View source for NOC-AE-01001214, Proposed Changes to Loss of Power & AC Sources Technical Specifications

{{Adams
| number = ML020580507
| issue date = 02/14/2002
| title = Proposed Changes to Loss of Power & AC Sources Technical Specifications
| author name = Sheppard J
| author affiliation = South Texas Project Nuclear Operating Co
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000498, 05000499
| license number = NPF-076, NPF-080
| contact person = 
| case reference number = NOC-AE-01001214
| document type = Letter type:NOC, License-Application for Facility Operating License (Amend/Renewal) DKT 50
| page count = 37
}}

=Text=
{{#Wiki_filter:Nuclear Operating Company South Tms ProectElectric GeneiatingStation PO. Box 282 Wadsworth Teas 77483 February 14, 2002 NOC-AE-01001214 10CFR50.90 STI: 31374845 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 South Texas Project Units 1 and 2 Docket Nos. STN 50-498, STN 50-499 Proposed Change to Loss of Power and AC Sources Technical Specifications STP Nuclear Operating Company (STPNOC) submits the attached proposed amendment to South Texas Project Operating Licenses NPF-76 and NPF-80. This license amendment request proposes revising the Technical Specification 3.3.2 requirements for Loss of Power Instrumentation (Functional Unit 8) and Technical Specifications 3.8.1.1, 3.8.1.2, and 3.8.1.3 for AC Sources. In addition, changes to Technical Specification Bases pages are included for your information.
STPNOC requests approval of the proposed amendment by December 15, 2002 to support implementation prior to the Unit I spring 2003 outage. STPNOC requests 60 days for implementation of the amendment after it is approved.
The STPNOC Plant Operations Review Committee and Nuclear Safety Review Board have reviewed and concurred with the proposed change to the Technical Specifications.
In accordance with 10 CFR 50.91(b), STPNOC is notifying the State of Texas of this request for license amendment by providing a copy of this letter and its attachments.

NOC-AE-01001214 Page 2 If there are any questions regarding the proposed amendment, please contact Mr. A. W. Harrison (361) 972-7298 or me at (361) 972-8757.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on             4 1'02.
                        - ate Engineering & Technical Services awh/
Attachments:
: 1. Description of Changes and Safety Evaluation
: 2. Annotated Technical Specification Pages
: 3. Technical Specification Pages with Proposed Changes Incorporated
: 4. Inserts for Technical Specification Bases

NOC-AE-01001214 Page 3 cc:
Ellis W. Merschoff                      Jon C. Wood Regional Administrator, Region IV       Matthews & Branscomb U.S. Nuclear Regulatory Commission      112 East Pecan, Suite 1100 611 Ryan Plaza Drive, Suite 400         San Antonio, Texas 78205-3692 Arlington, Texas 76011-8064 Institute of Nuclear Power Mohan C. Thadani                        Operations - Records Center Project Manager                         700 Galleria Parkway U. S. Nuclear Regulatory Commission     Atlanta, GA 30339-5957 1 White Flint North, Mail Stop 07-DI 11555 Rockville Place                   Richard A. Ratliff Washington, DC 20555                    Bureau of Radiation Control Texas Department of Health Cornelius F. O'Keefe                    1100 West 49th Street c/o U. S. Nuclear Regulatory Commission Austin, TX 78756-3189 P. 0. Box 910 Bay City, TX 77404-0910                 R. L. Balcom/D. G. Tees Reliant Energy, Inc.
A. H. Gutterman, Esquire                P. 0. Box 1700 Morgan, Lewis                           Houston, TX 77251 1111 Pennsylvania Avenue N.W.
Washington, DC 20004                    C. A. Johnson/A. C. Bakken, III AEP - Central Power and Light Company M. T. Hardt/W. C. Gunst                 P. 0. Box 289, Mail Code: N5022 City Public Service                     Wadsworth, TX 77483 P. 0. Box 1771 San Antonio, TX 78296                   U. S. Nuclear Regulatory Commission Attention: Document Control Desk A. Ramirez/C. M. Canady                 Washington, D.C. 20555-0001 City of Austin Electric Utility Department 721 Barton Springs Road Austin, TX 78704

NOC-AE-01001214 Attachment I ATTACHMENT 1 DESCRIPTION OF CHANGES AND SAFETY EVALUATION

NOC-AE-01001214 Attachment 1 Page 1 1.0      Introduction STPNOC is proposing to revise the STP Technical Specifications so that they better reflect the design and function of the loss of power instrumentation and the ESF load sequencer. The current Technical Specification requirements impose unnecessarily restrictive actions that are not consistent with other STP Technical Specification requirements or the STP design basis.
The proposed changes to the STP Technical Specifications are based in part on the Westinghouse Standard Improved Technical Specifications (NUREG-1431). STP's plant specific differences are described and justified.
2.0      Description Each of the proposed changes to the Technical Specifications is described in Table 1 below.
Table 1: Description of Proposed Changes Page      Affected Section             Description of Change                       Reason for Change 3/4 3-24    3.3.2, TABLE      Table 3.3-3 is revised to change the         The STP 2 of 4 actuation logic has 3/4 3-27    3.3-3             Minimum Channels OPERABLE                    adequate redundancy to meet design FUNCTIONAL         requirement for the loss of power            basis requirements with one of the UNIT 8,           instrumentation from 3 channels/bus to 2     channels out of service with no ACTION 20         channels/bus. A new ACTION 20A is            operational restrictions. The current added that prescribes actions for I and 2    TS would require the plant to enter inoperable loss of power channels and        TS 3.0.3 for a condition where more includes an additional action to declare the than one channel of loss of power associated load sequencer inoperable and     instrumentation is inoperable. The apply the ACTION required by TS 3.8.1.1      condition renders the ESF load (AC Sources) when the number of              sequencer inoperable and the OPERABLE channels is less than the           appropriate action is to apply the Minimum Number of Channels. The time         requirements of TS 3.8.1. 1.
required to place the inoperable channel in  STPNOC considers this proposed trip is changed from 1 hour to 72 hours. change an increase in plant reliability.
The time allowed to be in bypass for testing The proposed requirements are is extended from 2 hours to 12 hours.        similar to NUREG-1431.

NOC-AE-01001214 Attachment I Page 2 3/4 8-1     TS 3/4.8.1.1    LCO b. is modified to require an automatic       The proposed change clarifies the load sequencer for each standby diesel           requirements of the current TS and generator. The word "generator" in               complements the proposed change for ACTION d. is made plural. ACTION g. is           the loss of power instrumentation. It added to restore an inoperable load              reflects the way STPNOC currently sequencer to operable status within 7 days       applies the existing TS except that or be in HOT SHUTDOWN within the next            ACTION h. is a new condition. The 12 hours and in COLD SHUTDOWN                    proposed new ACTION h. is different within the following 24 hours. ACTION h.         from NUREG- 1431 in that the is added for one inoperable load sequencer       NUREG has no corresponding action.
and an inoperable standby diesel not             It precludes the need to apply TS associated with the inoperable sequencer,        3.0.3 in this configuration. Changing and requires restoration of one or both          "generator" to "generators" in inoperable components to OPERABLE                ACTION d. is an editorial change status within 24 hours or be in HOT              that acknowledges STP has two SHUTDOWN within the next 12 hours and            remaining operable SDGs in this in COLD SHUTDOWN within the                      configuration.
following 24 hrs.
                           +
3/4 8-9   TS 3/4.8.1.2      The surveillance requirements are revised to     The automatic start of the Standby 3/4 8-9a   TS 3/4.8.1.3      delete the applicability of SRs associated       Diesel Generator (SDG) and load with the load sequencer and/or ECCS (i.e.        sequencing is not required in the 4.8.1.1.2.e.4, 4.8.1.1.2.e.5, 4.8.1. 1.2.e.6,    modes of applicability for these TS.
4.8.1.1.2.e.8, 4.8.1.1.2.e. 10, 4.8.1.1.2.e. 11, ECCS is not required to be operable 4.8.1.1.2.e. 13, and 4.8.1.1.2.f,), and to       in the modes of applicability for these identify SRs that the AC sources are to be       TS. Not requiring certain SRs to be capable of meeting but which are not             performed prevents a SDG from required to be performed (i.e., SRs              being unavailable for required testing 4.8.1.1.2.a.3, 4.8.1.1.2.e.2, 4.8.1.1.2.e.3,     at a time when there may be limited 4.8.1 .1.2.e.7, 4.8.1.1.2.e.9, 4.8.1.1.2.e. 12,  AC sources available. The proposed and 4.8.1.1.2.g)                                 changes assure that the TS clearly represent the STP design basis and reduce the potential for confusion with regard to applying the TS requirements.
3.0      Background STPNOC identified areas where the STP TS are unnecessarily restrictive with regard to the actions required for the TS 3.3.2 Loss of Power Instrumentation. STPNOC determined that the Improved Technical Specifications (NLUREG-1431) offered an approach that is consistent with the STP design. The changes with respect to the requirements for the ESF sequencer and the SRs that are applicable in Mode 5 and 6 will clarify the STP Technical Specifications and minimize the potential for confusion in their application.

