Text

South Texas Project, Units 1 and 2, Revised Broad Scope Risk-Informed Technical Specification Amendment Request
	ML070040247
Person / Time
Site:	South Texas
Issue date:	12/28/2006
From:	Rencurrel D W; South Texas
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	NOC-AE-06002036, TAC MD2341, TAC MD2342
	Download: ML070040247 (121)
	v • d • e

Nuclear Operating Company South Teaws Pro/ecd Electric Genejating Station PO Bow 28.9 Wadsworth, Texs 77483ý ý ý A December 28, 2006 NOC-AE-06002036 1OCFR5O.36 I 0CFR5O.90 U. S. Nuclear Regulatory Commission Attention:

Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MID 20852-2738 South Texas Project Units 1 and 2 Docket Nos. STN 50-498, STN 50-499 Revised Broad Scope Risk-Informed Technical Specification Amendment Request (TAC Nos. MID 2341 & MID 2342)

Reference:

1. Letter from T. J. Jordan to NRC Document Control Desk dated August 2, 2004, "Broad Scope Risk-Informed Technical Specification Amendment Request" (ML042 190366, NOC-AE-0400 1666)2. Letter from T. R. Tjader (NRC) to Biff Bradley (NEIE) dated July 14, 2004, transmitting Requests for Additional Information on the Risk-Informed Technical Specification Initiative 4B submittals (MLO4 1820347)3. Letter from T. R. Tjader (NRC) to Biff Bradley (NIEI) dated May 31, 2005, transmitting Requests for Additional Information on the STP application in Reference I (ML051570016)

4. Letter from M. A. McBurnett to NRC Document Control Desk dated February 10, 2006, "Response to NRC Requests for Additional Informnation on STPNOC Proposed Risk-Informed Technical Specifications" (ML060480439, NOC-AE-0600 1969)5. Letter from M. A. McBurnett to NRC Document Control Desk dated April 26, 2006,"Response to NRC Requests for Additional Information on STPNOC Proposed Risk-Informed Technical Specifications" (ML061280591, NOC-AE-0600 1994)6. Letter from David W. Rencurrel to NRC Document Control Desk dated June 6, 2006,"Broad Scope Risk-Informed Technical Specification Amendment Request" (MLO6 1630315, NOC-AE-06002005)

The STP Nuclear Operating Company (STPNOC) submitted a license amendment request for a broad scope risk-informed set of Technical Specification changes and a subsequent revision to that request (References I and 6). This submittal revises the license amendment request for the proposed risk-informed changes to the Technical Specifications (TS) described in those referenced letters with respect to the scope and content of the proposed changes to reflect the results of STPNOC -NRC STI:t32023041

,00Qý NOC-AE-06002036 Page 2 discussions and incorporate responses to NRC observations and comments made during the NRC audit conducted at the South Texas Project (STP) site the week of June 19, 2006.The attached revision to the STPNOC license amendment request includes the following changes from the Reference 6 application:

-The Electric Power Research Institute (EPRI) Risk-Managed Technical Specifications (RMTS)Guidelines have been transferred to the Nuclear Energy Institute (NEI) as NEI 06-09 and the references changed accordingly.

-Several clarifications are made in the Discussion of Changes and Table 2 of Attachment 1 with regard to how the RMTS are applied. A column has been added to Table 2 describing the input to the risk calculator tool to quantify risk-informed completion time for each action statement.

Text changes are highlighted.

-TS 3.3.2 Items 3.a.2 and 3.a.3, Containment Phase A Isolation Actuation Logic and Actuation Relays have been removed from the scope of RMTS. Item 3.a. I for Manual Containment Phase A Isolation has also been removed from the scope of RMTS.-TS 3.3.2 Items 3.c.1I and 3.c.2, Containment Phase B Isolation Actuation Logic and Actuation Relays, have been removed from the scope of RMTS. Item 3.c.3, Containment Phase B Isolation on Containment Pressure Hi-3 has also been removed from the scope of RMTS.-TS (TS) 3.6.1.7, Containment Ventilation, has been removed from the scope of the RMTS.-The proposed changes to TS 3.7.1.5, Main Steam Isolation Valves, have been revised to apply only to the MODE I requirements.

Proposed changes in the format of the TS have been deleted so that the only format changes requested are the grammatical changes required to incorporate the RMTS reference.

-TS 3.6.2.1, Containment Spray, ACTION a. has been revised to restore the current provision to"1restore the inoperable Spray System to OPERABLE status within the next 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months " after shutting down to MODE 3. STPNOC had previously proposed to delete the provision as unnecessary.

-TS 3.7.7, Control Room Makeup and Cleanup Filtration, will apply the provisions of RMTS only to the cooling function of that system. The description in Table 2 has been modified accordingly and the modifications to the Bases for TS 3.7.7 are provided for the staff's information.

-The wording has been changed for the note on TS 3.8.2. 1. The second sentence of the originally proposed wording provides the necessary limitation, so the first sentence was deleted.-Proposed TS 3.13.1, Risk-Informed Completion Time Determination, has been deleted and direction to apply the Configuration Risk Management Program (CRMP) added to the affected ACTION statements instead. This is a TS format change that does not affect how the RMTS are applied.-Proposed TS 3.13.2, Risk-Informed Completion Times for Entry into Multiple Action Statements, has been deleted along with its description and associated Bases.-TS 3.8.1.1.d, originally proposed to be deleted because TS 3.13.2 would supersede it, has been restored with the CRMP applicable.

-The administrative change to the Table of Contents to add TS 3.13.1 and TS 3.13.2 has been deleted.-Mode applicability has been added to the description of the Configuration Risk Management Program in the Administrative TS 6.8.3.k NOC-AE-06002036 Page 3 There are no commitments in this letter.The proposed amendment will not have an adverse impact on the health and safety of the public.The STP Plant Operations Review Committee has reviewed and concurred with the proposed changes., In accordance with 10 CFR 50.91(b), the South Texas Project is providing the State of Texas with a copy of this proposed amendment.

STP requests approval of the proposed change by March 31, 2007. Because of the extent of the proposed changes, STPNOC requests 180 days for implementation after NRC approval.Attachment I describes the proposed changes and their technical and safety bases.Attachment 2 is the markups of the affected TS.Attachment 3 is the inserts for the TS Bases.If you have any questions, please call Wayne Harrison at 361-972-7298 or me at 361-972-7867.

I declare under penalty of perjury that the foregoing is true and correct.Executed on L hY20&_Date David W. Rencurrel Vice President Engineering

& Strategic Projects Attachments:

1. Description of Changes and Safety Evaluation

2. Technical Specification Mark-up Pages 3. Bases Inserts NOC-AE-06002036 Page 4 cc: (paper copy)(electronic copy)Regional Administrator, Region IV U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, Texas 76011-8064 Senior Resident Inspector U. S. Nuclear Regulatory Commission P. 0. Box 289, Mail Code: MNI 16 Wadsworth, TX 77483 C. M. Canady City of Austin Electric Utility Department 721 Barton Springs Road Austin, TX 78704 Richard A. Ratliff Bureau of Radiation Control Texas Department of State Health Services 1100 West 49th Street Austin, TX 78756-3 189 A. H. Gutterman, Esquire Morgan, Lewis & Bockius LLP Mohan C. Thadani U. S. Nuclear Regulatory Commission Steve Winn Christine Jacobs Eddy Daniels Marty Ryan Harry Holloway NRG South Texas LP J. J. Nesrsta R. K. Temple Kevin Pollo Ed Alarcon City Public Service Jon C. Wood Cox Smith Matthews C. Kirksey City of Austin NOC-AE-06002036 Description of Changes And Safety Evaluation Attachment 1

Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 1 1. Description of the changes being proposed and the reasons for seeking the changes.STP Nuclear Operating Company (STPNOC) is proposing in this application to implement a risk-informed process for determining allowed outage times for South Texas Project (STP)Technical Specifications (TS). The risk-informed process involves the application of the STP Configuration Risk Management Program (CRMP) to calculate a risk-informed completion time (RICT) based on the time required for the risk calculated for a plant configuration to attain a threshold.

The risk thresholds, the process for calculating the configuration risk, and the requirements for probabilistic risk analysis (PRA) quality are described in the Nuclear Energy Institute (NEI) Risk Managed Technical Specification Guidelines (referred to as NEI 06-09, Rev. 0 or RMTS Guidelines).

The RMTS Guidelines are incorporated by reference in the proposed STP Technical Specification changes. The STP CRMP is a procedurally controlled program utilized by STPNOC for the implementation of 1OCFR5O.65(a)(4).

The details of the proposed changes are described in Section 2 of this attachment and in the mark-ups of the TS.STPNOC is proposing this change as a pilot plant for the industry RMTS initiative and for evaluation of NRC Regulatory Guide (RG) 1.200, "An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informned Activities".

This change proposes the option to apply the CRMP, as defined in the TS Administrative Section, to LCO ACTION statements to determine a RICT.The operator will have the option of using the existing TS allowed outage time (AOT) for routine plant activities and emergent conditions that would not be expected to require an extension of the AOT. This existing AOT will be referred to in this application as the"frontstop" time. The frontstop time also provides the operator sufficient time to determine and apply an appropriate extended time from the application of the CRMP for those situations where it is determined that an extended AOT (i.e., a RICT) is necessary.

Once the CRMP is applied and a component has exceeded its frontstop time, the CRMP must be applied to all subsequent inoperable TS components within the scope of the CRMP to determine the RICT for the new configuration until no components are in ACTIONS beyond the frontstop time. Since the CRMP is the implementing process for 1OCFR5O.65(a)(4), this achieves consistency between the regulations and the TS.In accordance with the RMTS Guidelines, the CRMP will establish a set of risk thresholds reflecting increasing risk significance with commensurate levels of severity and actions.These actions would range from restoring equipment to service, installing temporary modifications, or rescheduling maintenance activities, up to and including transition to safer plant operating modes. The CRMP establishes an incremental core damage probability (ICDP) of 1 OE-06 as the first level threshold below which routine work controls are adequate with no requirement for specific risk management actions. At or above this threshold, the operator is required to initiate action to reduce or manage the risk in accordance with the CRMP. The TS RICT is established with an ICDP of I OE-05 to define the limit for the AOTs for plant configurations.

The RICT would be calculated as the time required for the cumulative risk associated with a plant configuration to cross the threshold.

Attachment 1: Description of Changes a nd Safety Evaluation NOC-AE-06002036 Page 2 Should the RICT be exceeded, the CRMP would impose the TS requirements for action or completion time not met for the affected TS. The provisions of TS 3.0.2 are not affected by referencing the CRMP in TS in the scope of RMTS. If the affected system, structure, or component (SSC) is restored before completion of a required shutdown or if the RICT is determined prior to completion of a required shutdown, the shutdown need not be completed.

The RMTS introduces the concept of overall plant configuration risk management into the TS. Allowable action times would be replaced for the affected specifications with an action requirement for the overall plant configuration based on the CRMP. A backstop AOT limit of 30 days is provided in the new specifications for those cases where the risk analysis by itself would allow excessively long allowable outage times for a loss of function of a TS component.

The proposed change may be applied to those structures, systems, and components (SSCs)that are supported by a plant-specific CRMP. All of the components within the scope of the proposed-change are modeled in the STP PRA such that the revised RICT can be calculated.

The Limiting Conditions for Operation (LCO) and ACTIONs to which this proposed specification applies would each be modified to reference the CRMP.Approval of the changes proposed in this submittal will allow the plant to concentrate efforts on restoring and maintaining plant SSCs with the objective of maintaining low overall risk profile and reducing the likelihood of plant transients.

In this way, the focus and attention to items most impacting nuclear safety are enhanced.

Maintenance actions can then be prioritized based on how to most effectively limit or reduce risk due to the specific plant configuration at a specific time. This ability represents a significant and substantive technological improvement over current TS methodology.

With multiple SSCs out of service, the operator would be able to prioritize efforts to address equipment that would have the biggest effect in reducing the incremental risk. If the operator cannot restore the inoperable equipment, the proposed RMTS would require the plant to transition to lower operating modes should the overall risk accumulation exceed the 1 OE-05 ICDP level.Because of plant-specific three-train design features, a portion of the STP application necessarily addresses conditions where TS 3.0.3 currently applies. The STP TS typically do not have an action for conditions where more than one of the three required trains of a function are inoperable and TS 3.0.3 must be applied to those configurations.

Consequently, STP's application includes a risk-informed action for configurations with more than one inoperable train. STP's application also includes a provision to apply the risk-management process to situations where more than one channel of instrumentation actuation logic is inoperable.

STPNOC believes it is appropriate for the CRMP to be able to determine the time that can be allowed in a configuration that previously required entry into TS 3.0.3. For many cases, the current TS would require application of TS 3.0.3 simply because the configuration is outside of that defined in the TS although the plant is unlikely to be in a seriously degraded condition.

Even in unusual cases where all trains or channels of a system required by a LCO are inoperable, a risk assessment to determine the appropriate action time is preferable to Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 3 application of TS 3.0.3. In such situations, there are often functionally redundant capabilities or the degree of degradation of the inoperable equipment would not prevent the plant level function from being achieved.In accordance with RMTS Guidelines, RMTS will not be applied for configurations where there is a complete loss of function.

If a component is deter-mined to be inoperable, it may still be considered to have PRA Functionality for calculation of a RICT if there is reasonable assurance that it can perform its required functions for events not affected by the degraded or non-conforming condition and if the condition can be quantified in the STP PRA. The NEI RMTS Guidelines provide more detail on how PRA functionality may be applied for the determination of a RICT.2. Detailed Description of Proposed Changes STPNOC proposes to modify the ACTION statements in LCOs modeled in the STP PRA to allow an option to apply the CRMP to extend the completion time. The CRMP will be included in the Administrative Section of the TS where it will be required to be in accordance with the N]EI RMTS Guidelines.

Table 2 describes the proposed changes to the TS. It includes the basis for each proposed change and the input to the computer tool used to determine the RICT.The risk basis column provides the calculated RICT for the inoperable condition existing with no other SSC within the scope of the CRMP (i.e., PRA) being inoperable.

To illustrate the "risk margin", a number of the functions in Table 2 depict the RICT without the application of the proposed 30-day backstop.

The AOTs in this column represent "base case" and are calculated using the I.OE3-05 threshold.

When "inoperable" is used in this column, it means that the SSC is not capable of performing its intended function.Application of the CRMP to those conditions where the functionality requirements defined in the RMTS Guidelines are met could result in a longer AOT. The AOTs in Table 2 were determined using information from Revision 4 of the STP PRA model. The train-related AOT asymmetry will be less pronounced for the AOTs calculated using Revision 5 of the STP PRA, which is currently being finalized.

The AOTs in Table 2 provide useful insight into the available margin. To determine AOTs for actual plant configurations, STPNOC will use the PRA or the RICT calculator, which is an extensive database of over 20,000 pre-calculated maintenance states.3. Background STPNOC is proposing in this application to implement a risk-informed process for determining AOTs for STP TS. The risk-informed process involves the application of the STP CRMP. The STP CRMP is also utilized by STPNOC for the implementation of lOCFR5O.65(a)(4) for the Maintenance Rule. The STPNOC application is based on the N]EI RMTS Guidelines.

Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 4 The current STP TS are based on Westinghouse Standard TS (Draft NUREG-0452 Rev. 5), which assume a two-train Engineered Safety Features (ESF) design. However, the STP utilizes a three-train ESF design. Therefore, although the STP maintains an additional ESF train above the standard Westinghouse design, the South Texas TS LCOs and associated Action Statements have not completely incorporated the availability of the third ESF train.Furthermore, traditional TS are component and system-specific in the sense that the designated AOTs do not take into consideration the cumulative risk of various other components being in their associated individual Action Statements concurrently; instead, each Action Statement is independent of the other.The Configuration Risk Management and Maintenance Rule Programs establish the means and methods to assess the risk due to out-of-service equipment associated with various plant configurations, including those in which multiple TS-related systems are affected.

Therefore, the intent of the changes to the TS proposed in this submittal is to integrate the availability of the third ESF train along with the insights provided by the CRMP to establish risk-informed AOTs for selected Specifications and which take into consideration the cumulative risk associated with each entry into an Action Statement.

RG 1. 174 and 1. 177 provide guidance on risk-informed licensing applications.

The criteria of both of these guides are primarily oriented toward permanent changes to the TS.STP's operating history has shown that the extension of the AOT beyond the frontstop will not be done for most entries into the TS, whether for planned or emergent work. While the criteria of RG 1. 174 and RG 1. 177 would be appropriate for extensions to the frontstop, it is.more appropriate to view entry into these RMTS AOT extensions as occasional events where the guidance of RG 1. 182 for assessing risk from maintenance activities should be applied.RG 1. 182 and RG 1. 160 are used in conjunction with Nuclear Utilities Resources and Management Council (NUMARC) 93-0 1, "Industry Guidance for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," as standards for implementation of 1OCFR5O.65 (Maintenance Rule). Section 11.3.7.2 of NUMARC 93-01 includes recommended quantitative risk action thresholds for maintenance activities.

These thresholds were adapted for use in the RMTS Guidelines that forms the technical basis for the STPNOC application.

Although STPNOC does not believe RG 1. 174 and 1. 177 are directly applicable to this submittal, the format addresses the principles of risk-informed decision-making set forth in those RGs. Specifically, justification is provided which demonstrates that: I1. The proposed change meets the current regulations.

No exemption or rule change is being requested.

The proposed changes provide a risk-informed methodology for determining the AOTs associated with selected TS. The proposed changes are in compliance with current regulations.

The evaluations provided in this application confirm that the proposed changes maintain adequate defense-in-depth, safety margin, and the capability to meet Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 5 plant design-basis.

Additionally, the risk-informed AOTs proposed are consistent with the CRMP and the Maintenance Rule in ensuring adequate margin to core damage and/or radiation release. Therefore, the proposed changes to the TS are in compliance with all current regulations while meeting all license conditions.

Refer to Section 5.2 of this attachment for additional justification.

2. The proposed change is consistent with the defense-in-depth philosophy.

Traditional engineering considerations have been used to demonstrate this consistency.

The proposed TS changes preserve the existing balance between prevention of core damage, prevention of containment failure, and consequence mitigation by ensuring that AOTs are based upon the cumulative risk associated with the current plant configuration.

The CRMP, in conjunction with the STP PRA, explicitly measures and accounts for the level of defense-in-depth from both an instantaneous and a cumulative basis. It considers plant design features, operating philosophy, and equipment capability.

The ability of the CRMP to assess the level of defense-in-depth is a substantial technological improvement over current methods.The risk assessment will adequately consider defense-in-depth, quantitatively in the PRA model and by a qualitative assessment of the specific configuration.

Application of the risk assessment will generally allow sufficient extension of the frontstop time to meet station needs for maintenance and corrective action. Due to the availability of STP's third ESF train, in situations where the CRMP is applied, the CRMP will generally allow a significant extension of the frontstop completion time.Refer to Section 4 of this attachment for a detailed justification.

3. The proposed change maintains sufficient safety margin.The AOT changes proposed represent a risk-neutral to risk-beneficial change. Therefore, sufficient margins are maintained as a result of the proposed changes. Since this is a risk-informed application, no change is proposed on design-basis features of the station.There are no changes to plant safety limits or setpoints.

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

4. The proposed change does not measurably change overall average core damage frequency for STP. The proposed change implements a mechanism to ensure changes from modeled core damage contributors are identified and monitored.

Therefore, the proposed change itself does not significantly impact core damage frequency and is consistent with the Commission's Safety Goal Policy Statement.

The proposed changes will ensure that AOTs are based on and evaluated against established risk thresholds consistent with the Safety Goal Policy.Refer to Section 4 of this attachment for a detailed justification.

Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 6 5. The impact of the change should be monitored using performance measurement strategies.

Changes to core damage frequency and cumulative risk associated with TS related equipment being out of service will continue to be monitored in accordance with the CRMLP and Maintenance Rule Program. Plant-specific performance indicators have already been identified and developed and have been in use for several years at STP.Refer to Section 4 of this attachment for a detailed justification.

4. Technical Analysis STPNOC proposes to apply a risk-informed process to determine the AOT for a number of TS. The risk-informed process would apply the CRMP to evaluate plant configurations and determine the time required for the risk to exceed a incremental core damage probability threshold of 1.OE-05 and establish a RICT for the configuration based on that time. The action required by the TS must be taken if the threshold is exceeded.

The CRMP would require the plant to initiate action to manage risk levels that are at or above an incremental core damage probability threshold of 1 OE-06. Because of the low risk significance of a number of components in the TS, the process includes a "backstop" maximum AOT of 30 days.Compliance with Design and Licensing Basis STPNOC is proposing a risk-informed method for determining configuration-based AOTs in lieu of TS LCOs.The proposal does not include new plant design features, new operating parameters, new operating configurations, new design analyses, or new analytical assumptions.

No new accidents are postulated and the mitigation for existing design-basis accidents is unchanged.

Table 2 describes the basis for each of the requested changes and depicts the calculated times required to accrue risk to a 1 OE-05 incremental core damage probability (ICDP) threshold for the affected systems assuming no additional modeled systems are concurrently unavailable.

For single items, these times are longer than the AOTs in the existing TS. The longer calculated times are a result of the robust design and redundancy typical of nuclear, plants, coupled with the low likelihood of design-basis initiating events. Table 2 demonstrates that the proposed changes can be managed to meet the criteria established in the RMTS Guidelines.

STPNOC will continue to manage its maintenance practices to maintain good material condition of plant components.

STPNOC will not unnecessarily extend out-of-service times such that equipment availability and reliability are adversely affected or in conflict with Maintenance Rule requirements.

Since 1996, STPNOC has been able to routinely quantify risk from maintenance configurations.

In that time, STP's maintenance history has Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 7 consistently kept configuration risk in a band with an ICDP < 1.OE-06. The 2003-2004 Standby Diesel Generator 22 extended allowed outage time of 113 days resulted in an ICDP of about 1 .2E-06 when availability of temporary non-safety diesel generators is credited in the analysis (Ref. STP Unit 2 License Amendment 149). STP equipment reliability and availability requirements will still meet licensing and design-basis requirements established by regulations such as 1OCFR5O.63, "Loss of all alternating current power," and 1OCFR5O.65, "Requirements for monitoring the effectiveness of maintenance at nuclear power plants." The 30-day AOT backstop limit established in the CRMP provides further assurance that there is no significant challenge to the design and licensing bases from the longer AOTs.Based on the assessment above, the extended AOT will not affect design-basis assumptions for equipment availability and STPNOC concludes the proposed change does not change the design and licensing bases for STP.Defense-in-Depth Following the guidance provided in RG 1.177, the impact of the proposed TS change on the defense-in-depth philosophy is addressed below. Based on the following discussion, STPNOC has concluded that the proposed change meets the defense-in-depth philosophy.

A reasonable balance among prevention of core damage, prevention of containment failure, and consequence mitigation is preserved, i.e., the proposed change in a TS has not significantly changed the balance among these principles of prevention and mitigation, to the extent that such balance is needed to meet the acceptance criteria of the specific design-basis accidents and transients, consistent with 10 CFR 50.36. TS change requests should consider whether the anticipated operational changes associated with a TS change could introduce new accidents or transients or could increase the likelihood of an accident or transient (as is required by 10 CER 50.92).The proposed change represents a more robust technical approach that preserves a reasonable balance among prevention of core damage, prevention of containment failure, and consequence mitigation.

STPNOC is proposing no changes to the design of the plant or any operating parameter.

No new operating configurations are being proposed.

The design basis is not changed by the proposed changes to the TS.The effect of the change when it is implemented will be that the CRMP will allow AOTs to vary based on the risk significance of the given plant configuration (i.e., the amount of equipment removed from service at any given time).As discussed above, STPNOC's CRMP has shown that STPNOC's risk monitoring practices are effective.

Application of the NIEI RMTS Guidelines establishes a 30-day limit on the AOTs for those components whose calculated AOTs are particularly long (the "backstop").

Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 8*Over-reliance on programmatic activities to compensate for weaknesses in plant design is avoided, e.g., use of high reliability estimates that are primarily based on optimistic program assumptions.

The proposed application of a plant-specific CRMP to determine AOTs uses plant-specific operating experience for component reliability and availability data. Thus, the allowances permitted by the CRMP are directly reflective of actual component performance in conjunction with component risk significance.

In some cases the CRMP may use compensatory actions to reduce calculated risk in some configurations.

Where credited in the PRA, these actions are incorporated into station procedures or work instructions and have been modeled using appropriate human reliability considerations.

The high degree of redundancy at STP reduces the reliance that might otherwise be placed on operator action or other programmatic activities.

STP's design includes three trains of Engineered Safety Feature (ESF) equipment, which is a robust design. Table 1 compares the defense-in-depth of STP's three-train design to the two-train design for a comparable Westinghouse PWR. Table 2 provides additional detail with respect to STP's accident mitigation capability with fewer than three trains available.

The AOTs shown for STP with two of three trains out of service are roughly what would be expected to apply for a two-train plant with one of two trains out of service. The table clearly shows that significant margin is retained for either a three-train or a two-train design. The Table 2 values used to support the backstop are in most cases based on change in core damage frequency.

With the exception of functions that directly affect containment capability (e.g., containment on-line purge), changes in large early*release frequency are less significant than the associated change in core damage frequency.

The Standard TS for Westinghouse plants are written for standard plants with two trains of ESF equipment.

For such standard plant designs, the safety functions are degraded (loss of single failure protection) when a single train of an ESF function is inoperable, and there is a loss of safety function when two trains of an ESF function are inoperable.

At STP, however, when only one of the three ESF trains is inoperable, there is more margin than for a two-train plant during conditions where one of two ESF trains is inoperable.

STP does not experience a complete loss of safety function when two of three trains of an ESF function are inoperable.

Because of the third ESF train, it is reasonable for the probabilistic risk assessment calculations for STP to justify relatively long AOTs when one of three trains is inoperable, and a reasonable AOT for conditions where two of three trains are inoperable.

STPNOC proposes to apply the CRMP to determine the appropriate AOTs based on quantifying the risk associated with the plant configuration.

The advantage of the CRMP is that it quickly and accurately assesses the relative significance of a given configuration, including those that involve multiple components in a single train or more than one train of equipment.

The use of the CRMP proposed in this submittal is an effective method to determine the safety implications associated with multiple inoperable components.

In addition, the combined CRMP enables the operator to identify the most effective actions Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 9 (i.e., return-to-service priority) to take to restore the plant to a safer (i.e., less risk-significant) configuration and how prompt the corrective or compensatory action should be.STP has structured its application for Risk-Informed TS to incorporate the three-train design concepts described above. The first entry in Table 1 outlines a general philosophy of a typical two-train plant and a three-train plant with risk-informed TS. The time allowed to be in a condition with less than three trains operable is based on a reasonable time to restore operability and the capability of the remaining operable equipment.

The STP PRA shows that the risks incurred by the proposed AOTs are acceptable and consistent with guidance contained in the EPRI PSA Application Guide.System redundancy, independence, and diversity are maintained commensurate with the expected frequency and consequences of challenges to the system, e.g., there are no risk outliers.

The following items should be considered." Whether there are appropriate restrictions in place to preclude simultaneous equipment outages that would erode the principles of redundancy and diversity, Application of the CRMP determines the risk significance of plant configurations.

It also permits the operator to identify the equipment that has the greatest effect on the existing configuration risk. With this information, the operator can manage the out-of-service duration and determine the consequences of removing additional equipment from service. The application of the CRMP approach places high value on key safety functions and works to ensure they remain a top priority over all plant conditions." Whether compensatory actions to be taken when entering the modified AOT for pre-planned maintenance are identified, Application of the CRMIP provides a structure to assist the operator in identifying effective compensatory actions for various plant maintenance configurations to maintain and manage acceptable risk levels. In accordance with the RMTS Guidelines, risk management actions are required for configurations that exceed or are expected to exceed the IE-06 threshold." Whether voluntary removal of equipment from service during plant operation should not be scheduled when adverse weather conditions are predicted or at times when the plant may be subjected to other abnormal conditions, and The CRMP is based on STP's Level 1 and 2 PRA, including external events; thus, the calculated values for configuration risk include the effect of adverse weather conditions on average. Consideration of existing weather effects on specific plant configurations is accounted for in the risk-informed programmatic application of the CRMP and in the station's Severe Weather procedure.

STPNOC typically considers the potential effect of weather on planned maintenance of components that could Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 10 potentially be challenged during severe weather, such as Standby Diesel Generators, Turbine Driven Auxiliary Feedwater pump, and Switchyard.

Compensatory measures are also taken at STP for adverse weather conditions in accordance with plant procedures (e.g., freeze protection, storm warnings and watches).Whether the impact of the TS change on the safety function should be taken into consideration.

For example, what is the impact of a change in the AOT for the low-pressure safety injection system on the overall availability and reliability of the low-pressure injection function?Application of the CRMP incorporates the impact of the RICT on the availability and reliability of the affected plant-level safety functions and associated equipment.

The effects will be quantified and traceable on the key figures-of-merit such as core damage frequency and large early release frequency.

Managing to the actions required in the CRMP and the risk-informed configuration management program will assure that the effects are known, small, and manageable.

Also, the balance of availability and reliability will also be monitored and corrected in accordance with the station's compliance with the Maintenance Rule.STP proposes to allow application of the CRMP to an emergent condition where*more than one channel of instrumentation actuation logic is inoperable.

This would allow the CRMIP to be applied in conditions that previously would have required entry into TS 3.0.3.The proposed action is a logical application of a CRMP. TS 3.0.3 was created to address conditions where the other TS had no prescribed action; i.e., where the plant was in an undefined operating configuration.

Application of the CRMP specifically addresses that situation by defining the risk associated with the configuration and facilitating the determination of the correct response.

TS 3.0.3 prescribes only one action -shutdown.

Shutdown might not be the most appropriate action and application of the CRMP provides the means for the operator to take a more effective and safer course of action.

Attachment 1: Description of Changes and Safety Evaluation NOC-AiE-06002036 Page I11 Safety Margin In accordance with RG 1. 177, with sufficient safety margins:* Codes and standards or their alternatives app roved for use by the NRC are met.* Safety analysis acceptance criteria in the Licensing Basis (e.g., FSAR, supporting analyses) are met, or proposed revisions provide sufficient margin to account for analysis and data uncertainty.

