip Function                                                        Comments Section        transient/accident       Unit (FU)*                                  to Trip   Unit (FU)*       Function(s)
Source range high FU4 neutron flux Intermediate range high FU3 Uncontrolled Rod Withdrawal               Power range high neutron                            neutron flux 14.1.1                                     FU2b                                  2 out of 4 from Subcritical                          flux (low setting)
Power range high FU2a neutron flux (low setting)
FU1     Manual Trip FU6     Overpower LlT FU2a     Power range high neutron     2 out of 4             Pressurizer pressure -
FU7b flux (high setting)                                 High Uncontrolled Rod 14.1.2 Withdrawal at Power FU8     Pressurizer Level - High FU5     Overtemperature LlT           2 out of 4 FU1     Manual Trip FU5     Overtemperature LlT FU6     Overpower LlT Rod Cluster Control 14.1.3                                      NA       No primary Rx trip credited     NA Assembly (RCCA) Drop                                                                          Pressurizer Pressure -
FU7a Low FU1     Manual Trip Chemical and Volume             FU2a      Power range high neutron     2 out of 4 14.1.4                                                                                          FU6     Overpower LlT Control System Malfunction               flux (high setting)

Point Beach Nuclear Plant, Units 1 and 2                                                                                                 L-2023-011 Docket Nos. 50-266 and 50-301                                                                                                          Attachment 2 Page 2 of?
Table E1-3(1) - Information to Support RPS Instrumentation Redundancy and Diversity (revised)
FSAR            FSAR described         Functional                                Channels   Functional        Diverse Trip Primary Trip Function                                                               Comments Section        transient/accident        Unit (FU)*                                to Trip   Unit (FU)*        Function(s)
Source range high FU4     neutron flux (during Assuming at-power FU5     Overtemperature LlT          2 out of 4            startup) dilution with no operator action FU1     Manual Trip Power range high FU2b Startup of an Inactive                                                                       neutron flux (low setting).
14.1.5                                      NA      No primary Rx trip credited     NA Reactor Coolant Loop FU5     Overtemperature LlT Power range high FU2b neutron flux (low setting).
FU5     Overtemperature LlT Reduction in Feedwater 14.1.6                                     FU2b     No primary Rx trip credited     NA Enthalpy Incident FU6     Overpower LlT FU1     Manual Trip Power range high FU2a     neutron flux (high settino).
FU5     Overtemperature LlT Excessive Load Increase 14.1.7                                       NA      No primary Rx trip credited    NA Incident FU6     Overpower LlT Pressurizer Pressure -
FU? a Low

Point Beach Nuclear Plant, Units 1 and 2                                                                                               L-2023-011 Docket Nos. 50-266 and 50-301                                                                                                        Attachment 2 Page 3 of 7 Table E1-3(1) - Information to Support RPS Instrumentation Redundancy and Diversity (revised)
FSAR          FSAR described          Functional                                Channels    Functional        Diverse Trip Primary Trip Function                                                             Comments Section       transient/accident        Unit (FU)*                                 to Trip   Unit (FU)*        Function(s)
FU1     Manual Trip FU10a    RCP breaker position -
FU10b    (single loop) (two loops)
Underfrequency Bus RCS Flow - Low                1 out of 2   FU12 FU9a                                                         A01, A02 (single loop) (two loops)      per loop FU9b Loss of Reactor Coolant 14.1.8                                                                                         FU5     Overtemperature LlT Flow FU11                                                         Pressurizer pressure -
Undervoltage Bus A01, A02   1 out of 2     FU?b per bus                high taken twice          FU1     Manual Trip FU8    Pressurizer Level - High Power range high          Turbine trip causes Rx FU? a     Pressurizer pressure - High  2 out of 3    FU2a    neutron flux (high        trip above P9 Loss of External Electrical                                                                   settinQ).
14.1.9 Load                                                                                                                    Assuming no PORV or SG Water Level - Low, FU5      Overtemperature .6.T         2 out of 4    FU13                              Steam dump valve Low release Turbine trip on low oil FU15a pressure