NOC-AE-01001214 Attachment 1 Page 3 4.0 Technical Analysis A technical review of each of the proposed changes described in Table I is provided below. The review identifies the affected instrumentation, describes its function, including relevant references to the STP UFSAR, and provides a technical justification for the proposed change.
Proposed Changes to TS 3.3.2 for Loss of Power Instrumentation Two under-voltage sensing schemes are employed for each Class 1E 4.16 kV bus to provide two levels of under-voltage protection. The first scheme detects loss of voltage and the second scheme detects degraded voltage conditions on the bus. Voltage signals to each scheme are provided through four potential transformers connected to each bus.
Four solid-state type instantaneous under-voltage relays and four time delay relays are used for the first scheme (loss of voltage). The devices used for the second scheme (degraded voltage) include four solid-state type instantaneous under-voltage relays and two sets of four time delay relays. (Ref: UFSAR Section 8.3.1.1.4.6.3)
The OPERABILITY requirements for the Loss of Power 4.16 kV ESF under-voltage relays and the 4.16 kV ESF degraded voltage relays are found under functional unit 8 in Table 3.3-3 of TS 3.3.2. The Loss of Power 4.16 kV ESF under-voltage relays and the 4.16 kV ESF degraded voltage relays are required for the ESF systems to automatically function in any accident in which the loss of offsite power is assumed in the safety analysis.
The design function of the Loss of Power 4.16 kV ESF under-voltage relays and the 4.16 kV ESF degraded voltage relays is to provide an input to the associated ESF load sequencer when an under-voltage or degraded voltage condition is sensed from the offsite power source. The normal logic for a loss of power ESF actuation is two of four channels actuating.
The TS allow continued operation with one inoperable loss of power instrumentation channel if the channel is placed in the tripped condition. There is no action in the TS if more than one channel is inoperable. The applicable TS in this case would be TS 3.0.3, which is unduly restrictive. STPNOC proposes to change the Minimum Channels OPERABLE requirement for the loss of power instrumentation in Table 3.3-3 from 3 channels to 2 channels and provide ACTION requirements for one and two inoperable channels. This will take advantage of STP's 4 channel design for the function and enhance plant reliability. With less than the Minimum Channels OPERABLE, the associated sequencer would be declared inoperable. If the plant were operating in the proposed Minimum Channels Operable configuration, it would be in compliance with a required action to have one of the inoperable channels in the trip condition, similar to the action required by the current TS.

NOC-AE-01001214 Attachment 1 Page 4 Four channels per bus comprise the STP loss of power instrumentation design and the TS reflect that the Total Number of Channels is four. The loss of power actuation logic is 2 of the 4 channels tripping. There is no regulatory requirement for the station to have 4 channels in this function, and as long as STP retains adequate assurance that at least two channels would trip on undervoltage, the design basis will be met. If one channel is inoperable, this can be accomplished with a 2 of 3 logic with the remaining operable channels with the inoperable channel taken out of service. If two channels were inoperable, it can be accomplished by placing one of the inoperable channels in the tripped condition and operating with a 1 of 2 logic. In each of the action conditions, there is adequate assurance that the operable instruments will perform the design function, even considering that one operable channel fails.
As described above, the loss of power instruments perform a support function for their associated ESF load sequencers. Therefore, when there are fewer than the Minimum Channels Operable requirement, the result is that the ESF load sequencer is inoperable.
The appropriate TS to apply to an inoperable ESF load sequencer in Mode 1, 2, 3 or 4 is TS 3/4.8.1.1 for AC Sources - Operating. STPNOC proposes to revise the TS for the loss of power instrumentation to direct the operator to apply this TS when there are fewer than the Minimum Channels Operable requirement for this instrumentation.
The proposed change includes extending the time allowed to place an inoperable channel in the tripped condition from 1 hour to 72 hours and the time allowed for being in bypass for testing from 2 hours to 12 hours. The time extensions are the same as those requested for ACTION 20 in STPNOC's proposed change dated May 30, 2001 "'ProposedRevision to Reactor Trip System and Engineered Safety Features Actuation System Allowed Outage Times and Bypass Test Times" (NOC-AE-01001055). The technical basis and justification for changes to ACTION 20 in the May 30, 2001 letter also apply to the loss of power instrumentation.
This change is generally consistent with the requirements of NUREG- 143 1, although the format is somewhat different in that STPNOC is not proposing to make the Loss of Power Instrumentation a separately numbered specification. In addition, NUREG-1431 does not limit the mode of applicability to Modes 1, 2, 3, and 4. However, STP's current TS for the instrumentation apply only in Mode 1, 2, 3, and 4 and STPNOC has determined that is consistent with the STP design basis, so no change to the modes of applicability is proposed.

NOC-AE-01001214 Attachment I Page 5 Proposed Change to TS 3/4.8.1.1 for ESF Load Sequencer The current STP Technical Specifications do not have specific LCO or ACTION for the ESF load sequencers although the sequencers are addressed in the surveillance requirements. STPNOC proposes to add the load sequencers to the LCO and incorporate an ACTION g. to define the required action for situations where a sequencer is inoperable.
The UFSAR Section 8.3.1.1.4.4 description of the ESF load sequencer design functions is summarized below.
Mode I: Safety Injection (SI) only
: 1. Energize the equipment for the emergency event in programmed steps
: 2. "Memorize" the existence of a Mode I signal to enable recognition of a Mode III condition For Mode I, the sequencer does not start the SDGs; however, the SDGs are started by the ESFAS SI signal but not loaded on the bus.
Mode II - Loss of Off-site Power (LOOP) only and Mode II - SI + LOOP
: 1. Shed all loads on the 4.16 kV ESF bus. However, shedding of the load center transformers distribution network is accomplished by tripping the breakers on the 480 V secondary side of the transformers only. The breakers on the primary side of the transformers remain connected
: 2. Start the SDG with the governor in the isochronous mode and the voltage regulator in the automatic mode.
: 3. Trip the 4.16 kV ESF power supply breakers to disconnect the Class 1E onsite power system from the offsite source
: 4. Energize the equipment for the emergency event (LOOP or SI + LOOP) in programmed steps For Mode II, the SDGs will receive a redundant start signal from ESFAS.
The ESF load sequencer is considered a support system for the associated diesel generator and those components actuated by a sequencer Mode I signal (Ref: TS Bases SR 4.8.1.1.2.e. 11).
Based on the above, the proposed required action is to declare the sequencer inoperable and to restore the inoperable sequencer to operable status within 7 days or go to COLD SHUTDOWN. The 7 day allowed outage time for an inoperable sequencer is based on the most limiting allowed outage times for components actuated by the sequencer. The