Use of the CRMP to determnine a RICT will not affect STPNOC's commitment to the codes and standards used in the design of STP. STPNOC is not proposing in this application to change any quality standard, material, or operating specification.

Acceptance criteria for operability of equipment are not changed.The design-basis analyses for STP remain applicable.

Although STPNOC will be able to have design-basis equipment out of service longer than the current TS allow, the actual expected increase in unavailability will be insignificant with respect to design-basis assumptions regarding accident mitigation.

In addition, an increase in reliability to offset any increase in unavailability would be expected.In support of its application for the license amendment extending the AOT for the Standby Diesel Generators (approved in Amendments 85 and 72), STP evaluated the capabilities of a single train of ESF equipment to mitigate design-basis accidents.

Because the governing event is a condition where only one train of ESF equipment is postulated to be available, the analyses and evaluations performed in support of Amendments 85 and 72 are relevant to the evaluations of the changes to the AOTs being proposed in the RMTS. The results of the deterministic evaluation done in support of those amendments show that with only one train of ESF equipment available, and allowing for some operator actions, STP can mitigate nearly all design-basis events. The design-basis event that could not be mitigated is not considered credible (i.e., design-basis LOCA).The CRMP also helps protect the margin of safety by preventing operation for extended periods in a configuration where a single failure would cause the loss of function of a system required to mitigate a design-basis accident.

Effective and timely maintenance practices will limit the time that any train of accident mitigation equipment is unavailable such that having even one train of ESF equipment out of service for 30 days (assuming a system or component where that duration is permitted by the CRMP) is expected to rarely occur. In addition, compliance with Maintenance Rule requirements and availability and reliability standards from the Revised Reactor Oversight Program will limit the time any required equipment is out of service.In accordance with the RMTS Guidelines, the CRMP may be used for calculating a risk-informed completion time only in Mode 1 and Mode 2 where the STP PRA is directly, applicable.

Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 12 Exceptions to the RMTS Guidelines STPNOC is taking no exceptions to the RMTS Guidelines.

5. Regulatory Safety Analysis 5.1 No Significant Hazards Determination The following changes to the TS are included in the proposed license amendment: " Proposed changes to certain ACTION statements in individual specifications to allow the application of the CRMP.* Proposed change to the CRMP in TS 6.8.3.k to reference the NEI RMTS Guidelines.

In accordance with the criteria set forth in lOCFR5O.92, the STP has evaluated these proposed TS changes and determined they do not represent a significant hazards consideration.

The following is provided'in support of this conclusion.

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

The proposed changes to the Technical Specifications to apply the CRMP do not involve a significant increase in the probability of an accident previously evaluated because the changes involve no change to the plant or its modes of operation.

In addition, the risk-informed configuration management program will be applied to effectively manage the availability of required systems, structures, and components to assure there is no significant increase in the probability of an accident.

These proposed changes do not increase the consequences of an accident because the design-basis mitigation function of the affected systems is not changed and the risk-informed configuration management program will be applied to effectively manage the availability of systems, structures and components required to mitigate the consequences of an accident.

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

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

Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 13 Therefore, none of the proposed changes involve a significant increase in the probability or consequences of an accident previously evaluated.

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

None of the proposed changes involves a new mode of operation or design configuration.

There are no new or different systems, structures, or components proposed by these changes. Therefore, there is no possibility of a new or different kind of accident.3. Does the proposed change to the Technical Specifications involve a significant reduction to a margin of safety?The associated changes to the specifications that apply the CRMP implement a risk-informed configuration management program to assure that adequate margins of safety are maintained.

Application of these new specifications and the configuration management program complements the risk assessment required by the Maintenance Rule and manages the risk more effectively than the current Technical Specifications.

Therefore, application of these new specifications will not involve a significant reduction in a margin of safety.Changing TS 6.8.3.k to reference the NEI Risk-Managed Technical Specification Guidelines is an administrative change that establishes the industry standard as the STP licensing basis. Meeting the standard provides additional assurance that the risk management program properly manages the plant configuration risk. Consequently, it does not involve a significant reduction in the margin of safety.Changes to the affected TS require some minor grammatical and structure changes to effectively incorporate the reference to the CRMP. These changes are editorial and administrative and have no safety significance.

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

Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 14 5.2 Applicable Regulatory Criteria The proposed changes will revise the AOTs associated with selected specifications so that they will be managed in accordance with a risk-informned configuration risk management program instead of having a prescriptive time in the specification.

As discussed below, this change in format and RICT management still incorporates the elements required by 1OCFR5O.36 for TS.1OCFR5O.36 requires that TS contain LCOs. The changes proposed will retain the LCOs.The current LCOs associated with the specifications to be changed include ACTION statements that require shutdown if required conditions are not met in a specified time.1OCFR5O.36 requires that: "When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met." STPNOC is proposing to change the specifications to allow for a risk-informed process for determining required remedial action. The mechanism for STPNOC's change is a risk-informed configuration management program for determining required actions and AOTs, up to a 30-day limit. Individual LCOs will indicate if the CRMP is applicable.

Consequently, the provisions of 1OCFR50.36 are met with the proposed CRMP.STPNOC is not proposing changes that remove existing LCOs or which affect the 1OCFR5O.36 requirements for Safety Limits, Surveillance Requirements, Design Requirements, or Administrative Controls.The proposed change complements recent changes to 1OCFR5O.65 requiring licensees to assess and manage risk associated with removing equipment from service for maintenance.

The risk-informed configuration management program used to determine the AOT of the TS also meets the requirement of 1OCFR5O.65(a)(4) for performing a risk assessment for equipment removed from service for maintenance.

As discussed in the section below, STPNOC is not proposing to change the design or licensing basis for STP. Compliance with other design-basis regulations (e.g., 1OCFR50.49, 1OCFR5O.46) or the General Design Criteria is not changed.Based on the discussion above, STPNOC concludes that the proposed changes to the LCOs to eliminate the specified required ACTION times and replace them with application of the CRMP is in compliance with regulatory requirements.

Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 15 6. Environmental Assessment This proposed Technical Specification change has been evaluated against the criteria for and identification of licensing and regulatory actions requiring environmental assessment in accordance with 1OCFR5 1.21. The proposed changes meet the criteria for categorical exclusion as provided for under 1OCFR5 1.22 (c) (9). The following is a discussion of how the proposed Technical Specification change meets the criteria for categorical exclusion.

Although the proposed change involves changes to requirements with respect to the use of a facility component, (i) the proposed change involves no Significant Hazards Consideration (refer to the No Significant Hazards Consideration section of this Technical Specification Change Request), (ii) there is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite since the proposed changes do not change the assumptions regarding generation of any radioactive effluents nor do they affect any of the permitted release paths, and (iii) there is no significant increase in individual or cumulative occupational radiation exposure.Accordingly, the proposed change meets the eligibility criteria for categorical exclusion set forth in 1OCFR5 1.22 (c)(9). Based on the aforementioned and pursuant to 1OCFR5 1.22 (b), no environmental assessment or environmental impact statement need be prepared in connection with issuance of an amendment to the Technical Specifications incorporating the proposed changes of this request.

Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 16 Table 1 General Case: Three-Train Design TS Requirements System/Condition Standard Two- Current STP Proposed STP Risk- Safety Evaluation Comments Train Specification Specification Informed_______________

_______________

Specifications-All Trains Operable Unlimited Unlimited Unlimited Two train and three train plants meet design-basis, including_______________

_______________

________________

single failure criterion.

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

_______________

________________

________________systems.

2 Trains Inoperable T.S 3.0.3 or T.S. 3.0.3 or As determined by the 2-train olant: loss of safety Application of the CRMP equivalent equivalent (typ.) CRMP function.

Application of CRMP recognizes the defense-in-depth recognizes plant level functional capabilities and limitations and redundancy in safety systems and provides reasonable time to take-the low probability of an initiating corrective actions. CRMP also event requiring two trains for takes into account unavailability of mitigation.

Some time to restore multiple systems.the inoperable function is appropriate based on the very low Because STP typically has no probability of an initiating event action for 2 inoperable trains, TS while in this configuration.

3.0.3 applies

and this extends RITS Initiative 4B3 to cover Initiative STP (3 trains): loss of safety 6 for these configurations.

function only for specific low probability events. Retains safe shutdown capability for non-accident conditions.

A risk-______________

_______________________________________________informed AOT is appropriate.

3 Trains Inoperable NA T.S. 3.0.3 or As determined by the Loss of safety function Some time to restore the equivalent CRMP inoperable function is appropriate based on the very low probability of an initiating event while in this_______________

________________

_________________

________________

_________________configuraonfguraion Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 17 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement New Action Requirement, Technical Discussion and Risk Basis Input to Risk Calculator to Nuimber Comments ..Determine RICT Calculated STP RICT Before Backstop,~. .(base case)1 3.3.1.18 SI input from ESFAS Action 9A With the number of OPERABLE channels one less than the Minimum Channels OPERABLE requirement, restore the inoperable channel to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ; however, one channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing per Specification 4.3.1.1, provided the other channel is OPERABLE.ACTION 9A is split into 9A.a for one inoperable channel and 9A.b for more than one inoperable channel.a. With the number of OPERABLE channels one less than the Minimum Channels OPERABLE requirement, within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months restore the inoperable channel to OPERABLE status, or apply the requirements of the CRMP, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ; however, one channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing per Specification 4.3.1.1, provided the other channel is OPERABLE.b. With the number of OPERABLE channels more than one less than the Minimum Channels OPERABLE requirement, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore at least one inoperable channel to OPERABLE status or apply the requirements of the CRMP, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months The SI Input from ESFAS ensures that if a reactor trip has not already been generated by the PITS, the ESFAS automatic actuation logic will initiate a reactor trip upon any signal that initiates SI. This is a condition of acceptability for the LOCA. However, other transients and accidents take credit for varying levels of ESE performance and rely upon rod insertion, except for the most reactive rod that is assumed to be fully withdrawn, to ensure reactor shutdown.Therefore, a reactor trip is initiated every time an SI signal is present.There are two channels for this function.

With one channel inoperable, the other channel will be available to perform the function.

There are also functionally redundant reactor trip signals (e.g. pressurizer pressure -low)With both channels inoperable, the proposed change retains the time limits consistent with TS 3.0.3 that would apply to current TS with more than one inoperable channel'.

Hoeethe_bperiators would-be alowed to apply the ,CRMP if at least one channel is still functional In accordance with theýRMTS GuidelinesY-TS 3.3.1.18, SI input from ESFAS: 485 days for one channel (train)of SSPS to be inoperable/non-functional (30 day backstop applies)'The CRMP may be applied-fo~r more than one inoperable-

-'channel.

In this case, the RMTS'Guideline criteria for~functionalit-wouldneed to be met F-or example, for a channel that is inoperable only for seismic reasons, a PRA analysis can be performed to demonstrate the risk associated with this specific situation.

ITh ere ared esii-tm;ýn associated Configluration R~isk Management

[CRM]_Cu~iqpehnes)_for SSPS Logic Train S I. SPUS Logr [RT I PS& .1 1 ______________________________

&

Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 18 Table 2 Detailed Description of Changes and Basis Specification -Old-Action Requirement New Action Requirement Technical Discussion and Risk Basis, Input to Risk Calculator to Nube Comments ~Determine RICT Calculated STP RICT Before Backstop.(base case)l~3.3.1.21 Same as 9A above Same as 9A above The LCO requirement for the Automatic 3.3.1.21 -Same result as There ar 9 de'signatoris (and Trip Logic ensures that means are 3.3.1.18, SI Input associated Configuration Risk~Automatic Trip provided to interrupt the power to allow Mvarnagem~ent

[CRM]and Interlock the rods to fall into the reactor core. (30 day backstop applies) Pgdei Iin es) f o r;Logic The reactor trip signals generated by_______the RTS Automatic Trip Logic cause PiS~ Logic Train R Action 9A the reactor trip breakers and associated

[§PRL'or [RTRI PlR bypass breaker 's to open and shut down the reactor.SS~PS Logic Tra i,[S.PS] orE[RTR IPS There are two channels for this function.

With one channel inoperable, the other channel will be available to perform the function.The PRA modelsthditaloc Iprocessing and generation digital p utput signals for the reactor trip, switchgear that causes a reactor tr~ip]With both channels inoperable, the proposed change retains the time limits consistent with TS 3.0.3 that would apply to current TS with more than one inoperable channel._However the ,ýWeiators would be allowed to app~ly the PRMP if at least one channel is still functional In accordance with the RMTS Guidelines.

1_3.3.2.1.b -SI With the number of ACTION 14 is split into 14.a The SI signal is used to initiate the Except for the pressurization and [Theý~re a si~g~nato~rs (and Automatic OPERABLE channels one for one inoperable channel functions listed below. recirculation function of the associated Configuration Flisik Actuation Logic less than the Minimum and 14.b for more than one

Reactor Trip System Control Room Envelope HVAC Management

[CRM]Channels OPERABLE inoperable channel. System and the FHB HVAC '_uidelin~es) for:ýAction 14 requirement, restore the

Turbine Trip Exhaust Subsystem, the initiated inoperable channel to a. With the number of

Feedwater Isolation functions are modeled in the SSPS -Logic Tr ai In R OPERABLE status within 24 OPERABLE channels one

Auiir Feedwater System PRA. The pressurization and S j_hours, or be in at least HOT Iless than the Minimum IIrecirculation function of the Attachment 1: Description of Changes and Safety Evaluation NOC7AE-06002036 Page 19 Table 2 Detailed Description of Changes and Basis Specification

'Old Action Requirement New Action Requiremenit Technical, Discussion an~d Risk Basis Input to. Risk Calculator to N~umber .comments, Determine RIOT I. Calculated STP RIOT Before~~Backstop

____________________

.~ (base case)l STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months ; however, one channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing per Specification 4.3.2.1, provided the other channel is OPERABLE.Channels OPERABLE requirement, within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months restore the inoperable channel to OPERABLE status, or apply the requirements of the CRMP, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months ;however, one channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing per Specification 4.3.2.1, provided the other channel is OPERABLE.b. With the number of OPERABLE channels more than one less than the Minimum Channels OPERABLE requirement, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore at least one inoperable channel to OPERABLE status or apply the requirements of the CRMP, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .*Standby Diesel Generators

Component Cooling Water System* Safety Injection System* Essential Cooling Water System* Reactor Containment Fan Coolers* Containment Isolation Phase A* Containment Ventilation Isolation" Control Room Envelope HVAC System* EAB Main Area HVAC System* FHB HVAC Exhaust, Subsystem* ESE Load Sequencers

Essential Chilled Water System* Electrical Penetration Space HVAC System There are two channels of SI automatic actuation.

With only one channel inoperable, the other channel will be available to perform the function.Manual action is also available to perform the function.

For one inoperable channel, the existing frontstop of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is adequate time to perform an assessment of the condition and determine the appropriate action and AOT.Control Room Envelope HVAC System and the FHB HVAC Exhaust Subsystem have no effect on CDF orLERF.'However, bt fteef~in have separate automatic initliation on high{ radiation and are varif led' obe actuated by the Em g c_perating Procedures., The PRA conservatively assumes that failure of any function required to be actuated causes SSPS/ESFAS failure. The required functions are specific to the initiating event. For general transients, the actuation functions are: reactor trip; auxiliary feedwater actuation; turbine trip and feedwater isolation.

For LOCAs, including SGTR, the actuation functions are: Safety injection; the ESF load sequencer, and those functions required for general transients.

For steam line breaks, the actuation functions are: steam line isolation, those required for general transients, and;depending upon location, the safety injection and ESF load sequencer functions.

For Loss of Offsite Power, the actuation functions are: the functions required for general transients, and the ESF load sequencer.

Calculated RICT: 3.3.2.1 .b -Same result as W~SSPS Logi TrainS[SPS]With morn than nn~ r'.h~nnpI IWt more__ __ _ than -on chne Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 20 Table 2 Detailed Description of Changes and Basis Specification' Old, Action Requirement New Action Requirement Technical Discussion and Risk Basis Input to Risk Calculator to Number Comments SPDetermine RiCT Calulaed TP ICTBefore Backstop (base case)1 inoperable, the proposed time limits 3.3.1.18, Si Input reflect the same allowance that application of TS 3.0.3 would provide (30 day backstop applies)for the existing botWff-Rih ch-annels' inoperable, applia~tion of the CRMFý_will allow the operators to determine if RMTS Guidelin, e f unctionality criteria-___________

__________________

_________________

beaplie. ______________can___

be_________________

3.3.2.1.c

-S I Same as Action 14 above Same as Action 14 above For the actuation relays, there are three The PRA can be applied to model There are designators (and-Actuation Relays channels, each associated with its ESF the failure of an actuated ESE associated Configuration Riik train. Actuation of either of the two train or a function associated with ManagementGidens o~Action 14 trains of actuation logic will actuate all the ESE train.three ESE trains. STP can mitigate

ESFi Act uat io nriA nearly all design-basis accidents with a Calculated RIOT: [EHSFA]_single ESE train.___One inoperable train of ESE ,42 ESE Actuation Train 0 With more than one channel relays: [SB inoperable, the proposed time limits reflect the same allowance thatESAtuio Train A 5 dy application of TS 3.0.3_would provide Trai AE C 25Idy for th e exsing TS'With two or morFe TranSF57Oay

ýhannls inoperable , appicton of tie TanB57dy RMP will allo th operators tL determine if FRMTS Guideline Train C 460 days functionality criteria can be 66pleW Mai nua6 l a ctio-0n i s generally ti _,m ely -fo r (30 day backstop applies)most accidents that would require actuation.

Two inoperable trains of ESE relays: Trains A and Care limiting:

10 days The asymmetry in the train contribution is largely due to the contribution of fires outside the control room. These fires primarily affect the B and C trains, leaving the A train for fire__________________________________

___________________

___________________________mitiationi Anyunavilablity fuAavailability_____of__A Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 21 Table 2 Detailed Description of Changes and Basis Specification Old Action Requir~ement New Action Requirement Technical Discussion and Risk Basis Input to Risk Calculator to~Number 2Comments Determine RIOT Calculated STP RIOT Before Backstop: (base case)i train equipment is more significant than the corresponding B or C trains.3.3.2.2.b

-CS Same as Action 14 above Same as Action 14 above Containment Spray automatic actuation No measurable impact on ODE or ~Although designators exist for Automatic logic actuates the Containment Spray LERF $SPS (see 3.3.1.18, 'above), if Actuation Logic System and Containment Isolation

-only the Containment Spray'Phase B. (30 day backstop applies) actuation is affected, then the Action 14 diesignators and ORM[__There are two channels for this guidelines for Containmiient function.

With only one channel Spray Trains A, B3 and C couldi inoperable, the other channel will be be used, resulting in a lower~available to perform the function.

Tis~k -value (lon~ger -RICT).Manual action is also available to perform the function.

For one IFf both ýichan n elI s ar inoperable channel, the existing INOPERABLE, useth-e frontstop of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is adequate time dlesignators for the to perform an assessment of the Con~tainment Spra ri condition and determine the appropriate action and AOT. Containrrn Spra Fi gri S__ayArq]With more than one channel inoperable, the proposed time limits C-o-ntai nrnt S~pray rain ref lect the same allowance that P[gB application of TS 3.0.3 would provide for the existinlgTS.

With býoth ch'anneqls Cna pa i in Ioperable, application of the CRMPCotimn pa rg will allow the operators to determineý if the RMTS Guidelinie criteria for_uct ___t~q~bpp~e~

Manual action is generally timely for most accidents that would require actuation of these functions 3.3.2.2.c Same as Action 14 above Same as Action 14 above For the actuation relays, there are three No measurable impact on ODE or Although doesig7iators exist for~channels, each associated with its ESE LERF ZESFAS (see 33.12.1 .c above), CS Actuation train. Actuation of either of the two if only the Containment Spray Relays trains of actuation logic will actuate all (30 day backstop applies) 'actuation is affected, then thei three ESE trains. STP can mitigate 'designators and ORM Action 14 nearly all design-basis accidents with a guifdelines frContainment

___________

_________________

____________________

pray Trains A, B,,and C willI Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 22 Table 2 Detailed Description of Changes and Basis Specif ication Old Action Requirement New Action Requirement Technical Discussion and >. Risk Basis Input to Risk Calculator to Number. Comments~

+, Determine RIOT Calculated STP RICT Before Backstop (base case)1 single ESF train. be used, resulting in a lower!dsk vque (longer RlCT)ýV With more than one channel inoperable, the proposed time limits Con~tainmnent Sprav Train reflect the same allowance that A [CGSA]application of TS 3.0.3 would provide for the existing TS. With ornee than one conia~rment 5P~Y Train channel inoperable, application of the B CSB]CRMP will allow the operators to determine if the RMTS Guideline 4 tt '~riterifor functionality can be applied.oannnryrr Manual action is generally timely for ~C I most accidents that would require actuation of the containment spray function.3.... ACTION 141 'u-n-ch-an'ged far A-CT'IO-N 1-4'is tmod-ifi-e-dbya

'Althobu~g-h COD-F -w'oul-d not b'e NA IContainment Isolation Pha'se 'note that states: affected, the PRA LR'...3a3 A and Phase B actuation'I modeling of this actuation oic6-0 logic and actuation rI~y h rvso oapyti does not account for the failure of 33 2. d.c-. CRMP does not apply fo! 'mulipleisqlation valves to ciosefr'Item 3.a.2, Containment 3.32.3ý.c.2 Isolation Phase A Autor-a-ic Actuation Logic; Item 3.a.3r kiffi-n 1'74Containment

'Isolation

'Phase A Actuation Relay'§'Item 3.c.1, Containmentti Isolation Phase B Automati Actuation Logic; or Item-,3.c.2, Containment Isolation Phase B Actuation-Relay '-3.3.2.2.d With the number of Existing Action 17 to be The Containment Pressure HI-3 signal The PRA models the .2.32d .Tc.3A OPERABLE channels one 17.a: actuates containment spray and Containment Pressure HI-3 bounding calculation in th~e CS on less than the Total Number Containment Isolation Phase B.. actuation function.

'systemn CRM guideline boLriis Containment of Channels, place the With the number of CnittwthAio14Action 17 is teeffecso igecanli Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 23 Table 2 Detailed Description of Changes and Basis Spcfiaio l Action Requirement.

New Action Requirement TechnicaI Dis 'cussion and Risk, Basis ~ s Input to Risk Caiculator "to-Nube Comments -. Determine RICT Caclated STP RICT~ Before;.--- -.~. -Backstop-

--~ --- -~ -.(base case)II K Pressure Hi-3 inoperable channel in the OPERABLE channels one 'modified by a note that it does not y Jped bypassed condition within 72 less than the Total Number 'apply to Item 3.c.3, Containment (See 3.6.2.1, Containment Bpas_oSr Tipd 3.3.2.3.c.3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months , or be in at least HOT of Channels, within 72 'Isolation Phase B onContainmenti Spray)STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months place the inoperable Pressure Hi-3.Containment hours and in at least HOT channel in the bypassed Calculated RICT: Isolation Phase SHUTDOWN within the condition or apply the The current requirement would be B on following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . One requirements of the CRMP, retained as Action a and a provision to 1 channel inoperable:

Containment additional channel may be or be in at least HOT apply the CRMP would be added.Pressure Hi-3 bypassed for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months STANDBY within the next 6 Application of the CRMP could allow >10 yrs.for surveillance testing per hours and in at least HOT application of PRA functionality to Action 17 Specification 4.3.2.1. SHUTDOWN within the conditions where the channel is (30 day backstop applies)following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . One inoperable but still able to perform its additional channel may be function in some conditions (e.g., only bypassed for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months inoperable in a seismic event). In such for surveillance testing per a condition, application of the CRMP Specification 4.3.2.1. may be preferable to placing the______channel in bypass.i~heprovs&

to apply t-h-e CJRMP does not apply for Item 3.c.3, Containment Isolation Phase B on-ConainentPressure Hi-3.3.3.2.2.d NA New Action 17.b: Action b. that applies the CRMP is Calculated RICT: 2 or more See _3j.32.'2.d, above added for conditions where more than channels inoperable:

CS on With the number of one channel is inoperable.

The ýMultiple channel in Bypass wil Containment OPERABLE channels more actuation logic for the subject functions As an upper bound, assuming the require quantification in ther Pressure Hi-3 than one less than the Total is 2/4, which allows a relatively high Containment Pressure Hi-3 signal PRA. A bou ,ndinhg calculatioii Number of channels, within de!gree of redun "any. ' ppica~tion of is unavailable, there is no change ýIn the system C IRM guideline f 3.3.2.3.c.3 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months apply the the CRMP would permit the use of the- in CDF or LERF. 'bounds the effects of two m-requirements of the CRMP RMVTS Guideline criteria for functionality

'channels in BypassFL Containment or be in at least HOT w0Lhich woud aLoW action~s such as (30 day backstop applies)Isolation Phase STANDBY in the next 6 placing an inoperable chainnel in trip for B on hours and in HOT those functions that have that Containment SHUTDOWN within the capability.

The proposed one-hour Pressure Hi-3 following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . This f rontstop time for ACTION b. is action is not required for the consistent with TS 3.0.3 that currently surveillance testing applies for this condition and is Action 17.b. provision of Action 17 a. conservative with respect to the safety significance.

Current TS allow for two (New Action) inoperable channels for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 24 Table 2 Detailed Description of Changes and Basis~Specification Old Action Requirement New Action Requirement Technical Discussion and -Risk Basis >: In-put to Risk Calcuiator to Number Comments Determine RIOt'Calculated STP RICT B~ef ore (base dase)1 for surveillance testing. To preserve this allowance, the requirements of Action b do not apply if the surveillance testing provision of Action 17.a is being applied.3.3.2. 1. a With the number of Split into ACTION 19.a and There are two actuation channels The PRA models the manual There are designators (and _OPERABLE channels one 19 gb._with a niote tFhat the associated with each of these actuation of these functions.

associated Configuration Risk SI Manual less than the Minimum CRP does not apply to functions.

Management

[CRM]Initiation Channels OPERABLE I tem 3.a.1 for Manual Pha~se Calculated RIOT: _Mdelines)for requirement, restore the Wdontainment Isolation Fr Automatic initiation of these functions is 3.3.2.2.a inoperable channel to the primary initiation process. In 1 channel: > 10 yrs. d. .24 .OPEABL sttuswitin 8 NTE:Theprovision td addition, SI and CS can be manually CS Manual hours or be in at least HOT apply the CRMP does no t i aligned and started from the control (0dybcso ple)*S S~rjl Initiation SADYwtithnet6 apply for Item 3.a.1,1 room. There are two channels for[PR hours and in COLD Containment Isolation manual actuation.

The most critical SHUTDOWN within the Phase A Manual lsolatF6uii systems for containment isolation are SP ~~TanSSS 3.32.3a. foloing30hous.those that could be open to the 9 Cotineta.

With the number of atmosphere, which is generally limited Csonataionments OPERABLE channels one to the normally closed RCB purge. For IsolMatinuPase less than the Minimum most design-basis events, manual '.3 -AnitManual Channels OPERABLE alignment is adequate for mitigation.

A____Initiation requirement, within 48 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months frontstop time for one_____hours restore the inoperable inoperable channel is commensurate A bounding calcuýlatio-n in-f-Action 19 channel to OPERABLE with the risk-significance of the Isystem .CRM~iuideline boundi status or apply the condition.

the effects of f~ lie of on#r-requirements of the CRMP, initiation charriF-or be in at least HOT A one-hour frontstop for more than one STANDBY within the next 6 inoperable channel is consistent with 332-3.a.1 hours1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and in COLD TS 3.0.3 that would apply to the current SHUTDOWN within the TS. 55ibouding calculati-on in th~following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . IytmCMtieiebud tConsisT6ent -with Action 11-4, A-ction i 9-is the effects of -fail ure of oner-b. With the number of modified by a note that it does not i nitiation chapn elI OPERABLE channels more ap~ply to Item 3.a.1 for Phase A Manual_than one less than the _Containment Isolation Minimum Channels OPERABLE requirement, Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 25 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement, New Action Requirement -Technical Discussion and Risk Balsis Input to Risk Calculator to Number Comments Determine RICT Calculated STP RICT Before Backstop (base case)1 within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore at least one channel to OPERABLE status or apply the requirements of the CRMP, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .Automatic With the number of a. With one train with the SI and CS will automatically switch over The automatic switchover to There are designators (and__Switchover to OPERABLE channels one number of OPERABLE from taking suction from the RWST to containment sump function is 'associated ConfigurationRisk Containment less than the Minimum channels less than the taking suction from the containment modeled in the recirculation SI 'Management

[ORM] -Sump: Channels OPERABLE Minimum Channels sump when the RWST low-low level is common system model. _Guidelines)_fo~r:

requirement, restore the OPERABLE requirement, reached.3.3.2.7.a inoperable channel to within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months restore Calculated RICT: r 1 Common T-ra-in A OPERABLE status within 48 the inoperable channel to There is one channel for each of the [S!PA]Automatic hours or be in at least HOT OPERABLE status or three ESE trains for both of these 1 channel: 246 days based on_____Actuation Logic STANDBY within the next 6 apply the requirements of functions.

A single inoperable channel switchover function in PRA

SI j Co0mmonwtrah-and Actuation hours and in COLD the CRMP, or be in at effectively makes the associated train [SnB9 Relays SHUTDOWN within the least HOT STANDBY of CS and SI inoperable.

The 48-hour (30 day backstop applies)following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months allowed outage time is not consistent t~~m o~an 3327band in COLD with the 7-day allowed outage time for SlCmo ri-3327bSHUTDOWN within the a train of SI. Application of the CRMP [Sjpg]f RWST low-low following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . will allow the requirements to be levelconsistent.