Point Beach Nuclear Plant, Units 1 and 2                                                                                               L-2023-011 Docket Nos. 50-266 and 50-301                                                                                                        Attachment 2 Page 4 of 7 Table E1-3(1) - Information to Support RPS Instrumentation Redundancy and Diversity (revised)
FSAR           FSAR described           Functional                              Channels    Functional       Diverse Trip Primary Trip Function                                                            Comments Section        transient/accident         Unit (FU)*                               to Trip   Unit (FU)*        Function(s)
Turbine trip on stop valve FU15b closure SG Water Level Low; coincident w/ Steam FU14 Flow I Feed Flow Mismatch Pressurizer pressure -
FU?b high FUS    Pressurizer Level - High Turbine trip causes Rx 14.1.10   Loss of Normal Feedwater          FU13      SG Water Level - Low, Low  2 out of 3 FU5    Overtemperature ti.T       trip above P9 Turbine trip on low oil FU15a pressure Turbine trip on stop valve FU15b closure FU1    Manual Trip SG Water Level Low; Loss of All AC Power to                                                                      coincident w/ Steam 14.1.11                                     FU13      SG Water Level - Low, Low  2 out of 3    FU14 Station Auxiliaries                                                                          Flow I Feed Flow Mismatch

Point Beach Nuclear Plant, Units 1 and 2                                                                                         L-2023-011 Docket Nos. 50-266 and 50-301                                                                                                  Attachment 2 Page 5 of 7 Table E1-3(1) - Information to Support RPS Instrumentation Redundancy and Diversity (revised)
FSAR            FSAR described        Functional                               Channels    Functional        Diverse Trip Primary Trip Function                                                        Comments Section        transient/accident       Unit (FU)*                                to Trip   Unit (FU)*        Function(s)
Pressurizer pressure -
FU7b high FUS     Pressurizer Level - High FU5     Overtemperature Lff Turbine trip on low oil FU15a pressure Turbine trip on stop valve FU15b closure FU9a     RCS Flow - Low FU9b    (single loop) (two loops)
Undervoltage Bus A01, FU11 A02 Underfrequency Bus FU12 A01, A02 Likelihood ofTurbine-14.1.12                                    NA       Rx trip not credited           NA          NA     Rx trip not credited Generator Unit Overspeed 14.2.1   Fuel Handling Accident           NA       Rx trip not credited            NA         NA     Rx trip not credited Accidental Release-Recycle 14.2.2                                    NA       Rx trip not credited            NA         NA     Rx trip not credited or Waste Liquid Accidental Release-Waste 14.2.3                                    NA       Rx trip not credited            NA         NA     Rx trip not credited Gas Steam Generator Tube            FU? a     Pressurizer Pressure - Low  2 out of 3            Safety Injection (SI) Input 14.2.4                                                                                       FU16 Rupture -                                                                                   from ESFAS

Point Beach Nuclear Plant, Units 1 and 2                                                                                                L-2023-011 Docket Nos. 50-266 and 50-301                                                                                                         Attachment 2 Page 6 of 7 Table E1-3(1) - Information to Support RPS Instrumentation Redundancy and Diversity (revised)
FSAR           FSAR described          Functional                               Channels    Functional        Diverse Trip Primary Trip Function                                                             Comments Section        transient/accident        Unit (FU)*                                to Trip   Unit (FU)*         Function(s)
FU5      Overtemperature Lff         2 out of 4     FU1     Manual Trip Power range high FU2a     neutron flux (high settinQ).
FU6     Overpower Lff 14.2.5    Rupture of a Steam Pipe          FU7a     Pressurizer Pressure - Low  2 out of 3 Safety Injection (SI) Input FU16 from ESFAS FU1     Manual Trip FU2a     Power range high neutron     2 out of 4    FU6     Overpower Lff Rupture of a Control Rod flux (high setting) 14.2.6    Mechanism Housing -
RCCA Ejection FU2b      Power range high neutron    2 out of 4    FU1     Manual Trip flux (low setting)
Inadvertent Opening of a                                                                                                 Bounded by 'Rupture of a 14.2.7                                      NA       NA                             NA          NA     NA SIG Relief or Safety Valve                                                                                               Steam Pipe' event Safety Injection (SI) Input FU16 from ESFAS                  Analysis assumes Small Break Loss-of-Coolant 14.3.1                                     FU7a      Pressurizer Pressure - Low  2 out of 3                                        beyond Charging pump Accident FU5     Overtemperature /::,. T     capacity Safety Injection (SI) Input FU16 from ESFAS Large Break Loss-of-                                                                FU9a      RCS Flow - Low 14.3.2                                     FU7a      Pressurizer Pressure - Low  2 out of 3 Coolant Accident                                                                    FU9b      (single loop) (two loops)
FU1      Manual Trip