NOC-AE-01001214 Attachment 1 Page 6 limiting systems include safety injection, essential cooling water, component cooling water, and essential chilled water'.
No ACTION is proposed for cases where more than one sequencer is inoperable, so TS 3.0.3 would apply in those cases. In this configuration, at least two of STP's three trains of Design Basis Accident mitigation equipment would be inoperable because of the inoperable sequencers (eg., Essential Cooling Water or Component Cooling Water), and the current TS already require STPNOC to apply TS 3.0.3.
Action h. is proposed for the configuration where there is one inoperable sequencer and one inoperable diesel (on a different train than the inoperable sequencer). The action requires restoration of at least one of the two inoperable components within 24 hours.
The proposed action time is consistent with the time required in TS 3.8.1.1.d for an inoperable diesel with another component that depends on one of the operable diesels also inoperable. The proposed action time is also consistent with the required action time for TS 3.8.1.1.f. for two inoperable standby diesel generators. A condition where there is one inoperable sequencer and one inoperable standby diesel is considered comparable to the conditions of TS 3.8.1.ld. or TS 3.8.1.1.f. Note that the operator can manually start and load the standby diesel that is made inoperable by the inoperable sequencer. NUREG 1431 has no corresponding action and STP's design with 3 standby diesels makes this plant-specific action reasonable.
Proposed Change to SR for TS 3/4.8.1.2 and TS 3/4.8.1.3 The current TS 4.8.1.2 and 4.8.1.3 refer the operator to the Surveillance Requirements for TS 3.8.1.1 with only one exception each. Application of the current TS would require the surveillance requirements for the ESF sequencer to be met in Modes 5 and 6 and would further require the surveillance requirements related to ECCS to be met. However, as described below, the sequencer and ECCS functions are not required by the STP design basis for OPERABILITY in these Modes. Tables 2 and 3 below outline the changes proposed for these TS surveillance requirements. The tables apply to both TS since both TS are applicable in Modes 5 and 6.
Table 2 lists the SRs that are still required to be met but are not required to be performed.
The technical basis is the same for each surveillance in the table and is as stated in the NUREG-1431 Bases:
                  ... to preclude requiring the OPERABLE DG(s) from being paralleled with the offsite power network or otherwise rendered inoperable during performance of SRs, and to preclude deenergizing a required 4160 V ESF bus or disconnecting a required offsite circuit during performance of SRs. With limited AC sources This proposed change is prepared anticipating approval of STPNOC's proposed change to TS 3.7.1.2 required ACTION times for Auxiliary Feedwater submitted in letter dated December 3, 2001 (NOC-AE-01001 196). With the proposed change to the AFW allowed outage times in that application, AFW will not have the most limiting allowed outage time (currently 72 hours).

NOC-AE-01001214 Attachment 1 Page 7 available, a single event could compromise both the required circuit and the DG.
It is the intent that these SRs must still be capable of being met, but actual performance is not required during periods when the DG and offsite circuit is required to be OPERABLE.
SR 4.8.1.1.2.e.12 and 4.8.1.1.2.g have no corresponding NUREG-1431 requirements, but the same technical justification applies.
Table 3 lists the SRs that are not applicable in Modes 5 and 6 and the basis for the exclusion of each one. The changes are generally consistent with NUREG-1431 and the differences are identified in the table.
The ESF Load Sequencer is not required to be operable in Mode 5 or Mode 6. STP's accident analyses take no credit for automatic load shedding or sequencing in these modes.
The pertinent design basis accidents in Modes 5, 6, and defueled are the Fuel Handling Accident, Low Temperature Overpressure, and Boron Dilution (Mode 5 with RCS filled and vented). The STP analyses for these accidents do not assume a concurrent loss of off-site power. Assuming a loss of off-site power with a Fuel Handling Accident is not required. Assuming a loss of off-site power in this scenario would remove the forced air circulation and subsequent dispersion of the contaminated air, which may be nonconservative. In the case of Low Temperature Overpressure, assuming a loss of off site power would not have an adverse effect on the results of the analysis. Assuming a loss of off-site power with a dilution event would be nonconservative because the loss of power will terminate the dilution flow as the charging pump loses power.
A loss of off-site power in Mode 5 or Mode 6 would be expected to cause a loss of power to RHR and interrupt decay heat removal. Although the loss of power instrumentation and the sequencer are normally operable for their associated SDG in Mode 5 and Mode 6, the current TS do not require them to be operable. Operator response may require manual start of the Standby Diesel Generator and manual loading of the ESF bus. The STP design does not automatically sequence RHR on to the bus even in Modes where the sequencer is required to be operable. Application of the definition of OPERABLE OPERABILITY in conjunction with the use of STP's procedures provides adequate guidance for STP operators to determine the instrumentation required for the plant configuration. For instance, during reduced inventory operations, STP procedures require all diesel support instrumentation to be operable.

NOC-AE-01001214 Attachment 1 Page 8 Table 2: Surveillance Requirements to Be Met But Not Required To Be Performed SR                                                       Description 4.8.1.1.2.a.3  At least once per 31 days on a staggered test basis:
Verifying the generator is synchronized, loaded to 5000 to 5500 kW, and operates with a load of 5000 to 5500 kW for at least 60 minutes (4)(6) 4.8.1.1.2.e.2  At least once per 18 months during shutdown, by:
Verifying the generator capability to reject a load of greater than or equal to 785.3kW while maintaining voltage at 4160 +/- 416 volts and frequency at 60 +/- 4.5 Hz (4)(5) 4.8.1.1.2.e.3  At least once per 18 months during shutdown, by:
Verifying the generator capability to reject a load of 5500 kW without tripping. The generator voltage shall not exceed 5262 volts during and following the load rejection(4)(5) 4.8.1.1.2.e.7  At least once per 18 months during shutdown, by:
(10) Verifying the standby diesel generator operates for at least 24 hours. During the first 2 hours of this test, the diesel generator shall be loaded to 5700 to 6050 kW141(l)(6' and during the remaining 22 hours of this test, the diesel generator shall be loaded to 5000 to 5500 kW. (6) The steady-state generator voltage and frequency shall be 4160 +/- 416 volts and 60 +/- 1.2 Hz during this test. Within 5 minutes after completing this 24-hour test, perform a fast start per Specification 4.8.1.1.2.a.2(7) 4.8.1.1.2.e.9   At least once per 18 months during shutdown, by:
Verifying the standby diesel generator's capability to:
a) Synchronize with the offsite power source while the generator is loaded with its ESF loads upon a simulated restoration of offsite power, b) Transfer its loads to the offsite power source, and c) Be restored to its standby status 4.8.1.1.2.e.12  At least once per 18 months during shutdown by:
Verifying that the standby diesel generator emergency stop lockout feature prevents diesel generator starting 4.8.1.1.2.g     At least once per 10 years by draining each fuel tank, removing the accumulated sediment and cleaning the tank.
Table 3: Surveillance Requirements Not Applicable in Mode 5 and 6 SR                            Description                                Basis for Proposed Change 4.8.1.1.2.e.4   At least once per 18 months during shutdown by:       This proposed change differs from NUREG Simulating a loss-of-offsite power by itself, and:     1431. As discussed above, the ESF Load Sequencer is not required to be OPERABLE by a)     Verifying deenergization of the ESF busses     the STP design basis or accident analyses.
and load shedding from the ESF busses, and b)     Verifying the diesel starts on the auto-start signal within 10 seconds, energizes the auto-connected shutdown loads through the load sequencer and operates for greater than or equal to 5 minutes while its generator is loaded with the shutdown loads. After energization, the steady-state voltage and frequency of the ESF busses shall be maintained at 4160 +/- 416 volts and 60 +/- 1.2 Hz during this test.

NOC-AE-01001214 Attachment 1 Page 9 4.8.1.1.2.e.5    At least once per 18 months during shutdown by:      The STP ECCS is not required to be operable Verifying that on a Safety Injection test signal,    in Mode 5 or Mode 6 and this change is without loss-of-offsite power, the diesel            consistent with the ECCS instrumentation generator starts on the auto-start signal and        requirements that do not require the ECCS operates on standby for greater than or equal to 5   signals when the ECCS System is not minutes. The generator voltage and frequency         required to be OPERABLE This is consistent shall be 4160 +/- 416 volts and 60 +/- 1.2 Hz within     with NUREG-1431.
10 seconds after the autostart signal; the steady state generator voltage and frequency shall be maintained within these limits during this test 4.8.1.1.2.e.6    At least once per 18 months during shutdown by:      The STP ECCS is not required to be operable Simulating a loss-of-offsite power in conjunction    in Mode 5 or Mode 6 and this change is with a Safety Injection test signal, and:            consistent with the ECCS instrumentation a)     Verifying deenergization of the ESF busses    requirements that do not require the ECCS and load shedding from the ESF busses;        signals when the ECCS System is not b) Verifying the diesel starts on the auto-start signal within 10 seconds, energizes the       required to be OPERABLE. Items a and b are auto-connected ESF (accident) loads           consistent with NUREG- 1431.
through the load sequencer and operates for greater than or equal to 5 minutes while  Item c differs from NUREG- 1431 in that a its generator is loaded with the ESF loads,   correlation with NUREG- 1431 would list this After, energization, the steady-state voltage SR with the SRs in Table 2. However, within and frequency of the ESF busses shall be      the STP TS, this is a SR that is directly maintained at 4160 +/- 416 volts and 60+/-        associated with supporting ECCS requirements 1.2 Hz during this test; and                  and is more appropriately listed with the SRs c)     Verifying that all automatic diesel             an is mor appriate iste w the         6.
generator trips, except engine overspeed,     that are not applicable in Mode 5 and 6.
generator differential, and low lube oil pressure are automatically bypassed upon loss of voltage on the ESF bus concurrent with a Safety Injection Actuation signal.
4.8.1.1.2.e.8    At least once per 18 months during shutdown by:      This SR is appropriately performed to confirm Verifying that the auto-connected loads to each      the ESF loads for the Mode 1, 2, 3, and 4 standby diesel generator do not exceed the 2000-     events. Since STP does not require an operable hour rating of 5935 kW                                sequencer in Mode 5 or 6, there are no auto connected loads to verify in these modes.
4.8.1.1.2.e. 10  At least once per 18 months during shutdown by:      The STP ECCS is not required to be operable Verifying that with the standby diesel generator      in Mode 5 or Mode 6 and this change is operating in a test mode, connected to its bus, a     consistent with the ECCS instrumentation simulated Safety Injection signal overrides the       requirements that do not require the ECCS test mode by: (1) returning the diesel generator     signals when the ECCS System is not to standby operation, and (2) automatically          required to be OPERABLE This is consistent energizing the ESF loads with offsite power (5)      with NUREG-1431.
4.8.1.1.2.e. 1I  At least once per 18 months during shutdown by:      This proposed change differs from NUJREG Verifying that the automatic load sequence timer     1431. As discussed above, the ESF Load is OPERABLE with the first sequenced load            Sequencer is not required to be OPERABLE by verified to be loaded between 1.0 second and 1.6     the STP design basis or accident analyses.
seconds, and all other load blocks within +/- 10%
of its design interval