There is substantial margin levelb. With more than one train in the design since STP can mitigate with the number of nearly all design-basis accidents with a Action 19 to new OPERABLE channels single ESF train.Action 19A less than the Minimum Channels OPERABLE The wording of Actionl19A better requirement, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months reflects the one channel/train and three restore the channels for train configuration and logic of this at least two trains to instrumentation than the wording of OPERABLE status or Action 19, which applies to functions apply the requirements of with two actuation channels._4~idiý&irs the CRMP, or be in at fj-sid aiqte ja6froristqtoptneoappl least HOT STANDBY ihe CRMPF§ -'within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD For conditions where more than one SHUTDOWN within the Itrain is inoperable, one hour is ______________

_____________

Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 26 Table 2 Detailed Description of Changes and Basis Specification Ol cin Requirement New Ae ctinRqieet TcnclDsusion n Risk Basis input to Risk 'Calculator to Numbe ComentsDetermine RICT: 4. Calculated STP RICT Before 4 Backstop________ <j (base case)1 following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . established to restore the channels for at least two of the three trains or to apply the requirements of the CRMP.One hour is consistent with the allowed outage time of TS 3.0.3 that would apply to the current TS.Containment ACTION 20: New Action 20A: The primary changes from original If the containment pressure Hi-i 3.3.2.1 .d, 3.3.2.3).a, .3.3 Pressure Hi-i Action 20 are the provision to apply the signal is INOPERABLE but Iand 3.3.2.3.oj With the number of a. With the number of CRMP with one inoperable channel and functional for some conditions 3.3.2. 1. d OPERABLE channels one OPERABLE channels a new Action c that applies with more (e.g., seismic qualification) then A b~oudn 6cuaibn tih less than the Total Number of one less than the Total than one inoperable channel, the PRA can be used to system CRM guidelrine bunds Loss of power POWneRlPRAINa STARTUP an/r Nme fCand/rTheonanensresreH-determine a RICT. As an upper the effects of failure of one ----POWR PEATON ay STRTP ad/r heConaimet resur H-1bound, assuming the Iinitiation channel.3328aproceed provided the POWER OPERATION actuation function is modeled in the Containment Pressure Hi-i signal ----3.3..8.afollowing conditions are may proceed provided PRA Cosqety nalwdis unavailable (only the hefecsobu___

4.1 k EF ussatisfied:

the following conditions outage time can be calculated for its pressurizer pressure Low signal UnevlaerlyfIurca ar aife:unavailability.

The function provides is available for SI actuation): .be estimated by ,disabling thie-Loss OfVoltage insalldbpasts For Functional Units wt mitigation for main steam line breaks, I soitdES u.Se Los O Vltae nsaled ypsstes Fr untioalUnts feed line breaks and LOCA. The SI Calculated RICT: > 10 years 3.8.3. 1.a capability, the inoperable with installed bypass actuation for the MSLB provides the 3.3.2.8.b.

channel may be placed in test capability, the input to the reactor trip. This function (30 day backstop applies)bypass, and must be inoperable channel has a bypass capability, so ACTION 4.16 kV ESF Bus placed in the tripped may be placed in 20.b ned ntbe apiedanit UdrVlae- condition within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . bypass, and within reureet ne e not e iaplue ad intse For undervoltage/degraded UnderaVoltae 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months place the prosequiremet arentionclddi.h voltage instrumentation, Degraded Note: A channel may be channel in the proposedlit new action.r Voltage bypassed for up to 12 tripped condition orchnesoeierfctnwul ConcdntWih hours for surveillance apply the Current TS allow for two inoperable be the same as one inoperable CicdnWih testing per Specification requirements of the channels for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for train of emergency ESF power SI 4.3.2.1, provided no more CRMP. surveillance testing. To preserve this (i.e., an inoperable SDG). See than one channel is in allowance, the requirements of Action b 3.8. 1.1 .b for the associated RICT.3.3.2.8.c bypass at any time. Note: A channel do not apply if the surveillance testing may be bypassed provision of Action 20A.a is being 4.16 kV ESF Bus b. For Functional Units with for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months applied.Undervoltage

-no installed bypass test for surveillance Sustained capability, testing per The degraded voltage and Degraded Specification undervoltage instruments do not have Voltage 1. The inoperable channel is 4.3.2.1, provided installed bypass capability, so only placed in the tripped chnnoel isa ine original ACTION 20 b. is relevant.New Action 20A condition within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , bypasselatsany Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 27 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement New Action Requirement Technical Discussion and ,Risk'Basis Ilnput to Risk Calculator to Number iComments K. Determine RICT: 4 ~~Calculated STP RICT Before .2:~4~ Backstop (base case)i and time.2. The Minimum Channels OPERABLE requirement is met; however, the inoperable channel may be bypassed for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for surveillance testing of other channels per Specification 4.3.2.1.For Functional Units with no installed bypass test capability, 1. Within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months place the inoperable channel in the tripped condition or apply the requirements of the CRIMP, and 2. The Minimum Channels OPERABLE requirement is met;however, the inoperable channel may be bypassed for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for surveillance testing of other channels per Specification 4.3.2.1.b. With the number of OPERABLE channels more than one less than the Total Number of Channels, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore at least two channels to OPERABLE status for functions with three channels and restore at least 3 channels to OPERABLE status for functions that have four channels, or apply the requirements of the CRMP; or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months There are four channels per ESF train for each of the functions with a 2/4 actuation logic. Consequently, the function remains capable of actuation as long as there are at least two operable channels.The consequences of the function not being capable of actuating is that a single train of emergency ESF power will not start in the event of a transient or accident that involves a loss of off -site power. The two remaining trains provide adequate mitigation capability.

The one-hour ACT for more than one inoperable channel is consistent with application of the current TS, which requires the application of TS 3.0.3.__ --I _ _I__ _ _ _ _ _ _ _ _ _ _ _ I-_

Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 28 Table 2 Detailed Description of Changes and Basis Z:OtIU I U)UVVN witnin mne following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and be in COLD SHUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . This action is not required for the surveillance testing provision in the note to Action 20A.a..9 I. I 4 4 3.3.2.4.b Steam Line Isolation Automatic Actuation Logic and Actuation Relays 3.3.2.6.b Auxiliary Feedwater Automatic Actuation Logic 3.3.2.6.c Auxiliary Feedwater Actuation Relays Action 22 With the number of OPERABLE channels one less than the Minimum Channels OPERABLE requirement, restore the inoperable channel to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in at least HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ; however, one channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing per Specification 4.3.2.1 provided the other channel is OPERABLE.Split Action 22 into 22.a and 22.b.a. With the number of OPERABLE channels one less than the Minimum Channels OPERABLE requirement, within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months restore the inoperable channel to OPERABLE status or apply the requirements of the CRMP, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in at least HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ;, however, one channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing per Specification 4.3.2.1 provided the other channel is OPERABLE.b.With the number of OPERABLE channels more than one less than the Minimum Channels Steam line isolation has 2 channels, either of which will initiate the isolation function.

With one channel inoperable, the other channel is available to initiate the function.

With one chan nel inoperable, 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months providesfirnie to3'restore the channel or apply he CRMP.With both channels inoperable, the one hour action time is consistent with the requirements of TS 3.0.3 that currently applies and provides operators with an option to determine if the RMTS G3uideline criteria for functionalit cap be applied The AFW automatic actuation logic and actuation relays are train-specific and the CRMP may be applied to provide AOTs that are consistent with the ACT for the AFW train(s) made inoperable by the inoperable actuation.

Calculated RICT: 3.3.2.4.b 1 channel: >10 yrs.(30 day backstop applies)3.3.2.6.b 1 channel >l10yrs.(30 day backstop applies)3.3.2.6.c Train A 39.4 days, train B 736 days, train C 502 days.Train A Actuation Relays fail AFW Trains A and D, The other actuation relay trains fail only the associated AEW train. Train C is different than Train B because of the two Loss of DC Bus Initiators (Bus A and Bus B). The AEW B train results show an effect on the Loss of DC Bus A, while the AEW There are designators (an~d associated Configuration Risk Manageme~nt

[CRM]Guideinies) for:* SSPS Logic Train R[SPR] or MS Isolationi Tr1ain A JMSISAJ S SLogic rain S [SPSI or MIS 1i3olation rin~[MSlSB]Tthere ierý,Jcignators (and assoc riated r C~onfigu ration Risk Maniagementý

[CRIVI3 Guielines) for:* SSPS Logic Train R[SPR]SSPS Logic Train S [SPS Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 29 Table 2 Detailed Description of Changes and Basis~Specification Old Action Requirement New Action Requirement Technical Discussion and Risk Basis Input to Risk Calculator to Number Commninets .Determine RICT Calculated STP RICT Before Backstop (base caae)1 OPERABLE requirement, C train results show an effect on within one hour restore at the Loss of DC Bus A and B. 3.-6c least one channel to The calculation did not credit _______OPERABLE status for operator action to manually start rL- Aýux-1arv functions with two the AFW pumps. Feedwater Train A [AFA)channels or restore at -.and Auxiliary-Feedwatei, least two channels to (30 day backstop applies) Yrrain D [AFD] -OPERABLE status for functions with three

Train B AuJxiliary channels, or apply the Feedwater Train 'B_[AFB]1 requirements of the CRMP; or be in at leastTriC uiiat HOT STANDBY withinFedarTaiC[AC the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in at gdaerinC[ý

]least HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .3.3.5.1 a. With one less than the Reword Actions 2.a and 2.b In Action 2, the inoperability of the The PRA models the function of There are designators (and required number of to reference the CRMP, and instrument makes the associated these valves to dissipate RCS associated Configuration Risk-Atmospheric OPERABLE channels, add new Action 2.c for equipment inoperable and the heat when the main condenser is 'Managenment[CM Steam Relief restore the inoperable condition where more than appropriate action is to enter the TS for not available.

See the discussion

%udlnsfor:

Valve channel to OPERABLE two channels are that equipment.

The proposed for TS 3.7.1.6 for additional Instrumentation status within 7 days; or be inoperable, changes to allow the application of the information on the PRA modeling Steam d -rat-rPOR in at least HOT STANDBY CRMP in Action 2 will permit operators of these valves.Action 2 within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , a. With one less than the to apply AOTs to the actuating

?8 j required number of instrumentation that are consistent with Calculated RICT >10 yrs. ____Ste-am TGqenator POV OPERABLE channels, the AOTs for the actuated equipment.

B [POýRVq]within 7 days restore the (30 day backstop applies)b. With two less than the inoperable channel to* Steam GeneratorPORV required number of OPERABLE status or apply C [POR VC]OPERABLE channels, the requirements of the See the assessment for TS 3.7.1.6. for restore at least three CRMP; or be in at least the design functions of the valves. Steam Gnrt-tO 'channels to OPERABLE HOT STANDBY within the Sem enrtIO status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ; or be next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . P [PFIRVD]in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . b. With two less than the required number of______________________________OPERABLE channels, _______________

_________________________

Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 30 Table 2 Detailed Description of Changes and Basis Specification Old Action 'Requirement New Action Requirement Technical Discussion and Risk Basis Input to Risk Calculator to Number Cmments- Determine RIOT Calculated STP RIOT Before Backstop (bafse case)1 within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months restore at least three channels to OPERABLE status or apply the requirements of the CRMP; or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .c. With more than two less than the required number of OPERABLE channels, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore at least two channels to OPERABLE status or apply the requirements of the CRMP; or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .__________

& I.

Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 31 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement New Action Requirement -Technical Discussion and Risk Basis 2.Input to Risk Calculator to Number Cbmffents.

Determine RlCT;Calculated STP RICT Before Backstop (base c~ase)1 3.4.4 Pressurizer PORVs and Associated Block Valves Action b.With one PORV inoperable due to causes other than excessive seat leakage, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months either restore the PORV to OPERABLE status or close the associated block valve and remove power from the block valve; restore the PORV to OPERABLE status within the following 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .With one PORV inoperable due to causes other than excessive seat leakage, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months either restore the PORV to OPERABLE status or close the associated block valve and remove power from the block valve; within the following 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months restore the PORV to OPERABLE status or apply the requirements of the CRMP, or be in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .The PORVs function to relieve RCS pressure during design transients up to and including the design step load decrease with steam dump. Operation of the PORVs minimizes the undesirable opening of the pressurizer safety valves.The operability of the PORVs and block valves is based on their being capable of performing the following functions: " Manual control of the PORVs to control RCS pressure for plant shutdown and for response to the steam generator tube rupture accident.* Maintaining the integrity of the reactor coolant pressure boundary.

Excessive leakage past the PORV could impair the ability to detect unidentified RCS pressure boundary leakage and the ability to effectively control excessive PORV leakage with the block valves is governed by this TS.Application of the ORMP Will allow an assessment of the functionality of the PORV and an assignment of a RIOT that reflects the actual plant condition.

The redundant PORV is still operable to perform the required safety functions.

The pressurizer safety valves are still available for design-basis overpressure relief.The PRA models the pressurizer PORVs for Feed and Bleed, RCS pressure response to loss of load events, ROS depressurization in response to a steam generator tube rupture, and response to ATWS overpressure events, If a PORV is blocked due to leakage, that PORV is unavailable for ATWS response in the PRA. If a PORV is unavailable for any other reason, the PRA assumes that the PORV is failed.Unavailability of either PORV guarantees failure of the feed and bleed function modeled in the PRA.Calculated RIOT: One inoperable PORV: 355 days (30 day backstop applies)TeeaIr-esignatorFs

-(and associated Configuration R~ik'Managemnent

[C -R1]bulidlelnes)"for:

P reýssurizer PORVý A SPress'u rizer'PORV Aýcvalve [BLOCKs,]block valve _[POCýKB]kbLcKAand BLOCKB are dýes ignato rs 'that are used in'and The risk assessment-

'calculator when PORV lea~ka~ge is isolated by block valve closuredF-I.

Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 32 Table 2 Detailed Description of Changes and Basis Speciflication Old'Action Requirement New Action Requirement Technical Discussion.

and ~ Risk Basis Input to Risk Calculator to Number Comments DtrieRO Calculated STP RIOT Before Backstop (base case)1 3 4.4 With both PORVs inoperable With both PORVs Overpressure protection is still provided Calculated RIOT: Se344~by due to causes other than inoperable due to causes by the Code safety valves and Pressurizer excessive seat leakage, other than excessive seat pressurizer spray is still available for Both PORVs inoperable:

343 PORVs and within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months either restore leakage, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months apply response to normal pressure days Associated at least one of the PORVs to the requirements of the fluctuations.

Block Valves OPERABLE status or close CRMP, or restore at least (30 day backstop applies)their associated block valves one of the PORVs to Action c. and remove power from the OPERABLE status or close The slight difference in the RIOT block valves and be in HOT their associated block STANDBY within the next 6 valves and remove power for one or two PORVs inoperable hours and HOT from the block valves, and reflects the small contribution of SHUTDOWN within the be in HOT STANDBY within pressurizer PORV failure to following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and HOT scenarios other than feed and SHUTDOWN within the

bleed.following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .3.4.4 With one block valve With one block valve The existing required action makes no INOPERABLE and Open S:ee 3.4 4,above inoperable, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inoperable, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months distinction regarding the degree of Pressurizer restore the block valve to restore the block valve to functionality of the block valve. A >10 yrs.PORVs and operable status or place its OPERABLE status or place degraded block valve may be able to Associated associated PORV in closed its associated PORV in perform its expected function.

(30 day backstop applies)Block Valves position; restore the block closed position; within 72 valve to operable status hours restore the block INOPERABLE and Closed within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ; otherwise, valve to OPERABLE status be in at least HOT or apply the requirements of Atod.STANDBY within the next 6 the CRMP; otherwise, be in *- .Same as PORV Action 3.4.4 Acin .hours and in HOT at least HOT STANDBY Action b.SHUTDOWN within the within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .A minor administrative format change is made to put OPERABLE in all capital letters.

Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 33 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement New Action Requirement Technical Discussion and RikBssInput to Risk Calculator to Number Comments ,*Determine'RIOT Calculated STP RICT Before,~ j Backstop.(base case)1 3.4.4 With both block valves With both block valves The existing time limit for restoration of INOPERABLE and Open e ý.4 4ý, ab~o ve inoperable, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inoperable, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months operability is inadequate to take Pressurizer restore the block valves to restore the block valves to reasonable action. Application of the >10 yrs.PORVs and operable status or place the OPERABLE status or place CRMP provides an appropriate Associated associated PORVs in the the associated PORVs in alternative that is commensurate with (30 day backstop applies)Block Valves closed position; restore at the closed position; restore the risk-significance of the least one block valve to at least one block valve to configuration.INPRBEadCoe OPERABLE status within the OPERABLE status withinINPRBEadCoe next hour; otherwise, be in at the next hour or apply the Atoe. least HOT STANDBY within requirements of the CRMP; Same as PORV Action 3.4.4 Acin .the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT otherwise, be in at least Action c.SHUTDOWN within the HOT STANDBY within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .A minor administrative format change is made to put OPERABLE in all capital letters.3.5.1 With one accumulator With one accumulator The accumulators function to assure that The PRA assumes that two of the Phe're rde ];isnat~is-(i~c inoperable, except as a inoperable, except as a a sufficient volume of borated water will three accumulators are required associated C'onfiguration Risk SaftyInecio rsut o bro cncntaton result of boron concentration be immediately forced into the reactor for success in mitigation of a large Managem~ntf[ORMI Guidleliný7) oaeyIjeto eultsd the brequirnedtrlimits outside the required limits, core through three RCS cold legs in the break and one of three for, System ousd h eurdlmt, within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months restore the event the RCS pressure falls below the accumulators is needed for_Accumulators restore the inoperable inoperable accumulator to pressure of the accumulators.

The mitigation of a medium break. The r---- 'accumulator to OPERABLE OPERABLE status or apply surge of water into the core provides the accumulators have little risk- !~LOLop A accumulatoir Action a. status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or be the requirements of the initial cooling mechanism in the event of significance due to the very low [CA in at least HOT STANDBY CRMP, or be in at least HOT a large RCS pipe rupture. The accident frequency of an initiating event within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and STANDBY within the next 6 analysis assumes the injection of two that would require them to ~ Lo'B~cmlti reduce pressurizer pressure hours and reduce pressurizer accumulators, since the volume of one function.LopBacmltr to less than 1000 psig within pressure to less than 1000 accumulator is assumed to go out the [CB the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . psig within the following 6 break in the RCS and not reach the Calculated RICT: hours, core. '*.Loop3 C accumulator, 1 inoperable accumulator:

2700 ýACCC]The accumulators would only be days expected to be used for the most unlikely accidents.

'An ab-sessmenrt

'can bI~e-i'form~ed~t6-d'termin~e the-- (30 day backstop applies)significance of the-con~dftionTs Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 34 Table 2 Detailed Description of Changes and Basis Specification.

Old Action Requirement New Action Requirement Technical Discussion and Risk Basis Input to Risk Calculator to Number Comments Determine RICT Calculated STP RICT Before'Backstop ,(base case)1 3.5.1 New ACTION With more than one The one-hour requirement is a 2 inoperable accumulators:

360 SW351abv accumulator inoperable, conservative time considering the low days Safety Injection except as a result of boron risk significance of these components System concentration outside the and is consistent with TS 3.0.3 which (30 day backstop applies)Accumulators required limits, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months would apply for more than one restore at least two inoperable accumulator in the current Action b. accumulators to OPERABLE TS.status or apply the requirements of the CRMP, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and reduce pressurizer pressure to less than 1000 psig within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .3.5.1 (Previously ACTION b) With the boron concentration Accumulator boron concentration 1 inoperable accumulator:

2700 Add__e~~Lý uCeii of one accumulator outside deviations are not likely to be days Safety Injection With the boron concentration the required limit, within 72 significantly outside required limits.System of one accumulator outside hours restore the boron Conservatism in the accident analysis (30 day backstop applies)Accumulators the required limit, restore the concentration to within the provides reasonable assurance that the boron concentration to within required limits or apply the accumulators would still provide their the required limits within 72 requirements of the CRMP, required function even with hours or be in at least HOT or be in at least HOT concentration outside the limits.Actonc.STANDBY within the next 6 STANDBY within the next 6 However, boron concentration is not Acin .hours and reduce hours and reduce specifically modeled in the PRA, and pressurizer pressure to less pressurizer pressure to less STP would consider an accumulator with than 1000 psig within the than 1000 psig within the boron outside its limit to be non-following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . functional.

3.5.1 New ACTION With the boron The one-hour requirement is a 2 inoperable accumulators:

360 Adre-si concentrations of more than conservative time considering the low days Safety Injection one accumulator outside the risk significance of these components System required limit, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and is consistent with TS 3.0.3 which (30 day backstop applies)Accumulators restore the boron would apply for more than one concentration of at least two accumulator with boron concentration Action d accumulators to within the out of limit in the current TS.____________________________________required limits or apply the I_________________

_____________________________

Attachment 1: Description of Changes and Safety Evaluation Table 2 Detailed Description of Changes and Basis NOC-AE-06002036 Page 35 Specification

'Old Action Requirement New Action, Requirement Technical Discussion and Rs ai nu oRs acltrt ,Number -Comments p eemneRC Calculated STP RICT BeforeDermnRIT IBackstop r (base case)1 requirements of the CRMP, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and reduce-pressurizer pressure to less than 1000 psig within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .3.5.2 With less than the above With less than the above The OPERABILITY of three The PRA success criteria Th1ere ' r designators (and~subsystems OPERABLE, subsystems OPERABLE, independent ECCS subsystems requires injection from at least associated Confiquration Risk7 ECCS in but with at least two High but with at least two High ensures that sufficient emergency core one train of ECOS. However, for M ,anagement

[CRiM]MODES 1 ,2,& 3 Head Safety Injection pumps Head Safety Injection cooling capability will be available-in the core cooling, the design basis _Guidelines) for:f'in an OPERABLE status, pumps in an OPERABLE event of a LOCA assuming the loss of acceptance criteria are the Action a. two Low Head Safety status, two Low Head one subsystem through any single criteria of I 00FR5O.46 while PRA _.SI CommonTraini Injection pumps and Safety Injection pumps and failure consideration.

Each subsystem acceptance criteria are based on associated RHR heat associated RHR heat operating in conjunction with the no core damage (core exit exchangers in an exchangers in an accumulators is capable of supplying thermocouple temperature less ~ orohii OPERABLE status, and OPERABLE status, and sufficient core cooling to limit the peak than 1200 9 F). [!B sufficient flow paths to sufficient flow paths to cladding temperatures within accommodate these accommodate these acceptable limits for all postulated The difference in the calculated OPERABLE Safety Injection OPERABLE Safety Injection break sizes. One EGGS is assumed to RIOT below is due to fires outside

SI Comqmon Train Q pumps and RHR heat pumps and RHR heat discharge completely through the the control room. These fires IIC exchangers,**

restore the exchangers,**

within 7 days postulated break in the RCS loop, primarily affect the B and C inoperable subsystem(s) to restore the inoperable Thus, three trains are required to trains, leaving the A train for fire OPERABLE status within 7 subsystem(s) to satisfy the single failure criterion, mitigation.

Any unavailability of A days or be in at least HOT OPERABLE status or apply train equipment is more STANDBY within the next 6 the requirements of the With 1 inoperable train of SI, there is no significant than the corresponding hours and in HOT CRMP, or be in at least loss of safety function, and STP meets B or C trains.SHUTDOWN within the HOT STANDBY within the single failure except for specific low Cluae IT following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT probability events. Cluae IT SHUTDOWN within the 1 inoperable train following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .TriA19das Train B 2087 days, Train C 2205 days (30 day backstop applies)

Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 36 Table 2 Detailed Description of Changes and Basis Specification:

Old Action Requirement New Action Requirement, Technical Discussion and Risk Basis ~ input to Risk Calculator to Number Comments KDetermine RICTK K Calculated STP RICT Before Backstop (base case)l 3.5.2 Existing ACTION b. moved New ACTION b. With two inoperable trains of SI there is 2 inoperable trains -35 days W~here are designators (and~to ACTION c. generally not a loss of safety function, associated Configuratior-n Rislk ECCS in With less than two of the although STP cannot mitigate LBLOCA (30 day backstop applies) Management

[ORM]MODES 1,2, & 3 required subsystems if the SI train is injecting into the broken 'G 1de Ii n es)_fo~r: OPERABLE, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months RCS loop. Mitigation of SBLOCA with 3 inoperable trains 5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months restore at least two SI in the broken loop requires operator SI Coim-mon Train A subsystems to OPERABLE action. Steam line break mitigation is (SIA]Actonb.status or apply the impaired, but DNB is not expected to Atob.requirements of the CRMP, occur. SICmoTriB or be in at least HOT § ______~a~ýý STANDBY within the next 6 With no operable trains and no -BI hours and in HOT functionality, STP loses the SI safety SICmoTriC SHUTDOWN within the function; however, a RICT is [SI Co] o' ri following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . appropriate to accommodate specific situations where the SI trains are degraded but still functional and to allow for timely actions commensurate with the actual significance of the condition.

The proposed one-hour time limit is consistent with the requirement of TS 3.0.3 which would apply to the current TS.3.5.2 No ACTION c. In the event the ECCS is Administrative change to accommodate NA NK/-actuated and injects water new ACTION b. No change to the TS ECCS in into the Reactor Coolant requirement.

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

_____________

Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 37 Table 2 Detailed Description of Changes and Basis Specification OdAction Requirement New Action Requ ireme~nt Technical DicsinadRslai nput to Risk Calculator to Number Comments Determine RICT Cluated STP RICT Before* Backstop V.. ...(base case)1i exceeds 0.70.3.5.5 RWST MODE 1,2, 3, 4 With the RWST inoperable, restore the tank to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or be in at least HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .With the RWST inoperable, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore the tank to OPERABLE status or apply the requirements of the CRMP, or be in at least HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .The OPERABILITY of the refueling water storage tank (RWST) as part of the ECOS ensures that a sufficient supply of borated water is available for injection by the ECOS in the event of a LOCA or a steamline break. The limits on RWST minimum volume and boron concentration ensure that: (1) sufficient water is available within containment to permit recirculation cooling flow to the core, (2) the reactor will remain subcritical in the cold condition following LOCA, and (3) the reactor will remain subcritical following a steamline break and there will be no fuel failure.The maximum allowable value for the RWST boron concentration forms the basis for determining the time (post-LOCA) at which operator action is required to switch over the ECOS to hot leg recirculation in order to avoid precipitation of the soluble boron.The limits on contained water volume and boron concentration of the RWST also ensure an acceptable pH value for the solution recirculated within containment after a LOCA.The proposed application of the CRMP allows the operator to make a determination based on the-specific., situation and the degree of degradation of the RWST. A number of situations may make the RWST inoperable, but still functional in accordance with the RMTS Guidelines.

The PRA does not model the boration function associated with the RWST.Calculated RICT: 5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months (based on RWST not being functional)

Voluntary entry into a condition where the RWST is non-functional is not permitted because it exceeds the 1 E-03 CDF criteria in the RMTS Guidelines.

Ifor Safety Injection,~

a noni___Ifunctional RWST requires 'entr'of all three SI Common Trains (SICA SICB SICC) in the Risk asessment caiculatooif I. I .1 ______________________________

£ Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 38 Table 2 Detailed Description of Changes and Basis Specfictio Ol AcionRequirement New A~ction Requirement Technical Discussion andRikBssIptoRskClu-aoro iNumber .Comments

.Determine RiCT Calculated STP RICT Before i Backstop (base case)1.3.5.6 With one RHR loop With one RHR loop The OPERABILITY of the RHR system The PRA models the RHR Theýre-are d~esignatours (and inoperable, restore the inoperable, within 7 days ensures adequate heat removal function to provide long term 'associated Configurtio~n Risk RHR required loop to OPERABLE restore the required loop to capabilities for Long-Term Core decay heat removal from the Management

[CRM]I status within 7 days or be in OPERABLE status or apply Cooling in the event of a small-break reactor core during the SI '_ukidriqqs) for: MODE 1, 2, 3 at least HOT STANDBY the requirements of the loss-of -coolant accident (LOCA), an recirculation phase of a small within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and CRMP, or be in at least isolable LOCA, or a secondary break in break or large break LOCA and Residual H-tR-emoval Acinain HOT SHUTDOWN within HOT STANDBY within the MODES 1, 2, and 3. The limits on the to remove core decay heat and ---A [RHRAJ@Acinathe following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT OPERABILITY of the RHR system sensible heat from the reactor SHUTDOWN within the ensure that at least one RHR loop is core and RCS to achieve and Resda-e-i

,.ud following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , available for cooling including single maintain cold shutdown after the ~ Ysda~aenvl active failure criteria, following events: feedwater line break, secondary steam line The proposed action is j ustifiled by the break, and SGTR _* ___ idaHeat Remnoval C plant-specific function of RHR and the [RtiRC]degree of redundancy at STP. STP's Calculated RICT: RHR does not perform a SI function.

It is required only for long-term cooling 1 inoperable RHR train: after shutdown or post-accident.

In post-LOCA conditions, LHSI is >10 yrs.functionally redundant.

(30 day backstop applies)3.5.6 With two RHR loops With two RHR loops The application of the CRMP is justified Calculated RICT: iThere are designators, (and~inoperable, restore at least inoperable, within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months by the plant-specific function of RHR associated Configufration Ris-k RHR two RHR loops to restore at least two RHR and the degree of redundancy at STP. 2 inoperable RHR trains: Management

[CRM]OPERABLE status within 24 loops to OPERABLE status STP's RHR does not perform a SI 'Gi~deline ) for: MODE 1, 2, 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months or be in at least HOT or apply the requirements of function.

It is required only for long- 524 days STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months the CRMP, or be in at least term cooling after shutdown or, post-... Residual Heat Pcemnval Action b and in HOT SHUTDOWN HOT STANDBY within 6 accident.

In post-LOCA conditions, (0dybcso ple)'A[H~within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . hours and in HOT LHSI is functionally redundant.(3dabcktpplis

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

Residual Hal Reoval B[RH RB]-L__Reosidual Heat Rmvi Attachment 1: Description of Changes and Safety Evaluation Table 2 Detailed Description of Changes and Basis NOC-AE-06002036 Page 39 Specification Old Action Requirement New Action Requirement technical Discussion and Risk Basis, Input to Risk Calculator to, Number Comments ~Determine RIOT Calculated STP RICT Before-Backstop ~(base case)1 3.6.2.1 Containment Spray Action a.With one Containment Spray System inoperable, restore the inoperable Spray System to OPERABLE status within 7 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ; restore the inoperable Spray System to OPERABLE status within the next 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or be in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .With one Containment Spray System inoperable, within 7 days restore the inoperable Spray System to OPERABLE status or apply the requirements of the CRMP, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ; restore the inoperable Spray System to OPERABLE status within the next 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or be in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .The OPERABILITY of the Containment Spray System ensures that containment depressurization and cooling capability will be available in the event of a LOCA or steam line break. Containment Spray System also provides a mechanism for removing iodine from the containment atmosphere.