Point Beach Nuclear Plant, Units 1 and 2                                                                                       L-2023-011 Docket Nos. 50-266 and 50-301                                                                                               Attachment 2 Page 7 of 7 Table E1-3(1) - Information to Support RPS Instrumentation Redundancy and Diversity (revised)
FSAR            FSAR described         Functional                            Channels   Functional     Diverse Trip Primary Trip Function                                                     Comments Section         transient/accident       Unit (FU)*                            to Trip   Unit (FU)*      Function(s)
Core and Internals Integrity                                                                                   See Large Break LOCA 14.3.3                                      NA      NA                          NA         NA      NA Analysis                                                                                                       event Containment Integrity                                                                                          See Large Break LOCA 14.3.4                                      NA      NA                          NA         NA      NA Evaluation                                                                                                     event Radiological Consequences                                                                                      See Large Break LOCA 14.3.5                                      NA      NA                          NA         NA      NA of Loss-of-Coolant Accident                                                                                    event Reactor Vessel Head Drop 14.3.6                                      NA      NA                          NA         NA      NA                    Rx trip not credited Event
(*)Functional Unit (FU)# from Point Beach TS Table 3.3.1-1

Point Beach Nuclear Plant, Units 1 and 2                                                                                          L-2023-003 Docket Nos. 50-266 and 50-301                                                                                                   Attachment 3 Page 1 of 3 Table E1-3(2), Information to Support ESFAS Instrumentation Redundancy and Diversity (revised)
FSAR             FSAR described         Functional                            Channels    Functional      Diverse ESFAS Primary ESFAS Function                                                             Comments Section          transient/accident       Unit (FU)*                             to Trip   Unit (FU)*        Function(s)
Uncontrolled Rod Withdrawal 14.1.1                                       NA      NA                           NA         NA      NA                           No credited ESF actuation from Subcritical Uncontrolled Rod 14.1.2                                       NA      NA                           NA         NA      NA                           No credited ESF actuation Withdrawal at Power Rod Cluster Control 14.1.3                                       NA      NA                           NA         NA      NA                           No credited ESF actuation Assembly (RCCA) Drop Chemical and Volume 14.1.4                                       NA      NA                           NA         NA      NA                           No credited ESF actuation Control System Malfunction Startup of an Inactive 14.1.5                                       NA      NA                           NA         NA      NA                           No credited ESF actuation Reactor Coolant Loop Reduction in Feedwater 14.1.6                                       NA      NA                           NA         NA      NA                           No credited ESF actuation Enthalpy Incident Excessive Load Increase 14.1.7                                       NA      NA                           NA         NA      NA                           No credited ESF actuation Incident Loss of Reactor Coolant 14.1.8                                       NA      NA                           NA         NA      NA                           No credited ESF actuation Flow Loss of External Electrical 14.1.9                                       NA      NA                           NA         NA      NA                           No credited ESF actuation Load AFW on Undervoltage Bus FU6d A01 and A02 FU6c     AFW on Safety Injection (SI)
AFW on SG Water Level -
14.1.10    Loss of Normal Feedwater         FU6b                               2-out-of-3 Low, Low FU1a     AFW on Manual SI NA      AFWonAMSAC