NOC-AE-01001214 Attachment 1 Page 10 4.8.1 .1.2.e. 13  At least once per 18 months during shutdown by:    This proposed change differs from NUREG Demonstrating the OPERABILITY of the               1431. As discussed above, the ESF Load automatic load shed bypass and the manual load     Sequencer is not required to be OPERABLE by shed reinstatement features of the load sequencer the STP design basis or accident analyses.
4.8.1.1.2.f        At least once per 10 years or after any           This SR is not applicable in Mode 5 and 6 modifications which could affect standby diesel   where the full complement of SDGs is not generator interdependence by starting all standby required and interdependence is of lesser diesel generators simultaneously, during          concern. This is consistent with NUREG-143 1.
shutdown, and verifying that all standby diesel generators accelerate to at least 600 rpm in less than or equal to 10 seconds Notes from TS page 3/4 8-7 applicable to Tables 2 and 3 (for completeness of information - no changes proposed):
(1)        Loss of one 13.8 kV Standby Bus to 4.16 kV ESF bus line constitutes loss of one offsite source. Loss of two 13.8 kV Standby busses to 4.16 kV ESF bus lines constitutes loss of two offsite sources.
(2)        All diesel generator starts for the purpose of these surveillances may be preceded by a prelube period.
(3)        A diesel generator start in less than or equal to 10 seconds (fast start) shall be performed every 184 days. All other diesel generator starts for the purpose of this surveillance may be modified starts involving reduced fuel (load limit) and/or idling and gradual acceleration to synchronous speed.
(4)        Generator loading may be accomplished in accordance with vendor recommendations, including a warmup period prior to loading.
(5)        The diesel generator start for this surveillance may be a modified start (see SR 4.8.1.1.2a.2)).
(6)        Momentary transients outside this load range due to changing conditions on the grid shall not invalidate the test.
(7)        If Specification 4.8.1.1.2a.2) is not satisfactorily completed, it is not necessary to repeat the preceding 24-hour test. Instead, the standby diesel generator may be operated at 5000-5500 kW for a minimum of 2 hours or until operating temperature has stabilized.
(8)        (Not used)
(9)        (Not used)
(10)       This test may be performed during power operation provided that the other two diesel generators are operable.
(11)       Credit may be taken for events that satisfy any of these Surveillance Requirements.

NOC-AE-01001214 Attachment 1 Page 11 5.0 Regulatory Safety Analysis 5.1      No Significant Hazards Determination STPNOC has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10CFR50.92, "Issuance of amendment," as discussed below.
: 1)      Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No.
The proposed changes do not change the plant design basis, system configuration or operation, and do not add or affect any accident initiator.
Therefore, STPNOC concludes that there is no significant increase in the probability or consequences of an accident previously evaluated.
: 2)      Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No.
The proposed changes do not change the plant design basis, system configuration or operation, and do not add or affect any accident initiator.
Therefore, STPNOC concludes the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
: 3)      Does the proposed change involve a significant reduction in a margin of safety?
Response: No.
No actual plant equipment or accident analyses will be affected by the proposed change. Additionally, the proposed changes will not relax any criteria used to establish safety limits, will not relax any safety systems settings, or will not relax the bases for any limiting conditions of operation. Therefore, STPNOC concludes the proposed changes do not involve a significant reduction in the margin of safety.
Conclusion Based upon the analysis provided herein, the proposed amendments do not involve a significant hazards consideration.

NOC-AE-01001214 Attachment 1 Page 12 5.2     Applicable Regulatory Requirements/Criteria The regulatory basis for Technical Specification 3.8.1.1, 3.8.1.2, and 3.8.1.3 (Electrical Power Systems, A.C. and D. C. Power Sources, Operating and Shutdown), and 3.3.2, "Loss of Power Instrumentation," is to ensure that sufficient power will be available to supply the safety-related equipment required for: (1) the safe shutdown of the facility, and (2) the mitigation and control of accident conditions within the facility. The minimum specified independent and redundant A.C. and D.C. sources satisfy the requirements of General Design Criteria (GDC) 17 of Appendix A to 10CFR Part 50.
The South Texas design has met GDC 2 and 4 with respect to structures, systems, and components of the onsite A.C. and D.C. power system being capable of withstanding the effects of natural phenomena (such as earthquake, tornadoes, hurricanes, and floods),
missiles, and environmental conditions associated with normal operation and postulated accidents.
The South Texas design has met GDC 5 with respect to structures, systems, and components of the A.C. and D.C. onsite power system. The onsite power system and components associated with Units 1 and 2 are housed in physically separate seismic Category I structures and are not shared.
The South Texas design has met GDC 17 which requires that all redundant equipment and circuits are separated by physically locating them in separate areas, separating by distance in the same area, and/or providing barriers between them.
The South Texas design has met GDC 18 with respect to the onsite A. C. and D.C. power system. The onsite power system is designed to be testable during station operation as well as when the station is shut down.
Because the proposed changes do not alter the design basis, change the plant configuration or significantly change operation procedures, STP maintains compliance with all applicable regulatory requirements.
In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

NOC-AE-01001214 Attachment 1 Page 13 6.0 Environmental Considerations 10 CFR 51.22(b) specifies the criteria for categorical exclusions from the requirements for a specific environmental assessment per 10 CFR 51.21. This amendment request meets the criteria specified in 10 CFR 51.22(c)(9). The specific criteria contained in this section are discussed below.
(i)     the amendment involves no significant hazards consideration As demonstrated in the No Significant Hazards Consideration Determination, the requested license amendment does not involve any significant hazards consideration.
(ii)     there is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite The requested license amendment involves no change to the facility and does not involve any change in the manner of operation of any plant systems involving the generation, collection or processing of radioactive materials or other types of effluents. Therefore, no increase in the amounts of effluents or new types of effluents would be created.
(iii)      there is no significant increase in individual or cumulative occupational radiation exposure The requested license amendment involves no change to the facility and will not increase the radiation dose resulting from the operation of any plant system. Furthermore, implementation of this proposed change will not involve work activities which could contribute to occupational radiation exposure. Therefore, there will be no increase in individual or cumulative occupational radiation exposure associated with this proposed change.
Based on the above it is concluded that there will be no impact on the environment resulting from this change. The change meets the criteria specified in 10 CFR 51.22 for a categorical exclusion from the requirements of 10 CFR 51.21 relative to specific environmental assessment by the Commission.