The Containment Spray System is comprised of 3 trains. 2 operable trains meet the design-basis and 1 train is adequate to perform the design basis functions at a degraded level. Reactor Cb-ntitaniffeit Fiin C~olers jpro'video' Sfunctionally redundant containment .hueat Lremoval capability!

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

The 30-day RICT for Containment Spray is a result of the following:

Containment Spray has little or no value for pressure challenges to containment because of the large margin in the containment building design. Containment will not fail from overpressure from a design basis event even with no spray." Containment Spray has little or no actual value for dose mitigation of a design basis accident.

The CS design basis assumes a degree of core damage that is not credible for design basis events where the ECCS performs as designed.Calculated RICT:>10 yrs. based on LERE (30 day backstop applies)The Containment Spray System is not risk-significant.

Therdiare designators,7an

~associaitedl Configuration Risk Marnagemrent

[CRM]Guidelitnes) for: C ntanment SpLay A C oa~ntamert Spjy[CSBJ*IContainmnent Spray C I I A Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 40 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement New Action Requiremenit Technical Discussion and Risk Basis Input to Risk Calculator to Number Comments Determine RICT CalculateldSTP RICT Before~Backstop 4. (base case)1 3.6.2.1 The current TS have no With more than one Reactor Containment Fan Coolers Calculated RIOT: IThere are desinators (and, action for more than one Containment Spray System provide functionally redundant associated, Configuration Risk~Containment train of CS inoperable and inoperable, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months containment heat removal capability.

>10 yrs based on LERF Management

[CRM]Spray TS 3.0.3 would apply. restore at least two Spray Evaluations performed for STP TS 9uidehnes) for:-Systems to OPERABLE Amendments 85/72 determined that a (30 day backstop applies)New Action b. status or apply the single train of RCFCs and Containment Reabtor Containment Fan requirements of the CRMP, Spray is adequate for containment heat ýCooler A [RCFCA]j or be in at least HOT removal and RCB pressure control in STANDBY within the next 6 accident conditions.

CompensatoryRecoCntnmna hours and in COLD actions can be taken to reduce Iodine CI71- B RC~FCB]-SHUTDOWN within the contribution to operator dose. oe following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . IC'The proposed time limit of one hour to n _RatrCnainment Fan apply the CRMP is consistent with the Coe E~FC time limit of TS 3.0.3 which would apply to the current TS for more than one inoperable train of CS.3.6.2.3 With one group of the above With one group of the above The OPERABILITY of the Containment The PRA models the RCFC frhere ar~e designators,(an'd required Reactor required Reactor Cooling System ensures that: (1) the functions to ventilate and cool the associated Conifigu ration Ri~sk Reactor Containment Fan Coolers Containment Fan Coolers containment air temperature will be main area reactor containment Management

[CRM]Containment inoperable, restore the inoperable, within 7 days maintained within limits during normal building and to maintain guý_idelings) fo~r:ýFan Coolers inoperable group of RCFC to restore the inoperable group operation, and (2) adequate heat containment pressure within OPERABLE status within 7 of RCFC to OPERABLE removal capacity is available when design limits during accident Reactor Containment Fan Action a. days or be in at least HOT status or apply the operated in conjunction with the conditions Cooler A [RCFCA]STANDBY within the next 6 requirements of the CRMP, Containment Spray Systems during II-hours and in COLD or be in at least HOT post LOCA conditions.

STPEGS has Reactor Containment Fan Cooler RAct- Cotimn a SHUTDOWN within the STANDBY within the next 6 three groups of Reactor Containment action levels have no significant

-CoolerB[BCFCB]

following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . hours and in COLD Fan Coolers (RCFCs) with two fans in effect on core damage frequency SHUTDOWN within the each group (total of six fans). Five fans or to large early release Rat CoaimnFn following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months , are adequate to satisfy the safety frequency.

__,Rea(-[r ConaimetFar requirements including single failure. C01C RqQf Calculated RICT: Application of the CRMP is acceptable for calculating an extension of the >10 yrs. based on CDF and allowed outage time for the RCFC LERF.function.

Three trains of RCFCs provide a high degree of redundancy and Containment Spray is functionally (30 day backstop applies)redundant for heat removal.

Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 41 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement New Action Requirement Technical Discussion and Risk Basis Input to Risk Calculator to Number ComnsDetermine RICT Calculated STP RICT Before Backst~op~(base case91 3.6.2.3 The current TS have no With more than one group Three trains of ROF~s provide a high Calculated RIOT: IThere are'desig-nators (and action for more than one of the above required degree of redundancy and Containment associated Configuration Ris-k Reactor group of RCFCs inoperable Reactor Containment Fan Spray is functionally redundant for heat >10 yrs. Based on CDF and Manaemen [cfor: Containment and TS 3.0.3 would apply. Coolers inoperable, within 1 removal. LERF ~udlns o: Fan Coolers hour restore at least two groups of RCFC to The one-hour "frontstop" time is (30 day backstop applies) _Reactor Contain~ment.

Fiarn Ne Atin .OPERABLE status or apply conservative considering the low risk- Cooler A [LRCFCA]Ne Atin .the requirements of the significance of the system and degree CRMP, or be in at least of redundancy.

Evaluations performed Reactor Conta Iinm Ient F an HOT STANDBY within the for STP TS Amendments 85f72 Cooler B [RCFCB]next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD determined that a single train of RCFCs SHUTDOWN within the and Containment Spray is adequate forFa following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . containment heat removal and RCB -Coe ,[R C]pressure control in accident conditions.ColrJR CC The one hour is consistent with TS 3.0.3 which the current TS would apply to more than one inoperable group of RCFCs.3.6.3 With one or more of the With one or more of the The OPERABILITY of the containment Calculated RICT: Thie Configurai~on Risk isolation valve(s) isolation valve(s) isolation valves ensures that the Management ujdein'p inoperable, maintain at inoperable, maintain at containment atmosphere will be >10 yrs. fsor theiofnctainmn Isolation Valves OPRBEi ahleast one isolation barrier* isolated from the outside environment Ioainfnto affected penetration that is OPERABLE in each in the event of a release of radioactive (0day backstop applies) Pvlaet efetso (Added new open and: affected penetration that is material to the containment atmosphere (0failure of single, ACTION d.) open and within 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months s: or pressurization of the containment ct plcto f h RPwud ontainment is6-ai~on a. Restore the inoperable and is consistent with the requirement eaplicatetefntion of the CRMPe woul valve(s) to OPERABLE a. Restore the inoperable of General Design Criteria 54 through pntais The individual valve(s) that are cotanent Phas"e~status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , valve(s) to 57 of Appendix A to 10 CFR Part 50. cnan or OPERABLE status, or Containment isolation within the time affectednawith repctt thei deocaed ,signator are used to limits specified for those isolation fucinlt'fthi soitd evaluate the effects of b. Isolate each affected b. Isolate each affected valves designed to close automatically system. mrultiple ccntainmenit penetration within 24 penetration by use of ensures that the release of radioactive Isltinvlesdet mateialto te eviromen wil besignal failure, hours by use of at least at least one mtra oteevrnetwl eCic~n afieo one deactivated deactivated automatic consistent with the assumptions used in ICicdn alr f vaveseurd n he the analyses for a LOCA. Multiplecontainment automatic valve secured vav euentei solatiorivalves and/or in the isolation position, isolation position, or 'ioswlbe or check valve with flow check valve with flow The proposed change to this penetr~atirwllb throgh he vlvethrough the valve specification adds ACTION d. to allow evaluated usi 'ng th4__________

_______________

_______________the application of the CRMP. The PRA on ~an a-needed Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 42 Table 2 Detailed Description of Changes and Basis>Specification Old Action Requirement New Action Requirement Technical Discussion and Risk BasisInutoRsCacloro, Number Comments -.Determine RICT'Calculated STP~ RICT Before Backstop (b~ase case?)1 secured-*, or secured-, or existing action time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is not basis changed. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is sufficient time to c. Isolate each affected c. Isolate each affected perform a risk assessment of the penetration within 24 penetration by use of condition to determine if additional time hours by use of at least at least one closed may be taken for corrective, one closed manual manual valve or blind maintenance before closing the valve or blind flange, or flange, or affected penetration.

If the RICT is not determined within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , one of the d. Be in at least HOT d. Apply the other actions must be taken. However, STANDBY within the requirements of the If the penetration is closed per ACTION next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in CRMP b or c and a RICT is calculated after the COLD SHUTDOWN 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months expires, the penetration may within the following 30 Otherwise be in at least be opendi codnewt.h hours. HOT STANDBY within the CRP next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .3.7.1.2 With one motor-driven With one motor-driven The "action not met" requirement for Calculated RICT: There are designators (and_auxiliary feedwater pump auxiliary feedwater pump ACTION a. is relocated from ACTION c associated Configuration RisV Auxiliary inoperable, restore the pump inoperable, within 28 days to ACTION a, which is consistent with 1 inoperable train: Management

[CRM]Feedwater to OPERABLE status within restore the pump to STP's TS format. This is an 1Guidelines) for: 28 days. OPERABLE status or apply administrative change to facilitate MAWAo :70dy the requirements of the incorporating the CRMP in the other MDAFWar Ad or C: 70rdy CRMP, or be in at least ACTIONs for this TS. MDAF B:1200day Action a. ~~~HOT STANDBY within the MAWB 20dy Actin a.next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the (30 day backstop applies)

Axlayd~rri following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . g~jAFB]SAxlay Fleedwater -Trainý-- -uiliarf E!-J- -*~~~~ __Axli edwqtqr Tra!in.D F&D Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 43 Table 2 Detailed Description of Changes and Basis Specification Old ~Action Requirement N jew Action Requ irement Technical Discussion and Risk Basis Input to Risk Calculator to-'Nme'Comments.

Determine RICT Calculated STP RICT Before Backstop'(base case)l 3.7.1.2 Auxiliary Feedwater Action b.With the turbine-driven auxiliary feedwater pump inoperable, or with any two auxiliary feedwater pumps inoperable, restore the affected auxiliary feedwater pump(s) to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .MODE 3 may be entered with an inoperable turbine-driven auxiliary feedwater pump for the purposes of performing Surveillance Requirement 4.7.1.2.1 .a.2.With the turbine-driven auxiliary feedwater pump inoperable, or with any two auxiliary feedwater pumps inoperable, within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months restore the affected auxiliary feedwater pump(s) to OPERABLE status or apply the requirements of the CRMP, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . MODE 3 may be entered with an inoperable turbine-driven auxiliary feedwater pump for the purposes of performing Surveillance Requirement 4.7.1.2.1 .a.2.STP's design is highly redundant with 3 motor-driven AFW pumps and 1 turbine-driven AFW pump. Each auxiliary feedwater pump is capable of delivering feedwater to the entrance of the steam generators with sufficient capacity to ensure that adequate feedwater flow is available to remove decay heat and reduce the Reactor Coolant System temperature to less than 350*F when the Residual Heat Removal System may be placed into operation.

One train of AFW feeding an intact steam generator is sufficient for post-accident decay heat removal.STP's safety analyses show that three trains of AFW feeding three steam generators are required for sufficient RCS cooling to prevent the pressurizer from going water solid in a loss of normal feedwater (LONF) assuming failure of Train A ESF actuation to start Train A AFW and Train D AFW and with credit for operator action to manually start one of the failed AFW trains from the control room.Proposed change to Action b. permits the application of the CRMP and uses the existing 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months action time. The existing 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months AOT is conservative with respect to the redundancy in the STP design. Additional justification is provided in letter dated December 3, 2001 (NOC-AE-01001 196) that is the basis for the existing AFW AOTs.Similar to the change~for ACTION-a-, the change to ACTION b includes an administrative change to relocate to ACTION b the 'action not met" The PRA models the AFW function during emergency operation to supply feedwater to steam generators to remove reactor core decay heat in case of: 1) loss of normal feedwater supply; 2) feedline rupture event;3) other transients;

4) main steam line break; 5) SG tube rupture; 6)small LOCAs; 7) as required for ATWS mitigation; or 8). the function to prevent the pressurizer from going water-solid.Calculated RICT: TDAFW: 380 days (30 day backstop applies)2 inoperable MDAFW: 7.9 days 1 inoperable MDAFW and inoperable TDAFW: 42.5 days.(30 day backstop applies)There are designators (and-associated Configuration Ri~Management

[CRMJ]_G yId n ep) f or: SAuxiliary Fe"eder Train L!_uxiiiary Feedwater Irin* AuxiliaryFe e d w 6r' fra i n D [AFD]

Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 44 Table 2 Detailed Description of Changes and Basis Specif ication ~Old Action Requirement New Action Requirement Technical Discussion and Risk Basis Input to Risk Calculator

~to Number Comnments.:, Determine RICT Calculated STP RICT Bef ore , Backstop requirements for ACTION b from ACTION c.3.7.1.2 With three auxiliary With three auxiliary As noted above, one train of AEW Three inoperable AEW pumps There -a-riie dinators"(a-nd,'

feedwater pumps feedwater pumps feeding an intact steam generator is will exceed the RMTS 1 E-03 CDF associated ConfigurationRisk Auxiliary inoperable, or if the inoperable, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months sufficient for post-accident decay heat limit if the pumps are not 'Management

[QFRM]Feedwater required action and apply the requirements of removal. For conditions where one or functional.

In accordance with Gu~delines) for: associated allowed outage the CRMP, or be in at least more of the inoperable pumps are the RMTS Guidelines, the time for a) or b) is not met, HOT STANDBY within the functional, the CRIMP could be applied condition shall not be entered uxlayFewtrai be in at least HOT next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT to calculate an appropriate AOT. voluntarily.

A[ýA Actonc.STANDBY within the next SHUTDOWN within the Action c. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . Al FewarTai SHUTDOWN within the _A~uxiia Fewte ri following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . _AB*jAux~iiary~eadwater Train* Auxiliary Eeedwyater Train 3.7.1.3 With the AFST inoperable, With the AEST inoperable, The OPERABILITY of the auxiliary The PRA models the AFW -Accrding to the CR-M within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months restore the within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months restore the feedwater storage tank with the function to provide a sufficient Guiideline for, Auxiliary.-

Auxiliary AEST to OPERABLE status AEST to OPERABLE status minimum water volume ensures that inventory of water to allow the Ieedwater,,a non-functional Feedwater or be in at least HOT or apply the requirements of sufficient water is available to maintain AFWS to perform its function.

~AFST requires enty,'of all'ifour Storage Tank STANDBY within the next 6 the CRMP, or be in at least the ROCS at HOT STANDBY conditions

~AFW trains (AFA AFB AKE-hours and in HOT HOT STANDBY within the for 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months with steam discharge to the Calculated RIOT: rAFD) in the Risk assessment SHUTDOWN within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT atmosphere concurrent with a MFWLB 'pcalculator.I`_

following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . SHUTDOWN within the and failure of the AFW flow controller Voluntary entry into a condition following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . followed by a cooldown to 350OF at where the AFWST is non-25*F per hour.`ý, functional is not permitted because it exceeds the RMTS Application of the CRMP is appropriate.

1 E-03 CDF limit.The cause for the inoperability may meet the criteria in the RMTS 1 1/2 hours (assumes the AEST Guidelines for functionality such that a is unavailable; however, RICT would be justified.

shutdown is neither appropriate

_____________

___________________

__________________

_________________________

nr reuird b theTS ithno __I__nor____________

Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 45 Table 2 Detailed Description of Chanrges-and Basis AI-w available to remove diecay heat. (See TS 3.7.1 .2.d)8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for tank level I. I *9 9 3.7.1.5 Main Steam Isolation Valves MODE 1 (No changes proposed for MODE 2 and 3).MODE 1: With one MSIV inoperable but open, POWER OPERATION may continue provided the inoperable valve is restored to OPERABLE status within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months ; otherwise be in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .a.With one MSIV inoperable but open, POWER OPERATION may continue provided that within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months the inoperable valve is restored to OPERABLE status or the requirements of the CRMP are met;otherwise be in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .b. With more than one MSIV inoperable but open, POWER OPERATION may continue provided that within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months at least three inoperable valves are restored to OPERABLE status or the requirements of the CRMP are met;otherwise be in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .The OPERABILITY of the main steam line isolation valves ensures that no more than one steam generator will blow down in the event of a steam line rupture. This restriction is required to: (1) minimize the positive reactivity effects of the Reactor Coolant System cooldown associated with the blowdown, and (2) limit the pressure rise within containment in the event the steam line rupture occurs within containment.

The OPERABILITY of the main steam isolation valves within the closure times of the Surveillance Requirements are consistent with the assumptions used in the safety analyses.The action is split into a. and b. Action a is the current action forr'6one inoperable MSIV with an added provision to apply the CRMP. Action b is added to provide an action for more than one inoperable MSIV with an allowance to apply the CRMP. Action b has a one-hour completion time, which is consistent with the TS 3.0.3 completion time Application of the CRMP appropriately addresses the safety significance of the MSIVS.The PRA models the function of the MSIVs to close to isolate containment.

Calculated RICT: 1 inoperable MSIV: >1 0 yrs.(30 day backstop applies)2 inoperable MSIVs: 410 days (30 day backstop applies)The~ calculation tosupport use of this risk- informed technical sp cfc to ilb nld di the Main Steam Sytei Conifiguration Risk M~anaemenit Guideines Failure of the main steam-1-isolation function or failure of more thian one MSIV is analyzed in the RMTS projgra by utilizing the main steam signal designators MSISA and JMSISB Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 46 Table 2 Detailed Description of Changes and Basis~Specification Old Action Requirement New Action Requirement Technical Disc9ussion and Risk Basis Input to Risk Ca lculator to: Number Comments-Determine RICT Calcuilated STP RICT Before Backstop (base case)1 .3.7.1.6 Atmospheric Steam Relief Valves Action a.With one less than the required atmospheric steam relief valves OPERABLE, restore the required atmospheric steam relief valves to OPERABLE status within 7 days; or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and place the required RCSIRHR loops in operation for decay heat removal.With one less than the required atmospheric steam relief valves OPERABLE, within 7 days restore the required atmospheric steam relief valves to OPERABLE status or apply the requirements of the CRMP or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and place the required ROS/RHR loops in operation for decay heat removal.The atmospheric steam relief valves are required for decay heat removal and safe cooldown in accordance with Branch Technical Position RSB 5-1. In the safety analyses, operation of the atmospheric steam relief valves is assumed in accident analyses for mitigation of small break LOCA, feedwater line break, loss of normal feedwater and loss-of-offsite power.The atmospheric steam relief valve manual controls must be OPERABLE in Modes 1, 2, 3, and 4 (Mode 4 when steam generators are being used for decay heat removal) to allow operator action needed for decay heat removal and safe cooldown in accordance with Branch Technical Position RSB 5-1.The atmospheric steam relief valve automatic controls must be OPERABLE with a nominal setpoint'of 1225 psig in Modes 1 and 2 because the safety analysis assumes automatic operation of the atmospheric steam relief valves with a nominal setpoint of 1225 psig with uncertainties for mitigation of the small break LOCA. In order to support startup and shutdown activities (including post-refueling low power physics testing), the atmospheric steam relief valves may be operated in manual and open in Mode 2 to maintain the secondary side pressure at or below an indicated steam generator pressure of 1225 psig..The PRA models the function of these valves to dissipate RCS heat when the main condenser is not available.

The valve function that the PRA credits depends on the initiating event. In general, the PRA is looking for the valves to function in response to changing plant conditions.

The primary function is to control reactor decay heat, which post trip is an automatic function.

For some initiating events, the valves are asked to perform a cooldown function in response to operator control input. The model can adjust for the situation where automatic actuation works, but manual does not by failing the associated valve for cooldown purposes.Calculated RIOT: 1 inoperable SG PORV: >790 days (30 day backstop applies)There are designators (and, asso'ciated Configuration Riik Management

[CýRMJ~Steam Generator PORV A [PORVAI.Steam Generator&

R SI teamenerator PORV SteamGni~ra~torPORV 7 7days is adequate time to determine Ialternative action and AOT. A RIOT will a a ________________________

a.

Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 47 STable 2 Detailed Description of Changes and Basis Seiiain OdAction Requirement New Action Requirement Technical Discussion and,, DekBaiIptteRmineCic alrt$.Number Comments DtrieRICT~

Calculated SýTP RICT Before:Backstop_______________

_______________(bas c~ase)l ________probably be justifiable based on the expected availability .of the condenser and associated steam dumps.3.7.1.6 With two less than the With two less than the A RIOT is likely to be justifiable based Calculated RIOT: d required atmospheric relief required atmospheric relief on the expected availability of the associated Co~nfiguratiQ2ý Risk Atmospheric valves OPERABLE, restore valves OPERABLE, within condenser and associated steam 2 inoperable SG PORVs: 83 days Management

[GRM]Steam Relief at least three atmospheric 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months restore at least dumps. Guidlihnes) for: __Valves relief valves to OPERABLE three atmospheric relief (0dybcso ple)______

status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be valves to OPERABLE status (3 Stea Generator appies in at least HOT STANDBY or apply the requirements of Sta[P GeReato PR with the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in the CRMP or be in at least !ý ER!j Action b.HOT SHUTDOWN within the HOT STANDBY within theSta Atob.following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and place next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT .,,SemGener tor PQ 'Ry the required RCS/RHR loops SHUTDOWN within the JP_[ORVB]in operation for decay heat following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and placeSta ___removal, the required RCS/RHR SemGenerator POFIV ioops in operation for decay ~PRC heat removal.ý_Stearri Gýe~nerator PObV 3.7.1.6 NA (New ACTION) With more than two less One hour is a conservative time to Calculated RIOT: Therre a(ýdesignators (and than the required determine alternative action and AOT. associated Configuration 4iik'Atmospheric atmospheric relief valves A RIOT is likely to be justifiable based 3 inoperable SG PORVs: 12 days Management

[ORM]Steam Relief OPERABLE, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months on the expected availability of the guidelines) for: Valves restore at least two condenser and associated steam atmospheric relief valves to dumps. the 1 -hour limit is consistent

.SemGnrt~R OPRALEstts r ppy with the limit of TS 3.0.3 which current ILQRAJ the requirements of the TS would require with more than 2 less Action c. CRMP or be in at least HOT than the required number of operable

SemGnrtrPR STANDBY within the next 6 valves. B eneatRrVB'~

hours and in HOT ______VB SHUTDOWN within the _§tea oen r iPORV following 6hours and place tem _n~t-___the required RCSIRHR [E2RIMqf Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 48 Table 2 Detailed Description of Changes and Basis Specification Old AcinRequirement New Action Requirement Technical Di'scussion and Risk Basis ; input to Risk Calculator to Number .Comments Determine RIOT Calculated STP RICT Before;~2Backstop (base case)1 -loops in operation for decay GnrtrPR heat removal. .. Steam Geerto _OY 3.7.3 With only two component With only two component The OPERABILITY of the Component The PRA models the design There are designatrs(~ind cooling water loops cooling water loops Cooling Water System ensures that basis heat removal functions of associated ConfigurationRj-s-Component OPERABLE, restore at least OPERABLE, within 7 days sufficient cooling capacity is available the CCW system. 'Management

[CRIVJ Cooling Water three loops to OPERABLE restore at least three loops for continued operation of safety- Guidelines)

'for: status within 7 days or be in to OPERABLE status or related equipment during normal and Calculated RICT:___Action a at least HOT STANDBY apply the requirements of accident conditions.

It provides post- 'oComponent -cqging within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and the CRMP, or be in at least accident heat removal for ECCS, RH R, 1 inoperable train of CCW: -,Water A [CLQA]in COLD SHUTDOWN within HOT STANDBY within the and reactor containment fan coolers.the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD >1 yr.Cm5net~rn SHUTDOWN within the CCW has a high degree of redundancy.

_W10e yrs [PCB]nn CoIn following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . With one inoperable train, the system Yae ~~generally still meets the single failure (30 day backstop applies)criteria with only modest degradation.

~Cmoetoin The 7-day frontstop time is not Wa4te C [CQCJ representative of the safety significance of one train of CCW being inoperable.

Proposed as Action a. because of proposed new Action b. below.3.7.3 The current TS do not have With two or more Evaluations performed for STP Calculated RICT: lThere are designators and an action for more than one component cooling water Amendments 85f72 showed that a 'associated Configuration R~ik Component inoperable train of CCW. TS loops inoperable, within 1 single train of CCW is adequate for 2 inoperable trains of CCW: ManagementjC9M]

Cooling Water 3.0.3 would apply. hour restore at least two safe shutdown and accident mitigation Giees) for:, loops to OPERABLE status with only modest degradation in 278 days Proposed new or apply the requirements of capability.

.Component Cooling Atob.the CRMP, or be in at least A [CCAW Atob.HOT STANDBY within the The one-hour time is conservative and (30 day backstop applies) Water A____~next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD consistent with TS 3.0.3 which would LComý6-etC-0§n SHUTDOWN within the be required by current TS for more than LCompoeýý[Cooiiig following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . one inoperable train of CCW.-Componrent Cooljing C [!r~_CCC]

Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 49 Table 2, Detailed Description of Changes and Basis Specification Old Action Requirement New Action Requirement Technical

ýDiscussion and Risk Basis Input to Risk Calculator to Number C1mnsDetermine RICT Calculated STP RICT Before, Backstop (base case)1 3.7.4 With only two essential With only two essential The OPERABILITY of the Essential The PRA models the ECW Trhere are designators (and cooling water loops cooling water loops Cooling Water (ECW) System ensures function to provide sufficient flow associated Configuration Risk Essential OPERABLE, restore at least OPERABLE, within 7 days that sufficient cooling capacity is thru the supply and return Management

[CRM]Cooling Water three loops to OPERABLE restore at least three loops available for continued operation of headers to meet design basis '_uideIns for:-status within 7 days or be in to OPERABLE status or safety-related equipment during normal accident and normal operating

___________

Action a at least HOT STANDBY apply the requirements of and accident conditions.

The ECW requirements and to provide ._Essentia Col ___M~tifA within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and the CRMP, or be in at least self-cleaning strainer must be in service cooling water thru heat -lal oon Wte in COLD SHUTDOWN within HOT STANDBY within the and functional in order for the exchangers of standby diesel the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD respective ECW train to be generators and their support ý. ssential Cqooh iWat~er B SHUTDOWN within the OPERABLE.

In an accident or loss of systems (design basis accident following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . offsite power, the ECW system and normal operating conditions).

transfers heat from the CCW system Esni!onr and the standby diesel generators to Calculated RICT: ,EsnilC rb C the ultimate heat sink. 1AC From a design basis perspective, ECW 1 inoperable train of ECW is comprised of three 50% trains.However, with a single train of ECW 99 days inoperable there is no loss of safety function, and the plant generally meets (30 day backstop applies)single failure for most probable design-basis events.Proposed as Action a. because of proposed new Action b. below.3.7.4 The current TS do not have With two or more essential With two inoperable ECW trains, the Calculated RICT: here are dsgaos(n an ationformoretha one cooing ate loos plnt etais is caabiity o mtigae a*associate id Confi r-S(iatndRs Essetialinopeal torai mofe ECW. Tne coinoprbe within 1hour dln esign-bsitscaaccidet.

2o inoperabl trin ofEWanscageedPnti raton i CoolninWate 3.03noueald tapply rfE S ioestreatbleaswthn1ou dei-bssacet.2nprbl twoin loop toW 'uaageetnts

[fjr OPERABLE status3or.applylThepone-hourttimeaislconservativepando102 hours ProposenewOtERAL reqireens of thel cheonstenhurtwith Ts 3.0.3 rvwhich woud 102 hour0.00118 days 0.0283 hours 1.686508e-4 weeks 3.8811e-5 months soa W Action b. CRMP, or be in at least be required by current TS for more than [EWA]HOT STANDBY within the one inoperable train of ECW.next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the Eseta Coln ae following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . WB EssentialCoolingj Water C Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 50 Table 2 Detailed Description of Changes and Basis'Specification Old ActionTRequiremient New Action Requirement Technical Discussion and Rs ai nu o ikCluao o NubrComments RikBaieptetrmisk RCacltort Calculated STP RIOT BeforeDermnRIT Backstop: I ~(base case)1 3.7.7 Control Room Makeup and Cleanup Filtration Action a With one Control Room Makeup and Cleanup Filtration System inoperable, restore the inoperable system to OPERABLE status within 7 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .With one Control Room Makeup and Cleanup Filtration System inoperable, within 7 days restore the inoperable system to OPERABLE status or apply the requirements of the CRMP, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .The Control Room Makeup and Cleanup Filtration System is comprised of three 50 percent redundant systems (trains) that share a common intake plenum and exhaust plenum. Each system/train is comprised of a makeup fan, a makeup filtration unit, a cleanup filtration unit, a cleanup fan, a control room air handling unit, a supply fan, a retumn fan, and associated ductwork and dampers. Two of the three 50% design capacity trains are required to be operable.The OPERABILITY of the Control Room Makeup and Cleanup Filtration System ensures that: (1) the ambient air temperature does not exceed the allowable temperature for continuous duty rating for the equipment and instrumentation cooled by this system, and (2) the control room will remain habitable for operations personnel during and following all credible accident conditions.

The OPERABILITY of this system in conjunction with control room design provisions is based on limiting the radiation exposure to personnel occupying the control room to 5 reins or less whole body, or its equivalent.