Point Beach Nuclear Plant, Units 1 and 2                                                                                         L-2023-003 Docket Nos. 50-266 and 50-301                                                                                                  Attachment 3 Page 2 of 3 Table E1-3(2), Information to Support ESFAS Instrumentation Redundancy and Diversity (revised)
AFW on Undervoltage Bus FU6d A01 and A02 Loss of All AC Power to                     AFW on SG Water Level -
14.1.11                                     FU6b                                   2-out-of-3 FU6c AFW on Safety Injection (SI)
Station Auxiliaries                         Low, Low FU1a AFW on Manual SI Likelihood ofTurbine-14.1.12                                       NA      NA                              NA       NA   NA                           No credited ESF actuation Generator Unit Overspeed 14.2.1   Fuel Handling Accident              NA      NA                              NA       NA   NA                           No credited ESF actuation Accidental Release-Recycle 14.2.2                                       NA      NA                              NA       NA   NA                           No credited ESF actuation or Waste Liquid Accidental Release-Waste 14.2.3                                       NA      NA                              NA       NA   NA                           No credited ESF actuation Gas Steam Generator Tube                        SI on Pressurizer Pressure -
14.2.4                                      FU1d                                  2-out-of-3 FU1a  Manual SI Rupture                                    Low SU on SG Flow - High, FU4d  coincident with SI and Low Tavq SU on Containment FU4c Pressure - High, High Steam Line Isolation (SU)
FU4e     on SG Flow - High, High, 1-out-of-2 FU6c  AFW on Safety Injection (SI) coincident with SI 14.2.5    Rupture of a Steam Pipe FU1e     SI on SG Pressure - Low                       SI on Pressurizer Pressure -
2-out-of-3 FU1d Low FU6b     AFW on SG Level - Low, 2-out-of-3       SI on Containment Pressure Low                                     FU1c
                                                                                                    -High, High FU1a  Manual SI

Point Beach Nuclear Plant, Units 1 and 2                                                                                       L-2023-003 Docket Nos. 50-266 and 50-301                                                                                                Attachment 3 Page 3 of 3 Table E1-3(2), Information to Support ESFAS Instrumentation Redundancy and Diversity (revised)
FU4a   Manual SU Rupture of a Control Rod 14.2.6     Mechanism Housing -               NA      NA                            NA       NA     NA                         No credited ESF actuation RCCA Ejection Inadvertent Opening of a                                                                                           Bounded by 'Rupture of 14.2.7                                       NA      NA                            NA       NA     NA SIG Relief or Safety Valve                                                                                         Steam Pipe' Event SI on Containment Pressure FU1c SI on Pressurizer Pressure                   - High Small Break Loss-of-Coolant                                                                                        Analysis assumes beyond 14.3.1                                     FU1d                                 2-out-of-3 Accident                                  -Low                                                                     Charging pump capacity FU1a    Manual SI SI on Containment Pressure FU1c
                                                                                                   - High FU1d     SI on Pressurizer Pressure 2-out-of-3 Large Break Loss-of-                      -Low 14.3.2                                                                                     FU1a    Manual SI Coolant Accident FU2c     CS on Containment           2-out-of-Pressure - High, High          3**    FU 2a   Manual CS Core and Internals Integrity                                                                                       See Large Break LOCA 14.3.3                                       NA      NA                             NA      NA     NA Analysis                                                                                                           event Containment Integrity                    CS on Containment                                                        See Large Break LOCA 14.3.4                                      FU4c                                    NA      NA     NA Evaluation                               Pressure - High, High                                                    event Radiological Consequences                CS on Containment                                                        See Large Break LOCA 14.3.5                                      FU4c                                    NA      NA     NA of Loss-of-Coolant Accident              Pressure - High, High                                                    event Reactor Vessel Head Drop 14.3.6                                       NA       NA                            NA      NA     NA                         No credited ESF actuation Event
(*) Functional Unit (FU)# from Point Beach TS Table 3.3.2-1
(**) 2 out of 3 taken twice; RICT not requested}}