NOC-AE-01001214 Attachment I Page 14 7.0 References
: 1. NUREG-1431 "Standard Technical Specifications, Westinghouse Plants"
: 2. South Texas Project Updated Final Safety Analysis Report
: 3. Procedure OPGP04-AE0001, "First Response to Loss of Any or All 13.8 KV or 4.16 KV Bus"
: 4. Procedure OPGP04-AE0003, "Loss Of Power To One Or More 13.8 KV Standby Bus"
: 5. Procedure OPGP03-ZO0035, "Reduced RCS Inventory Operations"
: 6. STPNOC letter to NRC Document Control Desk dated December 3, 2001, "Proposed Amendment to Technical Specification 3.7.1.2" (NOC-AE-0100 1196)
: 7. STPNOC letter to NRC Document Control Desk dated May 30, 2001 "Proposed Revision to Reactor Trip System and Engineered Safety Features Actuation System Allowed Outage Times and Bypass Test Times" (NOC-AE-01001055)

NOC-AE-01001214 Attachment 2 ATTACHMENT 2 PROPOSED TECHNICAL SPECIFICATION CHANGES

NOC-AE-01001214 Attachment 2 TABLE 3.3-3 (Continued)
ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION SMINIMUM                                                                            APPLICABLE
  ""                                          TOTAL NO.           CHANNELS  CHANNELS      MODES
  >        FUNCTIONAL UNIT                    OF CHANNELS           TO TRIP OPERABLE                  ACTION
: 8. Loss of Power
: a. 4.16 kV ESF Bus Under-       4/bus            2/bus        32 /bus  1, 2, 3,4        20A
  --             voltage-Loss of Voltage
: b. 4.16 kV ESFBus Under voltage-Tolerable Degraded Voltage Coincident with SI   4/bus            2/bus        32/bus   1, 2, 3, 4       20A
: c. 4. 16 kV ESF Bus Under voltage - Sustained Degraded Voltage                      4/bus            2/bus        32/bus   1, 2, 3, 4       20A
: 9. Engineered Safety Features Actuation System Interlocks
: a. Pressurizer Pressure, P- 11  3                2            2        1, 2, 3          21
: b. Low-Low T,,vg, P-12          4                2            3        1,2,3            21
: c. Reactor Trip, P-4            2                1            2        1, 2, 3          23 p    1 El.,
CDZ Elo

NOC-AE-01001214 Attachment 2 TABLE 3.3-3 (Continued)
ACTION STATEMENTS (Continued)
ACTION 19   With the number of OPERABLE channels one less than the Minimum Channels OPERABLE requirement, restore the inoperable channel to OPERABLE status within 48 hours or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours.
ACTION 20 - With the number of OPERABLE channels one less than the Total Number of Channels, STARTUP and/or POWER OPERATION may proceed provided the following conditions are satisfied:
: a.      The inoperable channel is placed in the tripped condition within 1 hour, and
: b.      The Minimum Channels OPERABLE requirement is met; however, the inoperable channel may be bypassed for up to 2 hours for surveillance testing of other channels per Specification 4.3.2.1.
I INSERT I1 ACTION 21   With less than the Minimum Number of Channels OPERABLE, within 1 hour determine by observation of the associated permissive annunciator window(s) that the interlock is in its required state for the existing plant condition, or apply Specification 3.0.3.
ACTION 22   With the number of OPERABLE channels one less than the Minimum Channels OPERABLE requirement, be in at least HOT STANDBY within 6 hours and in at least HOT SHUTDOWN within the following 6 hours; however, one channel may be bypassed for up to 2 hours for surveillance testing per Specification 4.3.2.1 provided the other channel is OPERABLE.
ACTION 23   With the number of OPERABLE channels one less than the Total Number of Channels, restore the inoperable channel to OPERABLE status within 48 hours or be in at least HOT STANDBY within 6 hours and in at least HOT SHUTDOWN within the following 6 hours.
ACTION 24      With the number of OPERABLE channels one less than the Total Number of Channels, restore the inoperable channel to OPERABLE status within 48 hours or declare the associated valve inoperable and take the ACTION required by Specification 3.7.1.5.
ACTION 25 -    With the number of OPERABLE channels one less than the Minimum Channels OPERABLE requirement, be in at least HOT STANDBY within 6 hours; however, one channel may be bypassed for up to 2 hours for surveillance testing per Specification 4.3.2.1 provided the other channel is OPERABLE.
SOUTH TEXAS - UNITS 1 & 2                   3/4 3-27              Unit I - Amendment No. -24 Unit 2 - Amendment No. 44

NOC-AE-01001214 Attachment 2 INSERT 1 ACTION 20A - a. With the number of OPERABLE channels one less than the Total Number of Channels, STARTUP and/or POWER OPERATION may proceed provided the following conditions are satisfied:
: 1. The inoperable channel is removed from service or placed in the tripped condition within 72 hours, and
: 2. The Minimum Channels OPERABLE requirement is met; however, an inoperable channel in the tripped condition may be bypassed for up to 12 hours for surveillance testing of other channels per Specification 4.3.2.1.
: b. With the number of OPERABLE channels two less than the Total Number of Channels, STARTUP and/or POWER OPERATION may proceed provided:
: 1. one inoperable channel is placed in the tripped condition and one inoperable channel is removed from service within 72 hours, and
: 2. The Minimum Channels OPERABLE requirement is met; however, the inoperable channel may be bypassed for up to 12 hours for surveillance testing of other channels per Specification 4.3.2.1.
: c. With the number of OPERABLE channels less than the Minimum Number of Channels, declare the associated load sequencer inoperable and apply the ACTION required by Technical Specification 3.8.1.1.

NOC-AE-01001214 Attachment 2 3/4.8 ELECTRICAL POWER SYSTEMS 3/4.8.1    A.C. SOURCES OPERATING LIMITING CONDITION FOR OPERATION 3.8.1.1  As a minimum, the following A.C. electrical power sources shall be OPERABLE.
: a. Two physically independ M t circuits between the offsite transmission network and the onsite Class IE Distribution System    , and
: b. Three separate and independent standby diesel generators, each with a separate fuel tank containing a minimum volume of 60,500 gallons of fuel, and an automatic load sequencer.
APPLICABILITY:            MODES 1, 2, 3, and 4.
ACTION:
: a. With one offsite circuit of the above-required A.C. electrical power sources inoperable, demonstrate the OPERABILITY of the remaining A.C. sources by performing Surveillance Requirement 4.8.1..1.a within 1 hour and at least once per 8 hours thereafter. Restore the offsite circuit to OPERABLE status within 72 hours or be in at least HOT SHUTDOWN within the next 12 hours and in COLD SHUTDOWN within the following 24 hours.
: b. With a standby diesel generator inoperable, demonstrate the OPERABILITY of the above-required A.C. offsite sources by performing Surveillance Requirement 4.8.1.1.1.a within 1 hour and at least once per 8 hours thereafter. If the standby diesel generator became inoperable due to any cause other than an inoperable support system, an independently testable component, or preplanned preventive maintenance or testing, demonstrate the OPERABILITY of the remaining OPERABLE standby diesel generators by performing Surveillance Requirement 4.8.1.1.2.a.2) for each such standby diesel generator separately within 8 hours, unless it can be demonstrated there is no common mode failure for the remaining diesel generator(s). Restore the inoperable standby diesel generator to OPERABLE status within 14 days or be in at least HOT SHUTDOWN within the next 12 hours and in COLD SHUTDOWN within the following 24 hours.
: c. With one offsite circuit of the above-required A.C. electrical power sources and one standby diesel generator inoperable, demonstrate the OPERABILITY of the remaining A.C. sources by performing Specification 4.8.1.1.1a. within 1 hour and at least once per 8 hours thereafter; and if the standby diesel generator became inoperable due to any cause other than an inoperable support system, an independently testable component, or preplanned preventive SOUTH TEXAS - UNITS 1 & 2                          3/4 8-1                   Unit I - Amendment No. 68,-g5 Unit 2 - Amendment No. 7,-7