This limitation is consistent with the requirements of General Design Criterion 19 of Appendix A, 10 CFR Part 50.The effects of inoperable heating ventilation and air conditioning (HVAC)functions of this system are addressed in the effects of an inoperable train of The PRA models the cooling function associated with this system as a potential plant initiating event. However, the pressurization and filtration function of this system is not modeled in the PRA. The CR dose mitigation design basis function of the system is not relevant to either core damage frequency or large early release frequency and does not factor into the calculation of an allowed outage time. However, as described in the Technical Discussion and Comments, the CRMP will apply only to the cooling function for the system.Calculated RICT (cooling function):

One inoperable train: 5500 days (30 day backstop applies)There are designtokrs (and associated Conf igu ration Ri -s Management

[CRMJ ,q Opienes) for: CRHVAC Train A[tiEA(CR)]

ýýCR HVA Train B CH-4CT-rain C

Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 51 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement New Action Requirement Technical Discussion and Risk Bsis~ Input to~ Risk Calculator to'Number~ >Comments Determine RICT Calculated STP RIC1T Before Backstop'(base case)1 Essential Chilled Water (TS 3.7.14).Therefore, an allowance to apply the CRMP is needed for consistency with TS 3.7.14.The Bases for TS 3.7.7 include a clarification for the operators that a RICT cannot be applied for configurations that make the dose mitigation function of the system inoperable.

The CRMP is only applicable for the cooling function of this system. The frontstop completion times will be applied for conditions where the dose mitigation function is inoperable.

The inserts for the Bases for this TS are included in Attachment 2 for the staff's information.

4 I I .1 3.7.7 Control Room Makeup and Cleanup Filtration Action b With two Control Room Makeup and Cleanup Filtration Systems inoperable, restore at least two systems to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .With two Control Room Makeup and Cleanup Filtration Systems inoperable, within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months restore at least two systems to OPERABLE status or apply the requirements of the CRMP, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .Same as above.Calculated RICT: STP models the loss of control room HVAC as an initiating event only. STP assumes that the cooling function can be provided by either chilled water or the smoke purge mode of operation, Chilled water inoperability or non-functional ity does not affect the initiating event frequency.

The number below reflects only one train of fans available to remove heat. In this case, there is opportunity to apply the RMTS Guidelines for functionality.

There is also a delay time until temperature alarms are reached.There are desigatoirs (and.associated Configuratign Risk Management

[CRM]guidlies) or:* -CIR HVAC Train[HjEA(PR)]

CR HVAC Train C Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 52 Table 2 Detailed Description of Changes and Basis Specification

~Old Action Requirement+

New Action Requirement

~Technical Discussion and RikBai In put to Risk Calculator to Number Comackstop Determine RICT,____________________________

____________________________________________

________________________________________C alculated___________

7________________________________Before__________

If a chilled water train and the associated smoke purge train are non-functional, the fan train is also non-functional and the CRMP may not be applied because the dose mitigation function is affected.Two inoperable trains: 61 hours7.060185e-4 days 0.0169 hours 1.008598e-4 weeks 2.32105e-5 months t 9 9 3.7.7 Control Room Makeup and Cleanup Filtration Action c With three Control Room Makeup and Cleanup Filtration Systems inoperable, suspend all operations involving movement of spent fuel, and crane operation with loads over the spent fuel pool, and restore at least one system to OPERABLE status within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .With three Control Room Makeup and Cleanup Filtration Systems inoperable, suspend all operations involving movement of spent fuel, and crane operation with loads over the spent fuel pool, and within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months restore at least one system to OPERABLE status or apply the requirements of the CRMP, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .The action requires actions to preclude a fuel handling accident in the spent fuel pooi. With three inoperable trains, the allowed outage time is 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .This accommodates maintenance or testing activities that require opening or entry into the common plenums. This time is reasonable to diagnose, plan, and possibly repair problems with the boundary or the ventilation system.This is acceptable based on the low probability of a design basis event in that brief allowed outage time and because administrative controls impose compensatory actions that reduce the already small risk associated with being in the ACTION.The RMTS Guidelines would allow extension of the allowed outage time for emergent conditions where there is PRA functionality that meets the criteria in the guidelines.-.

Three inoperable trains: Exceeds the RMTS 1 E-03 CDF limit if the trains are not functional for cooling for longer than 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . In accordance with the RMTS Guidelines, the condition shall not be entered voluntarily.(See commentary above for two inoperable trains.)There are designators (and'associated Configur-ation Rs Management

[CRy]9ukLe Yne§) for: E::C-RAVAC frai-nAB[HEB(PR)l~ RHVAC TrainB[HECRCRHV I. A A £ L Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 53 Table,2~ ---Detailed Description of Changes and Basis Specification Old Action Requirement New Action Reurmn Technical Discussion and Risk Basis Input to Risk Calculator to Number .comments Determine RICT Calculated STP RICT Before Backstop (base case)1 3.7.14 With only two Essential With only two Essential The OPERABILITY of the Essential The PRA models the EChW There are designators (and-Chilled Water System Chilled Water System loops Chilled Water System ensures that system functions to provide associated Configuration Rislk Essential Chilled loops OPERABLE, OPERABLE, within 7 days sufficient cooling capacity is available cooling for the design basis Management

[CRM]Water restore three loops to restore at least three loops for continued operation of safety- functions.

' _Quidelines) for: OPERABLE status to OPERABLE status or related equipment during normal and Action a within 7 days or be in at apply the requirements of accident conditions.

The EChW Calculated RICT: ý__Chille-d W-ate-r Tr-ai-n-A least HOT STANDBY the CRMP, or be in at least system supports the area cooling for [CHAJ within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months HOT STANDBY within the safety-related equipment in the 1_npealetaif_~W and in COLD next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD Mechanical/Electrical Auxiliary Building 1inprbetanoEhWCildWtrTanB SHUTDOWN within the SHUTDOWN within the and the Fuel Handling Building.

The >90dy CB following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . redundant cooling capacity of this >200dys__B system, assuming a single failure, is consistent with the assumptions used in (30 day backstop applies) -Chilled Water -TrainC the safety analyses.

t[.HC]From a design basis perspective, the EChW system is comprised of three 50% trains. With a single train of EChW inoperable there is no loss of safety function, and the plant generally meets single failure for most probable design-basis events.Proposed as Action a. because of proposed new Action b. below.3.7.14 The current TS do not have With two or more Essential With two inoperable EChW trains, the 2 inoperable trains of EChW: ,There are designators (an~d an action for more than one Chilled Water System loops plant retains its capability to mitigate a 'associated Configuration Ris Essential Chilled in03opeale tainpfly hW. T inoperable, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months design-basis accident.

36 days Mngmn OM Water 3.. ol pl.restore at least two loops to Gu~idelines) for: OPERABLE status or apply With three inoperable EChW trains, the (30 day backstop applies) 7Chiled Water Train A New Action b. the requirements of the function is lost unless the PRA CRMP, or be in at least functionality provisions from the RMTS All three trains of EChW[H]HOT STANDBY within the Guidelines can be applied, inoperable and non-functional:

next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD ~hle ae ri~SHUTDOWN within the The one-hour time is conservative and 74 hours8.564815e-4 days 0.0206 hours 1.223545e-4 weeks 2.8157e-5 months exceeds the 1 E-03/yr ý[CHB following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . consistent with TS 3.0.3 which would limit for voluntary entry as well as be required by current TS for more than being a loss of function where 'C~ldatrTa one inoperable train of EChW. RMTS may not be applied.

Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 54 Table 2 Detailed Description of Changes and Basis Old Action Requirement~

New Action RequirementI-al Discussion and Comments<Risk Basis Calculated STP RICT SBack stop S(base case)1 lisk Calculator toýrmlne RIOT 3.8.1.1 4.Operating Action a.With one offsite circuit of the above-required A.C. electrical power sources inoperable, demonstrate the OPERABILITY of the remaining A.C. surces by performing Survillance Requirement 4.8. 1. 1.1 .a within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter.

Restore the offsite circuit to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .With one offsite circuit of the above-required A.C.electrical power sources inoperable, demonstrate the OPERABILITY of the remaining A.C. sources by performing Surveillance Requirement 4.8.1.1.1 .a within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter.

Within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months restore the offsite circuit to OPERABLE status or apply the requirements of the CRMP, or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .The initial conditions of DBA and transient analyses in the FSAR, Chapter 6 and Chapter 15, assume ESE systems are OPERABLE.

The AC electrical power sources are designed to provide sufficient capacity, capability, redundancy, and reliability to ensure the availability of necessary power to ESE systems so that the fuel, Reactor Coolant System (RCS), and containment design limits are not exceeded.The OPERABILITY of the AC electrical power sources is consistent with the initial assumptions of the Accident analyses and is based upon meeting the design basis of the unit. In Modes 1, 2, 3, and 4 this results in maintaining at least two trains of the onsite or one train of the ofisite AC sources OPERABLE during Accident conditions in the event of: a. An assumed loss of all offsite power or all onsite AC power;and b. A worst case single failure.A single train onsite AC.source can effectively mitigate all but the most severe events with operator action in some cases. The events that cannot be mitigated by a single train onsite AC source are highly unlikely.STP's switchyard is served by 8 incoming lines. Three transformers are available to each unit to power the 13.8 KV buses that supply the 4.16 KV The PRA models the offsite power design basis functions including: " Receive normal electrical power from the 25 KVAC main and auxiliary transformers system through the 25/1 3.8 KVAC Unit Auxiliary Transformers." Receive alternate electrical power from the 345 KVAC switchyard through the 345/13.8 KVAC Standby Transformers." Distribute 13.8 KVAC electrical power through the switchgear auxiliary and standby busses." Control the supply of 13.8 KVAC electrical power to components in the Class 1 E 4.16 KVAC distribution system Calculated RICT: Assuming loss of the 13.8kV bus supply to a safety bus, 1460 days to 1 E-05 (30 day backstop applies)ffh-eri'are -designators and.'associated CRM gilln!-oýthe 13.8V, feed to the Class 141 60V buses.13.8kV BusF[U*13.k 3Bus~ [qUS!P]*"13,8kV Bus H [BUSH Fffhý345-kV/i3.8kV Standby~Transformers have dlesiginators ,and associated CRM guLidelines~

Transformer l`SXA1*Unit 2 Sta~nalb Tran~sformer

[SXBJ]T e Emg-ncy Traý-ýf has, a designator and associated CRM gluidle~inri

~EmergendyTasfre

[ETRANS]These guidelines and__designators can be used to'simulate the failure of 13.8kV Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 55 Table 2 Detailed Description of Changes and Basis Specif 'ication Old Action Requirement New Action Requirement Technical Discussion and ~'Risk Basi's 7 Input to Risk Calculator toýNumber Comments Determine RICT S Calculated STP RICT Before Backstop (basecase)1i emergency buses. There are 3 trains suppoyAQoafLny Clus I _160Ej~of ESF power, only one of which is blus!required to achieve and maintain safe shutdown.

This is a very reliable and redundant power supply system. 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is adequate to determine an alternate action or justify addition time to restore the condition.

STPNOC provided a detailed description of the application of RMTS to this action in response to NRC's request for additional information.

See letter dated April 26, 2006 (MLO61 280591)3.8.1.1 With a standby diesel With a standby diesel STP has three independent Standby The PRA models the SOG Ther-e are _designators

-(and-generator inoperable, generator inoperable, Diesel Generators (SDG) each functions to automatically start, associated Configuration RWis-Action b dmntaehedemonstrate the associated with its ESF train, load, and power their associated Management

[CRM]OPERABILITY of the above- OPERABILITY of the ESF systems while maintaining Guýieline ) for: required A.C. offsite sources a by performing Surveillance above-required A.C. offsite In the event of a loss of preferred required voltage and frequency.

~ ~ ~Requirement 4.8.1.1.1.a sources by performing power, the ESE electrical loads are The model includes the load 0 Standby Diesel Generator within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least Surveillance Requirement automatically connected to the SDGs in sequencer functions to strip loads '--I once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter.

4.8.1.1.1 .a within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months sufficient time to provide for safe and sequence on the required If the standby diesel and at least once per 8 reactor shutdown and to mitigate the ESF systems. Dependency on t db l t geneato beameinoerale our threater Ifthe consequences of a Design Basis required support systems is due tnopeany causeohrtaptndydeepeeaort Accident (DBA) such as a loss of modeled (e.g., combustion air, ssean inoprbe spporetl became inoperable due to coolant accident (LOCA). fuel oil, overspeed protection).

sytma idpednty any cause other than an _Standby pjqeienderator testable component, or ioeal upr ytm q P_preplanned preventive inprbespotsse, Ratings for Train A, Train B and Train C Calculated RICT: C maintenance or testing, an independently testable DGs satisfy the requirements of demonstrate the component, or preplanned Regulatory Guide 1.108. The 1 SDG inoperable:

OPERABILITY of the preventive maintenance or cotnuserieaigofahDGs remaining OPERABLE testing, demonstrate the 5500nou kWrwith 10% in ovrofad h 168 day standby diesel generators by OPERABILITY of the perissbl for upt to% 2ouersoa in8 anyy2 performing Surveillance remaining OPERABLE horpermsiblod.

(30 day backstopiapplies)

Requirement 4.8.1.1 .2.a.2) standby diesel generators hu eid 3 a aktpapis for each such standby diesel by performing Surveillance WihoenpralSDTPaso generator separately within 8 Reurmet481.t2ah)ls ofnaet fucinoadpeerabeSG allyo hours, unless it can be Rqieet48112a2 oso aeyfnto n eeal demonstrated there is no for each such standby I_______ common-mode failure for the Idiesel generator separately meets the single failure criteria.

Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 56 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement New Action Requirement Technical Discussion and ~,Risk Basis In put to Risk Calculator to Number -Comments, I Determine RIOT Calculated STP RICT Before Backstop__________

________________

______________________

L (base case)1 remaining diesel generator(s).

within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , unless it can Restore the inoperable be demonstrated there is no standby diesel generator to common mode failure for OPERABLE status within 14 termiigdee day's or be in at least HOT hee reaining) diesel1 SHUTDOWN within the next geraos)Wihn1 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD days restore the inoperable SHUTDOWN within the standby diesel generator to following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . (1 2) OPERABLE status or apply the requirements of the CRMVP, or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . (12)3.8.1.1 With one offsite circuit of the With one offsite circuit of the The design basis and redundancy of The PRA model includes the and e3388' .1.Eýabove-required A.C. above-required A.C. these systems is described above. offsite power and SOG design albov~e Action c electrical power sources and electrical power sources functions as described above.one standby diesel generator and one standby diesel Deletion of the requirement to restore inoperable, demonstrate the generator inoperable, at least two offsite circuits to The PRA credits the operation of OPERABILITY of the demonstrate the OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months and either station standby transformer remaining A.C. sources by OPERABILITY of the three standby diesel generators to for supplying power to the units performing Specification remaining A.C. sources by OPERABLE status within 14 days from ESF buses. Some examples 4.8. 1. 1.1a. within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and performing Specification the time of initial loss is an where this may be challenged.

at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 4.8.1.1.1

a. within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months administrative change only because thereafter; and if the standby and at least once per 8 proper application of the TS would 1 ) Unit 1, DGA out of service, diesel generator became hours thereafter; and if the require this, and station standby inoperable due to any cause standby diesel generator transformerl1fails, diesels B other than an inoperable became inoperable due to and C start automatically, the support system, an any cause other than an Abnormal Procedure for loss independently testable inoperable support system, of power to ESE bus would be component, or preplanned an independently testable used to restore power from preventive maintenance or component, or preplanned Unit 2's station standby testing, demonstrate the preventive maintenance or transformer.

After OPERABILITY of the testing, demonstrate the restoration, the PRA would remaining OPERABLE OPERABILITY of the sytepati etrdt standby diesel generators by remaining OPERABLE sorayhlan Adisetioraqupednto performing Surveillance standby diesel generator(s) norailurs(., ADditiona equimen*Requirement 4.8.1.1.2a.2) by performing Surveillance failure (empg.,t DGBhrDe C within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , unless it can Requirement 4.8.1.1 .2a.2) recovery, but no initiating be demonstrated there is no Iwithin 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , unless it can event should occur. The RIOT_______________

Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 57 Table 2 Detailed Description of Changes and Basis common modie tailure tor tne remaining diesel generator(s);

restore at least one of the inoperable sources to OPERABLE status within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .Restore at least two offsite circuits to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months and three standby diesel generators to OPERABLE status within 14 days from the time of initial loss or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . (12)be demonstrated there is no common mode failure for the remaining diesel generators; within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months restore at least one of the inoperable sources to OPERABLE status or apply the requirements of the CRMP, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . (12)is the same as the base case DG.2) Unit 1 DGB out of service and the Unit Auxiliary Transformer fails. Unit 1 trips, DGA starts automatically, ESEF busses B and C are unaffected.

RIOT is not applicable until the plant is stabilized.

9 I I 4 4 3.8.1.1 A~ction d.With one stand1by diesel generator inoprhei addition to ACTION-ýb._or c above, verify that: 1 .All eqired systems, subj systems, trains, components, and devices that depend on the remin in Wg OPERABLE diesel generator as a source of em~ergency power are also OP~ERABLE, and 2. When in M1ODE 1 .o 3, the steam-driven auxiliary feedwae pump With one, standby diesel generator inoperable in addition to ACTION b. or c.above, verify that: 1}. All requird systems, subsystems in.components, and devices that depend on the remaining OPERABLEi diesel generator asa source of emergency power are also OPERABLE, and 2. Whenin MODE , 2, or 3, the team-driven auxiliary feedwater Action ~d tests for a loss of function that could result from simultaneous inoperability of aSDG and cross-train equipment that depends ~on on~e of the other diesels.The propose acint-pl h CRMP is consistent with the applicaton of the CRIMP to the other TS in the~scope of RMTS. The change is needed for consistency with the applicationj of~RMTS to prevent this action from requiring an unnecessary restriction on a configuration that has been determined to have an acceptable RIOT.24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months s theeisting action timie and~The risk fromiione inoperable diesel and an inoperable train of a function that is backed by one~of the other to diesels is bounded by the risk from tiwo inoperable trains of the function.As described above, STP does not lose safety function with the loss of two ESF trains.NormalCR O~procedures i eff ect I.~~ha bee determined---

to__be____

_____ __

Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 58 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement New Actioh Requirement Technical Discussion and Risk Basis Input to Risk Calculator to, Number Comments Determine RICT-Calculated STP RICT Before Backstop V (base casie)l is OPRABL.' PmpjOPERABLE.

for assess!ngthe plant configuration riski (f thesie6conditiions -are no-t -If the-se conditions aenot'satisfied within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months b'e- 'satisfied wvithin 24 hiours, in at least, HOT STANDBYI, applthrquemtso within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and_ the CRMP or be in at least in COLD SHUTDOWN within HOT STANDBY within the thefollowingg 30 hour3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months sJ next 6 husand in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months ., 3.8.1.1 With two of the above With two of the above ACTION e establishes a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Calculated RICT: 1748 days Se .8.1.1 .a above required offsite A.C. circuits required offsite A.C. circuits required completion time if two required Action e. inoperable, restore at least inoperable, within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months circuits between the off-site Loss of both Standby one of the inoperable offsite restore at least one of the transmission network and the on-site Transformer feeds to ESF busses sources to OPERABLE inoperable offsite sources to Class 1 E distribution system are B and C was evaluated.

In this status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or be OPERABLE status or apply inoperable.

configuration, Train A will be in at least HOT STANDBY the requirements of the supplied from the Unit Auxiliary within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . With CRMP, or be in at least Two required circuits would be Transformer and Train B and only one offsite source HOT STANDBY within the considered inoperable if any of the Train C will be powered from their restored, restore at least two next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . following conditions are met: associated SDGs. Loss of the offsite circuits to OPERABLE Standby Transformer should not status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months from *Loss of two 13.8 kV Standby Bus to result in a reactor trip. This time of initial loss or be in at 4.16 kV ESE Bus lines (per Note i to configuration is an example of the least HOT STANDBY within TS 3.8.1.1) first bullet in the Technical the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in Discussion and Comments COLD SHUTDOWN withincoun the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . *Loss of a 13.8 kV Standby Bus to coun 4.16 kV ESE Bus line while in a configuration where ACTION a The expected operator response applies to this condition would be to align the Train B and Train C ESE A coditon heretwoor ore busses to the Unit Auxiliary properly aligned and energized ESE TasD omeGndseue.h busses are determined not to be in Ds conformance with the design basis (3dabcktpplis Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 59 Table 2 Detailed Description of Changes and Basis Specification)

Old Action Requirement New'Action Requirement Technical Discussion and Riskc Basis Input to Risk Calculator to Number ..Comments ' Determine RICT~Calculated STP RICT Before Backstop: (base case)1 such that they are inoperable TS Note 1 (cited above) does not reflect STP's three-train design. With the loss of two 13.8 kV Standby bus to 4.16 kV ESF lines, STP still has one 13.8 kV Standby to 4.16 kV ESE connection.

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

The first two conditions would result in either a de-energized ESF bus or one or more ESF busses powered from their associated SOG. If the condition involves a loss of the UAT, the SOG will pick up the ESF loads; however, the reactor will trip on reactor coolant pump (RCP) undervoltage/underfrequency or RCS low flow because the reactor coolant pumps will lose power and coast down. Loss of the Standby Transformer should not result in a reactor trip.If the condition is the result of a loss of offsite power (LOOP) or partial LOOP, the operators will be taking action to establish stable plant conditions from the transient as a priority before any consideration of applying-the CRMP to extend the completion time. One of those actions will most likely be securing the SDG and energizing the ESF bus from a preferred source, at which time the configuration will be the same as the condition addressed by ACTION a. ACTION e also imposes a________________

__________________________72-hour completion time, consistent

________________

______________

Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 60 Table 2 Detailed Description of Changes and Basis Specification Old Action Req~uir'ement New Action Requirement Technical Discussion and Risk Basis input to Ris k Cal Icu lator to Number Comments ,DtrieRO Calculated STP RIOT Before Backstop S(base case)1 with ACTION a. STPNOC proposes to delete the 72-hour portion of ACTION e as an administrative change that eliminates the potential for being in ACTION a and ACTION e at the same time.STPNOC proposes to allow application of the CRMP to TS 3.8.1.1 .e.3.8.1.1 With two or three of the With two or three of the With 2 inoperable SDGs, STP does not Calculated RIOT: There are design-at~ors

-(and__above required standby above required standby lose the safety function and can meet 'assoiated Configuration Risk Action f diesel generators inoperable, diesel generators almost all of its design bases. 2 SDGs inoperable:

'Management

[ORM]demonstrate the inoperable, demonstrate the L~uiid eIi nes) fo~r:.OPERABILITY of two offsite OPERABILITY of two offsite With 3 inoperable SDGs, the safety 185 hours0.00214 days 0.0514 hours 3.058862e-4 weeks 7.03925e-5 months _________A.C. circuits by performing A.C. circuits by performing function would be lost if there is no Standby DIel Gnrao the requirements of the requirements of PRA functionality.

The RMTS AltreS)sioeal:LDA Pisl-nrtr Specif ication 4.8. 1.1.1la. Specification 4.8.1.1.1a.

Guidelines allow application of a RIOT AltheSDsiorae:API within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least for emergent condition if there is PRA once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter; once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months

Stanldby Diesel Generator' restore at least one standby With three of the above ucinaiy _diesel generator to required standby diesel The worcding chang-esae OPRBEttswihn2_eeaor

__pe,-- grammatically necessary to incoirporat

~jSadb ise eerti hours and at least two witin_ 2_ho ursp restore at thaplcioofheCIP rwqC Gj standby diesel generators to least one standby diesel i oeal ~sadfrtr4 OPERABLE status within 24 generator to OPERABLE inoperble SDG I. -,,, hours or be in at least HOT status or apply the STANDBY within the next 6 requirements of the CRMP, Dltn h eurmn orsoea hours and in COLD or be in at least HOT Dltn h eurmn orsoea SHUTDOWN within the STANDBY within the next 6 least three standby diesel generators to following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . Restore hours and in COLD OPERABLE status within 14 days from at least three standby diesel SHUTDOWN within the time of initial loss is an administrative generators to OPERABLE following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . (12) Wih change since proper application of the status within 14 days from two of the above required Tb eqires thia ntrreaindihoti time of initial loss or be in at standby diesel generators bengsatd least HOT STANDBY within inoperable, within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in stres aleast two standby COLD SHUTDOWN within diesel generators to____________

__________________

I OPERABLE status or apply I______________________________

____________

Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 61 Table 2 Detailed Description of Changes and Basis Specification Old Action Requ~irement New Action Requirement Technical Discussion and Rs ai nu oRs acltrt Number ~comments Determine RICT Calculated STP, RICT Before Backstop;(base'case)l the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . (12 the requirements of the CRMP, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .3.8.2.1 New note to accommodate Iffth-e batte-ri'es -d-is'ch-ar-ge -for, Since the batteries provide the power NAN/implementation of RMTS more than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months as the__ for the field flashing for the emergency D.C. Sources sole source of power to their diesel generator, an emergent condition'DC bus while the CRMPsr- where a train of batteries is carrying the NOTE jbeing applied and no. associated DC bus with no power to Ialternate source of power i's either of the battery chargers could available, the LCO shall be indicate an in-progress loss of off -site considered not metj power transient in which the emergency diesel generator for the affected ESE train did not start or is not available.

STPNOC does not believe it is appropriate to apply the CRMP to extend the allowed outage time during an ongoing emergent transient condition.

Discharge of the battery banks supporting the Channel 11 and Channel IV DC loads will not result in a plant trip or transient; however, STPNOC would not normally permit continuous discharge of a battery in an emergent condition (provided power to one of the chargers is available) or plan a work activity that involved an extended discharge of a battery bank.Discharge of the battery banks supporting Channel I and Channel III will not result in an immediate plant trip;however, a plant trip on low steam generator level will result after a loss of DC power as the Feedwater Isolation Valve hydraulic control system pressure bleeds off and the valves close. The evolution of the event_____________

____________________

____________________provides the operators with an ______________

_____________

Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 62 Table 2 Detailed Description of Changes and Basis Specification Old Action; Requirement New Action Requirement Technical Discussion and Risk Basis Input to Risk Calculator to Number 4Comments~

Determine RIOT~Calculated STP RIOT Before Backstop ,~ ~ base case)l opportunity to anticipate this trip and it can be avoided with timely local operator action. It is not STPNOC's intent to use the CRMP to extend the allowed outage time for configurations where the battery bank is the sole source of power available for the loads on the DC bus.3.8.2.1 With one of the required With one of the required The initial conditions of Design Basis The PRA models the normal Ffhere are designators (an~d battery banks inoperable, battery banks inoperable, Accident (DBA) and transient analyses Class 1 E 125V DC busses associated Configuration R~is~k D.C. Sources restore the inoperable within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months restore the in the FSAR assume that Engineered supplied from one of two battery Management

[CRM]battery bank to inoperable battery bank to Safety Feature (ESF) systems are chargers with power from their gquideie)fr Action a OPERABLE status within OPERABLE status or apply OPERABLE. ,associated ESE motor control 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months or be in at least the requirements of the centers. The associated battery __DC Battery Train A HOT STANDBY within the CRMP, or be in at least The DC electrical power system bank provides the backup. [BA~IIA next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD HOT STANDBY within the provides normal and emergency DC SHUTDOWN within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD electrical power for the SDGs, Calculated RICT: b!__C Battefj =airB following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . SHUTDOWN within the emergency auxiliaries, and control and ______]following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . switching during all MODES of 1 inoperable battery bank: 140 operation.

The OPERABILITY of the days (Train D 1040 days)

DC-attfry tiIQ DC sources is consistent with the initial [DC attG assumptions of the accident analyses (30 day backstop applies) 79 and is based upon meeting the design basis of the unit. This includes !__DC Battery TrainDj maintaining the DC sources @IP OPERABLE during accident conditions in the event of an assumed loss of all offsite AC power or all onsite AC power and a worst-case single failure.STP has 4 battery banks. Channel I is associated with Train A ESE. Channel Illis associated with Train D (Train A ESE power). Channel Ill is associated with Train B ESE. Channel IV is associated with Train C ESF. Each battery ba 'nk has two full capacity chargers._________________________________________The DC bus could be energized

______________

_____________

Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 63 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement New Actionr R eq u irem ent Technical Discussion and~ Risk Basis Input to Risk Calculator to Number ComnsDetermine RICT Calculated STP RIOT Before-Backstop (base case)1 through its associated batteries with its associated charger powered from an alternate source or from a temporary charger. With inoperable batteries, the DC bus can be energized through an operable charger or a temporary charger. The CRMP would allow appropriate consideration of these alternatives in determining an-allowed outage time. In addition, the RMVTS Guidelines allow a determination of functionality not available in the current TS.3.8.2.1 New action With more than one of the Same as above. Two inoperable battery banks: There are'design~ato&rs (and_required battery banks associated Conf iguration RI-sl D.C. Sources inoperable, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months The proposed 1 -hour time limit is 6 days 'Management

[CRM]restore at least three battery consistent with TS 3.0.3 which would 'Puidelines)__

Action b banks to OPERABLE status be required by the current TS for more Three inoperable battery banks: DC______or apply the requirements of than one inoperable battery bank. !~ tr rainA the CRMP or be in at least 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months , which exceeds the [BA-UjAl HOT STANDBY within the RMTS 1 E-03 ODE limit for ;7-7_next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD vlnayetyit odto._ri SHUTDOWN within the voutryety noacodtonT CBateyTri folowng30 ous.Four inoperable battery banks:~.DC Battery Train C 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months , which exceeds theEBT]RMTS 1 E-03 ODE limit for voluntary entry into a condition.

.DC BattryjrinD,_

[BAlTTD]

Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 64 Table 2 Detailed Description of Changes and Basis 3.8.2.1 D.C. Sources Action c (Previously ACTION b)With no battery chargers for a channel OPERABLE, restore at least one battery charger to OPERABLE status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months With one channel with no battery chargers OPERABLE, within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months restore at least one battery charger to OPERABLE status or apply the requirements of the CRMP, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months Application of the CRMP to a stable configuration, as required by the note described above, may be justified by the RMTS risk evaluation.

Examples of this are situations where the chargers are inoperable but meet the RMTS requirements for PRA functionality or pre-planned maintenance activities where temporary chargers are used and their capability can be quantified in the PRA.One battery bank with no operable charger: same as above for an inoperable battery bank.(r_ )Jass-ciated f,-i -jwtn Risk"I~gn [CRM]Gii~d o this~iifg~rai.A PRA ,ýva Iu-n w -i ould be t,)r :support use of 1theý `ITSeyondl the cuirrent AC-TION 3.8.2.1 New action With more than one channel Same as above. Two battery banks with no ~ KThere are o designators with no battery chargers operable charger: (and associated D.C. Sources OPERABLE, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months The proposed 1 -hour time limit is Configuration R~isk restore at least one battery consistent with TS 3.0.3 which would Three battery banks with no Management

[CRM]Action d charger to OPERABLE be required by the current TS for more operable charger: Guidelines) for this status on at least three than one inoperable battery bank configuration.