NOC-AE-01001214 Attachment 2 ELECTRICAL POWER SYSTEMS LIMITING CONDITION FOR OPERATION ACTION (Continued) maintenance or testing, demonstrate the OPERABILITY of the remaining OPERABLE standby diesel generator(s) by performing Surveillance Requirement 4.8.1.1.2a.2) within 8 hours, unless it can be demonstrated there is no common mode failure for the remaining diesel generators; restore at least one of the inoperable sources to OPERABLE status within 12 hours or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours. Restore at least two offsite circuits to OPERABLE status within 72 hours and three standby diesel generators to OPERABLE status within 14 days from the time of initial loss or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours.
: d. With one standby diesel generator inoperable in addition to ACTION b. or c. above, verify that:
: 1. All required systems, subsystems, trains, components, and devices that depend on the remaining OPERABLE diesel generators as a source of emergency power are also OPERABLE, and
: 2. When in Mode 1, 2, or 3, the steam-driven auxiliary feedwater pump is OPERABLE.
If these conditions are not satisfied within 24 hours be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours.
: e. With two of the above required offsite A.C. circuits inoperable, restore at least one of the inoperable offsite sources to OPERABLE status within 24 hours or be in at least HOT STANDBY within the next 6 hours. With only one offsite source restored, restore at least two offsite circuits to OPERABLE status within 72 hours from time of initial loss or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours.
: f. With two or three of the above required standby diesel generators inoperable, demonstrate the OPERABILITY of two offsite A.C. circuits by performing the requirements of Specification 4.8.1.1. Ia. within 1 hour and at least once per 8 hours thereafter; restore at least one standby diesel generator to OPERABLE status within 2 hours and at least two standby diesel generators to OPERABLE status within 24 hours or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours. Restore at least three standby diesel generators to OPERABLE status within 14 days from time of initial loss or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours.
: g. With one required load sequencer inoperable, restore the inoperable load sequencer to operable status within 7 days or be in HOT SHUTDOWN within the next 12 hours and in COLD SHUTDOWN within the following 24 hours.
: h. With one required load sequencer inoperable and one required standby diesel generator not associated with the inoperable sequencer also inoperable, restore the inoperable load sequencer and/or the inoperable standby diesel generator not associated with the inoperable load sequencer to OPERABLE status within 24 hours or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours.
SOUTH TEXAS - UNITS I & 2                        3/4 8-2                Unit 1 - Amendment No. 68, 5 Unit 2 - Amendment No. 57,-,72

NOC-AE-01001214 Attachment 2 ELECTRICAL POWER SYSTEMS A.C. SOURCES SHUTDOWN LIMITING CONDITION FOR OPERATION 3.8.1.2 As a minimum, the following A.C. electrical power sources shall be OPERABLE:
: a. One circuit between the offsite transmission network and the Onsite Class IE Distribution System, and
: b. Two' standby diesel generators each with a separate fuel tank containing a minimum volume of 60,500 gallons of fuel.
APPLICABILITY:              Mode 5 and Mode 6 with water level in the refueling cavity <23 ft above the reactor pressure vessel flange.
ACTION:
With less than the above minimum required A.C. electrical power sources OPERABLE, immediately suspend all operations involving CORE ALTERATIONS, operations involving positive reactivity additions that could result in loss of required SHUTDOWN MARGIN or required boron concentration, movement of irradiated fuel, operations with a potential for draining the reactor vessel or crane operation with loads over the spent fuel pool. Immediately initiate actions to restore the inoperable A.C. electrical power source to OPERABLE status.
SURVEILLANCE REQUIREMENTS 4.8.1.2 The ab*ve required A.C. electrical power sources shall be demnstr-ated OPEP.A.BLE by the pefcf"-anee oe each4o the r-eqairements of Specifications 4.8.1.1.1, 4.8.6.1.2 (exeept fer Specification 4.9.1.1.2a.3), and 4.9.1.1.3.
For AC sources required to be OPERABLE, the surveillance requirements of Specification 3.8.1.1, "AC Sources - Operating", are applicable (except 4.8.1.1.2.e.4, 4.8.1.1.2.e.5, 4.8.1.1.2.e.6, 4.8.1.1.2.e.8, 4.8.1.1.2.e.10, 4.8.1.1.2.e.11, 4.8.1.1.2.e.13, and 4.8.1.1.2.f).
                                                           -NOTES
: 1. The following surveillance requirements are not required to be performed: 4.8.1.1.2.a.3, 4.8.1.1.2.e.2, 4.8.1.1.2.e.3, 4.8.1.1.2.e.7, 4.8.1.1.2.e.9, 4.8.1.1.2.e.12, and 4.8.1.1,2.g.
4.8.1.2.1        The alternate onsite emergency power source shall be demonstrated functional by:
: a.      Within 4 hours of taking credit for the onsite emergency power source as a standby diesel generator, verify it starts and achieves steady state voltage (+/-10%) and frequency (+/-2%) in 5 minutes.
: b.      Within 4 hours of taking credit for the onsite emergency power source as a standby diesel generator and every 8 hours thereafter, verify the emergency power source is capable of being aligned to the required ESF bus by performing a breaker alignment check.
 'An alternate onsite emergency power source, capable of supplying power for one train of shutdown cooling may be substituted for one of the required diesels for 14 consecutive days (SR 4.8.1.2.1 is the only requirement applicable).
SOUTH TEXAS - UNITS I & 2                               3/4 8-9                  Unit 1 - Amendment No. 71-428 Unit 2 - Amendment No. 60-17

NOC-AE-01001214 Attachment 2 ELECTRICAL POWER SYSTEMS A.C. SOURCES SHUTDOWN LIMITING CONDITION FOR OPERATION 3.8.1.3    As a minimum, the following A.C. electrical power sources shall be OPERABLE:
: a. One circuit between the offsite transmission network and the Onsite Class IE Distribution System, and
: b. One standby diesel generator with a separate fuel tank containing a minimum volume of 60,500 gallons of fuel.
APPLICABILITY:           Mode 6 with water level in the refueling cavity >23 ft above the reactor pressure vessel flange.
ACTION:
With less than the above minimum required A.C. electrical power sources OPERABLE, immediately suspend all operations involving CORE ALTERATIONS, operations involving positive reactivity additions that could result in loss of required SHUTDOWN MARGIN or required boron concentration, operations with a potential for draining the reactor vessel or crane operation with loads over the spent fuel pool. Immediately initiate actions to restore the inoperable A.C. electrical power source to OPERABLE status.
SURVEILLANCE REQUIREMENTS 4.8.1.3 The abov required A.G. ecetrical pow~er- sour-es shall be demonstr-ated OPERABLE bj' the peffermance of each of the r-equir-ements of Specifications 4.8.1.1.1, 4.8.1.1.2 (except for Specification 4.8.1.1.2a.3), and 4.8.1.1.3. For AC sources required to be OPERABLE, the surveillance requirements of Specification 3.8.1.1, "AC Sources - Operating", are applicable (except 4.8.1.1.2.e.4, 4.8.1.1.2.e.5, 4.8.1.1.2.e.6, 4.8.1.1.2.e.8, 4.8.1.1.2.e.10, 4.8.1.1.2.e.11, 4.8.1.1.2.e.13, and 4.8.1.1.2.1).
                                                -NOTES The following surveillance requirements are not required to be performed: 4.8.1.1.2.a.3, 4.8.1.1.2.e.2, 4.8.1.1.26e.3, 4.8.1.1.2.e.7, 4.8.1.1.2.e.9, 4.8.1.1.2.e.12, and 4.8.1.1.2.g.
SOUTH TEXAS - UNITS I & 2                    3/4 8-9a            Unit 1 - Amendment No. 7-1-1-28 Unit 2 - Amendment No. 60-1-1-7

NOC-AE-01001214 Attachment 3 ATTACHMENT 3 TECHNICAL SPECIFICATION PAGE WITH PROPOSED CHANGES INCORPORATED

TABLE 3.3-3 (Continued) 0            ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION MINIMUM  APPLICABLE t..                                    TOTAL NO.           CHANNELS  CHANNELS     MODES FUNCTIONAL UNIT                    OF CHANNELS           TO TRIP OPERABLE            ACTION
: 8. Loss of Power "a.4.16 kV ESF Bus Under-       4/bus            2/bus        2/bus    1, 2, 3, 4 20A
   -        voltage-Loss of Voltage
: b. 4.16 kV ESF Bus Under voltage-Tolerable Degraded Voltage Coincident with SI   4/bus            2/bus        2/bus    1, 2, 3, 4 20A
: c. 4. 16 kV ESF Bus Under voltage - Sustained Degraded Voltage                      4/bus            2/bus        2/bus    1,2,3,4    20A
: 9. Engineered Safety Features Actuation System Interlocks
: a. Pressurizer Pressure, P-11   3                2            2        1,2, 3     21
: b. Low-Low Tvg, P-12            4                2            3        1, 2, 3    21
: c. Reactor Trip, P-4            2                 1           2        1,2,3      23 P oZ Z