A PRA channels or apply the Four battery banks with no evaluation wouild be requirements of the CRMP, operable charger: required to support use of or be in at least HOT the RMVTS beyond the STANDBY within the next 6 Al h aea h vlainfr current ACTION hours and in COLD Al h aea h vlainfr Requiremnent.

SHUTDOWN within the the inoperable battery banks.following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months 3.8.3.1 With one of the required With one of the required The initial conditions of Design Basis The PRA models the design There are designators(and trains of A.C. ESE busses trains of A.C. ESE busses Accident (DBA) and transient analyses basis functions for the onsite associated Configuration Risk Onsite Power not fully energized, not fully energized, within 8 in the FSAR assume ESE systems are power distribution system. Management Guidelines) for Distribution reenergize the train within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months reenergize the train or OPERABLE.

The AC, DC, and AC vital 'the Class 1 E_410OV buse: hours or be in at least HOT apply the requirements of bus electrical power distribution 1 inoperable AC ESF bus: Train Operating STANDBY within the next 6 the CRMP, or be in at least systems are designed to provide A 22 days, Train B 58 days, Train

4160V Bus~ El A [El AM]hours and in COLD HOT STANDBY within the sufficient capacity, capability, C 79 days.SHUTDOWN within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD redundancy, and reliability to ensure .41 60V Bus El B [E 1 M]following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . SHUTDOWN within the the availability of necessary power to (30 day backstop applies for following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . ESF systems so that the fuel, Reactor Train B and Train C) 41 Bs1C[CM Action a. Coolant System, and containment 14 ,VBsE I I Attachment 1: Description of Changes and Safety Evaluation Table 2 Detailed Description of Changes and Basis NOC-AE-06002036 Page 65 Specification

~Old Action Requirement New Action Requirement Technical Discussion an~d Risk Basis Input to Risk Calculator to Number Comments CacltdDetermine RICT Calulaed TP ICTBefore Backstop (base case)1i design limits are not exceeded.This includes maintaining power distribution systems OPERABLE during accident conditions in the event of an assumed loss of all offsite power or all onsite AC electrical power and a worst case single failure.OPERABLE AC electrical power distribution subsystems require the associated buses, load centers, motor control centers, and distribution panels to be energized to their proper voltages.

OPERABLE DC electrical power distribution subsystems require the associated buses and distribution panels to be energized to their proper voltage from either the associated battery or charger. OPERABLE vital bus electrical power distribution subsystems require the associated buses to be energized to their proper voltage from the associated inverter connected to the DC bus.The inverters are the preferred source of power for the AC vital buses because of the stability and reliability they achieve. The function of the inverter is to provide AC electrical power to the vital buses.Conditions may arise where ACTION a is entered because a "downstream"'

bus (e.g. one half of the double ended 480-volt load center) has been de-energized by a fault or needs to be de-energized to perform maintenance.

Because of available design redundancy, the eight hour completion time of ACTION a is The difference in the RICTs for the ESF trains is due to fires outside the control room. These fires primarily affect the B and C trains, leaving the A train for fire mitigation.

Any unavailability of A train equipment is more significant then the corresponding B or C trains.Loss of a single AC ESF bus does not result in a plant trip.Only one of three available trains would be affected.The RICT for Section 3.8.2.1 would apply if the bounding assumption is made that the loss of the ESF bus results in the loss of the associated battery chargers.There arg-alo desýignator~s (and~ass 'ociated Configuration' Risk 'Management Guidelines) for the Class 1 E 120V Vital-D Pl12o Ca~nnel 1~DP1202 Channel 2[!N§TB]D' D -203-,ha6n-ne-3

[INSTO]-D TP1204Cai4 ftNST.P]----'

Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 66 Table 2 Detailed Description of Changes and-Basis Specification Nuimber Old Action Requirer Action Requirement Technical Discussion and~Comments Risk Basis Calculated STIP RIOT Before Backstop Input to Risk Calculator to Determine RIOT (base case)1 4. .4 unnecessarily restrictive and application of the CRMP is appropriate.

STPNOC provided additional detail on the application of RMTS to TS 3.8.3.1 in a letter dated April 26, 2006 responding to NRC request for additional information (MLO61 280591).3.8.3.1 New ACTION b With more than one of the One hour is a conservative time to The RICT for Section 3.8.2.1 required trains of A.C. ESF assess the configuration and determine would apply if the bounding Onsite Power busses not fully energized, the appropriate action and AOT. The assumption is made that the loss Distribution within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months reenergize at time is consistent with TS 3.0.3 which of the ESIF bus results in the loss least two trains or apply the would currently apply for conditions of the associated battery Operating requirements of the CRMP, with more than one required bus not chargers.or be in at least HOT fully energized.

Extending the time Action b. STANDBY within the next 6 further can be justified due to the hours and in COLD redundancy of the ESF power. STP SHUTDOWN within the does not lose the safety function unless following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months , all three trains of ESF power are lost.3.8.3.1 (Previously ACTION b) With one A.C. vital These completion times may be Inoperable inverter backed up by Trhere are designators (and With one A.C. vital distribution panel either extended with the application of the non-regulated transformer:

associated Configuration RI-sk OnsitePower distribution panel either not not energized from its CRMP. There is sufficient redundancy agent'udlesfo Distribution associated inverter, or to enable STPNOC to manage the Calculated RICT: ~the inverters and the'enegiedfrm tswith the inverter not configuration risk when this action distribution p~knesl Operating associated inverter, or with connected to its applies. The STPNOC letter dated 27_dy the inverter not connected to associated D.C. bus: (1) April 26, 2006 (ML061280591) 27 ay Channel 11 InvertriV-1i202 its associated D.C. bus: (1) within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months reenergize responded to NRC request ford bk reenergize the A.C. the A.C. distribution panel additional informati~ionon applicatin' of (30 day backstop applies) V-2)distribution panel within 2 or apply the requirements RMTS to electrical TS and includes ~ "~~vrl------

Action c. hours or be in at least HOT of the CRMP, or be in at additional discussion on application to -Channel IIIInerterV_120 STANDBY within the next 6 least HOT STANDBY TS 3.8.3.1. (IV -2031 hours and in COLD within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ~hnellvrel-~

SHUTDOWN within the adi OD_ _ _following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months ; and (2) SHUTnCODOW wihi then (el I 1vere?)6 reenergize the A.C. vital follDOWiNg 30 thours and(y-0 distribution panel from its (2)lowithng 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ; Chneandnetr

-O conce oisassociated ivre reenergize the A.C. vital ~(I-1 204)DConece tos witsi as ous oite distribution panel from its D.C. us wihin 4 hous or associated inverter ~thne1lS~be in at least HOT connecte toane it ___________________________

Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 67 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement New Action Requirement Technical Di~scussion and Risk Basis Input to Risk Calculator toe Number comments Determine RICT 2 Calculated STP RICT Before Backstop K~t ' ~t(base case)1 STANDBY within the next 6 associated D.C. bus or 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months and in COLD apply the requirements of bP22Canl2[INSTP]

SHUTDOWN within the the CRMP, or be in at _____following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . least HOT STANDBY 7-Dbp1 203 -Channel 3 [!INSTQ]within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD .DP 204 Channel 4 [NSTD]SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .3.8.3.1 New ACTION With more than one A.C. One hour is a conservative time for an Calculated RICT: Th-&ere a-re designators(a-nd vital distribution panel either assessment to determine an 'associated Configuration RIS Action d. not energized from its appropriate RICT for the configuration.

2 inoperable inverters:

16 days MangejqptnGufidelins) for: associated inverter, or with It is consistent with TS 3.0.3 which the inverter not connected would currently apply if more than one 1ioeal u:28dy hne M~~to its associated D.C. bus: vital distribution panel was not properly _A (1) within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months reenergize energized.

The redundancy of the STIP at least five A.C. distribution electrical power systems will provide (30 day backstop applies) !_.Channel I Inverter IV- 1201 panels or apply the adequate justification for extending the ( l21 requirements of the CRMP, time beyond two hours. Additional 2 inoperable buses: 8 days_____or be in at least HOT assessments may be performed to " PDF1 202LiCAqngpýI?[NSTB]

STAN DBY within the next 6 determine the time needed to re--_____hours and in COLD energize the panel (s) from the , jChannel 11 Inverte6r iV- 1202 SHUTDOWN within the associated inverter.

The panels can --(LV-1 202)following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months ; and (2) also be powered from an alternate 1 E within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months reenergize at diesel backed bus. ~D10 hne3ISC least five A.C. -vitalDP23Canl3 LS ]distribution panels from their .CanlIlIvre

-0 associated inverters Ly_3y-connected to their associated D.C. bus or_____________

apply the requirements of .DP1204 Channel 4r [T~4lP the CRMP, or be in at least __________

HOT STANDBY within the 'o Channel IV Inverter, V-i 204 next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD (IV-1204F)

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

Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 68 Table 2 Detailed Description of Changes and Basis~Specification Old Action Requirement New Action Requirement Technical Discussion and' ~ Risk Basis In~put to Risk Calculator to Number Comments Determine RICT Calculated STP RICT Before Backstop (base ca~se)1 3.8.3.1 (Previously ACTION c) With one D.C. bus not Power to the DC bus can also be As described in the Technical

S:382 Ato6c energized from its provided by either of its associated Discussion and Comments for Action e. With one D.C. bus not associated battery bank, chargers.

The two-hour allowed outage the Battery TS (3.8.2. 1) loss of energized from its within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months reenergize time is not consistent with the Bus A or B results in a plant trip, associated battery bank, the D.C. bus from its redundancy available from the other although not immediately.

reenergize the D.C. bus from associated battery bank or DC channels and the low likelihood of a its associated battery bank apply the requirements of LOOP. This action should be Calculated RICT: within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months or be in at the CRMP, or be in at least consistent with the action for TS 3.8.2.1 least HOT STANDBY within HOT STANDBY within the for batteries and chargers.

Bus C -95 days, Bus D 343 the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD Consequently, it is appropriate to be days.COLD SHUTDOWN within SHUTDOWN within the able to apply the CRMP to extend the the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . two-hour allowed outage time for either an emergent condition or a planned (30 day backstop applies)maintenance evolution for which the corrective action requires the battery bank to be disconnected from-the DC bus.3.8.3.1 New ACTION With more than one D.C. One hour is consistent with the time Two DC busses not energized SýEe3.8.2.1 Action c.bus not energized from its requirement of TS 3.0.3 which would from the associated battery bank: Action f. associated battery bank, currently apply with more than one bus Bus A or B, plant trip if totally within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months reenergize at not energized from its associated deenergized.

least three D.C. buses from battery bank.their associated battery Three DC busses not energized banks or apply the It is appropriate to be able to apply the from the associated battery bank: requirements of the CRMP, CRMP to extend the allowed outage or be in at least HOT time for either an emergent condition or Plant trip if totally deenergized.

STANDBY within the next 6 a planned maintenance evolution for hours and in COLD which the corrective action requires the Four DC busses not energized SHUTDOWN within the battery bank to be disconnected from from the associated battery bank: following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . the DC bus. Application of the proposed note in TS 3.8.2.1 prevents Plntrpadicseabv applying RMTS when the batteries are Plntrpadicseabv the sole source of power to their DC bus.

Attachment 1: Description of Changes and Safety Evaluation NOC-AE-06002036 Page 69 Table 2 Detailed Description of Changes and Basis Specification Old Action Requirement

'New Action Requirement Technical Discussion and Risk Basis, Input to Risk Calculator to, Number ~Comnments Determine RICT Calcu lated STP RICT Before Backstop~Admin TS k. Configuration Risk k. Configiuration Risk The CRMP description in the TS 6.8.3 NANA 6.8.3.k. Management Program Management Proairam Administrative section will establish the (CRMP) (CRMP). risk management technical standard by reference to the NEI RMTS. Deletion A program to assess A program to assess of the specific list of requirements is changes in core damage changes in core damage acceptable because the referenced NEI frequency and cumulative frequency and cumulative document includes the requirements.

core damage probability core damage probability resulting from applicable resulting from applicable plant configurations.

The plant configurations.!Thd program should include the pVrogram shall be in__following:

'accordance with NEI 06-09,!ý'Risk-Managed Technical-

1) training of personnel; Ppecifications (RMTSf)Guidelines, Rev. 0'. Th-9 2) procedures for identifying PRMP may be used for__plant configurations, the calculating a risk-informre-d generation of risk profiles completion time only in'and the evaluation of risk Mo de 1 and Mode 2-.1 against established thresholds; and 3) provisions for evaluating changes in risk resulting from unplanned maintenance activities.

BASES FOR Did not exist Section added to explain The Bases are provided for information NA 4A APPLICATION these new CRMP provisions and the final version will be sent for OF RISK- in the specifications incorporation into the NRC copy of INFORMED STP's TS after approval of the COMPLETION proposed amendment.

TIMES 1. Base case is number of hours to exceed the CRMP 1 E-05 threshold for core damage probability, assuming no other systems are inoperable.

The Base Case Action Level where risk management action must be initiated is 1 E-06, or 10% of the time allowed to the 1 E-05 Base Case. Note that the proposed backstop time will establish the AOT for conditions where the CRMP calculated time exceeds 30 days.

NOC-AE-06002036 Attachment 2 Technical Specification Mark-Up Pages Attachment 2

C/, 0 C: H-I C/90 TABLE 3.3-1 (Continued)

INO CHANGES REACTOR TRIP SYSTEM INSTRUMENTATION FUNCTIONAL UNIT TOTAL NO.OF CHANNELS TO TRIP MINIMUM CHANNELS OPERABLE 2 APPLICABLE MODES 1,2 ACTION 9A 18. Safety Injection Input from ESFAS 19. Reactor Trip System Interlocks

a. Intermediate Range Neutron Flux, P-6 b. Low Power Reactor Trips Block, P-7 P-10 Input or P-1 3 Input c. Power Range Neutron Flux, P-8 d. Power Range Neutron Flux, P-9 e. Power Range Neutron Flux, P-10 f. Turbine Impulse Chamber Pressure, P-13 20. Reactor Trip Breakers 2 2 1 2 8 CD CL CD z 0 (TI C: CD CD z 0 0)4 2 4 4 4 2 2 2 2 2 2 2 1 3 2 3 3 3 2 2 2 1 1 1 8 8 8 8 8 1 1,2 1 1 1 1 1,2 3*, 4*, 5*8 9,12 10 NO CHANGES TABLE 3.3-1 (Continued)

W, 0 r m x C,)C: z C,)90 REACTOR TRIP SYSTEM INSTRUMENTATION FUNCTIONAL UNIT 21. Automatic Trip and Interlock Logic TOTAL NO.OF CHANNELS 2 2 CHANNELS TO TRIP MINIMUM CHANNELS OPERABLE APPLICABLE MODES 1,2 3*, 4*, 5*ACTION 9A 10 1 1 2 2 C CD CD z 0 N)1 3 (D CD z 0 CA)0)

TABLE 3.3-1 (Continued)

ACTION STATEMENTS (Continued)

ACTION 7 -(Not Used)ACTION 8 -With less than the Minimum Number of Channels OPERABLE, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months determine by observation of the associated permissive annunciator window(s) that the interlock is in its required state for the existing plant condition, or apply Specification 3.0.3.ACTION 9 -With the number of OPERABLE channels one less than the Minimum Channels OPERABLE requirement, be in at least HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ; however, one channel may be bypassed for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing per Specification 4.3.1.1, provided the other channel is OPERABLE.ACTION 9A -i] With the number of OPERABLE channels one less than the Minimum Channels OPERABLE requirement9 or restore the inoperable channel to OPERABLE status ~y~n2 our~r applthreurmnso the CRMP, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ; however, one channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing per Specification 4.3.1 .1, provided the other channel is OPERABLE.6b. Wfi-th he nmbe-r -of -O"-P-ER-A BL`E c-ha-n-n-el-s more than one less th-an the Minimum Channels OPERABLE requirement, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore at 1'least one inoperable channel to OPERABLE status or apply the--requirements of the CMor be in at least HOT STANDBY' within the'next 6 hus ACTION 10 -With the number of OPERABLE channels one less than the Minimum Channels OPERABLE requirement, restore the inoperable channel to OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or open the Reactor Trip System breakers within the next hour.ACTION 11 -(Not Used)ACTION 12 -With one of the diverse trip features (undervoltage or shunt trip attachment) inoperable, restore it to OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or declare the breaker inoperable and apply ACTION 9. The breaker shall not be bypassed while one of the diverse trip features is inoperable except for the time required for performing maintenance to restore the breaker to OPERABLE status.SOUTH TEXAS -UNITS 1 & 2 3/4 3-8 Unit 1 -Amendment No.4-36 Unit 2 -Amendment No.12-3 INO CHANGES INSTRUMENTATION INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.2 The Engineered Safety Features Actuation System (ESFAS) instrumentation channels and interlocks shown in Table 3.3-3 shall be OPERABLE with their Trip Setpoints set consistent with the values shown in the Trip Setpoint column of Table 3.3-4 and with RESPONSE TIMES as shown in Chapter 16 in the UFSAR.APPLICABILITY:

As shown in Table 3.3-3.ACTION: a. With. an ESFAS Instrumentation or Interlock Trip Setpoint trip less conservative than the value shown in the Trip Setpoint column but more conservative than the value shown in the Allowable Value column of Table 3.3-4, adjust the Setpoint consistent with the Trip Setpoint value.b. With an ESFAS Instrumentation or Interlock Trip Setpoint less conservative than the value shown in the Allowable Value column of Table 3.3-4, declare the channel inoperable and apply the applicable ACTION statement requirements of Table 3.3-3 until the channel is restored to OPERABLE status with its Setpoint adjusted consistent with the Trip Setpoint value.C. With an ESFAS instrumentation channel or interlock inoperable, take the ACTION shown in Table 3.3-3.SOUTH TEXAS -UNITS 1 & 2 3/4 3-16 Unit 1 -Amendment No. 60, 116 Unit 2 -Amendment No. 39,104 NO CHANGES INSTRUMENTATION.qliRVFII I AKC.F PFO1IJIPFMFNJT5q 4.3.2.1 Each ESFAS instrumentation channel and interlock and the automatic actuation logic and relays shall be demonstrated OPERABLE by performance of the ESFAS Instrumentation Surveillance Requirements specified in Table 4.3-2.4.3.2.2 The ENGINEERED SAFETY FEATURES RESPONSE TIME of each ESFAS function shall be verified to be within the limit at least once per 18 months. Each verification shall include at least one train so that: a. Each logic train is verified at least once per 36 months, b. Each actuation train is verified at least once per 54 months*, and C. One channel per function so that all channels are verified at least once per N times 18 months where N is the total number of redundant channels in a specific ESFAS function as shown in the "Total No. of Channels" column of Table 3.3-3.*If an ESFAS instrumentation channel is inoperable due to response times exceeding the required limits, perform an engineering evaluation to determine if the test failure is a result of degradation of the actuation relays. If degradation of the actuation relays is determined to be the cause, increase the ENGINEERED SAFETY FEATURES RESPONSE TIME surveillance frequency such that all trains are tested at least once per 36 months.SOUTH TEXAS -UNITS 1 & 2 3/4 3-17 Unit 1 -Amendment No. 50, 4 30, 145 Unit 2 -Amendment No. 39,~119, 133 0)0 C: H 90 N)TABLE 3.3-3 ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION FUNCTIONAL UNIT TOTAL NO.OF CHANNELS CHANNELS TO TRIP MINIMUM CHANNELS OPERABLE APPLICABLE MODES ACTION 1 .Safety Injection (Reactor Trip, Feedwater Isolation, Control Room Emergency Ventilation, Start Standby Diesel Generators, Reactor Containment Fan Coolers, and Essential Cooling Water).a. Manual Initiation

b. Automatic Actuation Logic c. Actuation Relays d. Containment Pressure--

High-i e. Pressurizer Pressure--Low

f. Compensated Steam Line P ressu re-Low co 2 2 3 3 4 1 1 2 2 3 2 2 2 1,2,3, 4 1,2, 3,4 1,2,3,4 1, 2, 3,4 1, 2, 3#1, 2, 3#19 14 14 C:C: 3 3 (D CD 0 0 2 3 2/steam line in each steam line 10A 20 20 3/steam line 2/steam line any steam line NO CHANGES (n, 0 r m CD Cn z CD['0 TABLE 3.3-3 (Continued)

ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION TOTAL NO.OF CHANNELS MINIMUM CHANNELS TO TRIP MINIMUM CHANNELS OPERABLE APPLICABLE MODES FUNCTIONAL UNIT ACTION 2. Containment Spray C: 3 CD 3 CD z 0 CA)CA)CD 3 CD z 0 a. Manual Initiation

b. Automatic Actuation Logic c. Actuation Relays d. Containment Pressure-High -3 3. Containment Isolation a. Phase "A" Isolation 1) Manual Initiation

2) Automatic Actuation Logic 3) Actuation Relays 4) Safety Injection 2 2 3 4 1 with 2 coincident switches 1 2 2 2 2 3 3 1,2,3,4 1,2,3,4 1,2,3,4 1,2,3 19 14 14 17 2 2 1 1 2 2 1,2,3,4 1,2,3,4 19 14 14 requirements.

3 2 3 1,2,3,4 See Item 1. above for all Safety Injection initiating functions and INO CHANGES C', 0 r--i M C', z=1i cl)TABLE 3.3-3 (Continued)

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

ACTION CA b. Containment Ventilation Isolation 1) Automatic Actuation Logic 2) Actuation Relays***3) Safety Injection 4) RCB Purge Radioactivity-High 5) Containment Spray-Manual Initiation

6) Phase "A" Isolation-Manual Isolation c. Phase "B" Isolation 1) Automatic Actuation Logic 2) Actuation Relays 3) Containment Pressure --High-3 4) Containment Spray--Manual Initiation

d. RCP Seal Injection Isolation 1) Automatic Actuation Logic and Actuation Relays 2 1 2 1,2,3,4 18 3 2 3 1,2,3,4 18 See Item 1. above for all Safety Injection initiating functions and requirements.

2 1 2 1, 2,3, 4, 5##, 18 See Item 2. above for Containment Spray manual initiating functions and requirements.

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

2 3 4 1 2 2 2 3 3 1,2,3,4 1,2,3,4 1,2,3 14'14 17 C: CD CD z 0 See Item 2. above for Containment Spray manual initiating functions and requirements.

1 1 1 1,2,3,4 16 W, 0 M--i m CD W W_.L 90 INO CHANGES TABLE 3.3-3 (Continued)

ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION TOTAL NO.OF CHANNELS CHANNELS TO TRIP MINIMUM CHANNELS OPERABLE APPLICABLE MODES.FUNCTIONAL UNIT ACTION 3.d. RCP Seal Injection Isolation (Continued)

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

1) Individual 2/steam line 1/steam line 2/operating steam line 1,2,3 1,2,3 1,2,3 2) System b. Automatic Actuation Logic and Actuation Relays c. Steam Line Pressure -Negative Rate--High

d. Containment Pressure -High-2 e. Compensated Steam Line Pressure -Low 2 2 1 2 2 1 3/steamn line 2/steam line any steam line 2/ steam line in each steam line 24 23 22 20 20 20 (D CD CD CD z z 0 0 N) W CJ1C)3 2 2 1,2,3 3/steam line 2/steamn line any steam line 2/steam line in each steam line 1, 2, 3#

NO CHANGES TABLE 3.3-3 (Continued)

Cl)0 C: H M x z Cf, ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION TOTAL NO.OF CHANNELS CHANNELS TO TRIP MINIMUM CHANNELS OPERABLE APPLICABLE MODES FUNCTIONAL UNIT ACTION 5. Turbine Trip and Feedwater Isolation a. Automatic Actuation Logic and Actuation Relays b. Steam Generator Water Level--High-High (P-14)2 1 2 1,2,3 25 4 /stm. gen.2/ stm. gen. in any operating stm.gen.3/stm. gen. in each operating stm. gen.1,2,3 20 C,, CA, c. Deleted d. Deleted CD CD CE)z 0 e. Safety Injection f. Tavg -Low coincident with Reactor Trip (P-4)(Feedwater Isolation Only)See Item 1. for all Safety Injection initiating functions and requirements.

4 (1 /loop)2 3 1,2,3 20 TABLE 3.3-3 (Continued)

C,, 0 r m X (I, C: z C))r'0 ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION FUNCTIONAL UNIT 6. Auxiliary Feedwater TOTAL NO.OF CHANNELS CHANNELS TO TRIP MINIMUM CHANNELS OPERABLE APPLICABLE MODES ACTION CD C1 CD I.I.z 0 CD, CDI z 0 a. Manual Initiation

b. Automatic Actuation Logic c. Actuation Relays d. Stm. Gen. Water Level --Low-Low Start Motor-Driven Pumps and Turbine-Driven Pump e. Safety Injection f. Loss of Power (Motor Driven Pumps Only)7. Automatic Switchover to Containment Sump****a. Automatic Actuation Logic and Actuation Relays b. RWST Level -- Low-Low Coincident With: Safety Injection 1/pump 2 3 4 stm. gen.1/pump 1 2 1/pump 2 3 2 stm. gen. in any 3/stm. gen. in each stm. gen.See Item 1. above for all Safety Injection initiating functions and requirements., See Item 8. below for all Loss of Power initiating functions and requirements.

1,2,3 1,2,3 1,2,3 1,2,3 26 22 22 20 3-1/train 3-1/train 1 /train 1/train 1/train 1/train 1,2,3,4 1,2,3,4 1 9A See Item 1. above for all Safety Injection initiating functions and requirements.

0 C--i TABLE 3.3-3 (Continued)

--I m ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION C 1 MINIMUM CTOTAL NO. CHANNELS CHANNELS APPLICABLE z FUNCTIONAL UNIT OF CHANNELS TO TRIP OPERABLE MODES ACTION=1i CD 8. Loss of Power a. 4.16 kV ESF Bus Under- 4/bus 2/bus 3 /bus 1,2,3,4 ýMA voltage-Loss of Voltage b. 4.16 kV ESF Bus Under-voltage-Tolerable Degraded Voltage Coincident with SI 4/bus 2/bus 3/bus 1, 2, 3,4 4-A c. 4. 16 kV ESF Bus Under-voltage -Sustained coDegraded 4/bus 2/bus 3/bus 1,2,3,4 20Al 4ýý- Voltage K) 9. Engineered Safety Features a. Pressurizer Pressure, P-i 1 3 2 2 1, 2, 3 21 b. Low-Low Tavg, P-1 2 4 2 3 1,2,3 21 c. Reactor Trip, P-4 2 1 2 1, 2, 3 23 C: CD (D z 0 C/)0 r--I m Cf, z C,, INO CHANE TABLE 3.3-3 (Continued)

ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION TOTAL NO.OF CHANNELS CHANNELS TO TRIP MINIMUM CHANNELS OPERABLE APPLICABLE MODES FUNCTIONAL UNIT ACTION 10. Control Room Ventilation

a. Manual Initiation

b. Safety Injection c. Automatic Actuation Logic and Actuation Relays d. Control Room Intake Air Radioactivity

-High e. Loss of Power 3 (1/train) 2 (1/train) 3 (1 /train) All 27 See Item 1. above for all Safety Injection initiating functions and requirements.

3 2 3 All 27 2 1 2 All 28 CD, See Item 8. above for all Loss of Power initiating functions and requirements.

11. FHB HVAC a. Manual Initiation

b. Automatic Actuation Logic and Actuation Relays c. Safety Injection d. Spent Fuel Pool Exhaust Radioactivity

-High 3 (1/train)3 2 (1/train)2 3 (1 /train) 1, 2, 3, 4 or with irradiated fuel in spent pool 3 1,2, 3, 4or with irradiated fuel in spent pool 29, 30 29, 30 See Item 1. above for all Safety Injection initiating functions and requirements.

2 1 2 With irradiated fuel 30 in spent fuel pool TABLE 3.3-3 (Continued)

TABLE NOTATIONS-*Function is actuated by either actuation train A or actuation train B. Actuation train C is not used for this function.***Automnatic switchover to containment sump is accomplished for each train using the corresponding RWST level transmitter.

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

Setpoint.## During CORE ALTERATIONS or movement of irradiated fuel within containment.

1. 1. Trip function automatically blocked above P-i 1 and may be blocked below P-i 1 when Low Compensated Steamline Pressure Protection is not blocked.ACTION STATEMENTS ACTION 14 -N~t h rvso to apply the RMfr does not apply for Item 3.a.2, Containment Isolation Phase A Automatic Actuation Logic; Item 3.a.3, Containment Isolation Phase AActuation~

Relays;- Item 3.c.1, Containment Isolation Phase B AutomaticActuation Logic;or ltern3.c.2, ,Containment Isolation Phase B Actuation Relays.a,, With the number of OPERABLE channels one less than the Minimum Channels OPERABLE reqireent

~_4_n24 hours restore the inoperable channel to OPERABLE status Withi"-h~rapply the requiremnents of the CRMP, or bei in at least HOT STANDBY within the nx or and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months ; however, one channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing per Specification 4.3.2.1, provided the other channel is OPERABLE.b. ~With the num ' ber of OPERABLE, channelIs more than one less ,than the Minimum Channeik OPERABLE 'requirement, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore at least one inoperable channel to OPERABLE-'status or apply the requirements of the CRMP, or be in at least HOT STANDBY withinth next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hou ACTION 15 -(Not Used)ACTION 16 -With the Charging Header Pressure channel inoperable:

a) Place the Charging Header Pressure channel in the tripped condition within one hour and b) Restore the Charging Header Pressure channel to operable status within 7 days or be in at least Hot Standby within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in Cold Shutdown within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .ACTION 17 -NOE The provision to: app y the CRMP does not apply for Item 3.c.3, Co ,n tainment sol-ateio Phase B on Containment Pressure Hi-3.al With the number of OPERABLE channels one less than the Total Number of CansW~ith~iin7 ho0uri plc h nprable channel in the bypassed condition

'_6r pply uplcth nether rquirements ofithe'C RPJ ithn 72_ iiu, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in at least HOT SHUTDOWN within thle following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . One additional channel may be bypassed for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for surveillance testing per Specification 4.3.2.1.b.With thie nuidm-ber of OPERABLE -channels more than one less than the Total, Numberiof channels, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months apply the requirements of, theCRMP or be in at least HOT STANDBY in the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months rThis action is not-'required for the surveillance testing provision of Action 117a.ý- __SOUTH TEXAS -UNITS 1 & 2 3/4 3-26 Unit 1 -Amendment No. 4=60 Unit 2 -Amendment No. 450W TABLE 3.3-3 (Continued)

ACTION STATEMENTS (Continued)

ACTION 18 -a) With less than the Minimum Channels OPERABLE requirement for Automatic Actuation Logic or Actuation Relays, operation may continue provided the containment purge supply and exhaust valves are maintained closed.b) MODE1, 2, 3,4, or 5": 1. With one less than the Minimum Channels OPERABLE requirement for RCB Purge Radioactivity-High, within 30 days restore the inoperable channel or maintain the containment purge supply and exhaust valves closed.NOTE: MODE 1, 2, 3, or 4: Supplementary containment purge supply and isolation valves may be open during the allowed outage time for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months at a time for required purge operation provided the valves are under administrative control.MODE 5##: Supplementary or Normal containment purge supply and isolation valves may be open during the allowed outage time for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months at a time for required purgie operation provided the valves are under adminis~trative nnntrnl 2. With two less than the Minimum Channels OPERABLE requirement for RCB Purge Radioactivity-High, operation may continue provided the containment purge supply and exhaust valves are maintained closed.c) MODE 6##: With less than the Minimum Channels OPERABLE requirement for RCB Purge Radioactivity

-High" apply the requirements of Technical Specification 3.9.9 for an inoperable Containment Ventilation Isolation System.NOTE: With one less than the Minimum Channels Operable requirement for RCB Purge Radioactivity-High, Supplementary or Normal containment purge supply and isolation valves may be open for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months at a time for required purge operation provided the valves are under administrative control.ACTION19 -NOTE: IThe provisi on to appjy the CRMP does 3tapypj@,.a.1, Containment Isolation Phase ~A Man~ual Isolation.

a. With the number of OPERABLE channels one less than the Minimum Channels OPERABLE requirement, within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months restore the inoperable channel to OPERABLE status or apply'th~e requirements of the CRMP, or be in at least HOT STANDBY within th nex 6hours and in COLb'_HUTDOWN within the following, 30 ,hours.7 b. -With heium--rof O-PERABLE ct-h--a-nne-ls -m-o-re t hanr66 on le-ss t-ha t-1he Mi n im um -C-h-an n el s OPERA13LE requirement, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore at least one channel to OPERABLE~status or apply the requ~irements of the CRMP,ý or be in at least HOT STANDBY within the next*6 hours and in COLD SH~UTDOWN within the following 30 hou-rs.ACTION 16A a. W ith ne tr-ain witih t-h-e number of OPERABLE channels less than the Minimum Channels__

OPERABLE requirement, within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months restore the inoperable channel to OPERABLE statlusocii apply the requirements of the CRMP, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and ~in COLD SHýUTDOWN within the following 30hus b. o~hmr hn 6e train with the numr-be-r of OPERtfABLE-channiels less than the ii-nimum Channels OPERABLE requirement, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore the channels for atlattwo, trains ,to OPERABLE status or apply. the requirements of the CRMP, or be in at least HOT STANDBY 1 ,withlin the next 6_hours and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months ., SOUTH TEXAS -UNITS 1 & 2 3/4 3-27 Unit 1 -Amendment No. 4-W Unit 2 -Amendment No. 150 TABLE 3.3-3 (Continued)

ACTION STATEMENTS (Continued)

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

a. For Functional Units with installed bypass test capability, the inoperable channel may be placed in bypass, and must be placed in the tripped condition within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .Note: A channel may be bypassed for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for surveillance testing per Specification 4.3.2.1, provided no more than one channel is in bypass at any time.b. For Functional Units with no installed bypass test capability, 1 .The inoperable channel is placed in the tripped condition within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , and 2. The Minimum Channels OPERABLE requirement is met; however, the inoperable channel may be bypassed for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for surveillance testing of other channels per Specification 4.3.2.1.FACTION 20A- a.-With the number of OPERABLE channels one less than the Total Number of Channels, STARTUP and/or POWER OPERATION may proceed provided thjefollowing conditions r Isatisfied:

~~For Function6al U-nitwt install ed by-pass test capabili rty, thiein~operable -channel may be placed in bypass, and within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months place the channel in the tripped cond#itio or appjy jherequirements of the CRMP2---- cane m-a y-be-b-ypas"se

--d fio r, 0p t-o 1-2 -ho-ur-s f-o-r s-u-r-ve-i-l-la-n-c~e te-stiin,-g p-e-r'Speifcto 4.3.2.1, provided no qmore than _one, channel is in bypass at any timne.'For Fu nctional1 Units wit no installed byasse tetcapability,~~. Within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ~Lchannel in the trippedcnionopyth requirements of the CRMIP, and 2.The ---M inimumCanl OPEABLE r-e_-u-iremne nt, is- ethovrheioperable

,---channel may be bypassed for up to 12 hýours for surveillance testing of other channelis per Specification 4.31.2.41.

b. With the number of. OPERABLE cianri46&s~fmore than onie less than the Total Number of, Channels4ý within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 'restore at least two channels to OPERABLE status'for functions with, three cphannels and restore at least 3 channels to OPERABLE status for functions that have four'channels, or apply the requirements of the CRMVIP; or be in at least HOT STANDBY within the nex6:t'6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and be in at least HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and be in COLD-SHUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . This action is not required for the surveillance-Feting-provis~ion in the note to Action_20A.aJ

__With less than the Minimum Number of Channels OPERABLE, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months determine by observation of the associated permissive annunciator window(s) that the interlock is in its required state for the existing plant condition, or apply Specification 3.0.3.a. With the number of OPERABLE channels one less than the Minimum Channels OPERABLE requirement, Gotr h iooal hannolI to- OPR'ABLEF status, within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months restore the Lnoperable channel to OPERABLE status or apply theý requirements of the CRMIP, or bei in at least HOT STANDBY _within the -next 6 ho'ursa~n~d in at least HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ; however, one channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing per Specification 4.3.2.1 provided the other channel is OPERABLE.b._Wit~h_'

he" num-ber- -of OPERAL c-han-nels more -t'h-a'n on-e l-ess -tha~n 'th e M'i ni-m um ,Channels OPERABLE requirement, within one hour restore at least one channel to ,OPERABLE status for functions with two channels or restore at least two channels tod ,OPERABLE status for functions with three channels, or apply the requirements of the CRMVP; or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in at least HOT_SHUTDOWN within the following 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months si -- -ACTION 21 -ACTION 22 -SOUTH TEXAS -UNITS 1 & 2 3/4 3-27'ai Unit 1 -Amendment No.Unit 2 -Amendment No.

TABLE 3.3-3 (Continued)

ACTION STATEMENTS (Continued)

INO CHANE ACTION 23 -ACTION 24 -ACTION 25 -ACTION 26-ACTION 27-ACTION 28 -With the number of OPERABLE channels one less than the Total Number of Channels, restore the inoperable channel to OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or be in at least HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in at least HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .With the number of OPERABLE channels one less than the Total Number of Channels, restore the inoperable channel to OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or declare the associated valve inoperable and take the ACTION required by Specification 3.7.1.5.With the number of OPERABLE channels one less than the Minimum Channels OPERABLE requirement, restore the inoperable channel to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ; however, one channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing per Specification 4.3.2.1 provided the other channel is OPERABLE.With the number of channels OPERABLE less than the Minimum Channels OPERABLE requirement, declare the affected Auxiliary Feed Water Pump inoperable and take ACTION required by Specification 3.7.1 .2.For an inoperable channel, declare its associated ventilation train inoperable and apply the actions of Specification 3.7.7.a. With the number of OPERABLE channels one less than the Minimum Channels OPERABLE requirement, within 7 days initiate and maintain operation of the Control Room Makeup and Cleanup Filtration System (at 100% capacity) in the recirculation and makeup filtration mode.b. With the number of OPERABLE channels two less than the Minimum Channels OPERABLE requirement, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months initiate and maintain operation of the Control Room Makeup and Cleanup Filtration System (at 100% capacity) in the recirculation and makeup filtration mode, or immediately suspend CORE ALTERATIONS, movement of irradiated fuel as 'semblies and crane operations with loads, over the spent fuel pool, AND within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months initiate and maintain operation of the Control Room Makeup and Cleanup Filtration System (at 100% capacity) in the recirculation and makeup filtration mode. CORE ALTERATIONS, movement of irradiated fuel assemblies, and crane operations with loads over the spent fuel pool are permitted during operation of the Control Room Makeup and Cleanup Filtration System (at 100% capacity) in the recirculation and makeup filtration mode.c. With required ACTION 28a. or 28b. not met in MODE 1, 2, 3, or 4, immediately suspend movement of irradiated fuel assemblies and crane operations with loads over the spent fuel pool, AND be in MODE 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in MODE 5 in the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .d. With required ACTION 28a. or 28b. not met in MODE 5 or 6, immediately suspend CORE ALTERATIONS, movement of irradiated fuel assemblies, and crane operations with loads over the spent fuel pool.For an inoperable channel, declare its associated ventilation train inoperable and apply the actions of Specification 3.7.8.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.

ACTION 29 -ACTION 30-SOUTH TEXAS -UNITS 1 & 2 3/4 3-28 Unit 1 -Amendment No. 4Z3~Unit 2 -Amendment No. 4441-0NO CHANGES INSTRUMENTATION 3/4.3.5 ATMOSPHERIC STEAM RELIEF VALVE INSTRUMENTATION LIMITING CONDITION FOR OPERATION:

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

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

4.3.5.1 4.3.5.2 4.3.5.3 Perform a CHANNEL CHECK on each atmospheric steam relief valve automatic actuation channel at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .Perform a CHANNEL CALIBRATION on each atmospheric steam relief valve automatic actuation channel at a nominal setpoint of 1225 psig +/- 7 psi at least once every 18 months.Perform an ANALOG CHANNEL OPERATIONAL TEST on each atmospheric steam relief valve automatic actuation channel at a nominal setpoint of 1225 psig +/- 7 psi at least once every 18 months.SOUTH TEXAS -UNITS 1 & 2 3/4 3-85 U nit 1 -Amendment No. 114 Unit 2 -Amendment No. 102 C,)0 C: H x C,)C: z U)-Ao I NO CHA TABLE 3.3-14 ATMOSPHERIC STEAM RELIEF VALVE INSTRUMENTATION REQUIRED NO. OF CHANNELS APPLICABLE MODES FUNCTIONAL UNIT Manual actuation control channels Automatic actuation control channels ACTION 4 (1/valve)4 (1/valve)1,2,3,4-1 2 1, 2#CIO d~o 0)C=3r-CD 0-CD z 0 0)N)3 CL CDI z 0 TABLE 3.3-14 (Continued)

TABLE NOTATIONS*When steam generators are being used for decay heat removal.# Atmospheric steam relief valve(s) may be in manual operation and open, or in automatic operation, to maintain secondary side pressure at or below an indicated steam generator pressure of 1225 psig.ACTION STATEMENTS ACTION 1 -With the number of OPERABLE channels less than the required number of channels, declare the affected valve(s) inoperable and apply Technical Specification 3.7.1.6.ACTION 2 -a. With one less than the required number of OPERABLE channels, within 7 days restore the inoperable channel to OPERABLE status_____n 7 asor appl the requirements of the CRMP; or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .b. With two less than the required number of OPERABLE channels, withiln 72 hursrestore at least three channels to OPERABLE status w-thon-72 hýufsor a"pply the re~qu6ire-m~ents-of -the- CRM-P; or be in at least HOT STANDBY within the nex~t 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .c. With more than two less, than -the required number of OPERABLE channels, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore at least two channels to OPERABLE, s~tatus or apply the requirements of the CRMP; or be in at least HOT STANDBY within the next 6 "hours.SOUTH TEXAS -UNITS 1& 2 3/4 3-87 Unit 1 -Amendment No.-489 Unit 2 -Amendment No.1-39 REACTOR COOLANT SYSTEM 3/4.4.4 RELIEF VALVES LIMITING CONDITION FOR OPERATION 3.4.4 Both power-operated relief valves (PORVs) and their associated block valves shall be OPERABLE.APPLICABILITY:

MODES 1, 2, and 3.ACTION: a. With one or both PORV(s) inoperable, because of excessive seat leakage, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months either restore the PORV(s) to OPERABLE status or close the associated block valve(s)with power maintained to the block valve(s);

or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .b. With one PORV inoperable due to causes other than excessive seat leakage, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months either restore the PORV to OPERABLE status or close the associated block valve and remove power from the block valve;' ithi the~fo~oing72hou~

estrethe PORV to OPERABLE status ýWiti' h olwn ,72-heu or apply the requirements of the CRMVP, or be, in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .c. With both PORVs inoperable due to causes other than excessive seat leakage, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months apl h eurmnso h RMVP, or restore at least one of the PORVs to OPERABLE status or close their associated block valves and remove power from the block valves and be in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .d. With one block valve inoperable, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore the block valve to OPEABMLE status or place its associated PORV in closed postion; wihn7_hours [rest-ore the block valve to '0PýER:AABLE status Wi_'th 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months or applyth requirements of the CRMVP,; otherwise, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .e. With both block valves inoperable, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore the block valves to EOPERABLE status or place the associated PORVs in the closed position; restore at least one block valve to OPERABLE status within the next hour oqr appt 64jjly th_quFe_ tothC M; otherwise, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .SOUTH TEXAS -UNITS 1 & 2 3/4 4-10 Unit 1 -Amendment No.55-1-70 Unit 2 -Amendment No. 44 3/4.5 EMERGENCY CORE COOLING SYSTEMS 3/4.5.1 ACCUMULATORS LIMITING CONDITION FOR OPERATION 3.5.1 Each Safety Injection System accumulator shall be OPERABLE APPLICABILITY:

MODES 1 and 2 MODE 3 with pressurizer pressure > 1000 psig ACTION: a. With one accumulator inoperable, except as a result of boron concentration outside the required limits, withini 24 hobis restore the inoperable accumulator to OPERABLE status itn21hours6 0!'appl th reqireentsof he o bein at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and reduce pressurizer pressure to less than 1000 psig within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .bY.W ith -more than. one -accuImhiilfo&

i no perable-, except -as a resu It-of 5o-ron cbncentiratid-ii outside the, required limits, within'1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore at l~east two accumulators to OPERABLE status or apply the requirements of the 'CRMP, .or be in at leastHOT STAN DBY within, the next 6S hours'and reduce pressurizer pressure to'less than 1000 psig within the folio wing 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .'Ecl With the boron concentration of one accumulator outside the required limit, 'Wiithifi7-2hb-u-rs restore the boron concentration to within the required limitsw _ihn72hu rapy th ie reurments of: the-CRMP dfbr t in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and reduce pressurizer pressure to les than 1000 psig -within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .rd-With fhe bo6ron con66-c ..entrat-oionsiof -more than -one accumu laito6r- outside the 'required limit-1 within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore the boron concentration of at least two accumulators to within the-required limits or apply the requirements of the CRMP, or be in at least HOT STANDBY withift the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and red uce pressurizer pressure to less than 1000 psi 9 within the following~

6--hours.SURVEILLANCE REQUIREMENTS 4.5.1.1 Each accumulator shall be demonstrated OPERABLE: a. At least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months by: 1) Verifying the contained borated water volume is ! 8800 gallons and 9100 gallons and nitrogen cover-pressure is : 590 psig and ý 670 psig, and 2) Verifying that each accumulator isolation valve is open.b. At least once per 31 days and within 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months s* after each solution volume increase of greater than or equal to 1 % of tank volume that is not the result of addition from the RWST by verifying the boron concentration of the accumulator solution is : 2700 ppm and<3000 ppm and c. At least once per 31 days when the RCS pressure is above 1000 psig by verifying that power to the isolation valve operator is removed.*The 6 hr. SR is only required to be performed for affected accumulators SOUTH TEXAS -UNITS 1 & 2 3/4 5-1 Unit 1 -Amendment No. 51, 54, 59, 13 Unit 2 -Amendment No. 40, 43,147, 124 EMERGENCY CORE COOLING SYSTEMS 3/4.5.2 ECCS SUBSYSTEMS

-TAVG GREATER THAN OR EQUAL TO 350OF LIMITING CONDITION FOR OPERATION 3.5.2 Three independent Emergency Core Cooling System (ECCS) subsystems shall be OPERABLE with each subsystem comprised of: a. One OPERABLE High Head Safety Injection pump, b. One OPERABLE Low Head Safety Injection pump, C. One OPERABLE RHR heat exchanger, and d. An OPERABLE flow path capable of taking suction from the refueling water storage tank on a Safety Injection signal and automatically transferring suction to the containment sump during the recirculation phase of operation through a High Head Safety Injection pump and into the Reactor Coolant System and through a Low Head Safety Injection pump and its respective RHR heat exchanger into the Reactor Coolant System.APPLICABILITY:

MODES 1, 2, and 3.*ACTION: a. With less than the above subsystems OPERABLE, but with at least two High Head Safety Injection pumps in an OPERABLE status, two Low Head Safety Injection F pumps and associated RHR heat exchangers in an OPERABLE status, and sufficient flow paths to accommodate these OPERABLE Safety Injection pumps and RHR heat exchangers, **within 7 ldays( restore the inoperable subsystem(s) to OPERABLE status w 14hii--y or ,Apply the ieq ie nts of the CRMP, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in"HOT SHUTDOWN withi the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .b. With les tha~n two of thereqire subsyste-m-sOPERABLE, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 'restore at least two subsyst'em's to OPERABLIEstatus; or apply, the requirements of the CRMP, or be in at least HOTSTANDBY within the next 6 hou9rs and in HOT SHUTDOWN withi1n'thefolo-16w~ing 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .p. In the event the ECCS is actuated and injects water into the Reactor Coolant System, a Special Report shall be submitted within 90 days describing the circumstances of the actuation and the total accumulated actuation cycles to date.The current value of the usage factor for each affected Safety Injection nozzle shall be provided in this Special Report whenever its value exceeds 0.70.* Entry into MODE 3 is permitted for the Safety Injection pumps declared inoperable pursuant to Specification 4.5.3.1.2 provided that the Safety Injection pumps are restored to OPERABLE status within 4 0hours or prior to the temperature of one or more of the RCS cold legs exceeding 375 F, whichever comes first.**Verify required pumps, heat exchangers and flow paths OPERABLE every 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months .SOUTH TEXAS -UNITS 1 & 2 3/4 5-3 Unit 1 -Amendment No. 15&1,-170 Unit 2 -Amendment No. 1-39,--15g EMERGENCY CORE COOLING SYSTEMS 3/4.5.5 REFUELING WATER STORAGE TANK LIMITING CONDITION FOR OPERATION 3.5.5 The refueling water storage tank (RWST) shall be OPERABLE with: a. A minimum contained borated water volume of 458,000 gallons, and b. A boron concentration between 2800 ppm and 3000 ppm.APPLICABILITY:

MODES 1, 2, 3,and 4.ACTION: With the RWST inoperable, wifthfin1hourf-restore the tank to OPERABLE status wi~h44 Sor *pp ~ terqiments of the CRMP, or be in at least HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .SURVEILLANCE REQUIREMENTS 4.5.5 The RWST shall be demonstrated OPERABLE at least once per 7 days by: a. Verifying the contained borated water volume in the tank, and b. Verifying the boron concentration of the water.SOUTH TEXAS -UNITS 1 & 2 3/4 5-10 Unit 1 -Amendment No. 64 Unit 2 -Amendment No. 43 EMERGENCY CORE COOLING SYSTEMS 3/4.5.6 RESIDUAL HEAT REMOVAL (RHR) SYSTEM LIMITING CONDITION FOR OPERATION 3.5.6 Three independent Residual Heat Removal (RHR) loops shall be OPERABLE with each loop comprised of: a. One OPERABLE RHR pump, b. One OPERABLE RHR heat exchanger, and c. One OPERABLE flowpath capable of taking suction from its associated RCS hot leg and discharging to its associated RCS cold leg.*APPLICABILITY:

MODES 1, 2 and 3.ACTION: a. With one RHR loop inoperable, 'wit-hin 7 days restore the required loop to OPERABLE status within-7-daysý or a~pply the requirements of the CAMP, or, e in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .b. With two RHR loops inoperable, 'w-i't-hin_-2-4' hoursi restore at least two RHR loops to OPERABLE status WWt44nýe -orsor ag!ppl h eurmnsoýRMP orie' in at least HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .c. With three RHR loops inoperable, immediately initiate corrective action to restore at least one RHR loop to OPERABLE status as soon as possible.SURVEILLANCE REQUIREMENTS 4.5.6.1 Each RHR loop shall be demonstrated OPERABLE on a STAGGERED TEST BASIS pursuant to the requirements of Specification 4.0.5.4.5.6.2 At least once per 18 months by verifying automatic interlock action of the RHR system from the Reactor Coolant System to ensure that: a. With a simulated or actual Reactor Coolant System pressure signal greater than or equal to 350 psig, the interlocks prevent the valves from being opened.*Valves MOV-0060'A, B, and C and MOV-0061 A, B, and C may have power removed to support the FHAR (Fire Hazard Analysis Report) assumptions.

SOUTH TEXAS -UNITS 1 & 2 3/45-11 Unit 1 -Amendment No. 59 Unit 2 -Amendment No. 47-CONTAINMENT SYSTEMS 3/4.6.2 DEPRESSURIZATION AND COOLING SYSTEMS CONTAINMENT SPRAY SYSTEM LIMITING CONDITION FOR OPERATION 3.6.2.1 Three independent Containment Spray Systems shall be OPERABLE with each Spray System capable of taking suction from the RWST and transferring suction to the containment sump.APPLICABILITY:

MODES 1, 2, 3, and 4.ACTION: a. With one Containment Spray System inoperable, WIthi n- 7 days' restore the inoperable Spray System to OPERABLE status W-ithiii--day-s-or apply the r~equifrements of th~e_RMP, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ; restfore the inoperable Spray System to OPERABLE status within the next 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or be in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .b~Wih oe ha neC iaiiiet~irySy~ste-m'i-n-ope-rab-l-e-,w-ithiin 1 hou~ir re-sto-re at-l- east two Spray Systems to OPERABLE status or apply the requirements of tlheý'CRMP, or be in at, least HOT STANDBY within the next-6'hours, and in 0"61_SHUTDOWN within the-followingj30 hours.SURVEILLANCE REQUIREMENTS 4.6.2.1 Each Containment Spray System shall be demonstrated OPERABLE: a. At least once per 31 days by verifying that each valve (manual, power-operated, or automatic) in the flow path that is not locked, sealed, or otherwise secured in position, is in its correct position;b. By verifying on a STAGGERED TEST BASIS, that on recirculation flow, each pump develops a differential pressure of greater than or equal to 283 psid when tested pursuant to Specification 4.0.5;c. At least once per 18 months during shutdown, by: 1) Verifying that each automatic valve in the flow path actuates to its correct position on a Containment Pressure High 3 test signal, and 2) Verifying that each spray pump starts automatically on a Containment Pressure High 3 test signal coincident with a sequencer start signal.d. By verifying each spray nozzle is unobstructed following maintenance activities that could result in spray nozzle blockage.SOUTH TEXAS -UNITS 1 & 2 3/4 6-14 Unit 1 -Amendment No. 41-,%Unit 2 -Amendment No. 4-44 CONTAINMENT SYSTEMS CONTAINMENT COOLING SYSTEM LIMITING CONDITION FOR OPERATION 3.6.2.3 Three independent groups of Reactor Containment Fan Coolers (RCFC) shall be OPERABLE with a minimum of two units in two groups and one unit in the third group.APPLICABILITY:

MODES 1, 2, 3,and 4.ACTION: a. With one group of the above required Reactor Containment Fan Coolers inoperable, within 7 days restore the inoperable groupof RCFC to OPERABLE status within-'days or apply the requirements of the CRMP, 6rbe in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months a-nd in -COLD SHUTDOW-N within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .b. With more than one group of the above required Reactor Containment Fani Coolers inoperable, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore at l east two groups of RCFC to OPERABLE status or apply the requirements of the CRMP, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within th!followin~g 30Qou.SURVEILLANCE REQUIREMENTS 4.6.2.3 Each group of Reactor Containment Fan Coolers shall be demonstrated OPERABLE: a. At least once per 92 days by: 1) Starting each non-operating fan group from the control room, and verifying that each fan group operates for at least 15 minutes, and 2) Verifying a component cooling water flow rate of greater than or equal to 1800 gpm to each cooler.b. At least once per 18 months by verifying that each fan group starts automatically on a Safety Injection test signal.SOUTH TEXAS -UNITS 1 & 2 3/46-16 Unit 1 -Amendment No.7-4 Unit 2 -Amendment No. 63 CONTAINMENT SYSTEMS 3/4.6.3 CONTAINMENT ISOLATION VALVES LIMITING CONDITION FOR OPERATION 3.6.3 The containment isolation valves shall be OPERABLE with isolation times less than or equal to the required isolation times.APPLICABILITY:.

MODES 1, 2, 3, and 4.ACTION: With one or more of the isolation valve(s) inoperable, maintain at least one isolation barrier* OPERABLE in each affected penetration that is open and' ith~i~ni2_4Iioiur:

a. Restore the inoperable valve(s) to OPERABLE status w.ithin 24 hou rs, or b. Isolate each affected penetration Within 21 h6 , by use of at least one deactivated automatic valve secured in the isolation position, or check valve with lo-6w through the valve secured"*, or c. Isolate each affected penetration

~'ti 1hucby use of at least one closed manual valve or blind flange, or 7_pply the requirements 6f th e Cmp Otherwise be in at least HOT STANDBY within the next 6hours and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .SURVEILLANCE REQUIREMENTS 4.6.3.1 The isolation valves shall be demonstrated OP 'ERABLE prior to returning the valve to service after maintenance, repair or replacement work is performed on the valve or its associated actuator, control or power circuit by performance of a cycling test, and verification of isolation time.4.6.3.2 Each isolation valve shall be demonstrated OPERABLE during the COLD SHUTDOWN or REFUELING MODE at least once per 18 months by: a. Verifying that on a Phase "A" Isolation test signal, each Phase "A" isolation valve actuates to its isolation position;b. Verifying that on a Containment Ventilation Isolation test signal, each purge and exhaust valve actuates to its isolation position; and c. Verifying that on a Phase "B' Isolation test signal, each Phase "B" isolation valve actuates to its isolation position.d. Verifying that on a Phase "A" Isolation test signal, coincident with a low charging header pressure signal, that each seal injection valve actuates to its isolation position.4.6.3.3 The isolation time of each power-operated or automatic valve shall be determined to be within its limit when tested pursuant to Specification 4.0.5.*An isolation barrier may either be a closed system (i.e., General Design Criteria 57 penetrations) or an isolation valve.**A check valve may not be used to isolate an affected penetration flow path in which more than one isolation valve is inoperable or in which the isolation barrier is a closed system with a single isolation valve (i.e., General Designs Criteria 57 penetration)

SOUTH TEXAS -UNITS 1 & 2 3/46-17 Unit 1 -Amendment No. 59,-1-13 Unit 2 -Amendment No. 4 7 , 1 0 4 PLANT SYSTEMS AUXILIARY FEEDWATER SYSTEM LIMITING CONDITION FOR OPERATION 3.7.1.2 Four independent steam generator auxiliary feedwater pu~mps and associated flow paths shall be OPERABLE with: a. Three motor-driven auxiliary feedwater pumps, each capable of being powered from separate emergency busses, and b. One steam turbine-driven auxiliary feedwater pump capable of being powered from an OPERABLE steam supply system.APPLICABILITY:

MODES 1, 2, and 3.ACTION: i_ 1 With one motor-driven auxiliary feedwater pm nprbe ihn2 as restore the pump to OPERABLE status o1ra-p-ply the requirements of the CRMFIP oithii-28-daye or be mat-least HOT- -STANDBY within t he next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months an d in HOT SHUTDOWN within the following__6 hoursT b. With the turbine-driven auxiliary feedwater pump inoperable, or with any two auxiliary feedwater pumps inoperable, L Fi-th-in7_oumrs' restore the affected auxiliary feedwater pump(s) to OPERABLE status 4ihn 2ho6 or apply th -;requirements of the CRMVP, or be in at least HOT STANDBY within the next6d hours and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . MODE 3 may'be e-n-te6r-ed

_wit'h- -a~n -in-o~p,-erab-l-e t-urb-ine-d riven auxilIia ry f eedwate r p ump f or the purposes of performing Surveillance Requirement 4.7.1 .2.1 .a.2.c. With three auxiliary feedwater pumps inoperalwii1 hour apply the requirements of the CRMVP, or if tho reqi cto n aseoc~iatod allowod outao tinofr a) or b) or- not motbe in at le~ast HOT -STAN DBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .d. With four auxiliary feedwater pumps inoperable, immediately initiate action to restore at least one auxiliary feedwater pump to OPERABLE status as soon as possible.

LCO 3.0.3 and all other LCO actions requiring Mode changes are suspended until one of the four inoperable auxiliary feedwater pumps is restored to OPERABLE status.e. Specification 3.0.4.b is not applicable.