TABLE 3.3-3 (Continued)
ACTION STATEMENTS (Continued)
ACTION 19    With the number of OPERABLE channels one less than the Minimum Channels OPERABLE requirement, restore the inoperable channel to OPERABLE status within 48 hours or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours.
ACTION 20 -  With the number of OPERABLE channels one less than the Total Number of Channels, STARTUP and/or POWER OPERATION may proceed provided the following conditions are satisfied:
: a.      The inoperable channel is placed in the tripped condition within 1 hour, and
: b.      The Minimum Channels OPERABLE requirement is met; however, the inoperable channel may be bypassed for up to 2 hours for surveillance testing of other channels per Specification 4.3.2.1.
ACTION 20A - a.      With the number of OPERABLE channels one less than the Total Number of Channels, STARTUP and/or POWER OPERATION may proceed provided the following conditions are satisfied:
: 1. The inoperable channel is removed from service or placed in the tripped condition within 72 hours, and
: 2. The Minimum Channels OPERABLE requirement is met; however, an inoperable channel in the tripped condition may be bypassed for up to 12 hours for surveillance testing of other channels per Specification 4.3.2.1.
: b. With the number of OPERABLE channels two less than the Minimum Number of Channels, STARTUP and/or POWER OPERATION may proceed provided:
: 1. one inoperable channel is placed in the tripped condition and one inoperable channel is removed from service within 72 hours, and
: 2. The Minimum Channels OPERABLE requirement is met; however, the inoperable channel may be bypassed for up to 12 hours for surveillance testing of other channels per Specification 4.3.2.1.
C. With the number of OPERABLE channels less than the Minimum Number of Channels, declare the associated load sequencer inoperable and apply the ACTION required by Technical Specification 3.8.1.1.
ACTION 21 -   With less than the Minimum Number of Channels OPERABLE, within 1 hour determine by observation of the associated permissive annunciator window(s) that the interlock is in its required state for the existing plant condition, or apply Specification 3.0.3.
SOUTH TEXAS - UNITS I & 2                          3/4 3-27              Unit 1 - Amendment No Unit 2 - Amendment No.

TABLE 3.3-3 (Continued)
ACTION STATEMENTS (Continued)
ACTION 22   With the number of OPERABLE channels one less than the Minimum Channels OPERABLE requirement, be in at least HOT STANDBY within 6 hours and in at least HOT SHUTDOWN within the following 6 hours; however, one channel may be bypassed for up to 2 hours for surveillance testing per Specification 4.3.2.1 provided the other channel is OPERABLE.
ACTION 23   With the number of OPERABLE channels one less than the Total Number of Channels, restore the inoperable channel to OPERABLE status within 48 hours or be in at least HOT STANDBY within 6 hours and in at least HOT SHUTDOWN within the following 6 hours.
ACTION 24   With the number of OPERABLE channels one less than the Total Number of Channels, restore the inoperable channel to OPERABLE status within 48 hours or declare the associated valve inoperable and take the ACTION required by Specification 3.7.1.5.
ACTION 25    With the number of OPERABLE channels one less than the Minimum Channels OPERABLE requirement, be in at least HOT STANDBY within 6 hours; however, one channel may be bypassed for up to 2 hours for surveillance testing per Specification 4.3.2.1 provided the other channel is OPERABLE.
ACI'ION 26   With the number of OPERABLE channels one less than the Minimum Channels OPERABLE requirement, declare the affected Auxiliary Feedwater Pump inoperable and take ACTION required by Specification 3.7.1.2.
ACTION 27    For an inoperable channel, declare its associated ventilation train inoperable and apply the actions of Specification 3.7.7.
ACTION 28    With the number of OPERABLE channels less than the Minimum Channels OPERABLE requirement, within 1 hour initiate and maintain operation of the Control Room Makeup and Cleanup Filtration System (at 100% capacity) in the recirculation and makeup filtration mode.
ACTION 29    For an inoperable channel, declare its associated ventilation train inoperable and apply the actions of Specification 3.7.8.
ACTION 30-   With irradiated fuel in the spent fuel pool: With the number of OPERABLE channels less than the Minimum Channels OPERABLE requirement, fuel movement within the spent fuel pool or crane operation with loads over the spent fuel pool may proceed provided the FHB exhaust air filtration system is in operation and discharging through at least one train of HEPA filters and charcoal adsorbers.
SOUTH TEXAS - UNITS I & 2                      3/4 3-28             Unit 1 - Amendment No Unit 2 - Amendment No.

3/4.8 ELECTRICAL POWER SYSTEMS 3/4.8.1     A.C. SOURCES OPERATING LIMITING CONDITION FOR OPERATION 3.8.1.1   As a minimum, the following A.C. electrical power sources shall be OPERABLE.
: a. Two physically indepenlent circuits between the offsite transmission network and the onsite Class IE Distribution System , and
: b. Three separate and independent standby diesel generators, each with a separate fuel tank containing a minimum volume of 60,500 gallons of fuel, and an automatic load sequencer.
C.
APPLICABILITY:             MODES 1, 2, 3, and 4.
ACTION:
: a. With one offsite circuit of the above-required A.C. electrical power sources inoperable, demonstrate the OPERABILITY of the remaining A.C. sources by performing Surveillance Requirement 4.8.1.1. l.a within 1 hour and at least once per 8 hours thereafter. Restore the offsite circuit to OPERABLE status within 72 hours or be in at least HOT SHUTDOWN within the next 12 hours and in COLD SHUTDOWN within the following 24 hours.
: b. With a standby diesel generator inoperable, demonstrate the OPERABILITY of the above-required A.C. offsite sources by performing Surveillance Requirement 4.8.1.1.1.a within 1 hour and at least once per 8 hours thereafter. If the standby diesel generator became inoperable due to any cause other than an inoperable support system, an independently testable component, or preplanned preventive maintenance or testing, demonstrate the OPERABILITY of the remaining OPERABLE standby diesel generators by performing Surveillance Requirement 4.8.1.1.2.a.2) for each such standby diesel generator separately within 8 hours, unless it can be demonstrated there is no common mode failure for the remaining diesel generator(s). Restore the inoperable standby diesel generator to OPERABLE status within 14 days or be in at least HOT SHUTDOWN within the next 12 hours and in COLD SHUTDOWN within the following 24 hours.
: c. With one offsite circuit of the above-required A.C. electrical power sources and one standby diesel generator inoperable, demonstrate the OPERABILITY of the remaining A.C. sources by performing Specification 4.8.1.1.1a. within 1 hour and at least once per 8 hours thereafter; and if the standby diesel generator became inoperable due to any cause other than an inoperable support system, an independently testable component, or preplanned preventive SOUTH TEXAS - UNITS 1 & 2                           3/4 8-1                         Unit I - Amendment No.
Unit 2 - Amendment No.

ELECTRICAL POWER SYSTEMS LIMITING CONDITION FOR OPERATION ACTION (Continued) maintenance or testing, demonstrate the OPERABILITY of the remaining OPERABLE standby diesel generator(s) by performing Surveillance Requirement 4.8.1.1.2a.2) within 8 hours, unless it can be demonstrated there is no common mode failure for the remaining diesel generators; restore at least one of the inoperable sources to OPERABLE status within 12 hours or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours. Restore at least two offsite circuits to OPERABLE status within 72 hours and three standby diesel generators to OPERABLE status within 14 days from the time of initial loss or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours.
: d. With one standby diesel generator inoperable in addition to ACTION b. or c. above, verify that:
: 1. All required systems, subsystems, trains, components, and devices that depend on the remaining OPERABLE diesel generators as a source of emergency power are also OPERABLE, and
: 2. When in Mode 1, 2, or 3, the steam-driven auxiliary feedwater pump is OPERABLE.
If these conditions are not satisfied within 24 hours be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours.
: e. With two of the above required offsite A.C. circuits inoperable, restore at least one of the inoperable offsite sources to OPERABLE status within 24 hours or be in at least HOT STANDBY within the next 6 hours. With only one offsite source restored, restore at least two offsite circuits to OPERABLE status within 72 hours from time of initial loss or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours.
: f. With two or three of the above required standby diesel generators inoperable, demonstrate the OPERABILITY of two offsite A.C. circuits by performing the requirements of Specification 4.8.1.1.1 a. within 1 hour and at least once per 8 hours thereafter; restore at least one standby diesel generator to OPERABLE status within 2 hours and at least two standby diesel generators to OPERABLE status within 24 hours or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours. Restore at least three standby diesel generators to OPERABLE status within 14 days from time of initial loss or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours.
: g. With one required load sequencer inoperable restore the inoperable load sequencer to operable status within 7 days or be in HOT SHUTDOWN within the next 12 hours and in COLD SHUTDOWN within the following 24 hours.
: h. With one required load sequencer inoperable and one required standby diesel generator not associated with the inoperable sequencer also inoperable, restore the inoperable load sequencer and/or the inoperable standby diesel generator not associated with the inoperable load sequencer to OPERABLE status within 24 hours or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours.
SOUTH TEXAS - UNITS I & 2                   3/4 8-2                              Unit 1 - Amendment No.
Unit 2 - Amendment No.

ELECTRICAL POWER SYSTEMS A.C. SOURCES SHUTDOWN LIMITING CONDITION FOR OPERATION 3.8.1.2 As a minimum, the following A.C. electrical power sources shall be OPERABLE:
: a. One circuit between the offsite transmission network and the Onsite Class 1E Distribution System, and
: b. Two' standby diesel generators each with a separate fuel tank containing a minimum volume of 60,500 gallons of fuel.
APPLICABILITY:               Mode 5 and Mode 6 with water level in the refueling cavity <23 ft above the reactor pressure vessel flange.
ACTION:
With less than the above minimum required A.C. electrical power sources OPERABLE, immediately suspend all operations involving CORE ALTERATIONS, operations involving positive reactivity additions that could result in loss of required SHUTDOWN MARGIN or required boron concentration, movement of irradiated fuel, operations with a potential for draining the reactor vessel or crane operation with loads over the spent fuel pool. Immediately initiate actions to restore the inoperable A.C. electrical power source to OPERABLE status.
SURVEILLANCE REQUIREMENTS 4.8.1.2 For AC sources required to be OPERABLE, the surveillance requirements of Specification 3.8.1.1, "AC Sources - Operating", are applicable (except 4.8.1.1.2.e.4, 4.8.1.1.2.e.5, 4.8.1.1.2.e.6, 4.8.1.1.2.e.8, 4.8.1.1.2.e. 10, 4.8.1.1.2.e. 11, 4.8.1.1.2.e. 13, and 4.8.1.1.2.f).
                                                              -NOTES
: 1. The following surveillance requirements are not required to be performed: 4.8.1.1.2.a.3, 4.8.1.1.2.e.2, 4.8.1.1.2.e.3, 4.8.1.1.2.e.7, 4.8.1.1.2.e.9, 4.8.1.1.2.e.12, and 4.8.1.1.2.g.
4.8.1.2.1       The alternate onsite emergency power source shall be demonstrated functional by:
: a.      Within 4 hours of taking credit for the onsite emergency power source as a standby diesel generator, verify it starts and achieves steady state voltage (+/-_10%) and frequency (+/-2%) in 5 minutes.
: b.       Within 4 hours of taking credit for the onsite emergency power source as a standby diesel generator and every 8 hours thereafter, verify the emergency power source is capable of being aligned to the required ESF bus by performing a breaker alignment check.
 'An alternate onsite emergency power source, capable of supplying power for one train of shutdown cooling may be substituted for one of the required diesels for 142 consecutive days (SR 4.8.1.2.1 is the only requirement applicable).
SOUTH TEXAS - UNITS I & 2                                3/4 8-9                          Unit I - Amendment No.
Unit 2 - Amendment No.

ELECTRICAL POWER SYSTEMS A.C. SOURCES SHUTDOWN LIMITING CONDITION FOR OPERATION 3.8.1.3    As a minimum, the following A.C. electrical power sources shall be OPERABLE:
: a. One circuit between the offsite transmission network and the Onsite Class 1E Distribution System, and
: b. One standby diesel generator with a separate fuel tank containing a minimum volume of 60,500 gallons of fuel.
APPLICABILITY:          Mode 6 with water level in the refueling cavity &#x17d;23 ft above the reactor pressure vessel flange.
ACTION:
With less than the above minimum required A.C. electrical power sources OPERABLE, immediately suspend all operations involving CORE ALTERATIONS, operations involving positive reactivity additions that could result in loss of required SHUTDOWN MARGIN or required boron concentration, operations with a potential for draining the reactor vessel or crane operation with loads over the spent fuel pool. Immediately initiate actions to restore the inoperable A.C. electrical power source to OPERABLE status.
SURVEILLANCE REQUIREMENTS 4.8.1.3     For AC sources required to be OPERABLE, the surveillance requirements of Specification 3.8.1.1, "AC Sources - Operating", are applicable (except 4.8.1.1.2.e.4, 4.8.1.1.2.e.5, 4.8.1.1.2.e.6, 4.8.1.1.2.e.8, 4.8.1.1.2.e. 10, 4.8.1.1.2.e. 11, 4.8.1.1.2.e. 13, and 4.8.1.1.2.f).
                                                -NOTES
: 1. The following surveillance requirements are not required to be performed:
4.8.1.1.2.a.3, 4.8.1.1.2.e.2, 4.8.1.1.2.e.3, 4.8.1.1.2.e.7, 4.8.1.1.2.e.9, 4.8.1.1.2.e.12, and 4.8.1.1.2.g.
SOUTH TEXAS - UNITS 1 & 2                        3/4 8-9a                 Unit I - Amendment No.
Unit 2 - Amendment No.

NOC-AE-01001214 Attachment 4 ATTACHMENT 4 INSERTS FOR TECHNICAL SPECIFICATION BASES

NOC-AE-01001214 Attachment 4 The information below will be inserted in the Technical Bases for the loss of power instrumentation and the AC Sources. Copies of the revised Bases pages will be provided to the NRC after the amendment is approved and the pages have been revised.
Loss of Power Instrumentation Bases Inserts Four channels per bus comprise the STP loss of power instrumentation. The loss of power actuation logic is 2 of the 4 channels tripping. The design basis is met as long as STP retains adequate assurance that at least two channels would trip on undervoltage. If one channel is inoperable, this can be accomplished with a 2 of 3 logic with the remaining operable channels with the inoperable channel taken out of service. If two channels were inoperable, it can be accomplished by placing one of the inoperable channels in the tripped condition and operating with a 1 of 2 logic. In each of the action conditions, there is adequate assurance that the operable instruments will perform the design function, even considering that one operable channel fails.
The loss of power instruments perform a support function for their associated ESF load sequencers. Therefore, when there are fewer than the Minimum Channels Operable requirement, the result is that the ESF load sequencer is inoperable. The appropriate TS to apply to an inoperable ESF load sequencer in Mode 1, 2, 3 or 4 is TS 3/4.8.1.1 for AC Sources - Operating.
AC Sources Bases Inserts The 7 day allowed outage time for an inoperable sequencer is based on the most limiting allowed outage times for components actuated by the sequencer, which include safety injection, essential cooling water, component cooling water, and essential chilled water.
Action h. applies for the configuration where there is one inoperable sequencer and one inoperable diesel (on a different train than the inoperable sequencer). The action requires restoration of at least one of the two inoperable components within 24 hours. The proposed action time is consistent with the time required in TS 3.8.1.1 .d for an inoperable diesel with another component that depends on one of the operable diesels also inoperable. The proposed action time is also consistent with the required action time for TS 3.8.1.1 .f. for two inoperable standby diesel generators. A condition where there is one inoperable sequencer and one inoperable standby diesel is considered comparable to the conditions of TS 3.8.1. Id. or TS 3.8.1. L.f. Note that the operator can manually start and load the standby diesel that is made inoperable by the inoperable sequencer.
Each automatic sequencer has 6 actuation inputs. At least 4 of the inputs are required to be operable for the sequencer to be operable.
The SRs required to be met but not required to be performed preclude requiring the OPERABLE DG(s) from being paralleled with the offsite power network or otherwise rendered inoperable during performance of SRs, and to preclude deenergizing a required 4160 V ESF bus or disconnecting a required offsite circuit during performance of SRs. With limited AC sources available, a single event could compromise both the required circuit and the DG. It is the intent

NOC-AE-01001214 Attachment 4 that these SRs must still be capable of being met, but actual performance is not required during periods when the DG and offsite circuit is required to be OPERABLE.
The ESF Load Sequencer is not normally required to be operable in Mode 5 or Mode 6. STP's accident analyses take no credit for automatic load shedding or sequencing in these modes.
Although the loss of power instrumentation and the sequencer are normally operable for their associated SDG in Mode 5 and Mode 6, the TS do not require them to be operable. Operator response may require manual start of the Standby Diesel Generator and manual loading of the ESF bus. The STP design does not automatically sequence RHR on to the bus even in Modes where the sequencer is required to be operable. Application of the definition of OPERABLE OPERABILITY in conjunction with the use of STP's procedures provides adequate guidance for STP operators to determine the instrumentation required for the plant configuration. For instance, during reduced inventory operations, STP procedures require all diesel support instrumentation to be operable.}}