SOUTH TEXAS -UNITS 1 & 2 3/4 7-4 Unit 1 -Amendment No. 1-46,7-70 Unit 2 -Amendment No. 1-34, 15gg PLANT SYSTEMS AUXILIARY FEEDWATER STORAGE TANK LIMITING CONDITION FOR OPERATION 3.7.1.3 The auxiliary feedwater storage tank (AFST) shall be OPERABLE with a contained water volume of at least 485,000 gallons of water.APPLICABILITY:

MODES 1, 2, and 3.ACTION: With the AEST inoperable, within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months restore the AEST to OPERABLE status or applfy-thle requirements of the CRMVP, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOdT- SU--T"DOW'N w-it-hin't-he f-ollowing 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .SURVEILLANCE REQUIREMENTS 4.7.1.3 The AEST shall be demonstrated OPERABLE at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months by verifying the contained water volume is within its limits.SOUTH TEXAS -UNITS 1 & 2 3/4 7-6 Unit 1 -Amendment No. ,33 Unit 2 -Amendment No. 24 PLANT SYSTEMS MAIN STEAM LINE ISOLATION VALVES LIMITING CONDITION FOR OPERATION 3.7.1.5 Each main steam line isolation valve (MSIV) shall be OPERABLE.APPLICABILITY:

MODES 1, 2, and 3.ACTION: MODE 1: a. With one MSIV inoperable but open, POWER OPERATION may continue pirovided ,that within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months the inoperable valve is restored to OPERABLE statusmwihin-41 hous~ihe equirements of the CRMP are met; otherwise be in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .b_.-Withmo6're than one MVSIV inoperable but open, POWER OPERATION

_mayq 7,conti nue provided that within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months at least three inoperable valves areýrestored to OPERABLE status or the requirements of the CRMVP are. met;'otherwise be in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the follow~ing 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .MODES 2 and 3: With one MSIV inoperable, subsequent operation in MODE 2 or 3 may proceed provided the isolation valve is maintained closed. Otherwise, be in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .SUIRVEILL ANCE REQUIREMENTS 4.7.1.5 Each MSIV shall be demonstrated OPERABLE by verifying full closure within 5 seconds when tested pursuant to Specification 4.0.5. The provisions of Specification 4.0.4 are not applicable for entry into MODE 3.SOUTH TEXAS -UNITS 1 & 2 3/4 7-9 Unit 1 -Amendment No.Unit 2 -Amendment No.

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

MODES 1, 2, 3,and 4.*ACTION: a. With one less than the required atmospheric steam relief valves OPERABLE, within 7 days restore the required atmospheric steam relief valves to OPERABLE status or appy hereuirements of the CRMP whiay;or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and place the required RCS/RHR loops in operation for decay heat removal.b. With two less than the required atmospheric relief valves OPERABLE, 'within 72, ji-rs etr at least three atmospheric relief valves to OPERABLE stat-u-s or appl t,-he requirements of the CRMPIýO iti72ousrbenatlstHTSANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHFUTDOWN within the following

6 hours and place the required RCS/RHR loops in operation for decay heat removal.C. ýWith more than two less than the required atmospheric relief valves OPERABLE,, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore at least two atmospheric relief valves to OPERABLE statu!0r apply the requirements of the CRMP or be in at least HOT STANDBY-withini the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and. in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months n lc the required RCSIRHR loops in opertin for decay heat removal., SURVEILLANCE REQUIREMENTS 4.7.1.6 Each atmospheric relief valve shall be demonstrated OPERABLE prior to startup following any COLD SHUTDOWN of 30 days or longer or following any refueling shutdown, by verifying that all valves will open and close fully by operation of automatic#

and manual controls.*When steam generators are being used for decay heat removal.SRequired to be met for automatic controls only in MODES 1 and 2.SOUTH TEXAS -UNITS 1 & 2 3/4 7-10 Unit 1 -Amendment No. 114,-1-67 Unit 2 -Amendment No. 1-O2,-1-56 PLANT SYSTEMS 3/4.7.3 COMPONENT COOLING WATER SYSTEM LIMITING CONDITION FOR OPERATION 3.7.3 At least three independent component cooling water loops shall be OPERABLE.APPLICABILITY:

MODES 1, 2, 3, and 4.ACTION: a. With only two component cooling water loops OPERABLE, 7 days restore at least three loos t OPRABE satu ~ihi~-7-a~

r apiythe requirements of the CRMP, or b66- in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .b.With -two or, m- --o-r- e- com--6-ponent cooling water loops inoperable, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore at_least two loops to OPERABLE status or apply the requirements of the CRMP, or be in at'least 1-O1T STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the'-'following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .I SURVEILLANCE REQUIREMENTS 4.7.3 At least three component cooling water loops shall be demonstrated OPERABLE: a. At least once per 31 days by verifying that each valve outside containment (manual, power-operated, or automatic) servicing safety-related equipment that is not locked, sealed, or otherwise secured in position is in its correct position; and b. At least once per 18 months by verifying that: 1) Each automatic valve servicing safety-related equipment or isolating the non-nuclear safety portion of the system actuates to its correct position on a Safety Injection, Loss of Off site Power, Containment Phase "B" Isolation, or Low Surge Tank test signal, as applicable (performed during shutdown);

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

and 3) The surge tank level instrumentation which provides automatic isolation of portions of the system is demonstrated OPERABLE by performance of a CHANNEL CALIBRATION test.c. By verifying that each valve inside containment (manual, power-operated, or automatic) servicing safety-related equipment that is not locked, sealed, or otherwise secured in position is in its correct position prior to entering MODE 4 following each COLD SHUTDOWN of greater than 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months if not performed within the previous 31 days.SOUTH TEXAS -UNITS 1 & 2 3/47-12 Unit 1 -Amendment No. 4,59,91 Unit 2 -Amendment No. 47-,-7-8 PLANT SYSTEMS 3/4.7.4 ESSENTIAL COOLING WATER SYSTEM LIMITING CONDITION FOR OPERATION 3.7.4 At least three independent essential cooling water loops shall be OPERABLE.APPLICABILITY:

MODES 1, 2, 3, and 4.ACTION: a. With only two essential cooling water loops OPERABLE, within 7 days restore at least three loops to OPERABLE status ,w thin -4@y- or apý ply the requirelments of the CRMP, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .b,. With two or more essential cooling water loops inoperable, with~in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore at least two loops to OPERABLE status or apply the rquirements of the CRMP, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in CO LD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .SURVEILLANCE REQUIREMENTS 4.7.4 At least three essential cooling water loops shall be demonstrated OPERABLE: a. At least once per 31 days by verifying that each valve (manual, power-operated, or automatic) servicing safety-related equipment that is not locked, sealed, or otherwise secured in position is in its correct position;b. At least once per 18 months during shutdown, by verifying that: 1) Each Essential Cooling Water automatic valve in the flow path that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal, and 2) Each Essential Cooling Water pump starts automatically on an actual or simulated signal.SOUTH TEXAS -UNITS 1 & 2 3/4 7-13 Unit 1 -Amendment No. 126,-16gQ Unit 2 -Amendment No. 144.

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

All MODES.ACTION: MODES 1, 2, 3, and 4: a. With one Control Room Makeup and Cleanup Filtration System inoperable, within 7 day restore the inoperable system to OPERABLE status ~i--asor applythe requirements of the CRMP, orj be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .b. With two Control Room Makeup and Cleanup Filtration Systems inoperable,_

Wi-thin 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months restore at.......least two systems to OPERABLE status Within 72hoor apply the requirements of the CRMP, or b~in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .c. With three Control Room Makeup and Cleanup Filtration Systems inoperable, suspend all operations involving movement of spent fuel, and crane operation with loads over the spent fuel pool, and within16-ý hou-rs restore at least one system to OPERABLE status within 1I ý) a rppljy the requiiremhents of ,the CRM0"`6i be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the follwing 30 hors.MODES 5 and 6: a. With one Control Room Makeup and Cleanup Filtration System inoperable, restore the inoperable system to OPERABLE status within 7 days or initiate and maintain operation of the remaining OPERABLE Control Room Makeup and Cleanup Filtration Systems in the recirculation and makeup air filtration mode, or suspend all operations involving CORE ALTERATIONS, operations involving positive reactivity additions that could result in loss of required SHUTDOWN MARGIN or required boron concentration, movement of spent fuel, and crane operation with loads over the spent fuel pool.b. With more than one Control Room Makeup and Cleanup Filtration System inoperable, or with the OPERABLE Control Room Makeup and Cleanup Filtration Systems required to be in the recirculation and makeup air filtration mode by ACTION a. not capable of being powered by an OPERABLE emergency power source, suspend all operations involving CORE ALTERATIONS, operations involving positive reactivity additions that could result in loss of required SHUTDOWN MARGIN or required boron concentration, movement of spent fuel, and crane operations with loads over the spent fuel pool.SURVEILLANCE REQUIREMENTS 4.7.7 Each Control Room Makeup and Cleanup Filtration System shall be demonstrated OPERABLE: a. At least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months by verifying that the control room air temperature is less than or equal to 78 0 F;b. At least once per 92 days on a STAGGERED TEST BASIS by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers of the makeup and cleanup air filter units and verifying that the system operates for at least 10 continuous hours with the makeup filter unit heaters operating; SOUTH TEXAS -UNITS 1 & 2 3/47-16 Unit 1 -Amendment No. 9,-125,4-2-28 Unit 2 -Amendment No. 4-7,-1413,4-7-1 PLANT SYSTEMS 3/4.7.14 ESSENTIAL CHILLED WATER SYSTEM LIMITING CONDITION FOR OPERATION 3.7.14 At least three independent Essential Chilled Water System loops shall be OPERABLE.APPLICABILITY:

MODES 1, 2, 3,and 4.ACTION: a. With only two Essential Chilled Water System loops OPERABLE, within 7 days restore at least three loops to OPERABLE status "44hiR--4 or apply the requitremejjnts of the -RIMP, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .b. WMith two or more Eissential Chilleld W'at-e'r S-y-s't-e-mlo-ops inoper-able, -within 1 ho-u-r7 restore at least two loops to OPERABLE status or apply the requirements of!th CRMVP, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following, 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .SURVEILLANCE REQUIREMENTS 4.7.14 The Essential Chilled Water System shall be demonstrated OPERABLE by: a. Performance of surveillances as required by Specification 4.0.5, and b. At least once per 18 months by demonstrating that the system starts automatically on a Safety Injection test signal.SOUTH TEXAS -UNITS 1 & 2 3/4 7-33 Unit 1 -Amendment No. 95 Unit 2 -Amendment No. 72-3/4.8 ELECTRICAL POWER SYSTEMS 3/4.8.1 A.C. SOURCES OPERATING LIMITING CONDITION FOR OPERATION 3.8.1.1 As a minimum, the following A.C. electrical power sources shall be OPERABLE.a. Two physically independent circuits between the offsite transmission network and the onsite Class 1 E Distribution System('), and b. Three separate and independent standby diesel generators, each with a separate fuel tank containing a minimum volume of 60,500 gallons of fuel, and an automatic load sequencer.

APPLICABILITY:

MODES 1, 2, 3, and 4.ACTION: a. With one offsite circuit of the above-required A.C. electrical power sources inoperable, demonstrate the OPERABILITY of the remaining A.C. sources by performing Surveillance Requirement 4.8.1 .1.1 .a within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter.

Within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months restore the offsite circuit to OPERABLE status wihn 2VAr r pl the rqrents of thej ,qRMIp,_or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .b. With a standby diesel generator inoperable, demonstrate the OPERABILITY of the above-required A.C. offsite sources by performing Surveillance Requirement 4.8.1.1 .1 .a within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter.

If the standby diesel generator became inoperable due to any cause other than an inoperable support system, an independently testable component, or preplanned preventive maintenance or testing, demonstrate the OPERABILITY of the remaining OPERABLE standby diesel generators by performing Surveillance Requirement 4.8.1 .1 .2.a.2) for each such standby diesel generator separately within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , unless it can be demonstrated there is no common mode failure for the remaining diesel generator(s).

Within 14 days restore, the inoperable standby diesel generator to OPERABLE status N4*04n444dyq, or apply the requiFreents of the6 PRMW~r in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . (12)c. With one offsite circuit of the above-required A.C. electrical power sources and one standby diesel generator inoperable, demonstrate the OPERABILITY of the remaining A.C. sources by performing Specification 4.8.1.1. .a. within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter; and if the standby diesel generator became inoperable due to any cause other than an inoperable support system, an independently testable component, or preplanned preventive SOUTH TEXAS -UNITS 1 & 2 3/4 8-1 Unit 1 -Amendment No.895 Unit 2 -Amendment No. 72, 148 ELECTRICAL POWER SYSTEMS LIMITING CONDITION FOR OPERATION ACTION (Continued) maintenance or testing, demonstrate the OPERABILITY of the remaining OPERABLE standby diesel generator(s) by performing Surveillance Requirement 4.8.1 .1 .2a.2) within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , unless it can be demonstrated there is no common mode failure for the remaining diesel generators; wit"I iiiýn12ou~rsi restore at least one of the inoperable sources to OPERABLE status the' 2hur r py re~quirements of the CRMP, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOW`Nwithin the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . Rsooa es w fst icist PRBEsauývithin 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months and_ thrAeo standby diesel goner~ators to OPERABLE_

status within 14 daYs 4fro thor tFime of initialloss; or bt; in;t leasFt HOT STANIDBY w~ithin tho noxt 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COL D SHU TD N:ihnthe following 30 housj 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 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , Tap plyterqieet fteCM-rb na least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDbOWN wit-hin --th'e follow~ing

_3_0 hours.e. With two of the above required offsite A.C. circuits inoperable, WfihinN24fiours restore at least one-of'the inoperable offsite sources to OPERABLE status itn2hor rapply threueensoth ORPorbein at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . W ith onlY one ofio~uc irestored, restore at least two 04fs49 circuits to O)PER.ABL-E stausI1- w.ithin 7:2 hoursF9 froml-'imo Ofinta leesF or be in at least HOT STANIDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUJTDOW1N within h f. With two or three of the above required standby diesel generators inoperable, demonstrate the OPERABILITY of two offsite A.C. circuits by perform ing theq requirements of Specification 4.8.1.1.1 a.within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter.

With three of the above required standb~y Wiese g-ene-raIto r's fn~operable, w-ithi1n,2 h-ou restore at least one standby diesel generator to OPERABLE status O~'thihn 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months or apply the requirements of the CRMP, or at least~ twoi iaidb 04oc~lgonor

+-rs to OPRAL stauswihi 2 hur ,be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .Rotratlitho tdy die~l gnertorsto PERBLE tatswihin14 days from timn eOf initial loss or be inat least HOT SANDB wihinthenext 61ýhoursgand-in COLD SHUT-DOWNewifthn

~the following 30 heum.1 With~two of the iabo've required standby diesel generators inoperable, within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months restore at least tw o, s ,tandb Iy diesel ge Inerators to OPERABLE status or I a pply the requirements of the CRMP, "or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and ,in COLD SHUTDOWN Withýin~the following 30 hour3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months si SOUTH TEXAS -UNITS 1 & 2 3/4 8-2 Unit 1 -Amendment No. 85 Unit 2 -Amendment No. 72, 4 8 ELECTRICAL POWER SYSTEMS 3/4.8.2 D.C. SOURCES OPERATING LIMITING CONDITION FOR OPERATION 3.8.2.1 As a minimum, the following D.C. electrical sources shall be OPERABLE: a. Channel I 125-volt Battery Bank El All 1 (Unit 1), E2Al 1 (Unit 2) and one of its two associated chargers, b. Channel 11 125-volt Battery Bank El Dl 1 (Unit 1), E2Dl 1 (Unit 2) and one of its two associated full capacity chargers, C. Channel III 125-volt Battery Bank El B311 (Unit 1), E2B31 1 (Unit 2) and one of its two associated full capacity chargers, and d. Channel IV 125-volt Battery Bank El Cl 1 (Unit 1), E2Cl 1 (Unit 2) and one of its two associated chargers.APPLICABILITY:

MODES 1, 2, 3, and 4 ACTION: f t66zfi ei----If hebateresdischarge for more than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months as the sole source of power to their DC bus wh-ie, the CRMP is being applied and no alternate source of power is available, the LCO shall be r considered not met. ______a. With one of the required battery banks inoperable,j within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months restore the inoperable battery bank to OPERABLE status or ap~ply th~e::require ntofteRMihn ou or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .b.With more than one of the required battery banks inoperable, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore at least three=ýbattery banks to OPERABLE-status or apply the requirements of the CRMP or be in at least HOT~STANDBY within the next,6.houjrs and in COLD SHUTDOWN within the following 30 h~ours.c. With one charinel &ifih no battery chargers fe~aGhaReOPERABLE, within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months restore at least one battery charger to OPERABLE status wfthhin 2hu~:rapythe requirements of the CIMP, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .d., With more than one chane iwith no batter charge~rs -for a channe-1OPERABLE, withini 1 hour_restore at least one battery, charger to OPERABLE status on at least three channels or apply the Irequirements of the CRMP,; or be in at least HOT.STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD,'SHUT 1DOWN within the following 30 hour3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months sYr SURVEILLANCE REQUIREMENTS 4.8.2.1 Each 125-volt battery bank and charger shall be demonstrated OPERABLE: a. At least once per 7 days by verifying that: 1) .The parameters in Table 4.8-2 meet the Category A limits, and 2) The total battery terminal voltage is greater than or equal to 129 volts on float charge.SOUTH TEXAS -UNITS 1 & 2 3/4 8-10 Unit 1 -Amendment No. 44-3 Unit 2 -Amendment No. 62 ELECTRICAL POWER SYSTEMS NO CHANGES 3/4.8.3 ONSITE POWER DISTRIBUTION OPERATING LIMITING CONDITION FOR OPERATION 3.8.3.1 The following electrical busses shall be energized in the specified manner: a. Train A A.C. ESF Busses consisting of: 1) 4160-Volt ESIF Bus # FIA (Unit 1), E2A (Unit 2), and 2) 480-Volt ESF Busses # EIAI and EIA2 (Unit 1), E2AI and E2A2 (Unit 2) from respective load center transformers.

b. Train B A.C. ESE Busses consisting of: 1 ) 4160-Volt ESEF Bus # EIB (Unit 1), E2B3 (Unit 2), and 2) 480-Volt ESE Busses # El Bi and E11B2 (Unit 1), E2B31 and E2B32 (Unit 2) from respective load center transformers.

c. Train C A.C. ESF Busses consisting of: 1 ) 4160-Volt ESE Bus # EIC (Unit 1), E2C (Unit 2), and 2) 480-Volt ESE Busses # EICI and EIC2 (Unit 1), E2CI and E2C2 (Unit 2) from respective load center transformers.

d. 120-Volt A.C. Vital Distribution Panels DP1201 and DPOO1 energized from their associated inverters connected to D.C. Bus # EIAII* (Unit 1), E2AII* (Unit 2), .e. 120-Volt A.C. Vital Distribution Panel DPi 202 energized from its associated inverter connected to D.C. Bus # EIDII* (Unit 1), E2DII* (Unit 2), f. 120-Volt A.C. Vital Distribution Panel DP1203 energized from its associated inverter connected to D.C. Bus # EIBII* (Unit 1), E2BII* (Unit 2), g. 120-Volt A. C. Vital Distribution Panels DPi 204 and DPOO2 energized from their associated inverters connected to D. C. Bus #El Cli1 * (Unit 1), E2Cl1 * (Unit 2), h. 125-Volt D. C. Bus El Al 1 (Unit 1) E2Al 1 (Unit 2) energized from Battery Bank El All (Unit 1), E2A1 1 (Unit 2), L. 125-Volt D. C. Bus El Dli1 (Unit 1) E2ODl 1 (Unit 2) energized from Battery Bank El Dli1 (Unit 1), E2Dl 1 (Unit 2), j. 125-Volt D. C. Bus El Bi 1 (Unit 1) E2B31 1 (Unit 2) energized from Battery Bank El Bi 1 (Unit 1), E2B31 1 (Unit 2), and k. 125-Volt D. C. Bus El Cli1 (Unit 1) E2C1 1 (Unit 2) energized from Battery Bank El Cl 1 (Unit 1), E2C1 1 (Unit 2).*The inverter(s) associated with one channel may be disconnected from its D.C. bus for up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months as necessary, for the purpose of performing an equalizing charge on its associated battery bank provided:

(1) its vital distribution panels are energized, and (2) the vital distribution panels associated with the other battery banks are energized from their associated inverters and connected to their associated D.C. busses.SOUTH TEXAS -UNITS 1 & 2 3/4 8-14 Unit 1 -Amendment No. 4 Unit 2 -Amendment No.

ELECTRICAL POWER SYSTEMS LIMITING CONDITION FOR OPERATION (Continued)

APPLICABILITY:

MODES 1, 2, 3, and 4.ACTION: a. With one of the required trains of A.C. ESF busses not fully energized, ~wti8hours reenergize the train_or jppi th eurmns of th C-RMP, orbe in at least HOT STNDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months andin -COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .b. Wfit-hiimore than one of the required trains of A.C. ESF bu6s-ise n-ot -f-ully e-nergizied-, -within 1 ou~reenergize at least two trains or apply the requirements of the CRMVIP, or be in at least- HOT)'STANDBYwti the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLDSHUTDOWN within the 30loinA hours.c. With one A.C. vital distribution panel either not enrwgized from its associated inverter, or with the inverter not connected to its associated D.C. bus (1) within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months reenergize the A.C. distribution

'Panel within 2- hours or apply the requirements of the CRMVP, or be in at least HOT STANDBY.within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months ; land (2) witlhin 24 hou~rs ,reenergize the A.C. vital distribution panel from its associated inverter connected to its associated D.C. bus -it-hon 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or appjy therequirements of the CRMVIP, orbe in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .d. Wiith -more than one A.C. vital distribution panel either not energized from it's associated linverter, or with the inverter not connected to its associated D.C. bus: (1) within, 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , Ireenergize at least five A.C. distribution panels or apply the requirements of the CRMP, or be In, at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and inCOLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months ; and (2) within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months reenergize at least five A.C. vital distribution panels from their, associated inverter connected to their associated D.C. bus or apply the requirements of the CRMVP, or be in at least ýHOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and'in COLD SHUTDOW N within 4the ~following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .F '--e. With one D.C. bus not energized from its associated battery bank, wfithin 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months reenergize the D.C.bus from its associated battery bank _i!~hu~orapy the requirements of the C.RMP, or be i at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .f. With more than one D.C. bus not energized from i-iitsaissociated battery bank, within 1 ho.r reenergize at least three, D.C. buses from the'ira*s'socdiate'd battery banks or apply the requirements of the CRMVP, "or be in at least HO IT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following30hrs SURVEILLANCE REQUIREMENTS 4.8.3.1 The specified busses shall be determined energized in the required manner at least once per 7 days by verifying correct breaker alignment and indicated voltage on the busses.SOUTH TEXAS -UNITS 1 & 2 3/4 8-15 Unit 1 -Amendment No.Unit 2 -Amendment No.

6.0 ADMINISTRATIVE

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

Peak calculated containment internal pressure for the design basis loss of coolant accident (LOCA), Pa is 41.2 psig.The maximum allowable containment leakage rate, La, is 0.3 percent of containment air weight per day.Leakage rate acceptance criteria are: 1) Containment overall leakage rate acceptance criterion is <1.0 La,. During the first unit start-up following testing in accordance with this program, the leakage rate acceptance criteria are < 0.60 La for the combined Type B and Type C tests, and<.75 La, as-left and < 1.0 La as-found for Type A tests.2) Air lock testing acceptance criteria for the overall air lock leakage rate is < 0.05 L when tested at _> Pa.The provisions of Surveillance Requirement 4.0.2 do not apply to the test frequencies specified in the Containment Leakage Rate Testing Program.The provisions of Surveillance Requirement

4.0.3 apply

to the Containment Leakage Rate Testing Program.k. Configuration Risk Management Program (CRMP)A program to calculate risk-informed completion time based on changes in core damage frequency, large early release frequency and cumulative core damage probability resulting from applicable plant configurations.

The program-h**1d shall be in accordance with'NEI 06-09, "Risk-Managed Technical -Specifications (RMTS) Guidelines, Rev. 0".r The CRMP may be used for -_calculati ,ng a risk-info -rmed -completion time -o -nly in , Mode 1 and Mode 2j 2) proedues or dentifying the of risk profilef and the evaluation o frik 3aant established thr-eshofds, and 3) prvitionsfre (continued)

SOUTH TEXAS -UNITS 1 & 2 6-10 Unit 1 -Amendment No. 44--1 Unit 2 -Amendment No. 4-39 NOC-AE-06002036 Attachment 3 Bases Inserts (For Information Only)Attachment 3

NOC-AE-06002036 Attachment 3 Page 1 Bases for Application of Risk-Informed Completion Times The CRMP as described in TS 6.8.3.k and associated reference to NEI 06-09, "Risk Managed Technical Specifications Guidelines," establishes provisions for performing a risk assessment to determine required actions and allowed outage times for specifically identified specifications for structures, systems, and components.

Application of the risk assessment is consistent with the requirements of the Maintenance Rule, 1 OCFR5O.65(a)(4), to assess and manage the increase in risk that may result from maintenance activities.

The process to manage the risk assesses the rate of accumulation of risk in plant configurations and determines the allowed outage time (AOT) by calculating the time required to cross the incremental core damage probability threshold of 1 .OE-05.Application of the risk assessment to manage allowed outage time in different plant configurations is complemented by the station's programs to monitor performance indicators for long-term availability of risk-significant components.

The requirement to achieve acceptable long-term performance indicators provides a significant disincentive against extending baseline AOTs to the detriment of component or system availability.

The CRMP may be used for calculating a risk-informed completion time only in Mode 1 and Mode 2. If a MODE is entered where the PRA cannot be applied, the risk-informed provisions of the CRMP may not be applied and only the remaining frontstop completion time for the subject TS shall apply from the time of the MODE change. If the affected TS frontstop has been exceeded, then the applicable MODE 3 -MODE 5 transition times shall apply from the time MODE 3 was entered (e.g., "..be in COLD SHUTDOWN in the next 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months ").The Configuration Risk Management Program as described in TS 6.8.3.k and associated reference to NEI 06-09 establishes the conditions for performance of the risk assessment.

The LCOs subject to the Configuration Risk Management Program (CRMP) specifically reference the CRMP. The baseline AOT or required completion time specified in the LCO may be used to apply the CRMP to determine an alternate AOT and risk management actions.Although the CRMP may be applied to extend the allowed outage time for a referencing TS, except for the extension in the allowed outage time, the other requirements of the referencing TS continue to apply. For instance, if the CRMP is applied to extend the allowed outage time for Train A ECW (TS 3.7.4.a), the provisions of TS 3.7.4.b. will apply if another ECW train becomes inoperable.

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

The requirement to continually determine the acceptability of the plant configuration means that once the subject LCO has exceeded the baseline AOT, the risk assessment must be reperformed to determine the need to adjust the required action and time limits for any affected TS component based on the risk associated with any CRM P component that subsequently becomes inoperable or non-functional.

This requirement provides assurance that the configuration risk is adequately assessed.The CRMP is applied with the referencing specification and the ACTION required by the referencing specification must be taken if the configuration risk exceeds the 1 E-05 incremental core damage probability risk threshold.

The CRMP recognizes that the plant is in an extended NOC-AE-06002036 Attachment 3 Page 2 AOT that has a specified required action if the required action time is exceeded.

In a configuration where the risk exceeds the 1 E-05 threshold, the calculated RIOT has been exceeded and the action required at the expiration of the LCO AOT must be taken.Application of the CRMP will provide action for conditions where more than one train or channel of a function is inoperable.

Unless otherwise permitted in the TS, the CRMP will not be applied for configurations where there is a complete loss of function (e.g., all three trains of ECW non-functional or all channels of an actuation logic that results in all trains of a function being non-functional).

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

Examples of where a component has PRA Functionality such that the condition could be quantified in the determination of an allowed outage time are listed below:* SSCs that don't meet seismic requirements but are otherwise capable of performing their design function.* SSCs that are inoperable but secured in their safe position (e.g., a closed containment isolation valve).* SSCs powered from a source other than their normal power source, provided the alternate power source is modeled in the PRA.* An 350 with an inoperable automatic function if the manual actuation of the S50 is modeled in the PRA (e.g., a diesel generator with an inoperable sequencer).

Actuation channels are associated with their actuated components or trains. Loss of actuation channels is not considered a Loss of Function unless no train of the actuated 550 function has PRA Functionality.

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

Reference I specifies the criteria for determining functionality.

The ORMP establishes a backstop AOT of 30 days. This backstop AOT prevents allowing a component with little or no risk significance from being inoperable indefinitely and resulting in a de facto change to the design or licensing basis of the plant.

Reference:

1 .NEI 06-09 "Risk Managed Technical Specifications Guidelines"~

NOC-AE-06002036 Attachment 3 Page 3 Insert for Bases to TS 3/4.7.7, Control Room Makeup and Cleanup Filtration System ACTIONs a, b, and c allow the option of calculating a risk-informed completion time (RICT) in accordance with the requirements of the CRMP. This option applies only to the cooling function of the system supported by the Essential Chilled Water System (EChW) (TS 3.7.14) and may not be applied for conditions that affect the operability of the Control Room Makeup and Cleanup Filtration System (CRMCF) with respect to dose mitigation.

In cases where both functions are affected (e.g., an inoperable fan)the dose mitigation function determines compliance and the "frontstop" completion times may not be exceeded.The cooling function is modeled in the PRA and a RICT can be quantified if the function is not available.

The dose mitigation function is not modeled in the PRA because it has no effect on core damage frequency or large early release frequency.

Consequently, there is no technical basis for calculating a RICT for an inoperable condition involving the dose mitigation function.The dose mitigation function governed by TS 3.7.7 does not depend on the cooling function governed by TS 3.7.7 that is supported by TS 3.7.14 for EChW. Therefore, if a TS 3.7.7 action applies because EChW is not available or the cooling coil for CRMCF is not operable, the provision to apply the CRMP may be used.

v t e Letter Sequence Other
TAC:MD2341, RISK-INFORMED HPSI Aot/Ct Extension - WCAP-15773 (Approved, Closed) TAC:MD2342, RISK-INFORMED HPSI Aot/Ct Extension - WCAP-15773 (Approved, Closed)
Initiation Request, Request, Request Acceptance... Supplement Administration Questions 11 June 2007 Answers 26 April 2006 9 May 2007 Results Approval, Approval Other: ML071550240, ML080220065, NOC-AE-06002036, Revised Broad Scope Risk-Informed Technical Specification Amendment Request
MONTHYEAR2007-06-11 [Table View]

ML070040247

Text

Reference:

3.0.3 applies

6.0 ADMINISTRATIVE

4.0.3 apply

Reference:

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